The People of America's Oil and Natural Gas Indusry

Ozone NAAQs

Protecting the Environment and Economy

The Environmental Protection Agency (EPA) has a statutory duty under the Clean Air Act to periodically review the National Ambient Air Quality Standards for six primary pollutants: carbon monoxide, lead, nitrogen dioxide, ozone, particle pollution and sulfur dioxide. These reviews are designed to ensure that the air quality standards are set at levels to protect public health.

A combination of cleaner gasoline and diesel fuels, modernized equipment and facilities, and more fuel-efficient vehicles have helped reduce emissions of air pollutants by 62 percent between 1980 and 2013 — even as vehicle miles traveled went up more than 95 percent. Progress is clear — ozone concentrations under the current rules have decreased by 18 percent since 2000.

Reviews of air quality standards should be based on scientific analysis and conclusions, but too often EPA embraces an obvious politicization of the air quality standard-setting process that could mean unnecessary cost increases for consumers, job losses for workers and less energy security for America. Our national progress on air quality has been great, and we can build on this progress without some of the unnecessary and potentially very damaging standards EPA has proposed in the past.

“Communities and businesses must be allowed to continue the progress they have made without the uncertainty and unnecessary cost for all americans created by shifting standards to levels that achieve no demonstrable health benefit.”

Air Quality Progress

EPA creates air quality trends using measurements from monitors located around the country. The table below shows that air quality based on concentrations of the common pollutants has improved nationally since 1980.

Percent Change in Air Quality 1980 vs 2013 1990 vs 2013 2000 vs 2013
Carbon Monoxide (CO) -84 -77 -60
Lead (Pb) -99 -99 -91
Nitrogen Dioxide (NO2) (annual) -60 -54 -45
Nitrogen Dioxide (NO2) (1-hour) -59 -47 -31
Ozone (O3) (8-hr) -32 -22 -17
PM10 (24-hr) --- -39 -36
PM2.5 (annual) --- --- -37
PM2.5 (24-hr) --- --- -37
Sulfur Dioxide (SO2) (1-hour) -84 -81 -69

NOTES: --- Trend data not available
Negative numbers indicate improvements in air quality

The oil and gas industry has invested $284 billion since 1990 to improve its environmental performance – investments that build on past progress and that will continue to improve air quality in the years ahead. Like all Americans, we want a clean and healthy environment for ourselves, our neighbors and our families.

Sensible government regulations can contribute to safety and the protecting health without impeding energy development, job creation, revenue generation and economic growth. With more new rules coming in the next few years, including possible new ozone standards, it’s critical that our government ensure proposed regulations make sense and that standards aren’t changed needlessly.

The oil and natural gas industry operates under extensive rules that along with the industry’s own best practices and standards have enabled it to steadily improve safety and reduce environmental impacts. Our fuels are much cleaner today, and so are our facilities; this contributes significantly to decades of improving air quality – as EPA emissions data confirms.

We can build on this progress without stricter and potentially very damaging standards that EPA may soon finalize. Air quality continues to improve under current regulations and the oil and natural gas industry is committed to making the air we breathe cleaner, while creating new jobs and growing the economy.

Current Ozone Standards

Air Quality continues to improve as communities comply with existing standards.

Map: Ozone Concentration

Source: U.S. Bureau of Labor Statistics, January 8, 2013.

Current EPA standards for ozone are 75 parts per billion (ppb). They were adopted in 2008, but EPA’s implementation guidance for the 2008 rule has just been released. Even so, air quality is improving.

Take a look at California. In 2008, 34 of the state’s counties exceeded 75 ppb, according to EPA data. In 2014, the number of California counties over 75 ppb was just 20. We should finish implementing the current standards before new ones are proposed.

As is clear on the map, about 40 percent of the country’s population lives in areas that exceed 75 ppb standards. Air quality will improve as these standards are implemented in the individual states.

PROPOSED Ozone Standards

Projected Nonattainment in the United States (70 ppb)

Map: Projected non-attainment

Source: URS.

An analysis of the three most recent years of ozone data show that at the current standards, 217 counties are measured or projected to be out of attainment or in metropolitan areas that do not meet the standards. EPA is lowering those standards to 70 parts per billion, which would increase the number of counties in nonattainment to 958, a fourfold increase in the number of counties and county equivalents impacted. This includes even pristine areas with no industrial activity such as national parks.

The reality is that the EPA’s ozone standards approach or are lower than peak background ozone levels (the ozone that would normally exist without any human-produced emissions), which could effectively shut down new economic activity. Businesses of all sizes could be forced to navigate additional layers of bureaucracy and red tape to satisfy added permitting requirements. This could even prevent communities from improving aging infrastructure such as highways or waste treatment facilities.

Tightening the standards will not improve air quality any faster, but these regulations could hurt jobs and the economy by imposing unachievable emission reduction requirements on virtually every part of the nation. New standards could affect or restrict virtually any human activity that produces emissions. Strict standards aren’t justified from a health perspective and certainly aren’t needed to continue air quality progress that’s being made under current standards.