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Dr. Henry Gong <br />Post-Teleconference Comments on Chapter 6 -Staff Conclusions and Recommendations on the <br />Primary 03 NAAQS, Review of the National Ambient Air Quality Standards for Ozone: Policy <br />Assessment of Scientific and Technical Information. OAQPS Staff Paper, January 2007. <br />By Henry Gong, M.D., 3/5/07 <br />I compliment the EPA Staff for an excellent Chapter 6. The chapter is not perfect but adequately <br />and effectively summarizes the pertinent scientific information and presents informative <br />exposure-risk estimates. The chapter is also an important product of thoughtful dialogues <br />between the CASAC Review Panel and EPA Staff to achieve resolution and clarification and <br />effective focusing of concepts and conclusions. As such, this iterative process (as well as the <br />Staff Report) represents an important and necessary component of the scientific-policy-making <br />procedures for developing appropriate NAAQS. <br />My only concern is that Chapter 6 does not discuss "adequate margin of safety" which is <br />inherently part of public health protection and the Clean Air Act. I believe that the safety margin <br />(especially for sensitive groups) needs to be included in both the Chapter discussion and in the <br />fmal decision-making for the NAAQS for ozone. <br />Thus, I continue to strongly support CASAC's letter to the EPA Administrator (dated October <br />20, 2006). I support the range of 0.060 to 0.070 ppm for the primary 8-hour ozone NAAQS, <br />since there is no scientific justification for retaining the current NAAQS of 0.08 ppm. I also <br />support other considerations stated in the October 2006 letter, including CASAC's <br />recommendations for the secondary ozone NAAQS. <br />i~ <br />c.~r-~ <br />C-14 <br />