Unknown Controls To Protect You- EPA and Ozone Overreach

I am not a fan of the ever expanding collection of bureaucratic 'solutions'. The reality of unintended consequences seem downright unthinkable to those deciding.

Try to keep in mind I'm not actually your opponent as you review the following criticism of the argument you made. Your argument needs to be much stronger to have a chance of influencing the policy.

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First, for a subject like this, references are obligatory. At a minimum, links to the study you referenced concerning GDP effect and to the EPA proposal....especially the part about unknown controls...should be provided. This is a complex and diverse discussion. Many readers will likely adopt your analysis...but you should go out of your way to make sure they have the opportunity to make up their own minds.

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So here is one EPA link on this subject that provides information on many of the points you emphasize.

http://yosemite.epa.gov/sab/sabproduct.nsf/264cb1227d55e02c85257402007446a4/5EFA320CCAD326E885257D030071531C/$File/EPA-CASAC-14-004+unsigned.pdf

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In that link an estimate is made that 3 dollars in health care costs will be saved for every dollar spent on implementation. Asthma in children and adults as well as respiratory illness and cardiovascular disease are expected to see large reductions according to numerous academic papers and studies. Research is also referenced indicating an increase in crop yields and ever timber. Perhaps the recent study you reference concerning costs could provide a decent rebuttal to their projections.

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Speaking of projections: some insight into the projections you provided as 'Our Shops Can Expect' could be very helpful.

For example, if 75% of the cost of a raw material comes from the electricity used to produce it and electricity costs increase by 16%, then the increase in cost of the material related to the electricity cost increase should be 12%, where is the other portion (8+% in this example....but even more if electricity if not that big of a component) coming in? If production is tanking, shouldn't raw materials finding cheaper equalibrium on the supply demand curve?

If industry is right and the EPA estimates for implementation are an order of magnitude low, isn't it probable that machine shops will see addition orders to manufacture some portion of the unknown controls?

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By the way, lots of big projects are planned relying on yet to be invented tech. We built the atom bomb and put a man on the moon using plans that initially relied on solutions not yet invented.

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One more thing that deserves clarification: early on you suggest that machine shops might be force to purchase new equipment. What equipment do precision machine shops typically use that leads to ozone? The EPA isn't focused on actual ozone emissions, but rather the emissions of VOCs and oxides of nitrogen. I suspect laser and plasma cutting produce some oxides of nitrogen, though I'm not sure how much. Do machine shops really release that much in volition organic compounds to the environment to be a concern?

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I hope this critique is taken in the way it is intended.

Thanks for the thoughtful reply.I will jump right to your last question, as debating the minutiae of whether EPA estimates, sources and links are authoritative or not is probably not worth either of our time.

"One more thing that deserves clarification: early on you suggest that machine shops might be force to purchase new equipment. What equipment do precision machine shops typically use that leads to ozone? The EPA isn't focused on actual ozone emissions, but rather the emissions of VOCs and oxides of nitrogen. I suspect laser and plasma cutting produce some oxides of nitrogen, though I'm not sure how much. Do machine shops really release that much in volition organic compounds to the environment to be a concern?"

I spent a couple of days on Capitol hill last week: The EPA can set the limit, the states have to create compliance plans that the EPA approves. Our shops do not emit ozone, nor are we emitters of Nitrous oxides. VOC's, A small amount. Our consumption of electricity is really the only "control" we can envision. so the idea of new equipment is based on an assumption that we will not be permitted to expand our shops or add equipment if we are in an non attainment area, even though the non attainment is not of our making. So in order to grow, we might be forced to "trade" newer more efficient equipment for our existing equipment, rather than add capacity and keep running all of our productive equipment. We are not capital rich businesses, but our equipment is capital intensive.

My point is that due to geography geology, and prevailing winds, much of OHIO, Michigan, Illinois etc are Naturally noncompliant. Forcing businesses to do weird strange and unusual in an attempt to reach a non attainable goal is economic folly,. and we will pay the price, as will the people unable to find work.

Will they close Cuyahoga national Park and Yosemite on High Ozone days?

I remember when there used to be a concept called zero.

Now that we are able to count molecules, that has become a quaint anachronism, and the fools in rulemaking add yet another decimal point to requirements on industry regardless of natural occurrence of what it is that they are trying to regulate. Thanks for the thoughtful comments.

Miles

Unfortunately it is not the "fools in rulemaking" that is the issue. The current EPA works in the following manner.

Step 1 Interested Party files suit against the EPA.

Step 2 Interested Party attorneys and EPA attorneys sit down and write a "settlement"

Step 3 EPA and Interested Party go to court and state "we have come to terms, and no further court action is required."

Step 4 Attorneys and Judges go home and celebrate.

Step 5 EPA enters said agreement into the CFR (Code of Federal Regulations)

Step 6 The business(es) shut(s) down.

This is how we got the CO₂ regs and they shut down the last lead mine in the US using this tactic. Hopefully you post follow up progress reports as you go through the process.

A spot of good news in all this: SCOTUS is hearing arguments from Industry, States and the EPA and there seems to be a reasonable chance they might rule the EPA should consider cost of compliance early on.