The Mississippi Energy Institute urges EPA to maintain the current NAAQS Ozone Standard. Lowering the standard would unnecessarily impose economic sanctions on Mississippi while air models are known to be showing continued, steady improvement in ozone levels. Further, while major progress in ozone reductions has already been made over the past several decades due to technology and efficiency, EPA’s proposal will result in significant regulatory costs in addition to the economic sanctions and noticeably damage local economies. To be sure, job opportunities will decrease and costs to businesses and households will increase in these areas, all at a time when air quality is already improving under the current standard.
With at least 1/3 of the U.S. population already living in ozone non-attainment areas, a true, health-focused policy should first address those 100 million or more individuals who are, according to EPA, at the highest risk of negative health impacts.
Naturally occurring ozone levels are known to exist at different levels depending on location, climate and landscape. Mississippi, a rural state with a relatively low population, has monitors in places with little industrial activity nearby. Under the new standard, readings on these monitors could result in a non-attainment designation, virtually prohibiting industrial development in these areas. Energy and manufacturing are among the highest paying sectors in Mississippi, and community leaders in these areas are desperately eager to recruit new industrial projects to provide jobs to the citizens. Recruitment prospects diminish or even go away with non-attainment designations, leaving these small communities with no major options for economic growth.
Just a few years ago, EPA and a group of scientists set, what is to be assumed, a standard based on the Clean Air Act guidance, at that time lowering a standard that was set just several years before the 2008 standard. Now, with a proposed standard even lower, the standard seems to be ever-lowering each time the ordered review period comes up, suggesting a great deal of subjectivity in the process.
Given the regional variances in natural levels, I urge EPA to conclude the current standard is adequate and working in Mississippi, with no areas currently in non-attainment. For human health sake, I hope EPA can address the high ozone levels in current non-attainment areas, where much of the U.S. population resides. Mississippi’s environment does not need a lower standard, and Mississippi’s economy cannot afford one.