Primary Standard would be protective of welfare
impacts and effects on plants. The CASAC had
recommended that the averaging time form of the
Secondary Standard be changed to a more complex form that used a weighted average of the
Ozone concentration over a growing season.
Thus, it was not as easy to compare the Primary
and Secondary Standards. As an aside, the revision of the Ozone NAAQS in March 2008 also set
the dates for completing the next regularly scheduled 5-year review, March 2013.
The failure of the EPA Administrator to explicitly follow the advice of CASAC was greeted with
outrage by the CASAC Ozone Panel. The Committee took the unusual step, post-final announcement of the new Ozone NAAQS, of holding a
Panel meeting to discuss the new Standard and
writing a letter to the Administrator reminding
him of their previous advice and calling for the
Administrator to follow their advice in future
revisions of the standard [41].
In January 2009, President Barak Obama took
office and Lisa Jackson was appointed EPA
Administrator. Coincident with Obama taking
office his Chief of Staff, Rahm Emanuel, took
the customary step of reminding newly designated
Senior Agency officials of the opportunity to
review and, perhaps, revise any rules and regulations that originated with the prior Administration
and not yet finalized [21]. Administrator Lisa
Jackson took the bold step of announcing that
she was going to reconsider the Ozone NAAQS
set by Administrator Johnson in March 2008. In
taking this action she was in essence saying – if
I had been in office as EPA Administrator earlier
I would have made a different policy decision.
Administrator Jackson proceeded to publish a
proposal to “reconsider” the Ozone NAAQS
using the same science used as a basis of the
March 2008 standard [81]. The proposal indicated
Administrator Jackson intended to follow the
advice of CASAC and set a primary standard
(8-h averaging time) in the range of 60–70 ppb.
The proposed date for release of a final standard
was announced, a target date that was revised on
multiple occasions. A Presidential Executive
Order issued by President Clinton [18] requires
that any proposed federal rule or action that will
result in annual costs in excess of $100 million per
year must be reviewed by the Office of Information and Regulatory Affairs in the Office of Management and Budget. On September 2, 2011,
8H: summer
8H: all-year
1.0
0.8
0.6
0.4
0.2
0.0
1.0
0.8
0.6
0.4
0.2
0.0
1.0
0.8
0.6
0.4
0.2
0.0
1.0
0.8
0.6
0.4
0.2
0.0
24H: all-year
1H: all-year
Air Quality Guidelines and Standards, Fig. 12 Map of spatially dependent ozone-mortality coefficient for 8-h ozone
(all-year data), 8-h ozone (summer data), 24-h ozone (all-year data), and 1-h ozone (all-year data). (Adapted from [58])
36
Air Quality Guidelines and Standards
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