Director of Air Quality, Kevin Cromar, provided public testimony in opposition to EPA’s proposed rule, Increasing Consistency in Considering Benefits and Costs in the Clean Air Act Rulemaking Process. Among its many flaws, two of the most important identified by Dr. Cromar are the failure to consider co-pollutants in benefit calculations and limiting benefit calculations for health impacts attributable to ozone.
[Looking only at the health benefits for individual pollutants] is in direct opposition to the Agency’s long sought after, and in some instances realized, efficiency gains that occur when considering diverse pollutants together. There are numerous examples of this multi-pollutant efficiency across the agency that range from the cluster rules that combined not only air pollutants but also water-quality rules together for pulp and paper mills, to permitting issues involving pollution offsets for a range of various pollutants.... [It is equally concerning that the Agency] intends to rely on the results of their flawed Integrated Science Assessment to no longer quantitatively consider the economic benefits of reducing mortality risks attributable to exposure to elevated levels of ozone. This flawed approach would not only fail to reflect the collective body of evidence regarding the adverse impacts of ambient ozone exposures but it would also compound the institutional shortcomings that were demonstrated during the review of the [national ambient air quality standards] for ozone.