hma—perhaps looking at indoor air quality, which probably has a bigger impact on health than outdoor air quality, because data shows Americans likely spend at least 90 percent of their time indoors.
There are costs to regulation. Increased regulatory costs make nearly all goods and services more expensive, particularly energy. There is a real, human cost resulting from higher energy bills, especially in Texas. For poor Texans (and many poor Texans are elderly Texans), being able to keep their home cool on hot and humid summer days has a real health benefit.
If an area violates an ozone standard, it is in nonattainment, and new regulations are imposed, with the goal of bringing those areas into attainment. Those regulations and the expenses they impose make it more difficult and more expensive for many existing businesses and industries to operate, and those costs are eventually passed on to the consumer.
Being in nonattainment also means that new businesses that produce qualifying emissions may have to purchase emissions offsets to open their doors, or consider opening their business in another area that is in attainment.
If the EPA decides the new ozone standards should be at the lower end of the range, close to 60 ppb, it is likely that areas like El Paso; San Antonio; Victoria; the Tyler region in East Texas; the I-H 35 corridor between San Antonio and Dallas-Fort Worth, including Austin and Waco; Beaumont and Port Arthur; parts of the Panhandle and Rio Grande Valley; and Big Bend National Park would be in nonattainment.
For the DFW and Houston-Galveston-Brazoria areas, which are already in nonattainment, and already heavily regulated, reaching attainment would become even more difficult and further impact economic growth. All residents of these areas would be affected.
A study commissioned by the National Association of Manufacturers found that, in a scenario where new ozone standards constrained natural gas production, electricity prices could increase by 15 percent for residential customers and 23 percent for industrial customers. The study found that the new ozone standards could reduce U.S. GDP by $270 billion per year and result in 2.9 million fewer job equivalents per year on average through 2040.
The Clean Air Act, which sets air quality standards for six pollutants including ozone, is the only federal environmental law that expressly forbids the EPA from considering the feasibility and costs of attaining a standard. In my mind, that should set the bar higher for the science. This is particularly the case with ozone, because the economic costs would be enormous, and the standard will be almost unachievable even if the public is able to bear those costs. There should be no doubt that lowering the standard will result in health benefits, but that is not the case for this consideration of the ozone standard. How can the EPA in good conscience make a policy decision this expensive when the data are so contradictory that their own modeling predicts more deaths in some areas from lowering the standard?
I’m often asked, wouldn’t it be easier to just accept what the EPA does? Isn’t it a lot of trouble to try to affect the direction of the EPA’s 16,000 employees and $8 billion budget? Yes, of course that would be easier, but it wouldn’t be the right thing to do.
Environmental regulations should be based on sound science. If they are not, then it opens the door for regulations that are based on politics, or on other reasons that do not benefit the public. The TCEQ has been provided with the expertise and funding to do research and science to assure that regulations are effective and beneficial to the environment and to public health. That is what the legislature and the people of Texas task us to do, and we take that task very seriously.
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Getting to Know Dr. Michael Honeycutt, Director, Toxicology Division
Dr. Michael E. Honeycutt is a dedicated, distinguished scientist who has served the people of Texas through his work for the Toxicology Division of the TCEQ since 1996. He has served as director of the 