Leave EPA air-quality standards alone for now

Sunday, April 4, 2010

By Chauncy Buchheit

I write in response to your editorial ("Air quality," March 31). Basically, I wanted to express our agreement with your position formally and for the record.

The Southeast Missouri Regional Planning Commission has a four-decade history of working with local governments, the state government, not-for-profit organizations, community organizations, educational institutions and private business on a variety of issues. During the process of developing recommendations for nonattainment areas under the ground-level ozone standards promulgated in March 2008, we were involved from the start. We hosted meetings, contracted technical support, prepared position papers and testified before the Missouri Air Conservation Commission. The result of that process was a series of recommendations submitted to EPA by the state of Missouri, recommendations with which we agreed.

As of January of this year, though, EPA changed the rules. It has decided that the 75-parts-per-billion standard is not adequate. Rather, they propose a primary standard in the range of 60 to 70 parts per billion and a secondary standard that will, almost certainly, be more stringent still. This has been done before the existing standard was fully implemented and had a chance to work -- or not work, as the case may prove.

We believe that this change will have, at best, extremely minimal effect and benefit. At worst it may well result in an actual deterioration in air quality as projects which might be undertaken are foregone due to added expenses associated with meeting more restrictive permitting requirements. From an economic development point of view this new standard will certainly hinder our efforts at business development and job creation. Stated in its simplest terms, designation as a nonattainment area will give prospects a reason to say "no" to our area.

This is, in the view of the membership of the regional planning commission, important enough that we have taken some unusual steps. We have formally commented to EPA on the proposed change in the standards. We have communicated with the entire Missouri congressional delegation regarding this issue, requesting their assistance in stopping the implementation of this proposed rule. We are working to gather allies among other regional organizations, local governments, business groups and others who would be affected by this rule.

It is important to understand that this is clearly a political/policy matter. For evidence, I offer EPA's own publications. They make the flat statement that no new scientific evidence was a part of the decision to reconsider the standards. If there is no science, the only conclusion is that there were disagreements of interpretation or, by definition, policy. As a policy matter we believe strongly that costs must be weighed.

The administration at the highest levels, including the president, and the governor of Missouri have made it clear that the economy, and more specifically, jobs should be the central focus of government efforts during the widely reported recession. It is impossible, in our view, to square this position with the imposition of new costs estimated in the range of $19 billion to $90 billion on a fragile economy. This is especially true in view of the scientific analysis that went into the 2008 standards. The precursors of ozone (nitrogen oxides and volatile organic chemicals) are, by their nature, extremely transportable. Our analysis, supported by the Missouri Department of Natural Resources, suggests that our ozone problems (presuming that levels above 75 parts per billion do present a problem) begin in the Ohio River Valley and as far away as the Gulf Coast. Any efforts we make locally will have minimal effects.

The regional planning commission's position is simple and clear. Leave the standard at 75 parts per billion and review results in five years. This would be the normal course of events. This simple approach would accomplish two very important things. First, it would give the standard that is not yet two years old and has yet to be fully implemented a chance to work. Second, it would give our fragile economy additional time to mend.

Chauncy Buchheit is executive director of the Southeast Missouri Regional Planning Commission.

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