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Dravis, Samantha[dravis.samantha@epa.gov] Jack Gerard, API Thur 11/2/2017 1:28:37 PM Regulatory Certainty on Ozone Can Protect U.S. Competitiveness
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November 2, 2017
Dear Samantha,
The combined emissions of six key air pollutants dropped 73 percent between 1970 and 2016, according to the Environmental Protection Agency's latest annual air quality report, and ground level ozone levels have decreased 17 percent since 2005. All this occurred during a time of significant economic growth, and these are achievements we all can and should be proud of since it is the result of the combined efforts of states, counties and industry to reduce air emissions.
Congress can ensure continued environmental and economic progress by implementing reforms to ozone regulations that eliminate duplicative regulatory requirements. In simple terms, EPA issued new ozone regulations in 2015 before its existing 2008 regulations -the strictest in history - had been fully implemented. That is leaving states in the costly position of attempting to comply with two competing sets of ozone regulations.
To understand how important reform is, take a look at the long and varied list of 303 organizations that wrote a letter explaining the economic impact of dueling standards that, in some cases, require states to achieve ozone levels approaching or below naturally occurring levels of ozone. The coalition includes local governments, chambers of commerce, businesses, and associations representing: manufacturers, construction workers, energy producers, dairy farmers, cattlemen, auto dealers, truckers, timber producers, restaurant and hospitality groups, poultry producers, convenience stores, engineers, grocers, retailers, and many others.
Here's what they had to say:
"If implemented, EPA's stringent ozone standards could limit business expansion in many areas of the United States and risk the ability of U.S. companies to create new jobs. The standards add red tape to companies seeking to grow even in areas that can attain those standards. ... Increased costs associated with restrictive and expensive permit requirements could likely deter companies from siting new facilities in a nonattainment area, making the United States a less attractive place to do business and risking shipping jobs overseas."
The fact is, the strict 2008 ozone standards are working and will continue to reduce ozone concentrations. A House-passed bill would help cut the red tape and provide the regulatory certainty that states need to keep reducing ozone emissions without hurting job growth. The Ozone Standards Implementation Act of 2017, approved in the House earlier this year, recognizes ongoing state efforts to improve air quality, would reduce onerous requirements and facilitate the ability of businesses to expand operations and create jobs, while including other reforms that bring more regulatory certainty to federal air quality standards.
With Congress focused on tax reform and other budget issues, ozone regulatory reform fits right in as a policy priority with major economic implications for the entire nation. We urge the
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Senate to join the House in passing commonsense ozone regulatory reform. Sincerely, Jack N. Gerard President & CEO API
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API is the only national trade association representing all facets of the oil and natural gas industry, which supports 10.3 million U.S. jobs and nearly 8 percent of the U.S. economy. API's more than 625 members include large integrated companies, as well as exploration and production, refining, marketing, pipeline, and marine businesses, and service and supply firms. They provide most of the nation's energy and are backed by a growing grassroots movement of more than 40 million Americans.
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Jack Gerard, API 1220 L Street, NW Washington, DC 20005 US
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