By Donna Harman
President & CEO
Originally published by the Washington Examiner
The Environmental Protection Agency is about to impose new rules for ground-level ozone that would have little benefit to air quality, but a very significant and negative effect on economic growth and the creation of jobs we need.
Beginning Oct. 1, the EPA plans to require states and localities to have air with no more than 65-70 parts per billion of the tiny components that make ground-level ozone when they react to sunlight, heat and other conditions. The current standard, set in 2008, is 75 ppb. The EPA's stated goal, protecting people from adverse health effects of ozone, is laudable. Whether the new standard would advance that goal is another matter.
First, there is the scientific evidence. Just four years ago, President Obama declined to seek tougher standards. He determined that the 2008 standard was acceptable for human health and that the economy would likely not be able to bear the additional costs of new rules.
Even if the economy is in better condition now, will the health benefits be significant enough to justify the impact on manufacturers and consumers? The science hasn't changed since 2008. The only thing that has changed is the EPA's reliance on studies that reinforce its concerns while ignoring or giving little weight to those that do not.
Second, states have yet to implement the 2008 standards, in which they are required to designate areas as non-attainment and then identify additional controls from mobile and stationary sources through their State Implementation Plans. As a result, almost 40 percent of Americans live in areas designated as being in non-attainment. Before imposing new standards, states should be given the chance to implement existing ones.
One of the challenges states and counties face is identifying the sources that contribute to ozone. Some ozone is generated naturally from plants, fires and ozone drifting down from the stratosphere. A lot comes from outside a state or even from countries as far away as China. States do not have tools to control sources of ozone that cross their borders, as the EPA has itself acknowledged.
Constantly moving these air quality goal posts raises a third area of concern: Significant uncertainty and added costs for our industry. The steps needed to comply with the new standard will almost certainly squeeze out new investments at forest product mills, which are essential to our global competitiveness.
Most of the country would fall short of the 65 ppb standard, metropolitan and rural areas alike. There would be only two ways to meet the new standard. One would require massive investments in new technologies, many of which the EPA itself admits have not been developed yet. The other would require sharply limiting economic development and the jobs that come with it.
For the paper and wood products manufacturing industry, new capital costs could reach at least $3 billion plus the lost economic opportunities from projects that are scraped due to the "no growth" restrictions that come with a much lower NAAQS. The EPA's own cost-benefit analysis estimates that the new regulations would cost industry up to $15 billion in new machinery and technology, making it one of the most expensive air regulations ever.
Few industries represent the link between careful environmental stewardship and economic growth better than the U.S. paper and forest products industry — an industry that employs some 900,000 people. Air quality has gotten significantly better over the last several years and will continue to improve due to other EPA rules on the books even if the ozone NAAQS are not changed. Nitrogen oxide (NOx) and volatile organic compound (VOC) emissions from pulp, paper and wood produce mills continue to steadily decline.
At this critical juncture, we believe the new ozone rules would undermine this progress and create potentially significant economic disruption but without a clear and scientifically-backed benefit to public health. Public policies are most effective when they meet the economic needs, environmental concerns and societal expectations of our diverse communities. The new ozone rules fail this test.