Ozone Science, Facts Should Guide Public Debate

Mark Green
Posted January 29, 2015

With EPA opening public hearings (subscription required) on its proposed new ground-level ozone standards, it’s important that we not let some key facts get lost in the wave of comments and anecdotes that results when there’s an open microphone available.

At issue is EPA’s plan to make more restrictive the National Ambient Air Quality Standard for ozone, from the current 75 parts per billion (ppb) to between 65 and 70 ppb. The agency is collecting input until mid-March before finalizing the rule this fall.

We’ve made the case before that the existing standards are working, that our air is getting cleaner and will continue to do so with the current rule. In short, there’s no good reason to make the standards more stringent. That’s what the science shows, as experts detailed at EPA’s hearing in Washington, D.C. (here and here). Indeed, EPA’s own data shows that ozone levels have fallen 33 percent since 1980, including 18 percent since 2000:

Howard Feldman, API’s director of regulatory and scientific affairs, talked about this during a conference call with reporters this week:

“… we urge the administration to keep the current standards, which are not only the strictest standards ever imposed, they are standards that have yet to be fully implemented. Our view is that we need to allow existing regulations to work – and in this case they are – before adding more costly regulations. The facts are clear: the current standards protect our environment while not stifling jobs or harming our economy. Most important, when looking at the science, it is clear that the current standards are protecting public health.”

This really gets to the heart of the issue: If the existing standards are working, lowering ozone and protecting public health, then the potential impacts of a stricter standard on jobs and the economy – fundamental to the ability of individuals and families to thrive – should be considered. Potential impacts such as:

Non-Compliance

With a primary ozone standard of 60 ppb, which EPA is taking comment on, 94 percent of the U.S. population lives in places that would be deemed out of compliance. At 65 ppb, 45 of the lower 48 states would have areas that would be out of compliance:

Feldman said the new standards would impose “unachievable” emission reduction requirements on virtually the entire country, including pristine areas with no industrial activity such as national parks, where naturally occurring ozone is present:

“This is not smart policy or good government. … With new standards that approach or are even lower than naturally occurring levels, these new rules could restrict virtually any economic activity. In some cases, new development simply would not be feasible or permitted. States would have to place new restrictions on businesses of all sizes and add additional bureaucratic red tape to the permitting process for public works projects. … That’s what being out of compliance means. Needless to say, operating under such stringent requirements could stifle new investment. After all, it is precisely new investments that create jobs – the jobs that underpin our economy.”

Economic Reductions

A study for the National Association of Manufacturers estimated U.S. GDP could be reduced by $270 billion per year and $3.4 trillion from 2017 to 2040, with likely impacts on millions of jobs.

With all the rhetorical attention given to job creation and working to build up America’s middle class, EPA’s proposal would simply take a step in the opposite direction – again, without scientific or public health justifications. Feldman:

“If President Obama is serious about lifting up the middle class and closing the income inequality gap, the last thing his administration should do is threaten jobs and our energy and manufacturing renaissance with unnecessary new regulations. … We need policies that make sense. We have many already in place. We need to let them work before adding more.”