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documents) that the time has come for the Administrator of the USEPA to establish a <br />biologically appropriate secondary (public-welfare based) National Ambient Air Quality <br />Standard for ozone that is distinctly different in form from the primary (public-health based) <br />standard for ozone and related photochemical oxidants. <br />Avoiding the Necessity for a Second NRC Report on <br />"Rethinking the Ozone Problem in Urban and Regional Air Pollution" <br />during the Years Between 2002 and 2017 <br />Statement by Ellis B. Cowling <br />University Distinguished Professor At-Large and <br />Professor of Plant Pathology and Forest Resources at <br />North Carolina State University <br />to the <br />Clean Air Act Scientific Advisory Committee (CASAC) <br />EPA Auditorium <br />Research Triangle Park, North Carolina <br />March 21, 1996 <br />The objective of this written statement is to provide additional justification to CASAC for <br />recommending to the Administrator of EPA, that a secondary standard for ozone clearly different <br />in form from the primary standard should be promulgated in 1997. This justification is based on <br />three fundamental premises: <br />1) As discussed in the EPA Staff Paper on the secondary standard for ozone, a longer term <br />seasonal standard, which is cumulative in form will provide an addition measure of protection <br />against the harmful effects of ozone on the many different species of crop plants, forest trees, <br />shade trees, ornamental plants, and the thousands of other plant, animal, insect, and microbial <br />species that make up the ]jving components of all the natural and managed ecosystems on which <br />the quality of American life depends. <br />2) A secondary standard different in form from the primary standard will also accelerate and <br />improve the processes of public education about many aspects of the tropospheric ozone <br />problem. These aspects include, among others, the following general ideas: <br />-Contemporary ozone pollution causes significant harm to crops, forests, ornamental plants, <br />and natural ecosystems in. many parts of the United States. <br />-Ozone pollution is a serious threat to the welfare of people and ecosystems in many rural as <br />well as urban areas of our! country. <br />-Ozone and its chemical precursors are frequently transported from rural areas to urban areas <br />and from urban areas to rural areas in many parts of the United States. <br />C-7 <br />