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-The air concentrations of ozone and other oxidants that cause harm to crop plants, forests, and <br />natural ecosystems are appreciably lower than the concentrations of ozone and other oxidants <br />that cause harm to most people. <br />-Ozone pollution is not just an urban problem associated with high peak concentrations of <br />ozone during exceptional weather episodes but also a problem of longer-term chronic exposures <br />of plants to much lower, but still toxic, concentrations under persistent weather conditions. <br />3) A secondary standard clearly different in form from the primary standard will also have <br />significant and pronounced effects on the nature, quality, and policy relevancy of ozone-related <br />scientific research that will be undertaken during 1997 and beyond. Avery important objective <br />of that research should be to: <br />-fill the persistent gaps in available knowledge, and <br />- decrease the continuing scientific uncertainties <br />that have plagued ozone decision making in the past and, <br />if we do not change the way we think about the ozone problem, will continue to plague the <br />periodic updates and CASAC reviews of the Ozone Criteria Documents that are now scheduled <br />to occur in 2002, 2007, 2012, 2017, etc. <br />Every CASAC member is aware of the 10 principal fmdings of the 1991 NRC report entitled <br />"Rethinking the Ozone Problem in Urban and Regional Air Pollution" and the call for reform of <br />the precepts for decision making about tropospheric ozone that were advanced in Milton <br />Russell's classic paper: Ozone Pollution: The Hard Choices (Science 241:1275-1276, 1988) - <br />see attached reprint. <br />The title-words Rethinking in the NRC report and Hard Choices in Milton Russell's paper were <br />chosen very deliberately. The intent in both cases was to encourage a significant change in the <br />way American scientists, regulatory officials in industry and government, and the public at large <br />think about ozone pollution and its management. Without a radical change in the quality of <br />scientific, regulatory, and public thinking, both the NRC committee, and Milton Russell, former <br />Assistant Administrator of EPA, were convinced, the United States will continue to fall short of <br />its own objective - to develop robust, scientifically sound, and cost effective strategies and <br />tactics by which to manage ozone pollution during the remainder of this century and beyond. <br />The NRC report of 1991 indicated that despite 20 years of expensive and well-intentioned <br />attempts, America's efforts to manage ozone near the ground "lazgely have failed." These <br />attempts failed for two primary reasons: <br />1) Because the identical primary and secondary ozone standards established in 1970-71 and in <br />1978-79 were neither statistically robust nor founded on an adequate scientific understanding of <br />the biological, chemical, and meteorological processes that lead to ozone accumulation near the <br />ground, and <br />2) Because previous decisions about the kinds and quality ofozone-relevant biological-effects <br />reseazch and atmospheric-science research that was done were too often driven primarily by <br />short-term regulatory deadlines, and, frequently, by incomplete scientific perceptions and policy <br />assumptions. <br />V~- 1 L-Y <br />C-8 <br />