Environment

INGAA recommends that the EPA does not adopt more stringent Ozone regulations.

INGAA recommends that the EPA retain the current 75 part per billion (ppb) ozone NAAQS rather than pursue a more stringent standard.

In addressing its concerns, INGAA raises the following specific issues: (1) ambient ozone levels are declining and likely will continue to decrease in the coming years; (2) there is significant uncertainty in both the health benefits and implementation costs (3) EPA’s analysis is based on the use of “unknown” controls; and (3) if the EPA chooses to adopt lower NAAQS, INGAA supports the proposed grandfathering provisions for Prevention of Significant Deterioration (PSD) permitting.