With the release of EPA’s 600-plus page proposal on ozone, all attention turns to the fine details of such an expansive regulation. American Action Forum (AAF) research found that 100 national and state parks might not the meet EPA’s standards of 60-70 parts per billion (ppb). Hardly transportation corridors and centers of heavy pollution, many observers would be surprised to know that Death Valley National Park, Sequoia National Park, and Cape Cod National Seashore have ozone readings of 71 to 87 ppb.

The map below details the geographic distribution of state and national parks in danger of EPA’s non-attainment label for ozone.

It’s not entirely clear how these levels would be addressed at national parks. It’s likely the state’s responsibility to address ozone concentrations at parks within their borders. Even though these parks don’t contain large manufacturing facilities or refineries, states will have to find ways to address each county that is in non-attainment.

What is clear is the price tag: $15 billion at the 65 ppb threshold. EPA is more than frank that this is one of the most expensive regulations ever, but they offer some solace: there are half a dozen other major recent regulations that will help states meet this expensive new standard. Here’s how EPA explains the situation:

“Existing and proposed federal rules, including the final Mercury and Air Toxics Standards [MATS], the final Tier 3 Vehicle Emissions and Fuels Standards, requirements to reduce the interstate transport of ozone [CSAPR], Regional Haze rules, and the proposed Clean Power Plan, will help states meet the proposed standards by making significant strides toward reducing ozone-forming pollution.”

 In other words, there are so many other major rules in the regulatory world on emissions standards that overlap, they might make it easier to comply with the new ozone measure. Tallying costs for the litany of the past rules reveals outrageously high burdens. Here is the real cost of EPA’s ozone approach:

• CSAPR: $1.85 Billion
• MATS: $10 Billion
• Standards for Particulate Matter: $350 Million
• Tier 3 Fuel Standards: $1.5 Billion
• Proposed Clean Power Plan: $8.8 Billion
• Latest Ozone Proposal: $15 billion

• Total Cost of Recent Proposals: $37.5 Billion

To put this $37.5 billion in perspective, it’s roughly seven times higher than the cost of all major rules issued in fiscal year 2011, according to the White House. $37.5 billion is almost as high as the entire bill for all major rules issued from 1999 to 2009, according to the White House. These recent regulations, coupled with an ozone rule that doesn’t even spare national parks, is a decade’s worth of regulating in just four or five years.

It’s likely these rules would add another layer of compliance for power plants and manufacturing facilities just as they have to deal with MATS and EPA’s incredibly complex Clean Power Plan. On one hand, plants have to add technology to capture emissions, which requires more energy and reduces efficiency. On the other hand, the Clean Power Plan will mandate that plants increase their efficiency to reduce greenhouse gases. As AAF commented to EPA, “Achieving efficiency gains while adding additional environmental protections unrelated to the Clean Power Plan may not be possible for the fleet.”

Conclusion

The notion that EPA’s ozone regulation will affect just dirty power plants and manufacturing facilities is farce. In fact, many of the dirtiest power plants have already closed from MATS and CSAPR. These new regulations will hit states, their parks, national wildlife refuges, and countless pending construction projects across the U.S. The price tag from this rule isn’t just $15 billion; it’s closer to $37 billion and it’s likely that states and businesses won’t know the full burden for years.