Establishing the National Ambient Air Quality Standards for Additional Hazardous Air Pollutants (HAPs) and Clarifying th

The Phl is known for having too many environmental laws but weak in implementation and several of these laws/regulations remain vague. There are already 17 pollutants in the National Ambient Air Quality Standards for Source Specific Air Pollutants from Industrial Sources/Operations of the Clean Air Act to which is recently added PM 2.5. There is weak implementation in the monitoring and management of these pollutants and thus adding the HAPs listed below should be with sound basis.

• Acrylonitrile
• 1,2 - dichloroethane
• Benzene
• Benzo(a)pyrene
• Dichloromethane
• Tetrachloroethylene
• Trichloroethylene

There are more than 1,000 MSATs (Mobile Sources Air Toxics) studied and identified by the US EPA, so why the focus on these particular. Why not for example include 1-3 butadiene a carcinogene which was studied in the roadsides of Thailand? Aldehyde should be included because this results from the mandate on using ethanol in gasoline.

There are no good baselines for the existing identified HAPs. Without source apportionment the proposed DAO could place non-polluting industrial facilities to undue and irresponsible complaints, given the extraordinary interpretation of the Writ of Kalikasan. Further, the local facilities for the sampling and testing of these parameters are inadequate.

Our participation in multi sectoral consultations and dialogues with the EMB will be helpful in the crafting of more rationale DAOs.

We see and support the logic for the industry thinking that a DAO on HAPs should clearly stipulate that the numerical values for the parameters are for guideline purposes and not for compliance, this similar to the DAO on PM2.5.