Our Comment on National Ambient Air Quality Standards for Ozone Pollution

Submitted by Mary Meade on August 31, 2020
Chuttersnap on Unsplash

Fran Teplitz, Executive Co-director, Green America and Director of Green America’s Green Business Network provided the following testimony during a virtual public hearing conducted by the Environmental Protection Agency on August 31, 2020:

EPA Public Comment on National Ambient Air Quality Standards for Ozone Pollution: August 31, 2020

Good afternoon. My name is Fran Teplitz and I serve as the executive co-director of Green America for business, investing, and policy where I direct our Green Business Network. Green America is a national membership organization that uses the power of consumers, investors, and business to build an economy that works for people and the planet. We have 200,000 individual consumer members and more than 2,000 business members dedicated to socially just and environmentally responsible practices.

I appreciate the opportunity to speak before you today, representing our business members who care deeply about policies that address the human, environmental, and economic health of our nation. The need to effectively regulate ozone pollution, is one of those policies. I therefore urge the EPA to adhere to the scientific findings and strengthen the National Ambient Air Quality Standards. The American Lung Association and others have done extensive research and recommend that the ozone level be no higher than 60 parts per billion. The current standard allowing up to 70 parts per billion is unacceptable. Let me explain why responsible businesses care about clean air, as I have articulated in past testimony.

A growing number of business leaders now recognize that policies that support workers, communities, and natural eco-systems also best serve the long-term interests of our economy. We see time again that exploitation of resources, whether human or environmental, while potentially financially profitable for certain sectors in the short term, ultimately does not serve our national interests well over time. With ozone pollution, as with pollution from methane and other greenhouse gases, policy makers need to take into account the serious health and economic consequences that will result if weak standards, that violate the Clean Act, are allowed to move forward.

Smart business leaders therefore are increasingly speaking out and taking action related to community health and climate pollution.

First, in terms of public health, the business community only stands to gain from having a healthy workforce. Days lost to sick leave, whether for oneself or for one’s dependents, and increasing visits to the emergency room, take an economic toll. The EPA’s regulation of ozone air pollution in the troposphere should play a leading role in protecting public health. A weak standard will increase the rate of people suffering from asthma attacks, risk of respiratory infections, low birth weight and damaged lungs in newborns, and heightened risk of death. Communities of color face even worse health outcomes than white communities.

Secondly, in terms of climate pollution, businesses, especially small business, only stand to gain from actions that address the climate crisis. Leaking, venting and flaring of methane gas, which the EPA is failing to regulate, also leads to unhealthy ozone smog. Methane emissions have 80% times the heat-trapping capability of carbon dioxide, making it a major cause of the climate crisis. Strong regulation of methane is therefore needed as well to mitigate the climate crisis, lower ozone pollution, and protect human health. As the Union of Concerned Scientists assets: “Given the strong dependence of ozone formation on temperature, a changing climate can make ozone pollution worse.”

Among the many disruptions caused by climate change are its economic impacts, especially for small businesses that are far less capable of responding successfully than are large corporations. In the sectors of agriculture, landscaping, fishing, tourism, recreation, and others – the impacts of climate change are expected to be profound. We need to recognize the connection between the climate crisis and ozone pollution and take strong action immediately.

On behalf of small businesses, especially those committed to sustainability, I urge the EPA to adopt a strong ozone pollution standard that ensures ozone pollution is no higher than 60 parts per billion as the science recommends.

Thank you.

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