The Central Oklahoma region has been in compliance with national ambient air quality standards for ozone since 1978. In addition, we have been in compliance with the standards for carbon monoxide since 1990. This accomplishment has been due to the continuing proactive efforts of our civic leaders, local businesses, government officials and residents. However, we are fearful that changes to the NAAQS for ozone and particulate matter in September 1997 will thwart the progress made by grass roots efforts in Central Oklahoma.
The last three years have brought exceptionally difficult weather to Central Oklahoma, in which the best efforts of our community haven't always been able to combat the power of Mother Nature. Hot, dry weather, coupled with a persistent high-pressure system permeated the region in the summers of 1998-2000. Though our region appears to remain in compliance, it is likely or inevitable that with another hot summer, we will violate the current National Ambient Air Quality Standards for ozone. Being labeled a "non-attainment" region, even a marginal one based on the EPA's definitions, would be an unfortunate label for the region to be tasked with, as it would wipe away years of proactive and concerted work from the citizenry to address this issue.
In addition, such a label would have major financial impact on our citizens; we estimate a cost of at least 43 million dollars just for our motoring public, not to mention ramifications for our businesses.
As Congress addresses reauthorization of the Clean Air Act, we appreciate this opportunity to express some concerns from a heartland regional perspective: (1) Consistent with the position of the Oklahoma Department of Environmental Quality, leaders in Central Oklahoma also support an 8-hour measuring standard for ground-level ozone. We believe that this mode of measuring allows for a more realistic method of gathering air quality data. However, we feel that the measure currently in place is too strict and limiting, and would favor a measure that is more scientifically sound. We urge that the EPA's Science Advisory Board revisit its studies regarding air quality standards, and that EPA take smaller steps in implementing the scientists' recommendations. (More specifically, the Board's recommendation for an ozone standard was a range of .07-.09 ppm. If more stringent requirements were shown to be scientifically justifiable, we would favor a more gradual implementation schedule, beginning with .09 ppm). (2) Congress should allow states and local governments to use flexibility in determining the most effective control measures for their particular regions. Geography, climate, transport issues, in addition to the cultural values and habits of the people of a given area, are all factors that affect the success of given actions. Along those lines, we also encourage EPA to invest in additional research related to the effectiveness of various measures in different regions of the country. (3) We strongly encourage national emphasis to be put on research and technological solutions rather than heavy-handed enforcement. We encourage national research for nationwide remedies, including new technologies for mitigating industrial pollution as well as mobile source pollution, such as the rapid acceleration of the use of alternative fuel vehicles (hybrid/dual powered, electric, compressed natural gas, propane and so forth). (4) It is clear that current motor vehicle emission standards, including the new laws regarding light and heavy duty trucks and sport utility vehicles, will be necessary to continue to make progress on the clean air front. The positive effect of these new regulations are likely to have a dramatic effect in Oklahoma since a relatively large portion of our population is prone to driving trucks and SUVs. One thought would be to direct EPA to refrain from declaring new non-attainment areas until such time as the new mobile source emissions regulations have had time to make an impact. (5) Then, there is the conformity "hammer". Should a region be declared non-attainment, the state and local governments in that area should be given ample time (at least three years) to adjust their transportation plans before federal transportation dollars are withheld in the name of conformity. In the current Act, federally funded transportation projects must be found to conform to state air quality plans before they are adopted, accepted, approved or funded. The dilemma, however, is that it takes several months to develop an emissions budget (requires an inventory of all emission sources and the use of a photochemical dispersion model to identify reductions through transportation control measures) which must be done before a draft State Implementation Plan is developed. Once a draft plan is on the table, it takes at least one legislative session to get the plan and pertinent laws approved by the state legislature, and still additional time to measure Transportation Improvement Programs (TIPs) against the state plan once it's approved. In Oklahoma, this process would take no fewer than two years and probably three. It is ludicrous for the federal government to hold up progress in a regional community, as long as good faith efforts in response to air quality have been made and are being made to work toward adoption and implementation of a plan. (6) Because anomalous weather patterns have aggravated the region and the state for the past three years, we are particularly sensitive to how weather or other situations (such as wild fires in Mexico a couple of summers ago) can affect adversely local efforts to maintain clean air. Therefore, we ask that EPA expand its current guidelines and parameters regarding exceptional events such as those attributed to wildfires, industrial fires and accidents and other anthropogenic phenomenon that affect air quality conditions. Proposed guidance offered a few years ago by the EPA addressed this situation, but did not make it through the rule-making process.
Thank you for listening. Thank you for your efforts to maintain the country's clean air status, but please keep in mind the economic and financial ramifications of your decisions. As long as there is true scientific basis for the decisions made in this regard, we will all be the winners. The local elected officials of ACOG recognize that we can't each live in a bubble, and we can't pass out jars of clean air to each of our citizens. Given that reality, we're anxious for your wisdom in finding solutions that will help us all breathe a little easier. Thank you.