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NAM Call to Action: Proposed Rule Could Choke US Economic Growth, Job Creation – Contact EPA Today!

Environmental Protection Agency (EPA) proposed regulations that will severely harm U.S. companies and jobs.

On July 11, 2007, the EPA published proposed ozone regulations that could lead to significantly more heavy-handed environmental controls on your company. If approved, the new rules could replace the current ozone standard – which has yet to be fully implemented – with a much more costly and unworkable standard.

Manufacturers and interested parties have 90 days – until October 9, 2023 – to provide public comments to EPA on its proposed ozone rules. The EPA will issue final rules in March 2008.

Impact on Manufacturing:
Some 391 counties are in "non attainment" – not in compliance with EPA’s current proposed ozone standard. That number could triple – to 1,243 counties – should EPA’s most stringent option take effect.

A more stringent ozone standard – especially one that is not based on sound science – could have a devastating effect on American manufacturers, their workers and their communities. Consider the following:

Plant closures and massive manufacturing job losses are inevitable

  • Several metropolitan areas have concluded that they will not be able to meet the current standard even if they close down every factory and refinery in their city;
  • Higher energy and transportation costs would be unavoidable;
  • More reliance on foreign sources of energy would occur, as a stringent rule would make it nearly impossible to expand U.S. refining capacity or pursue development of any fossil fuels; and
  • Stricter environmental controls for companies in non-attainment areas will require billions of dollars in capital expenditures.

Action Requested:
The EPA needs to hear from American manufacturers, workers and their families as well as state, county and community leaders potentially affected by the new rules. We need your company to weigh in with EPA as soon as possible.

The NAM has drafted sample comments for your convenience – accessible at – that can be emailed directly to EPA and placed in the public docket. The comments underscore vast improvements made to air quality during the past 30 years and question the "science" used by EPA to justify a more stringent standard.

We expect additional information that may be helpful in drafting your own comments to EPA, including a study on the economic and health affects of the new regulation, to be available in August. We will provide you with that information, along with sample comments to state and local officials, job data, and other resources, as soon as it becomes available.

NAM Position: Keep the current ozone standards intact:
Many states and communities are well on their way to investing more than $100 billion in implementing these standards. Under the current rules, emissions from power plants will be cut in half by 2015; emissions from cars and trucks will be reduced by more than 70 percent by 2030. The current standard continues to protect human health.  The EPA should focus on helping communities meet the current standard before imposing new standards.

NAM Resources and Staff Experts:
For more information, contact Bryan Brendle, NAM Director of Energy and Resources, at [email protected] or (202) 637-3176.

To access the NAM’s Ozone Tool Kit, visit

To use the NAM’s sample comments to EPA, go to

To receive regular email updates on this issue, contact Bryan Brendle, [email protected].


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