Unknown Controls To Protect You- EPA and Ozone Overreach

“PMPA urges EPA to maintain the current 75ppb standards for ozone. Allowing for the full and continued implementation of the current law will continue to drive significant reduction in ozone emissions. The proposed rule fails to demonstrate benefits, relies on “unknown controls,” and fails to consider natural influences in ozone levels and attainment. “

The Precision Machined Products Association (PMPA) today filed official comments opposing the U.S. Environmental Protection Agency’s proposal to lower the National Ambient Air Quality Standards (NAAQs) for Ozone to as little as 65ppb. This reduced standard would place virtually the entire U.S. in nonattainment status, ignoring natural influences, restricting economic activity and manufacturing production.

A recent study showed the EPA’s latest proposal would lower U.S. GDP by $140 billion annually. At a 65ppb level, the entire state of Ohio falls into nonattainment status.

“The EPA needs to give the current standards a chance to work,” said Miles Free, co-Interim Executive Director of PMPA. “The White House delayed the rules twice for other considerations, I think they should consider the impact on manufacturing and stay with the current levels. Current rules have resulted in an 18% drop in ozone emissions between 2000 and 2013, with an additional 36 percent reduction on deck.”

Furthermore, over 60 percent of the controls and technologies needed to meet the rule’s requirements are “unknown controls,” according to EPA terminology. How are “unknown controls” a key step in attainment. How do “unknown controls” have credibility in Science based policy?

"Unknown controls" in science are like "Then a miracle happens' in Theology.

“Unknown controls” in science are like “Then a miracle happens’ in Theology.

 

Due to the “unknown control”status, the new regulation will likely result in the closure of plants and the early retirement of equipment used for manufacturing, construction and agriculture. In the precision machining industry, well-maintained equipment can last decades and small businesses like our members can ill afford to invest millions of dollars in new machines because of an EPA regulation.

It is not clear how EPA plans on curtailing manufacturing during bouts of seasonal nonattainment, regardless of whether the basis is natural or manmade causes.

However, should the EPA’s 65ppb standard take effect, virtually all PMPA members will find themselves in a nonattainment zone restricting their manufacturing activity.

Our shops can expect

  • Face EPA ordered restrictions on their production due to this rule
  • An EPA estimated 6-12% electricity price increase resulting from the existing power plant emissions regulation on their own operations;
  •  20% or more increase in cost of raw materials used in our shops that are produced by electrically intensive means such as electric arc furnaces (which are actually recycling steel scrap into new useful material)
  • Reduced hiring
  • Reduced creation of new plants
  • Reduced production and sales
  • Reduced U.S. GDP

EPA Ordered Restrictions?

“They could also mean reducing energy-intensive economic activity, which could have substantial impacts on regional and state economies. States or AQMDs that are unable to comply with the new standards on time would also face harsh economic sanctions, too. No new industrial activity could open in that state or AQMD unless the state or AQMD was first able to obtain even greater emission reductions elsewhere.”- source Pillsbury Law Blog

The EPA estimates of cost impacts are also low, as our suppliers are energy intensive and we will also face much higher raw material prices making us non-competitive globally.

Our members support sound environmental policies based on proven science and health benefits balanced with realistic economic expectations.

  • We do not believe that “unknown controls” rise to the level of mature thought let alone science basis.
  • We do not believe that EPA has shown that this proposal will have significant public health benefits over the current standards.
  • We do believe, that lowering the levels to 70ppb or 65ppb would have a significant negative economic impact on the entire country, especially small and medium sized manufacturers.

For these reasons, PMPA urges EPA to maintain the current 75ppb standards for ozone. Allowing for the full and continued implementation of the current law will continue to drive significant reduction in ozone emissions. The proposed rule fails to demonstrate benefits, relies on “unknown controls,” and fails to consider natural influences in ozone levels and attainment. As businessmen, we do not base our plans on “unknown controls.” We cannot see how smart policy can put the manufacturing sector and the overall economy at risk, by relying on unknown and unproven controls either.

 

Then a miracle happens cartoon by Sidney Harris via   TrulyFallacious

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