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Business Voice for the Environment


March 17, 2015

Regina McCarthy, Administrator
U.S. Environmental Protection Agency
Attention Docket ID No. EPA-HQ-OAR-2008-0699
1200 Pennsylvania Ave. NW
Washington, DC 20460
            RE:  National Ambient Air Quality Standards for Ozone; Proposed Rule
Dear Administrator McCarthy:
As members of Environmental Entrepreneurs, we recognize that strong air pollution standards have allowed the United States to significantly reduce air pollution while supporting robust economic growth. Therefore, we write today in support of the Environmental Protection Agency’s proposal to update National Ambient Air Quality Standard (NAAQS) for ozone to the lowest level being considered.  We also urge EPA to support innovative compliance methods that allow communities and industry to partner together in order to find solutions that meet these standards while increasing economic returns. These standards will provide an opportunity for communities to innovate the energy, manufacturing, and transportation systems they rely upon to lower emissions, improve economic productivity, and provide a healthier, higher quality of life for Americans across the country.
About Environmental Entrepreneurs
E2 is a nonpartisan, national community of business leaders who promote sound environmental policies that grow the economy. We are entrepreneurs, investors, and professionals from every sector of the economy who collectively have been involved in the financing, founding or development of more than 1,700 companies that have created more than 570,000 jobs. Our members manage billions of dollars in venture and private equity capital that will flow over the next several years into new companies.
Economic Costs of Ground Level Ozone
The health impacts of ground level ozone are well known. Even very low levels of exposure can lead to acute respiratory problems, aggravated asthma, inflammation of lung tissue and decreased lung capacity.  Ozone pollution can also cause temporary decreases in lung capacity, lead to hospital admissions and emergency room visits, and impair the body's immune system defenses, making people more susceptible to respiratory illnesses, including bronchitis and pneumonia. The U.S. economy is impacted by these health costs – losing over $56 billion per year from asthma alone.
EPA estimates that an ozone health standard set at 60 parts per billion (ppb), which is even stronger than the range currently being formally proposed by EPA, would prevent up to:  
  • 1.8 million asthma attacks,
  • 1.9 million missed school days,
  • up to 180,000 missed work days,
  • 4 million days where people have to deal with pollution-related symptoms, and
  • 6,400 premature deaths.[i] 
Avoiding these health impacts means the rule would produce economic benefits of between $6.4 billion to $38 billion by 2025, significantly outweighing costs, which are estimated at $3.9 billion to $15 billion over the same time frame.  This nearly 3 to 1 return on investment will produce health benefits and help boost economic productivity and create economic activity as innovative solutions are implemented to lower pollution.

Economic Opportunities
Critics of strong ground level ozone standards have claimed that these standards are a death sentence for local economies, with an area’s non-attainment status effectively shutting down its opportunity for growth. History has shown us that this is false. Populations have grown, economies expanded, and miles traveled by car have all continued to grow nationwide—all while new standards have cleaned up our air.  In fact, we have 44 years of experience to show that cleaning up air pollution doesn’t hurt economic growth—it drives innovation.  Since 1970 dangerous air pollution has been reduced by 68% while the economy has grown by over 200%.[ii] Indeed, the Office of Management and Budget reviewed 32 major EPA rules and determined that their benefits were up to $550.7 billion dollars, compared to a combined total of $28.5 billion in costs.[iii]  
Strong air pollution standards drive economic innovation. Achieving ozone standards requires reducing the emission of two types of pollution that combine to make ozone--nitrogen oxides and volatile organic compounds (NOx and VOCs).Over the past 30 years, an abundant amount of cost-effective technologies have been developed to reduce these pollutants.
Today’s Selective Catalytic Reduction (SCR) technologies mean that plants with these pollution controls can reduce NOx emissions by over 90%. Adoption rates of this technology continue to improve, with 67% of power plants having SCR or similar technologies installed.[iv] Additionally, new thermal and catalytic oxidizers have also made control of VOCs more effective.
