Dog Bites Man; Compliance With New NAAQS To Be Costly, Difficult

As I noted on Friday, EPA has proposed to revise the NAAQS for ozone to a range of from 0.060-0.070 ppm, a reduction from the 0.075 ppm standard promulgated in 2008 by the Bush administration.  EPA’s analysis of the available date indicates that 650 counties – out of 675 counties which have ozone monitors – would be in violation of a 0.060 ppm standard. For those counting, that’s more than 96% of all counties in nonattainment. Even if the standard were set at 0.070 ppm, 515 counties would be in non-attainment.

In fact, EPA estimates that, even by 2020, 203 counties would remain in nonattainment at 0.060 ppm and 99 counties would be in nonattainment at 0.070 ppm. EPA’s estimate is that the cost to comply with a 0.060 standard would be $52B to $90B per year in 2020. I confess that I have not reviewed the rule closely enough to know exactly what that means, given EPA’s prediction that more than 30% of all counties would not be in compliance at that time. We’re going to spend $52B to $90B per year to comply with the standard – and still not meet the standard?

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