August 1, 2003

Proposed Rule to Implement the 8-Hour Ozone National Ambient Air Quality Standard

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Rulemaking:

Implementation of the 8-hour national ambient air quality standard (NAAQS) for ozone

Stated Purpose:

To solicit comment on alternative approaches to implementing the 8-hour ozone NAAQS

Summary of RSP Comment:

In this proposal, EPA requests comment on alternative approaches to implementing the 8-hour national ambient air quality standard (NAAQS) for ozone that it promulgated amid controversy in 1997. At that time, EPA’s analysis recognized that it would impose costs on Americans far in excess of the value of any health benefits achieved.

Though net costs are inevitable under the standard, EPA can minimize these costs. Because already-adopted EPA requirements will eliminate the vast majority of remaining ozone precursor emissions during the next 20 years or so, the details of how non-attainment areas are classified and treated under the 8-hour NAAQS rule will have at most a modest effect on future emission reductions. However, the option EPA selects could have significant impacts on the costs of achieving emission reductions.

Thus, EPA should seek to maximize the flexibility non-attainment areas have in developing and implementing state implementation plans to attain the standard. It should also reconsider its focus on large, near-term NOx reductions, as research suggests they are likely to worsen ozone in at least some areas and slow progress in others.

In addition, EPA should develop realistic emission inventories and require states to do the same. Known errors in these inventories continue to misdirect emission reduction efforts. In particular, too little focus has been placed on the potential for rapid, substantial VOC and CO reductions from the in-use automobile fleet.