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API Director of Regulatory and Scientific Affairs on Ozone NAAQS

Oilfield Technology,

‘Tomorrow, EPA’s scientific advisory board, known as CASAC, will meet to discuss the agency’s upcoming five year review of Ozone NAAQS standards. We’re urging the agency to include the current standard, which was set in 2008 at 75 ppb, in the range they consider for a new rule.

‘Further tightening the 2008 ozone standards, the most stringent ozone standards ever, is a major concern because of the potential cost and impact on the economy. We recognise 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.’

Impacts and research

‘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.

‘EPA and the states have only just begun to develop the plans to meet the current standard, and we will continue to make progress improving air quality as the current standards are implemented.

‘First, states should determine what controls will be required in order to get them into attainment with the current standards. Next, those controls should be implemented in a reasonable manner. This would result in cleaner air, even without changing the standards.

‘The challenges of meeting new standards would be massive and disruptive to the current plans already underway 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.’

‘With new standards that approach or are even lower than peak naturally occurring levels, virtually any human activity that produced emission could ultimately be restricted or affected. In some cases, new development simply would not be feasible or permitted.

‘According to earlier EPA analyses, the controls needed to achieve new standards just don’t exist today. Needless to say, operating under such stringent requirements could stifle new investment necessary to create jobs and grow our economy.’

Three key points

‘First, such strict standards are not justified from a health perspective and are not needed to continue air quality progress.

‘Second, the 2008 standards, which have not been implemented yet, will require significant emission reductions and efforts toward meeting those standards should be undertaken before tightening any new standards.

‘And third, the potential of significant national economic harm with stricter standards at or below naturally occurring levels is real.’


‘Our industry operates under extensive rules that, along with the industry’s own best practices and standards, have enabled it to steadily improve safety and reduce environmental impacts. Our fuels are much cleaner today and so are our facilities. Indeed, that’s a primary reason whey so much national progress has been made over the decades improving air quality. EPA emissions data confirms this.

‘We can build on this progress without going to a stricter and potentially very damaging standard EPA may soon be proposing. We urge EPA to finish their review and include the retention of the existing standards in the proposal. With a fair analysis of the record, we believe retaining the existing standards of 75 ppb is the right policy choice.’

Adapted from speech by Claira Lloyd

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