Consumer Specialty Products Association Testimony at the EPA Public Hearing Proposed Rule National Ambient Air Quality Standards for Ozone EPA, Room 1153, 1201 Constitution Avenue NW, Washington, DC January 29, 2015
I am D. Douglas Fratz, Senior Science Fellow of the Consumer Specialty Products Association. CSPA is a national trade association representing more than 250 companies that manufacture and market consumer specialty products. These products include formulated products for household and automotive care as well as lawn and garden care. They are used by household consumers, as well as institutional, commercial and industrial users. The safe and effective use of these products provides numerous health, safety and environmental benefits.
CSPA member companies have spent very significant amounts of time and resources over the past 25 years to reduce the volatile organic compounds (VOCs) in our products. We are proud of our success to date in reducing VOCs by more than 50% in compliance with regulations adopted by California and various other states. The cost of those reformulations, however, have been high, with billions of dollars spent to date. Due to the low photochemical reactivity of our emissions, studies show that our emissions result in minimal ozone. Nevertheless, we know that our industry will continue to be targeted by regulations until ozone standards are attained. While CSPA and its members remain committed to the goal of improved air quality, the costs of attaining those goals are substantial, and time is needed to develop new attainment strategies.
CSPA believes that it is inappropriate to lower the ozone standard further at this time. In 2008, EPA lowered the primary ozone standard from 84 ppb to 75 ppb. But implementation of that standard is still in progress. California will be developing its SIP this year for submission to EPA next year, and will be implementing further regulations in years after that. Consumer products play a very minor role in ozone formation. Nonetheless, we realize that our consumer products will likely continue to be targeted by California and other states. Premature imposition of a lower standard—whether 70 or 65—could force states to seek reductions from consumer products that are simply not feasible. Implementation of the current ozone standard may result in significant new insights regarding what measures are cost effective in lowering ozone in California and other non-attainment regions. We urge EPA to allow time for state and regional implementation of the existing standard, and for necessary new technologies in various sectors to be developed and commercialized.
CSPA appreciates the opportunity to comment on this proposal to lower the National Ambient Air Quality Standards (NAAQS) for Ozone. We all want clean and healthy air, but we should not move the target too fast. CSPA urges the EPA to retain the current ozone standards until states have completed their implementation planning. Thank you once again.