The Environmental Protection Agency (EPA) is in the process of revising the National Ambient Air Quality Standards (NAAQS) for ozone. Because of court action, the proposal is required by June 20, 2007, and the final standard by March 12, 2008. Currently the standard is 0.084 parts per million (ppm) averaged over eight hours.
Background
The EPA staff concluded in a staff paper that “the overall body of evidence on ozone health effects clearly calls into question the adequacy of the current standard.” The staff recommends the administrator consider a range below 0.080 ppm to 0.060 ppm for the primary ozone standard (to protect public health). The Clean Air Scientific Advisory Committee (CASAC) Ozone Review Panel recommended that the primary ozone standard be set between 0.070 ppm and 0.060 ppm.
The CASAC letter on ozone is available at www.epa.gov/sab/pdf/casac-07-001.pdf, and the EPA ozone staff paper is at www.epa.gov/ttn/naaqs/standards/ozone/s_o3_cr_sp.html.
Implications
The lower standard will mean many new non-attainment areas (0.070 ppm – 1,087 counties; 0.060 ppm – 1,243 counties), including isolated rural counties. Agriculture production and processing, including methane and ethanol, produces volatile organic compounds (VOCs) and nitrogen oxides, or NOx, which will be regulated through monitoring and possibly via controls.
Stringent control measures will be implemented that could curtail production activities, restrict pesticide applications, designate/limit pesticide application times, eliminate pesticide availability, restrict animal agricultural feeding operations (emissions from animal waste handling and storage), prescribe costly control measures for animal agriculture, and prescribe costly control measures for certain food and agricultural processing industries (including scaling factors for VOC measurements).
Indirect impacts to agriculture could be greater than direct impacts. The new standards will significantly increase farm energy, fuel, and equipment prices, and transportation costs. For example, the profitability and profit margins of some crops can be dramatically influenced by motor fuel and electricity prices. Indirect impacts include restrictive permitting requirements on processors that affect plant expansions, as well as the loss of federal highway and transit funding.
Taking Action
Several agricultural processors have been involved over the last few years with a large industry coalition, including the American Petroleum Institute, the Corn Refiners Association, and the National Petrochemical and Refiners Association, fighting to keep the EPA from making the particulate matter and ozone NAAQS more stringent. Last year, this coalition pushed to maintain the particulate matter NAAQS, and this year is pushing to maintain the ozone NAAQS.
The coalition has said the existing “primary and secondary standards are ‘requisite to protect’ the public health and welfare,” and that the revisions to the standard are not justified. Also, “the controlled human clinical studies have not demonstrated effects of health concern, even in asthmatics, at levels below the current standard. The epidemiological studies have too many uncertainties and confounding factors to reliably implicate ozone, particularly at levels below the current standard, as causally related to the health effects involved in those studies. Also, EPA’s risk assessments are based on a number of unsupported assumptions, including a substantial underestimate of ‘policy-relevant background,’ that make them an insufficient basis for lowering the standard.”
In referring to “policy-relevant background,” the coalition does not necessarily argue with all of the scientific conclusions of EPA and CASAC, but emphasizes that the risks have been overemphasized and the economic impacts on industry and the economy have been underestimated.
The U.S. Department of Agriculture (USDA) has been reluctant to weigh in on the ozone issue as strongly as they did on the particulate matter regulation.
The National Renderers Association is monitoring, attending meetings, and communicating with the NAAQS coalition, which is meeting with administration officials and USDA personnel to emphasize the consequences of unnecessarily stringent ozone limits. The coalition is undeterred even though the chances of success on lessening the impact of new ozone regulations is believed to be somewhat less than was accomplished on particulate matter last year.
June 2007 Render