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BRT Letter on Forthcoming Proposed Ozone Rule

October 21, 2014

The Honorable Gina McCarthy
Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW, Room 3000
Washington, DC  20460

Dear Administrator McCarthy:

On behalf of the more than 200 CEO members of Business Roundtable, who lead major U.S. companies operating in every sector of the economy, we are writing regarding the ozone national ambient air quality standard (NAAQS).

The Clean Air Act has been a success.  The air we breathe is cleaner, the skies over our cities are clearer, and the risks associated with air toxic emissions substantially lower. Many Business Roundtable member companies offer cutting edge energy and environmental technologies and continue significant investment in developing new innovative products including advanced emissions control technologies.  However, there are areas in the U.S. still struggling to meet the existing ozone standard.  While technological feasibility is not necessarily a factor to be considered in setting a health-based NAAQS, we should be careful to weigh the impact on economic growth and job creation.

We respectfully request that when the EPA issues its proposed rule regarding possible revisions to the ozone NAAQS this December, it specifically request comment on maintaining the existing level of 75 ppb.  By including this option, EPA will ensure that a robust record is developed covering a variety of options for the agency to consider.

We know that you and your team are considering these concerns in the development of the revised ozone standard.  Thank you for your consideration of this request, and we look forward to working with you and serving as a resource as you move forward.

Sincerely,

David M. Cote
Chairman and Chief Executive Officer
Honeywell
Chair, Energy and Environment Committee
Business Roundtable

C: Dr. Howard Shelanski, Administrator, Office of Information and Regulatory Affairs, Office of Management and Budget, Executive Office of the President
 

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