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"Several additional factors should be considered when selecting an appropriate level for a <br />secondary standard. These include: <br />1) The fact that 03 effects are cumulative and have been shown to have carry over effects from <br />one year to the next; <br />2) Some seedling tree species have sensitivities as great as annual crops and the importance of <br />protecting against small percentages of biomass loss on an annual basis has been <br />expressed by some within the scientific community; <br />3) Visible foliar injury impacts can occur within a growing season at very low levels of 03 <br />exposure; and <br />4) The extent to which a secondary standard is precautionary in nature, given the possibility of <br />03 impacts acting in synergy with other natural and manmade stressors. <br />Should a 3-year average of a 12-hr W 126 be selected, the level chosen should reflect the <br />fact that annual impacts are still a concern for visible foliar injury, tree seedling biomass loss, <br />and crop yield loss, so that a potential lower. level might be considered to reduce the potential of <br />adverse impact from a single high 03 year that could still occur while attaining a 3-year <br />average." <br />Additional Comments on the Scientific Merit of a Secondary Standard for Ozone that is <br />Distinct in Form from the Primary Standard <br />Ozone is a general metabolic poison. In the light of EPA's consistently strong emphasis <br />on effects of ozone and related photochemical oxidants on human health, how interesting it is to <br />realize that the injurious effects of ozone and other photochemical oxidants were first discovered <br />on vegetable crops'and forest trees and only later were discovered also to be injurious to human <br />health and to be the principal cause of eye irritation in photochemical smog. <br />Ozone and other oxidants cause stress in plants and thus predispose both individual plants <br />and whole ecosystems to attack by natural enemies that include disease- and injury-inducing <br />bacteria, fungi, nematodes, viruses, and insects. In some cases, exposure to high concentrations <br />of ozone also decreases the resistance of plants to injury and damage by abiotic stress factors <br />such as drought and frost: <br />Different species and varieties of plants vary widely in susceptibility to ozone and other <br />oxidants. Many species of crop plants, forest and shade trees, and some of the multiple-species <br />of plants in natural ecosystems are more sensitive to injury and damage by ozone than most <br />people. That is, many plants show visible symptoms of injury at concentrations of ozone that are <br />considerably lower (40 to 60 ppb of ozone) than the 80 to 120 ppb of ozone that are generally <br />recognized to cause ill-health in people. <br />The injurious effects of ozone and other oxidants on plants and ecosystems are <br />CUMMLJLATIVE in their effects rather than acute or chronic in their effects as is found for most <br />health effects of ozone on people. <br />n ° ~ ~-~. <br />C-5 <br />