BY: Bradley L. Coyle, CHMM
President Barrack Obama may have actually inadvertently saved
jobs recently when he asked EPA's administrator, Lisa Jackson, to
withdraw the agency's draft for more stringent ozone National
Ambient Air Quality Standards (NAAQS). By some estimates, the
new ozone standard may have cost as much as $700 billion in
negative economic impact as well as potentially costing as many as
7 million jobs by the year 2020(1).
It's obvious that no one wants to breathe dirty air but, the
reality is that the ozone standards are already pretty tight.
I'm neither a health nut nor a toxicologist but, it's likely
getting to the point that the cost to bring the NAAQ down is not
likely to have a significant positive effect on human
health. In short, the costs of tightening the standard
would likely outweigh the benefit. This particular NAAQ falls
in to the law of 'Diminishing Returns'.
I've read where the numbers of asthmatics has increased by 70%+
over the past 15 years(2). Odd, isn't it?
We've made HUGE strides to better the air quality through the
addition of various pieces of legislation and stringent permitting
programs over the past 40 years yet these types of air
quality-driven illnesses rise? Sure…some of it is diagnosis
and understanding of the ailments but, will driving an ozone NAAQ
further towards the floor be actually advantageous from a health
standpoint, or will it simply continue to slow economic growth and
reduce the United State's overall economic well-being?
The tip of the iceberg was revealed by allowing the proposed
ozone NAAQ to be shelved. This, in my opinion, was a very
good thing in today's economic times and offered a level of
recognition that many of the regulations in the pipeline or coming
out are BAD for the overall good of Americans.
What has failed to be recognized is the cost of many other
burdensome pieces of air regulation that are still 'in the wild'
and will be law (or may have already become law); these will cost
Americans more in nearly every aspect of their lives. The
boiler MACT, the utility MACT, transport rule… the list goes on and
on in to what has even been called the regulatory 'Train
Wreck'(3).
Again, we all want great air(4). We all want
to be healthy. We all want to live long and prosper (yes, I'm
giving the Vulcan Salute while typing)… but, where's the line and
is there a line? So far, this administration's focus has been
at the edge of overly burdensome, in my opinion. Further
though, it is my opinion that President Obama should be recognized
for shelving this legislation while in the heart of an economic
downturn. Overall though - the bulk of the iceberg is still
below water and poses a SIGNIFICANT threat to how we operate as
Americans(5).
(1) http://www.mapi.net/Filepost/ER-707.pdf
(2)
http://www.ncpa.org/pub/ba598/
(3)
http://www.alec.org/docs/EPA-TRAIN-WRECK-2011-Final-Full-printres.pdf
(4)
http://www.aei.org/article/energy-and-the-environment/a-clean-air-regulation-
hazardous-to-health/
(5)
http://www.whitehouse.gov/the-press-office/2011/09/02/statement-president-ozone-national-ambient-air-quality-standards
______
Mr. Coyle has worked with Linebach Funkhouser, Inc. for nearly
10 years. In his current role, Mr. Coyle leads the
environmental compliance group assisting various nationwide
clientele with air, water, and waste issues. Mr. Coyle can be
reached by calling 502.895.5009.