November 19, 2014
The Honorable Terence R. McAuliffe
Governor of Virginia
P.O. Box 1475
Richmond, VA 23218
RE:
EPA NAAQS Ground-Level Ozone Standard
Dear Governor McAuliffe:
Thank you for raising awareness about the economic disparity of the U.S. EPA’s proposed rule for reducing
carbon emissions from existing power plants through Section 111(d) of the Clean Air Act (CAA or Act). As
you know, in a recent letter to President Obama, fifteen governors stated that “The economic health of our
nation depends on accomplishing a balanced energy and environment policy. The United States should be
pursuing a strategy that achieves its objectives without severely harming our economies and pitting states
against one another.” With that in mind, I write you today to ask for your continued leadership on U.S. EPA’s
proposed ground-level ozone limit under the National Ambient Air Quality Standards.
It is our observation that the proposed 60 ppb standard would stall an already stumbling Virginia economy. In
fact, a study recently completed by NERA for the National Association of Manufacturers estimated that the
Virginia economic impact would be:
•
$46 billion in gross state product loss through 2040
•
36,123 fewer Virginia jobs (or job equivalents) each year through 2040
•
$11 billion increase in total compliance costs across all state sectors from 2017 - 2040
•
$990 more paid by Virginia households annually in the form of lost consumption
•
Up to 32% increase in household natural gas prices and up to 15% increase in household electricity
prices nationwide
•
Estimated shutdown of 31% of Virginia’s coal-fired generating capacity
To be clear, much of Virginia is already compliant with the current 75 ppb standard set in 2008, though some
Northern Virginia locales have fallen short. A lower standard is almost certain to exponentially increase nonattainment zones across the Commonwealth. If that happens, it is likely to set off a chain reaction of events
including mandates to retrofit facilities with expensive filtration equipment, added vehicle emissions testing and
stalled economic development.
Like U.S. EPA’s proposed Section 111(d) rule, the final standard has not been set. We strongly encourage you
to write a letter to President Obama detailing how harmful the proposed NAAQS ground-level ozone standard
will be to the Commonwealth. We also encourage you to ask President Obama to reconsider the entire
standard. This is not a foreign concept to the White House. In 2011, President Obama directed the U.S. EPA to
halt development of similar regulations due to the economic harm they could cause.
Thank you for your consideration.
Sincerely,