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DETERMINING COMPLIANCE: THE FORM OF THE STANDARDS <br />• When EPA sets air quality standards, it also must specify the measurement unit, or "form" of <br />each standard, that the Agency will use to determine whether an area is meeting the <br />standards. <br />• For the primary ozone standard, an area meets the standard if the three-year average of the <br />annual fourth-highest daily maximum 8-hour average at a particular monitor is less than or <br />equal to the level of the standard. <br />• EPA is proposing a new and distinct form for the secondary standard. The form, called <br />W 126, is designed to account for the cumulative effects of ozone on vegetation during the <br />three months of the year when ozone concentrations are highest. The form focuses on <br />repeated exposures to elevated ozone levels during the growing season. <br />• If EPA finalizes the W 126 option, an area would meet the secondary standard if the W 126 <br />value is less than or equal to the level of the standard. If the agency fmalizes the second <br />option proposed, compliance with the secondary standazd would be based on compliance <br />with the primary 8-hour standard. <br />BENEFITS AND COSTS <br />While the Clean Air Act prohibits EPA from considering costs in setting or revising National <br />Ambient Air Quality Standards, the Agency analyzes the benefits and costs of meeting the <br />standards in order to provide states and other stakeholders with the information necessary to <br />assess the implications of meeting alternative standards. The analysis, which is required by <br />Executive Order 12866, is based on guidance from the White House Office of Management <br />and Budget. These analyses of benefits and costs will be detailed in a Regulatory Impact <br />Analysis to be released in the next few weeks. <br />• To estimate the benefits of meeting a standard, EPA utilizes a sophisticated peer-reviewed <br />approach to modeling the relationship between air quality and health and welfare effects, the <br />air quality impacts of implementing future control technologies, and the dollaz values of <br />public health improvements. <br />• To estimate the costs of meeting a standard, EPA uses several peer-reviewed approaches for <br />modeling the cost of using both existing controls and controls that maybe developed in the <br />future for reducing NOx and VOCs. <br />.._ I, ' - <br />