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Synapse Energy Economics analyzes and debunks claims made by NERA Economic Consulting regarding the costs of a proposed 65 ppb ozone standard. Synapse finds that NERA inflated compliance costs by over 700% through flawed assumptions on emission reduction requirements, an inappropriate use of 'cash for clunkers' data to price unknown controls, and significant mathematical errors. Synapse's re-analysis suggests annualized costs of $13.6 billion to $21.6 billion, far below NERA's $155 billion estimate. Additionally, the document argues that NERA's prediction of 1.4 million 'job-equivalent' losses is based on a 'black box' model that does not predict actual unemployment and ignores the economic benefits of pollution control investments.