Two weeks ago I was invited to speak to the White House’s Office of Management and Budget (OMB) regarding the Environmental Protection Agency’s (EPA) proposal to revise the national ozone standard. That standard reflects this nation’s seriousness in taking efforts to reduce air pollution and protect public health. Using evidence-based data to conclude that the current standard of 75 parts-per-billion (ppb) “is not adequate to protect public health,” the EPA sought to strengthen the standard by lowering it to 65-70 ppb. Pressure from the American Lung Association, the American Academy of Pediatrics, and others prompted the EPA to go even lower — 60 ppb. (Read “The Case For 60 PPB” here.)  As I mentioned in my public comment:

“…I have read the EPA’s proposal to lower the ozone standard. I understand that the lower we go, the more costly the proposal becomes. But I also see that the lower we go — even down to 60 PPB — the greater the health benefits AND economic benefits become.

Going low also sends the message that finally, Americans are being serious about addressing a critical topic you don’t need to be a scientist to understand: the real and present danger of climate change.

Because of all of this, I endorse a new ground-level ozone standard of 60 PPB — the lower the better — in order to do what’s right for children and protect their health today, and tomorrow.”


Last week the EPA announced its decision for the new national ozone standard: 70 ppb. The Associated Press reported that no one seemed happy with the decision:

Business groups said a new ozone standard is unnecessary and could jeopardize jobs.

Environmental and public health groups also were unhappy. They said the new standard was a step in the right direction but did not go far enough.

EPA Administrator Gina McCarthy said her job is to set science-backed standards that protect the health of the American people.

“Put simply, ozone pollution means it hurts to breathe for those most vulnerable: our kids, our elderly and those suffering from heart and lung ailments,” McCarthy said. “Today’s action is one of the most important measures we can take for improving public health, reducing the costs of illness and protecting our children’s health.”

Harold Wimmer, president and CEO of the American Lung Association, said the new standard “simply does not reflect what the science shows is necessary to truly protect public health.”


“Business groups” have a long history of being wrong in their cost-benefit analyses when it comes to regulations enacted to protect public health (think of predictions of economic catastrophe that accompanied proposals to regulate seat belts, energy efficiency, acid rain and other environmental policies, tobacco, occupational health, and so on), even though, as Patrick Rucker discovered, there will be costs of compliance with the new standard:

Industry will face costs of $3.9 billion under Thursday’s rules, the agency has estimated.

Business groups say stringent ozone rules will harm the economy by forcing manufacturers and utilities to buy expensive new “scrubbers” and other technology to make sure their plants reduce emissions of toxins.

States will have years to work with power plants, factories and refineries to limit pollutants like nitrogen oxide and volatile organic compounds, components of smog.

The American Chemistry Council, a Washington-based lobbying group, predicted that the rule will increase business uncertainty.

“Today’s action puts $10 billion in chemical industry investment at risk,” it said in a statement. We are very concerned that some projects – new facilities, plant expansions and factory restarts – will remain in limbo until EPA explains how to obtain a permit under the new standards.”


The modest lowering of the ozone standard to 70 ppb won’t cause economic ruin. But it isn’t nothing, either, when it comes to protecting public health. And it’s in line with President Obama’s strategy of getting various interests onboard with changes that end up being not-so-much revolutionary, but, rather, incremental. As the president recently told Jeff Goodell in an interview about climate change in Rolling Stone:

One of the things about being president is you’re never starting from scratch, you’ve got all these legacies that you wrestle with. And obviously, the fossil-fuel economy is deeply entrenched in the structure of everybody’s lives around the world. And so from the start, I’ve always talked about a transition that is not going to happen overnight.

And regardless of how urgent I think the science is, if I howl at the moon without being able to build a political consensus behind me, it’s not going to get done. And in fact, we end up potentially marginalizing supporters or people who recognize there’s a need to act but also have some real interests at stake.


Here is what the EPA scientists, actuaries, and accountants predict will result from dropping the national ozone standard from the current 75 ppb to the newly-proposed 70 ppb:


  • It will cost the nation (excluding California) $3.9 billion in 2025 to be in compliance. (Lowering the standard further — to 65 ppb — would cost $15 billion.)
  • The annual health benefit (i.e. savings) is $6.4 – $13 billion in 2025. (Going lower to 65 ppb, the benefit would be greater — $19 – $38 billion.)
  • The new standard of 70 ppb should result in the following estimated annual reductions in illness and death:


Premature deaths (children and adults): 710-1,400. (For 65 ppb: 2,000-4,300 lives would be saved.)

Asthma exacerbations (children 6-18): 320,000. (For 65 ppb: there would be 960,000 fewer asthma attacks.)

Acute bronchitis (children 8-12): 790. (For 65 ppb: 2,300 fewer cases.)

Upper and lower respiratory symptoms (children 7-14): 24,000. (For 65 ppb: 70,000.)

School loss days (children 5-17): 330,000. (For 65 ppb: 1 million less lost school days.)

Asthma emergency room visits (adults and children): 1,700. (For 65 ppb: 4,300 fewer ER visits).

Respiratory hospital admissions (adults and children): 510. (For 65 ppb: 1,500 fewer admissions.)

Cardiovascular hospital admissions (adults): 180. (For 65 ppb: 530.)

Days adults miss work: 65,000. (For 65 ppb: 180,000 days less of missed work.)

Non-fatal heart attacks (adults): 64-600. (For 65 ppb: 180-1,700 fewer heart attacks each year.)


A modest reduction of the national ozone standard from the current 75 ppb to the newly-proposed 70 ppb will result in large health and economic benefits compared to the costs of compliance. Moving further to 65 ppb would have cost more, but that cost would have been offset by even greater health and economic benefits. There is every indication that going even lower — to 60 ppb — would have resulted in even greater health and economic savings, even if it cost more to get there.

Nonetheless, the EPA decided on 70 ppb.

A modest, incremental, but meaningful change to protect public health and improve the lives of all Americans — especially children.

That is change we should all believe in.