API submit report in response to ozone standards

Below are highlights from a report written by the API in response to proposed alterations to ozone standards.

“The API supports the option EPA included in the proposal to retain the current primary National Ambient Air Quality Standards (NAAQS) for ozone at the level of 0.075 ppm. Further, API supports EPA’s proposal to retain the form of the secondary standard equal to the primary standard, in this instance at 0.075 ppm. API finds that the science does not support a change in these standards and that the current standards protect public health and welfare with an adequate margin of safety.”

API finds the current standards protect public health

“Under Section 109(b) of the Clean Air Act, the primary NAAQA must be set at a level requisite to protect public health with an adequate margin of safety. While the protection of sensitive subpopulations is an important part of establishing protectiveness with an adequate margin of safety, Congress did not intend for EPA to identify and impose a standard that guaranteed zero risk to all populations. The existing 2008 standard of 0.075 ppm or 75 ppb, is protective of public health with an adequate margin of safety, accounting for sensitive subpopulations.”

“Due to the complexity of atmospheric chemistry and the interplay between naturally occurring and human influenced ozone formation, EPA cannot assume that a lower NAAQS for ozone will provide substantial health benefits. Without an improved understanding of these atmospheric processes, a lowering of the NAAQS as proposed will not necessarily lead to that benefit.”

EPA should give state and local governments a chance to meet the most recent standards before changing them again

“API encourages the EPA Administrator complete the current review of the ozone standards by affirming that the standards finalised on March 12, 2008 continue to protect the public health with an adequate margin of safety. These standards are only new being implemented. In fact, EPA only finalised the State Implementation Plan (SIP) Requirements Rule during this comment period on March 6, 2015. States have a number of new deadlines looming as a result of this new rule.”

“Some of the tools needed to begin the implementation of the 2008 standard are only now beginning to appear. For example, states may need to make attainment demonstrations and often rely on EPA guidance to make those determinations. EPA only recently released guidance for public comment, which ended March 13 2015, and states will still need to wait until later this year for EPA to issue the finalised guidance.”

EPA should not set standards that cannot be achieved because of background ozone levels

“Changing the standards levels at or below peak background levels, as proposed in this rulemaking, would result in many areas of the country facing the huge economic burden of a non-attainment designation, with some of these areas never being able to achieve attainment. EPA has never established a NAAQS at background levels.”

Conclusion

“API recommends that EPA retain the current primary NAAQS for ozone at the level of 0.075 ppm. Further, API supports EPA’s proposal to retain the form of the secondary standard equal to the primary standard, and supports the level of 0.075 ppm for the secondary standard as well.”

Edited from report by Claira Lloyd

Published on 17/03/2015


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