May 28, 2015
In a March 17, 2015 letter to U.S. Environmental Protection Agency (EPA) Administrator, Gina McCarthy, the New Mexico Oil and Gas Association (NMOGA) challenged EPA’s proposed lower ozone standard saying EPA has not adequately considered a background ozone bias that impacts high altitude Western states.
EPA defines background ozone as the ozone that would exist in the absence of any man-made emissions inside the United States. This background ozone can come from natural processes, such as stratospheric intrusions or wildfires; and ozone resulting from international pollution sources. EPA says background ozone concentrations are highest in the intermountain West (especially at higher altitude sites) in the spring.
In its letter to EPA, NMOGA further states:
- EPA proposes to lower the ozone standard to a level at or near background levels, presenting a potentially impossible situation for states in the western part of the United States including New Mexico to achieve attainment.
- New Mexico suffers an even more severe impact due to the amount of terrain at a higher elevation because the method of measuring ozone introduces a high elevation bias and because stratospheric ozone impacts tend to be more frequent at higher elevations.
- The Proposed Rule seeks to impose new regulatory standards at or below background ozone levels for many western air quality control regions. Background ozone, whether attributable either to natural phenomena or to emissions from outside of the U.S. is plainly beyond a State’s (or EPA’s) control, and Congress simply did not intend to require states to do the impossible.
What this means to you
High elevation states in the western U.S. with higher than normal spring background ozone ratings may have an argument against lower EPA ozone limits.
MIRATECH can help
Contact MIRATECH to discuss emission controls for your stationary engines.