Dreaming the impossible ozone dream

The proposed regulations – now awaiting final EPA approval – illustrate the dangers of wishful thinking not grounded in reality and science.

The subject of the proposed regulations is ground-level ozone, the principal ingredient of smog. Ground-level ozone occurs in nature and is also produced by emissions from motor vehicles and manufacturing facilities.

In the final year of the administration of President George W. Bush, EPA significantly lowered the standard for ozone in the air at ground level from 84 parts per billion to 75 parts per billion. This was a dramatic reduction that many states are still struggling to reach.

Now the Obama administration wants to reduce the standard even further, to 60 to 70 parts per billion. The costs of imposing these proposed regulations would far exceed any possible benefits – assuming the regulatory goals could even be achieved.

In fact, reaching the levels of ozone in the proposed new regulations is a goal that simply can’t be reached using current technology. Apparently, EPA regulators believe they can mandate new scientific processes to make the reductions possible.

The 65 parts-per-billion level is approaching the naturally occurring level of ground-level ozone in many parts of the country. For example, a recent study found that even if all people and animals were removed from Houston and the city was turned into a ghost town, the lowest achievable level of ground-level ozone would be 68 parts per billion.

Almost all of the United States would be out of compliance with the new ozone limits now awaiting EPA approval. As a result, the proposed new regulations would trigger mandates forcing states to set severe reductions in emissions for cars, trucks and airports, as well as manufacturing plants.

Businesses would most likely abandon any plans to build, expand or modify facilities, severely limiting business growth and job creation in the United States.

The number of jobs jeopardized by these regulations is breathtaking and unconscionable, especially when our nation is experiencing the worst unemployment and underemployment since the Great Depression.

A new study by the Manufacturers Alliance/MAPI estimates that total U.S. job losses attributable to a 60 parts-per-billion ozone standard would rise to 7.3 million by 2020 – equal to 4.3 percent of the projected 2020 work force.

The financial, physical and mental toll this would take on the unemployed and their families is incalculable and would be poisonous for our nation.

In addition, according to the same study, the cumulative cost of attaining 60 parts per billion would be just over $1 trillion between 2020 and 2030 and would grow to trillions of dollars more in future decades. This is equivalent to 5.4 percent of the gross domestic product.

There are also fuel issues. Many regions might start requiring low-emission fuels, forcing refiners to revise and upgrade operations, which in turn would drive up the costs of manufacturing gasoline and diesel fuel. Even standard operations and maintenance issues for businesses would be affected, requiring more money and compliance staffing.

The United States has done a remarkable job of cleaning up the environment over the last few decades. No one is suggesting we turn back the clock. But it is not realistic to expect businesses to make further reductions to reach extremely low emission levels no matter what the cost, and no matter that technology does not exist to achieve the reductions.

The national interest demands that the EPA examine the terrible price America would pay to comply with its proposed new ozone regulations and reject these new standards – at least until science makes such reductions achievable at a realistic cost.

“To Dream the Impossible Dream” was a beautiful song in the play “Man of La Mancha,” describing the fantasy quest of Don Quixote. It should not become the driving principle of U.S. environmental regulation.

Charles T. Drevna is president of NPRA, the National Petrochemical & Refiners Association.