The EPA proposed revisions to the National Ambient Air Quality Standards in December 2014, requiring stricter regulations to volatile organic compounds, nitrogen oxides and other potential ozone precursors.
In a letter to EPA administrator Gina McCarthy (PDF, 260 KB), Moore says the proposed revisions will impose “real and significant costs while providing uncertain and unverified benefits.” Moore cited figures, saying that since 1980 ozone-forming emissions had already been cut in half and average ozone concentrations had dropped by 33 percent.
Although three decades of cleaner air have been achieved, the new restrictions would impose a stringent standard, pushing “vast swaths of the country into nonattainment.” Moore argues that in some areas the proposed range of volatile organic compounds, nitrogen oxides and other ozone precursors are at or near the level of naturally occurring or internationally transported background ozone, which would put rural communities located far from industrialized areas out of compliance.
While agriculture produces volatile organic compounds, nitrogen oxides and other potential ozone precursors during agricultural practices, the agricultural industry is a relatively small contributor to ozone levels and can already be regulated through monitoring and control measures.
However, imposing further restrictions creates higher input costs for agriculture (through diesel trucks and farm equipment), which costs must be passed to the consumer. This makes American agricultural products non-competitive in a global marketplace. Moore argues that further restrictions and the associated costs could further determine farm viability and prosperity.
Moore says if the proposed standards are adopted, the consequences would limit business expansion in nearly every populated region of the U.S., and it would limit the creation of new jobs. In addition, noncompliant areas would not be able to proceed with federally supported highway and transit projects unless states can demonstrate that the project will cause no increase in ozone emissions.
The EPA estimates the new ozone rule could cost tens of billions of dollars per year. Independent estimates, says Moore, predict costs will likely be much higher. FG
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