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Howard Feldman's remarks at press conference call on Ozone standards

Press conference call on Ozone standards
Howard Feldman, senior director of regulatory and scientific affairs
Wednesday, January 28th, 2015

Opening statement, as prepared for delivery

Good morning, and thanks for joining our call.

For the next few minutes I’d like to preview API’s comments on the administration’s proposed ozone standards that we’ll deliver at tomorrow’s public hearings in Washington, D.C.; Arlington, Texas; and Sacramento, California next week.

To put it simply, we urge the administration to keep the current standards, which are not only the strictest standards ever imposed. . .they are standards that have yet to be fully implemented.

Our view is that we need to allow existing regulations to work – and in this case they are – before adding more costly regulations.

The facts are clear: the current standards protect our environment while not stifling jobs or harming our economy.

Most important, when looking at the science, it is clear that the current standards are protecting public health.

We anticipate supporting testimony on that front from a number of key groups, including: 
  • Testimony on the lack of impact on health is expected to be presented (air travel permitting) by Dr. Goodman, and, by Dr. Sax of Gradient Corporation in DC and by the Texas Commission on Environmental Quality in Texas. 
The nation’s air is getting cleaner. And air quality will continue to improve as we implement the existing standards.

Ground level ozone in the U.S. declined by 18 percent between 2000 and 2013, and we expect that progress to continue under the current standards.

Further tightening of the standards will not improve air quality any faster. But they will add costs to jobs and the economy.

As proposed, the new standards would impose unachievable emission reduction requirements on virtually every part of the nation, including rural and undeveloped areas.

Even pristine areas with no industrial activity such as national parks would be out of attainment.

This is not smart policy or good government.

We anticipate supporting testimony on that front from a number of key groups, including: 
  • Testimony on the virtual impossibility of attaining the proposed tighter standards by the statutory deadlines will be presented by Nicole Downey, an environmental consultant and adjunct professor at the University of Houston, in Texas, and by Chris Emery, of Environ Corporation, in California. 
For a primary ozone standard of 60 parts per billion, which is in the range EPA is considering, 94 percent of the population lives in places that would be deemed to be out of compliance.

At a 65 parts per billion standard, 45 out of the lower 48 states would have areas that would be out of compliance.

What does being out of compliance mean?

With new standards that approach or are even lower than naturally occurring levels, these new rules could restrict virtually any economic activity.

In some cases, new development simply would not be feasible or permitted.

States would have to place new restrictions on businesses of all sizes and add additional bureaucratic red tape to the permitting process for public works projects.

New rules could block a new hospital – or a new highway – from being built.

That’s what being out of compliance means.

Needless to say, operating under such stringent requirements could stifle new investment. After all, it is precisely new investments that create jobs - the jobs that underpin our economy.

So, here’s what a recent report by NERA economic consulting reveals: A new ozone regulation from the Obama administration could cost $270 billion per year and place millions of jobs at risk.

If President Obama is serious about lifting up the middle class and closing the income inequality gap, the last thing his administration should do is threaten jobs and our energy and manufacturing renaissance with unnecessary new regulations.

The president talks about America’s energy renaissance. He even tries to take credit for it.

But, policy after policy stands to threaten our energy development and our competitiveness around the world.

We need policies that make sense. We have many already in place. We need to let them work before adding more.

This is a wake-up call. The administration must support the energy renaissance and America as an energy superpower and not stand in the way of it.

Thank you. And now I’d be happy to take your questions.