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On Ozone, the Science and Impacts of Regulation Speak Loudly

Mark Green

Mark Green
Posted May 27, 2015

With national ozone levels falling, some activists argue for stricter federal standards the best way they can – by pointing to the relatively few areas in the United States where ozone levels remain above the current standard of 75 parts per billion (ppb).

Yet, think about that. If an urban area like Los Angeles or Houston currently is out of attainment with the standard set at 75 ppb, how will lowering the national standard to 65 or 60 ppb – which EPA is considering – make a difference in those and other non-compliant areas? Good question.

The fact remains that the current standards are working. EPA data shows ozone levels declined 18 percent between 2000 and 2013:


Nationally, our air is getting cleaner, and the existing standards still aren’t fully implemented. Meanwhile, stricter standards aren’t justified by science or a public health need. Howard Feldman, API’s senior director of regulatory and scientific affairs from earlier this year:

“We think that the science is not compelling, the public health is already protected … So in and of itself these standards should not move forward. … There’s an adverse health impact from the impact of the cost of this regulation – the cost and financial impacts of this also has an adverse health impact that EPA needs to consider as well.”

Feldman refers to a study by NERA Economic Consulting that shows lowering the standards to 60 ppb could result in significant economic impacts:

Employing our integrated energy economic model … we estimate that the potential emissions control costs would reduce U.S. Gross Domestic Product (GDP) by $270 billion per year on average over the period from 2017 through 2040 and by more than $3 trillion over that period in present value terms.  The potential labor market impacts represent an average annual loss of 2.9 million job-equivalents.

Nonetheless, some argue current ozone standards aren’t enough to protect the air Americans breathe – claiming, for example, that a stricter standard would save the lives of asthma sufferers. Feldman, in a paper delivered earlier this year to the Air & Waste Management Association:

… the current scientific evidence does not demonstrate that the present standards fail to protect the public health and welfare with an adequate margin of safety. … (T)he current standards should be retained unless it is demonstrated that the new standards are requisite. Given the evidence described below, and many other uncertainties, changes in the standards are not requisite at this time.

Feldman cites a paper by Dr. Michael Honeycutt, director of the Texas Commission on Environmental Quality Toxicology Division, questioning the link between ozone and worsening asthma:

“The problem with this association is that asthma diagnoses are increasing in the United States, yet nationwide, air quality is improving. If asthma were actually tied to ozone, you would expect to see the instances of asthma decreasing, not increasing. In fact, data from Texas hospitals show that asthma admissions are actually highest in the winter, when ozone levels are the lowest.”

Honeycutt writes that ambient ozone concentrations don’t represent real-world exposure. Ozone is an outdoor air pollutant, he writes, because air conditioning removes it from indoor air. Honeycutt:

“Since most people spend more than 90 percent of their time indoors, we (and the people in the epidemiology studies used to justify lowering the standard) are rarely exposed to significant levels of ozone. … For ozone to cause a slight change in lung function in clinical studies, people need to be exposed to outdoor levels of ozone for hours while vigorously exercising (example: 6 hours of bicycling). These changes in lung function are often so small that they are within a person’s normal daily variation.”

Bottom line: Current standards are working, the scientific/public health case for stricter ozone standards hasn’t been made and there’s strong analysis that stricter standards could result in broad economic harm. As Honeycutt notes, there are costs to regulation – namely, increased costs to goods and services and especially energy – that lead to real human costs. Feldman’s paper concludes:

Given the uncertainties in the health data and the significant impact that tightening the standards may have, EPA and the states can best contribute to better air by helping communities attain the existing standards. Chilling local economies before attaining the current standards and without compelling changes in the science makes no sense.


Mark Green joined API after a career in newspaper journalism, including 16 years as national editorial writer for The Oklahoman in the paper’s Washington bureau. Mark also was a reporter, copy editor and sports editor. He earned his journalism degree from the University of Oklahoma and master’s in journalism and public affairs from American University. He and his wife Pamela live in Occoquan, Va., where they enjoy their four grandchildren.