The Texas Commission on Environmental Quality (TCEQ) engaged NERA Economic Consulting (NERA) to evaluate on an ex ante basis the potential costs and economic impacts on the state of Texas associated with a proposed National Ambient Air Quality Standard (NAAQS) for ozone of 65 parts per billion (ppb).

To perform this analysis, NERA estimated the total tons of NOX reductions that would be required to bring all Texas monitors into attainment with a 65 ppb standard. We then estimated the costs of the required reductions. Our analysis took as a starting point EPA’s cost analysis reported in its Regulatory Impact Analysis (EPA, 2014a), but we made several refinements we concluded would result in more realistic cost estimates.