“The current ozone NAAQS of 75 ppb is the most stringent ever and has not been fully implemented across the United States. We are very concerned that EPA appears to be lowering the ozone standard before finishing the job on the current standard. With air quality improving, maintaining the current standard would enable further reductions in emissions while supporting U.S. manufacturing growth.
“The natural gas revolution is driving historic levels of U.S. chemical industry investment, with more than $135 billion in new plants, expansions and factory re-starts planned or underway. The nation will benefit as the new activity generates new jobs, increased GDP and tax revenue and access to innovative new products.
“Manufacturing growth could slow or stop in states that find themselves unable to meet a lower ozone standard. In these ‘nonattainment’ areas, facilities face regulatory requirements that make projects far more costly and complex. Most likely, companies wanting to expand or build a facility will be forced to shut down operations elsewhere or find the significant additional investment required to buy emission offsets.
“Industry has significantly reduced NOx and VOC emissions, precursors to ozone, over the past 20 years with state-of-the-art technology. Emissions of the six principal air pollutants fell 67 percent between 1980 and 2012, even as U.S. gross domestic product grew 133 percent. Voluntary and regulatory programs will continue to reduce ozone concentrations through 2030.
“We hope EPA will elect to take comment on retaining the current ozone standard of 75 ppb and will immediately reconsider its plans for a new standard. The Administration’s path forward will determine whether America stays ‘open for business’ to manufacturing.
“We also hope that EPA recognizes there are a number of concerns about the implementation process for revised NAAQS. We look forward to sharing our views and recommendations.”
SOURCE American Chemistry Council