Review of NERA’s Ozone Standards Critique


In January 2010 (and again in November 2014), the U.S. Environmental Protection Agency proposed to strengthen the national clean air standard for ozone from 75 parts per billion (ppb) to a level between 65 and 70 ppb. In February 2015, NERA Economic Consulting issued a report for the National Association of Manufacturers making extreme claims about the cost and job impacts of meeting a 65 ppb standard. NERA’s cost estimates are more than ten times higher than those made by EPA in its 2014 Regulatory Impact Assessment (RIA) for the proposed standards. Synapse reviewed NERA’s report on behalf of Earthjustice and found that it grossly overstates compliance costs due to major flaws, math errors, and unfounded assumptions in NERA’s analyses.