Advances in pollution control technologies have also spread to the mobile emissions control market as a supplement to existing catalytic converter technologies. Today, nearly every major diesel engine manufacturer in the U.S. market has created, or is working to finalize, an SCR solution for their engines.  Another major development has been the creation and implementation of Onboard Refueling Vapor Recovery systems in individual automobiles as a replacement for Stage II vapor recovery devices at fueling stations.  Not only do these devices cut VOC emissions by 300,000 to 400,000 tons per year nationwide, but they also help reduce lost fuel costs to owners.[v]
Transitioning towards renewable energy such as solar, wind power and biofuels, as well as lower emission fuels like natural gas and propane also facilitate pollution reductions. Since 2000, the Sustainable Energy in America Factbook shows that 93% of new power capacity built in the United States has come from natural gas and renewable energy.[vi] Over the last four years, wind generation has doubled and solar capacity has grown by a factor of five,[vii] and both have reduced costs by close to 40 percent. [viii],[ix]  Meanwhile, utility-run efficiency program investments have increased from $2.7 billion in 2007 to over $7 billion in 2013.[x] Across the country, municipal vehicle fleets are increasingly converting to natural gas, propane, hybrid, and more fuel efficient vehicles, saving taxpayer money on fuel costs, reducing ground-level ozone, and putting Americans to work creating these next-generation vehicles.  Investments in clean technologies like these have created jobs and new projects across the economy.
In total, the clean energy industry has been growing at a strong rate. Including all clean energy and clean transportation sectors, the U.S. has an estimated 3.4 million clean jobs as of 2013 – a number that is steadily growing.[xi]  In the last two years E2 has tracked nearly 600 clean energy and clean transportation project announcements that could create more than 210,000 jobs when completed.[xii] Additionally, according to the International Trade Administration, in 2008, the latest year for which data is available, the U.S. environmental technology sector alone was generating approximately $290 billion in revenues and supporting 1.6 million jobs. Exports of pollution control technologies have grown dramatically from less than $10 billion in 1990 to about $43.8 billion in 2008, and the U.S. share of foreign environmental technology markets has increased.[xiii] Growth trends should remain positive as clean energy installations and pollution control implementation continues to grow while costs continue to fall.
Advances like these occurred because of standards and laws that act on the moral imperative to reduce the impacts of pollution. Importantly these technologies are now reaching efficiencies of scale where costs are falling rapidly and companies are choosing investments based on cost concerns alone.  Ozone levels have already fallen 7% between 2000 and 2012 in the areas with the highest ozone concentrations.[xiv] With lower prices for controls, and the projected growth in clean energy sectors, the clear health case for safer standards is buttressed by a strong economic case.
Innovative Planning 
Strong ground-level ozone standards have also encouraged communities to rethink the very systems which promote pollution.  Through innovative compliance pathways, communities have looked to new solutions that have not only reduced pollution, but also helped improve quality of life for their residents.  Participants in these programs are implementing an array of mobile source and energy efficiency programs, point and area source-related efforts, wood smoke reduction and green infrastructure measures, as well as air quality awareness and education programs.
Some examples of these techniques are bike racks and trails at work sites, encouragement of carpooling, policies requiring sidewalks and green spaces, energy efficient buildings, timing of refueling vehicles, and truck stop anti-idling programs.[xv] These projects have yielded continuing benefits that position communities well to comply with safer ozone standards.
EPA has an important opportunity to reduce ground-level ozone.  By setting a strong standard at the lowest level being considered, EPA can help catalyze greater implementation of existing technologies and additional innovation of new technologies that have yet to reach the market. History has shown that when pushed to plan for healthier, more productive communities, American ingenuity finds an answer.  This has been proven in the increasing effectiveness of pollution control technologies, innovative community planning and the growth of clean energy solutions.  We now lead the world in pollution control innovation and clean energy technologies and are exporting that expertise around the country and the world.  These technologies have also led to economic growth that has helped create millions of good paying jobs.
