AG 2007 10 15 - Laserfiche WebLink

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The time has come for American scientists, leaders in industry and government, and people in general to understand that the problem of ozone pollution can not be managed by continuing to believe that the people in metropolitan areas like Atlanta, Chicago, New York, and other urban and regional ozone non-attainment areas can "solve the problem" of urban smog and regional ozone exposures without understanding the regionality and the seasonality of both the ozone problem itself and the regionality and seasonality of the management approaches that must be used if the nation is to learn how to manage ozone and other oxidants at reasonable cost. This deficiency in understanding of the regionality and seasonality of the ozone problem was one of the most important points made in the NRC report and in Russell's "Hard Choices" paper. But these same deficiencies were driven home even more forcefully in November 1994, when 26 of the 29 states that were required to submit a State Implementation Plan for Ozone were unable to make an attainment demonstration following available guidelines. As a result: -Mary Nichols issued her now-famous "Memo of March 2, 1995," -The Environmental Commissioners of States (EGOS) joined together with EPA in creating the Ozone Transport Assessment Group (OTAG) involving more than 30 states east and some west of the Mississippi River, and -The Federal Advisory Committee Act Subcommittee on Ozone, Fine Particulate Matter, and Regional Haze Implementation was created to look at at least three of the five or six air-pollution problems that are related to the general oxidative capacity of the atmosphere (the other problems being acidification of soils and surface and ground waters, nitrogen saturation of forest soils, and airborne-nitrogen-induced eutrophication of surface waters). But even these more recent initiatives are driven by unrealistically short-term regulatory deadlines, and, frequently, by incomplete scientific perceptions and policy assumptions. Examples include: -Use of specific exceptional ozone episodes rather than by both episodic and season-long ozone time periods of interest, -Use of local and regional emissions inventories for natural and anthropogenic emissions that aze of uneven quality for both rural and urban/suburban sources of ozone precursors, -Use of emissions-based mathematical models rather than both emissions-based and observation-based air quality models, and -Use of models that may "get the ozone peaks right" but are not skillful enough to "get the peaks, and the low ozone concentrations, and the natural and anthropogenic ozone precursors right" at the same time. As CASAC makes its decisions about the closure letter that must now be written about the secondary standard for ozone, I hope all committee members will think very carefully about the nature, quality, pace, and intensity of research interactions that will occur as the result of the two choices you will help make today: C-9