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States Need Additional 25% Emissions Reduction to Address Ozone Climate Change Penalty

May 30, 2012

I don’t think anyone in the public is aware of this issue.  It appears that States will be required to find an additional 25% NOx reduction to address the projected climate change penalty according to recent scientific research.  This translates into billions of dollars in additional controls on top of what already will be required to address ozone.  Harvard University provided the following in a May 2012 presentation to EPA:

 “In this example, 2000-2050 climate change implies an additional 25% reduction in NOx emissions (from 40% to 50%) to achieve the same ozone air quality.” 

And who will be responsible for coming up with this additional 25% reduction on top of what already will be required to achieve the ozone NAAQS ?  Yup . . . the States!  It is the States responsibility to achieve the NAAQS under the current Clean Air Act (see 42 U.S.C. § 7407(a)).

BTW – In the ozone SIP context, the question of whether anthropogenic emissions are warming the planet is really moot.  The only question is whether the planet is warming.  In fact, the question really is not whether the planet is warming, but whether the planet is projected to warm—since SIP controls are based on modeling and projected future attainment needs.

Is the problem of continuing to rely upon the SIP process readily apparent?

The world is changing.  We must change with it.  Time to transform the SIP process.  We can make it happen.

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