These facts demonstrate that strong pollution standards are a net positive for the American economy as well as providing for a cleaner environment and improved public health.  Based on the evidence provided, as well as our moral duty to reduce pollution, we again urge EPA to update the primary National Ambient Air Quality Standard (NAAQS) for ozone to the lowest level being considered.


The following 122 E2 members have signed this letter:

Curtis Abbott (California)
CEO, Lucesco Lighting Inc
Clifford Adams (New York)
Managing Director, Coady Diemar Partners
Judith Albert (New York)
Chair, Board of Directors, Cornerstone Capital Group
Jay Baldwin (California)
Partner, Wind River Capital Partners, LLC
Dora Barlaz Hanft (New York)
Mark Bauhaus (California)
Partner, Just Business
Patricia Bauman (District of Columbia)
President, Bauman Foundation
Mitchell Beer
President, Smarter Shift
Dave Belote (Virginia)
Managing Partner & CEO, DARE Strategies LLC
Eric Berman (Washington)
President and Co-Chair, E8 Angels
Tony Bernhardt, PhD (California)
Northern California Director, Environmental Entrepreneurs
Aron Bernstein (Massachusetts)
Professor of Physics, MIT
Maureen Blanc (California)
Barbara Blumenthal (New Jersey)
President, Blumenthal Consulting LLC
Bill Boyk (Oregon)
CEO/Founder, GyroVolts by Ameristar Solar, LLC
Tim Brummels (California)
CEO/President, Prenexus Health, LLC
Reid Buckley (California)
Partner, Orion Renewable Energy Group
Barbara Brenner Buder (California)
Dianne Callan (Massachusetts)
Independent Legal Consulting, Green Tech Legal
Stephen Colwell (California)
Executive Director, Philanthropy Associates
Michael Cuddehe (New York)
Principal, Strategic Global Advisors, LLC
Andrew Currie (Colorado)
Investor, Active Minds LLC
John Cusack (New York)
Financial Services Risk Management, Maplecroft Limited
Mary Ann Cusenza (California)
Independent Consultant for high tech and cleantech companies
Peter Davis (California)
Retired Attorney
Wayne Davis (Massachusetts)
Rick DeGolia (California)
Executive Chairman, Cimbal, Inc
Michael Delapa (California)
DeLapa Consulting
Chris Dennett (Oregon)
Director of Strategy and Integration, The Tofurky Company
Ted Driscoll (California)
Partner, Digital Healthcare Lead, Claremont Creek Ventures
Tim Dwight (Iowa)
Business Development, Integrated Power Corporation
Scott Elliott (Washington)
CEO, MountainLogic
Bob Epstein (California)
Co-Founder, Sybase, New Resource Bank, Environmental Entrepreneurs
John Esposito (Tennessee)
President and CEO, Warner/Electra/Atlantic
Anne Feldhusen (California)
Consultant, Green Business Technology Marketing
Jon Foster (California)
Chief Financial Officer, Zoox
Rona Fried (New York)
President, SustainableBusiness.com
Rob Gemmell (California)
Addwater Marketing, Addwater Marketing
Nancy Gail Goebner (California)
Owner, Gardenpeach Place
Mitchell Golden (New York)
Principal, Jun Group
Susan Goldhor (Massachusetts)
Biologist, C.A.R.S.
Ken Goldsholl (California)
CEO, x.o.ware, Inc.
