On March 14, 2011, AGA submitted technical questions to the Clean Air Scientific Advisory Committee (CASAC) Ozone Review Panel concerning EPA’s reconsideration of the 2008 national ambient air quality standards (NAAQS) for ground-level ozone smog. If EPA makes the ozone NAAQS more stringent, this will create serious compliance problems in parts of the country that have not yet achieved the 2008 version of the air quality standards. Local air quality agencies do not have control over tailpipe emissions from cars, buses and trucks – the main source of smog inducing emissions – and they have already imposed stringent limits on stationary sources. They are now running out of options, particularly in areas such as Southern California where a more stringent ozone standard could require imposing a ban on all combustion – even of clean natural gas. Ironically, this could lead to increased reliance on imported coal-fired electricity causing increased air pollution and carbon emissions in other states.
In light of these unintended consequences, it is important to avoid setting the standard at a level that is overly stringent and not supported by the relevant science. AGA is asking the Ozone Review Panel to evaluate scientific approaches and assumptions that can affect the stringency of the ozone NAAQS.