What is NAAQS?

The National Ambient Air Quality Standard (NAAQS) for ground-level ozone is an outdoor air regulation established by the U.S. Environmental Protection Agency (EPA) under the Clean Air Act.  Ozone is a naturally occurring gas composed of oxygen molecules.  Ground-level ozone occurs both naturally and due to chemical reactions between nitrogen oxides and volatile organic compounds, which are emitted from industrial facilities, power plants, vehicle exhaust, and chemical solvents.

In March 2008, the EPA lowered the 8-hour primary NAAQS for ozone to its current level of 75 parts per billion (ppb).  In November 2014, the EPA proposed lowering the ozone standard to a range between 65 to 70 ppb.  By court order, the Agency must finalize the standard by October 1, 2015.

At this time, the EPA should retain the current 2008 ozone standard (75 ppb) because that standard still has not been fully implemented. 

States did not even find out which of their counties would be designated as nonattainment under the 2008 standard until April 2012.  Additionally, the EPA did not finalize the necessary implementation regulations and guidance for the 2008 standard until just recently in March 2015.  States are committing time and money to meet the 2008 ozone standard.  Yet the EPA now wants to move the goal posts in the middle of the game.  This action will further strain what are already limited resources that states have for implementation and fails to give states a chance to meet the current ozone standard.

It May Be Impossible to Meet Compliance Under the New Standard

According to the EPA’s Clean Air Scientific Advisory Committee (CASAC), the EPA “is not clear as to how background estimates might impact the primary and secondary standards and whether these impacts may differ regionally.”  For example, the Yellowstone National Park would fail the proposed 65 ppb standard due to having high natural background levels of ozone.  Also, the EPA does not consider the impact of international border pollution.  Ozone and other pollutants are transported to the U.S. from other countries, thereby causing states and counties to be nonattainment areas.

The Proposed Standards Have Significant Consequences

According to a February 2015 economic study done by the National Association of Manufacturers, a 65 ppb standard could reduce the U.S. GDP by $140 billion, resulting in 1.4 million fewer jobs and costing the average U.S. household $830 in lost consumption each year from 2017 to 2040.  That would mean a total of $1.7 trillion in lost U.S. GDP during that time period.

The U.S. House of Representatives Energy and Power Subcommittee, chaired by Rep. Ed Whitifield (R-KY), recently held a roundtable in Washington, D.C. entitled, “EPA’s Proposed Ozone Rule: Potential Impacts on Manufacturing and Jobs.” The Economic Alliance Houston Port Region was invited to participate, and City of Deer Park Mayor Jerry Mouton, Jr. represented the Economic Alliance and the city during the meeting.

The discussion builds off the committee’s ongoing work to highlight the potentially devastating effects on jobs and economic growth in many areas of the country from the EPA’s proposed revisions to the current National Ambient Air Quality Standards for ground level ozone.

During Mayor Moutons comments, he provided an overview of the national significance of the Houston Port Region, including sharing that the Port of Houston has more than 8,000 vessel and 200,000 barge movements per year, supports 1,026,820 jobs throughout Texas, provides more than $178.5 billion in statewide economic impact, including more than $4.5 billion in state and local tax revenues, and has a $500 billion national economic impact. In addition, the Port of Houston has a regional market reach of over 28 million people within a day’s drive, and trade around the world totaled $62.67 billion through the first five months of 2015 alone.

The economic development relationship between industry and communities in the Houston Port Region is significant and all stakeholders are keenly aware of regional air quality. In fact, with more than 50 air monitors, the Houston region has the most extensive monitoring network in the U.S. and should be considered a model for the EPA to use. The Houston Regional Monitoring (HRM) Network is an important part of Houston’s air monitoring system and is committed to the scientific understanding of air quality in the Houston area. The HRM Network shares its findings with communities, elected officials, the Texas Commission on Environmental Quality (TCEQ) and other state and national agencies.

The EPA’s ozone rules affect all aspects of our communities and municipalities, including consumers and vital industries. EPA data indicates that the air is cleaner today than it has been in thirty years, progress due in large part to control measures associated with past and current standards. This process shows that ozone standards- when given an opportunity to be fully implemented- produce significant reductions. The EPA should allow the 2008 standards the opportunity to be fully implemented before increasing restrictions.

These new ozone regulations being proposed by the Environmental Protection Agency are so restrictive that not only will the majority of the nation be considered non-compliant or in nonattainment- even some of our country’s most iconic National Parks will also be unable to reach attainment. This status means less development, fewer jobs and the potential for significant and long-term damage to our economy. If these pristine national treasures can’t meet the new standard, how can any community be expected to comply?

Common Sense – A Lost Art

The Houston Port Region is a clear example of how industry and communities work together for the greater good. There is no reason for an either/or approach. We can have clean air and support a growing, vital, economy. By allowing the 2008 standards to be implemented, further reductions in ozone will be achieved and our national economy will not be threatened.

If we continue on this unnecessary path as a nation, we are in jeopardy of losing not only future businesses- but also current ones- because they all will have difficulty finding emission offsets in nonattainment areas, and if they do find them, they will have to pay a higher price that will be passed down to you, the consumer.

The United States is one of the most environmentally restrictive countries in the world. Our economy is not only a national one, but a global one. Businesses have a choice; if we continue to place unnecessary roadblocks before them, they will relocate in countries with more lax environmental regulations. How does that serve the goals of the EPA in the end?

What Can You Do?

Contact the Administration

Ask your local and state officials to weigh in with the Obama Administration on the ozone issue.  A sample letter, which can be tailored to your particular community, can be found here.

Contact Elected Officials

Ask your Members of Congress in the House and Senate to support the CASE Act and the ORDEAL Act.  Also, encourage your local and state officials to weigh in with the U.S. Environmental Protection Agency on the ozone issue.


About the Economic Alliance

The Economic Alliance Houston Port Region, a non-profit organization created in 1985, provides professional economic development services for over 200 members, Harris County, the Port of Houston Authority, and 17 communities surrounding the Houston Ship Channel – home to one of the world’s most influential energy corridors and trade ports. Since 2008, the Economic Alliance has supported over 40 successful projects that have facilitated business activities creating over 4,400 new jobs and over $5.5 billion of capital investment to the Houston Port Region.  For more information: www.allianceportregion.com