Susan Graff (Georgia)
Principal and Vice President of Global Corporate Sustainability, Resource Recycling Systems (RRS)
Allen Greenfield (California)
Stewart Greenfield (Connecticut)
Chairman, Alternative Investment Group
Marianna Grossman (California)
Founder and Managing Partner, Minerva Ventures
Eric Grunebaum (Massachusetts)
Principal, Bequia Securities
John Harper (Massachusetts)
Principal, Birch Tree Capital, LLC
Carol Hazenfield (California)
Communications Coach
Sheryl Heckmann (California)
Ward Hendon (New York)
Business Advisor, Independent Consultant
Alan Herzig (California)
Independent Director
Mitch Hescox (Pennsylvania)
President and CEO, Evangelical Environmental Network
Shiela Hingorani (California)
First Vice President, Morgan Stanley
Jerry Hinkle (California)
Northern California Regional Coordinator, Citizens Climate Lobby
Delayne Johnson (Iowa)
CEO & Founding Board Member, Quad County Corn Processors
Jerome Kalur (Montana)
Attorney at Law
Ron Kamen (New York)
Founder, EarthKind Energy
Arthur Keller (California)
Managing Partner, Minerva Consulting
Yale Klat (New York)
General Counsel and Director of Government Relations, IdleAir
Charly Kleissner (California)
Co-Founder & Investor, KL Felicitas Foundation
David Kolsrud (South Dakota)
President, DAK Renewable Energy
Philip Korsant (Florida)
Managing Member, Korsant Partners
Chip Krauskopf (California)
VP Business Development, Aditazz
Pete Krull (North Carolina)
CEO & Director of Investments, Earth Equity Advisors, LLC
DC Kuhns (Delaware)
CEO, Executive Director, Founder, EDEN Delmarva
Nicole Lederer (California)
Chair and Co-Founder, Environmental Entrepreneurs
Rebecca Lee (California)
Waidy Lee (California)
Advisory Board Member, Sustainable Silicon Valley
Florence W. Liddell (New York)
Mark Liffmann (Washington)
Vice President of Sales, Marketing and Business Development, Clean Power Research
Andrew Magee (Massachusetts)
Senior Consultant, Epsilon Associates
James Marvin (Massachusetts)
Regional Manager, North America East & Canada, Expeditors International of Washington Inc.
John McGarry (Washington)
Carol Moné (California)
Producer, Our Earth Productions
John Montgomery (California)
President, Lex Ultima
Jay Morrow (Pennsylvania)
Senior VP, AIG Property Casualty
Carl Nettleton (California)
President, Nettleton Strategies LLC
Armand Neukermans (California)
Founder, Xros
Al Nierenberg (Massachusetts)
President, Evergreen Consulting & Training
Graham Noyes (California)
Managing Attorney, Noyes Law Corporation
Standish O'Grady (California)
Managing Director, Granite Ventures, LLC
Lyn Oswald (California)
Peter Papesch (Massachusetts)
Architect, Papesch Associates
Christopher Pribe (California)
Locke Raper (North Carolina)
Former Executive Director Marketing, BBG
Ingrid Rasch (Washington)
Board Chair, Earth Economics
Grant Ricketts (California)
CEO and Co-Founder, Tripos Software, Inc.
Jamila Rockette (Colorado)
David Rosenheim (California)
Founder and CEO, JobsWithImpact
David Rosenstein (California)
President, Intex Solutions
Joan Rossetti (Massachusetts)
Chair, Environmental Affairs Committee of the Prudential Center Residents' Association
Laurie Rothenberg (New York)
John Santoleri (New York)
Partner, StoneWork Capital
Tedd Saunders (Massachusetts)
CSO, The Saunders Hotel Group
David Schwartz (California)
James Schwartz (Connecticut)
Vice President, Independence Solar
Paul B. Scott (California)
Vice President, Advanced Technologies, Transportation Power Inc
Lt Gen (ret) Noman Seip (Virginia)
Owner, NS Solutions, LLC
Barbara Simons (California)
Research Staff Member, Retired, IBM Research
Jon Slangerup (California)
Chairman and CEO, American Global Logistics
Bryce Smith (Washington)
Level Ten Energy
Irene Stillings (California)
President, U.S. Green Chamber of Commerce
Scott Struthers (California)
Co-Founder, Sonance
Peter Sullivan (California)
Founder, Clear Light Ventures
Sally Supplee (California)
Former Chief Financial Officer
Sven Thesen (California)
Communication & Technology, Better Place
Robert Thronson (California)
VP Marketing & Business Development, Vigilent
Mike Ubell (California)
Bill Unger (California)
Partner Emeritus, Mayfield Fund
Troy Van Beek (Iowa)
President, Renewable Energy Expert, Ideal Energy, Inc.
