On Oct. 1, the EPA lowered the 8-hour primary National Ambient Air Quality Standard (NAAQS) for ground-level ozone from the 2008 standard of 75 ppb to 70 ppb. This may not seem like a significant change. However, sound environmental regulations have to be built upon a foundation of science. When science and expert opinion are disregarded in favor of politics, the result is often unachievable goals and harm to economic development.
Driving EPA’s push is the promise of improved health with lower ozone levels. Ozone levels in the U.S. are already vastly improved, and it is unclear if further lowering of ozone — particularly manmade contributions — will provide measurable health benefits. According to analysis of the EPA’s own models by experts at the Texas Commission for Environmental Quality (TCEQ), the new rule would actually increase mortality in some cities, including Houston. As TCEQ experts have explained, either lowering the ozone standard misses its purpose, or EPA is having trouble interpreting its own data.
States were informed about which of their counties would be designated as non-attainment under the 2008 standard in April 2012. The EPA did not finalize the necessary implementation regulations and guidance for the 2008 standard until March 2015. States have been committing time and money to meet the 2008 ozone standard. Yet the EPA is moving the goal posts in the middle of the game, further straining already limited resources states have for implementation and failing to give states a chance to meet the prior standard.
According to the EPA’s Clean Air Scientific Advisory Committee, the EPA “is not clear as to how background estimates might impact the primary and secondary standards and whether these impacts may differ regionally.” Also, the EPA does not consider the impact of inter-national border pollution. Ozone and other pollutants are transported to the U.S. from other countries, thereby causing states and counties to be nonattainment areas.
The economic development relationship between industry and communities in the Houston Port Region is significant, and all stakeholders are keenly aware of regional air quality. According to a recent economic study by the National Association of Manufacturers, the reduced standard would decrease the U.S. GDP by $140 billion, resulting in 1.4 million fewer jobs and costing the average U.S. household $830 in lost consumption each year from 2017 to 2040 for a total of $1.7 trillion in lost U.S. GDP during that period.
With more than 50 air monitors, the Houston region has the most extensive monitoring network in the U.S. and should be considered a model for the EPA to use. The Houston Regional Monitoring (HRM) Network is committed to the scientific understanding of air quality in the Houston area and shares its findings with communities, elected officials, TCEQ and other state and national agencies.
EPA’s own data indicates the air is cleaner today than it has been in 30 years, progress due in large part to control measures associated with past and current standards. This shows ozone standards, when given an opportunity to be fully implemented, produce significant reductions. The EPA should allow the 2008 standards the opportunity to be fully implemented before increasing restrictions.
The Houston Port Region is a clear example of how industry and communities work together for the greater good. There is no reason for an either/or approach. We can have clean air and support a growing, vital economy. Unreasonable restrictions from the EPA jeopardize not only future businesses from growing but also current ones, because they all will have difficulty finding emission offsets in nonattainment areas. And if they do find them, they will have to pay a higher price that will be passed down to the consumer.
Businesses have a choice. If we continue to place unnecessary roadblocks before them, they will relocate in countries with more lax environmental regulations.
Ask your local and state officials to weigh in with the Obama Administration on the ozone issue, and encourage your local and state officials to weigh in with the EPA.
For more information, visit www.allianceportregion.com or call (281) 476-9176.
