RMA against proposed ozone rule

ERJ staff report (RD)

Washington -- Concerned about the burdensome effect it will have on the US tyre industry, the US-based Rubber Manufacturers Association (RMA) has spoken out against a proposed new federal regulation “aimed at reducing ozone short circuits in the regulatory process.”

The RMA claims a new standard proposed by the Obama Administration to examine air quality under the Federal Clean Air Act adds up to $90 billion in costs to businesses and has an adverse effect on air quality, a 19 April RMA statement said.

Under the Clean Air Act, the US Environmental Protection Agency (EPA) is required to evaluate National Ambient Air Quality Standards (NAAQS) for ground level ozone. Recently, the Obama Administration has reconsidered the set of standards put in place by the George Bush Administration in 2008, the statement explained.

According to the RMA, the decision to revise the NAAQs for ground level ozone “short cuts” the process for revising the NAAQS established in the Clean Air Act, “and in the process the EPA Administrator is not relying on the “latest scientific knowledge” regarding public health and welfare, the RMA said.

“In simple terms, EPA is proposing to reduce the primary ozone NAAQS based largely on clinical studies showing respiratory effects -- but no apparent health effects -- in sensitive individuals at 0.060 ppm (parts per million), and on epidemiology studies that EPA believes suggest there may be effects of exposure to ozone concentrations below 0.075 ppm,” RMA said in its comments.

“The clinical studies, however, did not demonstrate a clear adverse health effect from exposure to ozone concentrations below 0.075 ppm, even in the harsh conditions of the clinical tests,” the statement added.

The RMA said the revised standard will have a “extremely burdensome” on the tyre industry, explaining that RMA member facilities are currently predominantly located in rural areas that are currently designated as “attainment areas” -- which comply with current federal regulation - whereas under the proposed standard, many RMA member facilities will be in non-attainment area and exceed federal ozone regulations.

The effect of being in a non-attainment area, the RMA said, means increased operating costs, permitting delays, and restrictions on expansions. Also, any facilities located in areas that are designated as “severe” or “extreme” non-attainment will face significant penalty fees under the Clean Air Act.

EPA estimates that revising the primary standard to a level at or near 0.060 ppm would produce annual benefits of $35-100 billion in 2020. Annual costs, however, are projected to be $52-90 billion.

“In other words, even using EPA's optimistic assumptions about attainment status, costs, and benefits, there is a good chance that the costs of meeting the revised NAAQS would exceed the benefits by billions of dollars,” RMA said. “If EPA lowers the primary ozone NAAQS to a level at or near 0.070 ppm, EPA projects annual benefits of $13-37 billion and annual costs of $19-25 billion. Again, even with EPA's dubious assumptions it is entirely possible that the costs would exceed any benefits,” the statement added.

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Press release from Rubber Manufacturers Association (RMA)