States Submit Comments on Proposed Ozone NAAQS Revision

The above map compiles and categorizes the comments that state officials submitted to EPA regarding the agency’s proposed revision of National Ambient Air Quality Standards (NAAQS) for ground level ozone.

EPA’s proposal calls for the current standard of 75 parts per billion (ppb) to be lowered to a level somewhere between 65 and 70 ppb. EPA also solicited comment for a standard of 60 ppb. Notably, the National Association of Manufacturers (NAM) has said that a standard of 65 would represent the most expensive regulation ever imposed on the country. Such a standard would put even more strain on an electric grid that will have to deal with the recently finalized Mercury and Air Toxic Standards (MATS) rule and the proposed Clean Power Plan.

In total, over half of the states – 28, to be precise – recommended that the current standard of 75 ppb be retained. This is the same position that ALEC took when it submitted it comments to EPA in March. Two other states – Arizona and Virginia – recommended maintaining the current standard or only lowering it to 70 ppb.

Fourteen other states recommended lowering the standard in some way. Iowa suggested lowering the standard to 70 ppb while Connecticut, Delaware, and Washington State suggested a standard of 65 ppb. Ten others recommended lowering the standard but did not recommend a specific level.

Needless to say, it will be interesting to see how (if at all) EPA uses the feedback provided in these comments when developing the final rule.