Comments on the EPA proposed revisions to the 8-hour National Ambient Air Quality Standard (NAAQS) for ozone
Please accept these comments from the above groups on the Environmental Protection Agency’s (EPA) proposed revisions to the 8-hour National Ambient Air Quality Standard (NAAQS) for ozone. A compelling body of scientific evidence supports EPA’s determination that the existing, national, health-based standard for ozone is not requisite to protect public health with an adequate margin of safety, as the law requires. Consistent with this body of scientific evidence and the law, the standard must be strengthened. Some of the groups party to these comments have also joined in a comprehensive set of national comments submitted by public health and environmental groups, which address many of the issues raised in the proposal and urge EPA to set the level of the 8-hour ozone NAAQS at 60 parts per billion (ppb). Other groups party to these comments have submitted their own comments urging a 60 ppb ozone NAAQS. We strongly support these requests and respectfully urge EPA to establish the level of the ozone NAAQS at 60 ppb.
These comments will address significant issues in the Intermountain West, with a particular focus on the state of Wyoming due to expertise gained there as a result of the state’s Upper Green River Basin (UGRB) ozone nonattainment area. Specifically, we focus on the public health imperative for action in the Intermountain West, the need to ensure adequate public health protections for communities in this area through rigorous monitoring, solutions available to restore healthy air both nationally and the west, and the issue of background ozone levels. We discuss each issue in greater detail, below.