Reconsideration of the 2008

National Ambient Air Quality Standard

Comment of Katrina Currie
Research Associate, Commonwealth Foundation for Public Policy Alternatives
Clean Air Scientific Advisory Committee (CASAC) Ozone Review Panel
March 03, 2011

Good Morning, I am Katrina Currie, Research Associate for the Commonwealth Foundation. We are a
nonprofit, independent public policy research and educational institute based in Harrisburg, Pennsylvania.

The EPA’s “reconsideration” fails to address concerns raised by many leading academics and
practitioners regarding the EPA’s methodology, and further research reveals that the revised ozone
standard will have a far greater negative impact than positive on public health.

The risks that this proposal may prevent are negligible and are far outweighed by the negative economic
impacts it will have nationally. Pennsylvania is considered one of the most severely impacted states.

According to the EPA’s 2008 impact analysis, 28 of the 31 Pennsylvania counties with ozone monitors
would not meet the revised standard in 2020. This number will likely increase as more counties begin
ozone monitoring.

National Economic Research Associates (NERA) Economic Consulting performed an economic impact
study on the EPA’s proposed ozone revision in Pennsylvania.

The analysis found:

 Reducing ozone precursors, such as nitrogen oxides and volatile organic compounds, would cost
Pennsylvania $347 billion between 2020 and 2030.
 The revised ozone standard would reduce employment in the state by 339,000 in 2020 and
eliminate more than 3.4 million jobs-years by 2030.
 Between 2020 and 2030, gross regional product would decrease by $254 billion, reduce
disposable income by $174 billion, and reduce state tax revenue by $2.7 billion.
 Urban areas, such as Philadelphia and Pittsburgh, which will likely be unable to meet this
mandate, could lose federal highway/transit funding. Further, these areas will struggle to get
permits for future development.

Reasonably Available Control Measures (RACM) for attaining the EPA’s revision does not exist. The
“known” controls listed by the EPA would only reduce Pennsylvania’s nitrogen oxide emissions by
61,000 tons, leaving another 164,000 tons to be reduced. Additional controls, identified in the study
above, used to meet this mandate are economically unreasonable.

Pennsylvania is facing an estimated $5 billion deficit; the resources that could better be used to benefit
residents will be redirected to attempt to meet this ill-advised ozone standard.

Furthermore, the EPA has not effectively defined what background levels for ozone are, and in many
cases the revision places the ozone standard below background levels, making it impossible for states to
comply. A clear example of this is Texas’ secluded, uninhabited Big Bend National Park, which will be in
violation of an ozone standard set a 65 parts per billion.

The lack of available controls and the severity of the economic impact should not by ignored by the EPA
as unemployment and poverty is proven to increase the risk of sickness and death. The EPA should
withdraw its ozone reconsideration proposal. The evidence suggests this will not provide significant
health protection, while it is certain to profoundly eliminate jobs revenue in states, and reduce living
standards for millions of Pennsylvanians.