March 12, 1997

National Ambient Air Quality Standard for Ozone

  • Susan Dudley

    Director, George Washington University Regulatory Studies Center
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National Ambient Air Quality Standard for Ozone; 61 FR 65716 - Docket No. A-95-58

Stated Purpose:

Set air quality standards that "protect the public health" with "an adequate margin of safety," and "the public welfare from any known or anticipated adverse effects associated with the presence of such air pollutant in the ambient air."

Summary of RSP Comment:

EPA has a responsibility for setting NAAQS that protect public health and welfare. Yet it based the selected standard on weak and uncertain science, and ignored important health and welfare effects. EPA supported the rule with limited evidence of respiratory effects (particularly asthma) on sensitive individuals during peak ozone episodes.

Focusing solely on the health impacts of the rule, the selected standard would harm public health. Ozone protects against harmful ultra-violet radiation, and the detrimental health effects of increased UV-B penetration are likely to be greater than the projected health benefits of lowering ozone concentrations.

When costs are considered, the ozone standard looks worse. By EPA's estimates, the partial costs of achieving the standard will exceed the benefits. The full costs are likely to exceed $80 billion per year. Since poverty is a greater risk factor for asthma than ozone, EPA's standard is likely to aggravate the very health risk it is aimed at improving.

Non-regulatory approaches, including public health advisories and other targeted approaches, would be more effective at addressing the health effects of concern.