Georgia Chamber Comments on EPA’s National Ambient Air Quality Standard for Ozone
The U.S. Environmental Protection Agency (EPA) is on the verge of imposing an expanded national ambient air quality standard (NAAQS) that will negatively impact the profitability and viability of businesses and industry across Georgia.
EPA’s proposal to further reduce the NAAQS from its current level of 75 part per billion (ppb) to a range of 65-70 ppb, or possibly lower to 60 ppb, would impose a crippling burden on Georgia’s economy, while only providing marginal environmental and health benefits beyond those already possible with the full implementation of the existing standard.
As a result of the potential far reaching negative impact of this EPA proposal, the Georgia Chamber has submitted comments expressing our unambiguous opposition to EPA imposing a NAAQS at 65-70 ppb.
The Chamber rejects any consideration of a move to a level of 60 ppb as this would impose catastrophic investment and operational conditions on Georgia’s economy and drive business investment out of the state and, possibly, out of the nation.
In comments to the EPA, the Chamber argued that this level (60 ppb) would be so close to natural background ozone levels that some regions in the state may never achieve compliance, effectively and permanently shutting people living in these areas out of positively participating in the economic and social abundance of the state and forever denying them the prosperity they strive to achieve for their families.
Given the tremendous costs of compliance and concern that, by EPA’s own admission, technologies do not even exist for many businesses and industries to comply with a lower standard, the Chamber cautioned EPA against imposing burdens on Georgia’s economy that will:
- Prematurely and negatively influence business investment and location decisions ahead of any new standard being imposed;
- Divert valuable funds from productive uses to comply with more stringent or non-attainable standards;
- Impact long-term investment decisions leading to lower economic growth and productivity;
- Reduce or stifle employment generation;
- Constrain or impose unfair investment and operating conditions on businesses;
- Reduce Georgia’s national and international competitiveness; and
- Impose any unfunded mandates on Georgia’s agencies, businesses, industries and communities by EPA actions.
The Chamber recommended to EPA that it prioritize consolidation and implementation of the existing standard before further consideration is given to a move to further lower the standard.