The ‘Unachievable’ Ozone Standard

Mark Green
Posted May 27, 2014

When EPA proposed tightening the national ozone standards a few years ago, President Obama told the agency to stand down. The existing standard of 75 parts per billion (ppb) wasn’t due for review, and there was concern stricter standards might harm the economy.

It’s a concern that hasn’t diminished as the agency starts regular review of ozone National Ambient Air Quality Standards. Howard Feldman, API’s director of regulatory and scientific affairs, discussed the review during a conference call with reporters:

“We recognize that EPA has a statutory duty to periodically review the standards. However, the current review of health studies has not identified compelling evidence for more stringent standards. Tightened standards could impose unachievable emission reduction requirements on virtually every part of the nation, including rural and undeveloped areas. These could be the costliest EPA regulations ever.”

Two maps – the first shows areas of the country (in red) that are out of attainment under the current 75 ppb standard:

Here’s what the map would look like with standards set at 60 ppb, which is possible under the new review. In red are monitored areas and rural counties that would violate a 60 ppb standard; in orange are unmonitored areas that are anticipated to violate a 60 ppb standard, based on spatial interpolation:

Feldman:

"The challenges of meeting new standards would be massive and disruptive to the current plans already under way by states and the EPA. In many places they would require ozone levels to be forced down to or below peak background levels -- even pristine areas such as national parks would be out of attainment. ... For ozone standards of 60 parts per billion, which EPA is considering proposing, 94 percent of the population would live in places out of compliance and subject to new emission reductions requirements. With new standards that approach or are even lower than peak naturally occurring levels, virtually any human activity that produced emissions could ultimately be restricted or affected. In some cases, new development simply would not be feasible or permitted."

Key points stressed by Feldman:

• Earlier EPA analyses acknowledge that the technology needed to achieve such a standard doesn’t exist.
• Such a stricter standard isn’t justified from a health perspective – and isn’t needed to continue air quality progress under the current standard.
• The 2008 standards, which haven’t been implemented yet, require significant emissions reductions – and those efforts should occur before tightening the standards further.
• The potential for harming the economy with stricter standards at or below naturally occurring ozone levels is real.

Feldman said the proposal could present a technological challenge:

“… we don’t know how to get to these levels. These levels are levels that are at or below peak background. Background levels at Yellowstone National Park are 66 parts per billion, background. So we’re talking about setting a standard at or below background. … We’re talking about reducing the headroom towards the background levels. Background at pristine locations is 65, 66, 67 (ppb). It means we have very little ability for our society to operate the way it normally does. … Our society does have some emissions, but that is the cost and benefit of our modern society, where we’re able to have the amenities and the social life that we like. So there is some impact on the environment. We’re talking about reducing that (head)room to almost zero.”

As it continues its ozone review, EPA should include retention of the existing 75 ppb standard in its forthcoming proposal that will be offered for public comment. As Feldman noted, the oil and natural gas industry long has operated under extensive rules that, combined with industry’s own best practices and standards, have made it possible for industry to steadily improve safety and reduce environmental impacts. Feldman:

“Our fuels are much cleaner today and so are our facilities. Indeed, that’s a primary reason why so much national progress has been made over the decades improving air quality. EPA emissions data confirm this. We can build on this progress without going to a stricter and potentially very damaging standard EPA may soon be proposing.”