Thomas Van Dyck (California)
Senior Vice President, RBC Wealth Management
Mark Vander Ploeg (California)
Retired, Investment Banker
Alex Wall (Oregon)
Privacy Counsel, Marketo, Inc.
Jeffrey Weiss (Rhode Island)
Member, Clean Energy Venture Group
Dave Welch (California)
President, Infinera Corporation
Eric Wepsic (New York)
Managing Director, D. E. Shaw & Co.
Bonni Widdoes (Massachusetts)
President, Gladden House
Erik Wohlgemuth (Oregon)
COO, Future 500
Ion Yadigaroglu (California)
Managing Partner, Capricorn Investment Group
George Yandell (California)
Director of Real Estate, Nature Conservancy
Mary M. Yang (California)
Former Biotech Co-Founder & President
Daniel Yost (California)
Partner, Orrick, Herrington & Sutcliffe LLP
Rosamund Zander (Massachusetts)
Chairman, Independent Design Center for the Environment

124 members


[i] U.S. Environmental Protection Agency, Air Quality Trends, available at: www.epa.gov/airtrends/images/comparison70.jpg (updated Jan. 6, 2011).
[ii] “Regulatory Impact Analysis of the Proposed Revisions to the National Ambient Air Quality Standards for Ground-Level Ozone”, U. S. Environmental Protection Agency, ES-14, http://www.epa.gov/ttn/ecas/regdata/RIAs/20141125ria.pdf”.
[iii] 2011 Report to Congress on the Benefits and Costs of Federal Regulation and Unfunded Mandates on
State, Local, and Tribal Entities, Office of Management and Budget, 2011,  http://www.whitehouse.gov/sites/default/files/omb/inforeg/2011_cb/2011_cba_report.pdf
[iv] “Power plant emissions of sulfur dioxide and nitrogen oxides continue to decline in 2012”, U.S. Energy Information Administration, Feb. 2013.  http://www.eia.gov/todayinenergy/detail.cfm?id=10151
[v]  “Commonly Asked Questions About ORVR”, U. S. Environmental Protection Agency. http://www.epa.gov/oms/regs/ld-hwy/onboard/orvrq-a.txt
[vi] “Factbook: U.S. trend toward sustainable energy continued in 2014”, AltEneryMag.com, 2 Feb 2015 http://www.altenergymag.com/news/2015/02/05/factbook-us-trend-toward-sustainable-energy-continued-in-2014/36092
[vii] "Electric Power Monthly with Data for April 2013", U.S. Energy Information Administration, June 2013.
[viii] "U.S. Solar Market Insight Q1 2013", Solar Energy Industry Association, June 2013.
[ix] Downing, Louise. "Wind Farm Operating Costs Fall 38% in Four Years, BNEF Says", Bloomberg, November 2012.
[x]  “2014 State Energy Efficiency Scorecard,” American Council for an Energy-Efficient Economy. Oct. 2014. http://www.aceee.org/files/pdf/summary/u1408-summary.pdf
[xi] “Employment in Green Goods and Services – 2011,” U.S. Bureau of Labor Statistics, March 2013. http://www.bls.gov/news.release/pdf/ggqcew.pdf
[xiii] International Trade Administration, Environmental Industries- Industry Facts, Office of Energy and Environmental Industries.
[xiv] EPA, Air Trends Ozone, available at: http://www.epa.gov/airtrends/ozone.html.  
[xv] Early Action Compact Program for Ground-Level Ozone: A Study, U.S. Environmental Protection Agency, http://www.epa.gov/oaqps001/eac/pdfs/eaccasestudy2009.pdf

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