National Ambient Air Quality Standards (NAAQS) for Ground-Level Ozone
The President of the United States
The White House
Washington, DC 20500
Dear Mr. President:
Our economy is perhaps at its most fragile point since the day you took office. Your administration should continue doing everything possible to promote job creation through reduced uncertainty for businesses. The undersigned organizations and businesses of every size and industry, employing millions of American workers, therefore urge you to stop the Environmental Protection Agency (EPA) from moving forward with its voluntary reconsideration of new National Ambient Air Quality Standards (NAAQS) for ground-level ozone.
EPA's new rules aren't based on worsening conditions of air quality. They aren't required by law or by court order. They aren't required by the EPA's own timetable. And they come as counties and states across the nation struggle to meet existing ozone standards, and as businesses are making investments to meet the stricter 2008 NAAQS now under reconsideration.
EPA predicts the new standard will cost between $20 billion and $90 billion annually. However, EPA often underestimates economic impact; private sector studies predict as many as 7.3 million lost jobs and up to $1 trillion in compliance costs by 2020. Hundreds of counties across the United States will be thrown out of compliance, making it difficult for businesses in these counties to build new facilities or expand existing ones.
Worst of all, EPA's action is completely voluntary. There is no statutory or judicial requirement for EPA to act. The Clean Air Act requires EPA to reevaluate the ozone NAAQS on a five-year cycle; the current cycle is already more than halfway complete. EPA is already scheduled to begin establishing the next Ozone standard in 2013.
A new ozone standard at this point in time would limit business expansion in nearly every populated region of the United States and impair the ability of U.S. companies to create new jobs. We urge you to delay this discretionary, out-of-cycle ozone standard and wait until 2013 before determining whether a new standard is needed. Now is not the time to saddle our economy with the extraordinary costs associated with EPA's proposed national ozone standard.