The EPA has proposed a rule to lower the primary National Ambient Air Quality Standard (NAAQS) for ozone from the current 2008 standard of 75 parts per billion (ppb) to a level between 60 and 70 ppb.
How could there be anything bad about that? Isn’t cleaner air a good thing?
Sure, it is. But we have to consider the costs of making it cleaner — and whether or not it warrants cleaning in the first place.
Bear in mind that the EPA is measuring ozone at levels that are essentially insignificant: parts per billion, not million. At those levels, even arsenic is harmless. So, what happens when the regulators get their hands on equipment that can measure ozone in parts per trillion, quadrillion and zillion? Will they then go to those extremes simply because they can and not because of any demonstrable benefit? Before they do, let’s consider the economic costs, right here in Nevada, of their proposal to lower the standard by 5 to 15 ppb. NERA Economic Consulting and Sierra Research conducted a study on the new rule’s estimated economic impact on our state economy and the results are chilling. Getting that already minuscule trace of ozone down to a slightly more minuscule level will require control measures with direct costs that are enormous and easy to measure.
Reducing ozone levels in Nevada from 75 ppb to 60 ppb would destroy 297,000 jobs, reduce our gross regional product by $22.2 billion, reduce the disposable income of state residents by $12.7 billion and reduce state tax revenues by $2.7 billion. The increased costs of compliance would affect every industry, every community and every family in Nevada.
Given the negligible benefit of an inscrutably small improvement in air quality, it’s hard not to conclude that the “unintended” consequences are exactly what the EPA has in mind.
Tony Clark is the state energy chairman of northern Nevada for the Nevada Energy Forum. He served as the adjutant general of the Nevada National Guard for 14 years, solicitor general for the Nevada attorney general’s office for two-and-a-half years and executive director of the Nevada Board of Medical Examiners for five years.