Comments of American Lung Association Appalachian Mountain Club Center for Biological Diversity Clean Air Council Earthjustice Environmental Defense Fund National Parks Conservation Association Natural Resources Defense Council Sierra Club on EPA’s Proposed Revisions to the National Ambient Air Quality Standards for Ozone

The document argues that the current 75 ppb ozone standard is insufficient to protect public health, particularly for sensitive populations like children and asthmatics. It advocates for a 60 ppb primary standard based on scientific evidence of lung function decrements and inflammation at that level. It also calls for a separate secondary standard of 7 ppm-hrs using the W126 metric to protect vegetation and ecosystems, specifically in Class I areas.

• The current primary ozone NAAQS of 75 ppb is inadequate to protect public health, as scientific evidence shows adverse effects, including lung function decrements and airway inflammation, occur at levels as low as 60 ppb.
• Controlled human exposure studies demonstrate that 60 ppb of ozone for 6.6 hours causes statistically significant lung function decrements and pulmonary inflammation in healthy young adults.
• Children are uniquely vulnerable to ozone due to their developmental stage, higher ventilation rates, and increased outdoor activity; evidence shows they experience respiratory impacts and diminished lung function at concentrations of 60 ppb and below.
• Asthmatics, particularly children, are highly sensitive to ozone, experiencing double the lung function decrements of healthy people at the same exposure levels.
• Epidemiological studies link short-term ozone exposure to premature mortality and respiratory morbidity at mean 8-hour maximum concentrations of less than 63 ppb.
• Long-term ozone exposure is associated with increased premature mortality, new-onset asthma, and stunted lung function growth in children.
• The proposed 'fourth highest 8-hour maximum averaged over 3 years' form of the NAAQS is insufficiently protective because it allows repeated exceedances of the nominal level without triggering nonattainment designations.
• The EPA's reliance on 'averting behavior' (people staying indoors) to justify a higher standard is unlawful and ignores the health benefits of outdoor activity and the needs of outdoor workers.
• Minority and low-income communities are disproportionately exposed to higher ozone levels and suffer a higher asthma burden, making the NAAQS an environmental justice issue.
• The secondary NAAQS should be set as a separate W126 standard of 7 ppm-hrs to protect vegetation, ecosystems, and carbon storage, as the 8-hour primary form is not biologically relevant for plants.
• Ozone acts as a potent greenhouse gas, particularly in the Arctic, where it increases temperatures and accelerates the loss of sea ice and permafrost.
• Significant NOx reductions are achievable and cost-effective, particularly through the installation and proper operation of Selective Catalytic Reduction (SCR) technology in coal-fired power plants.

APA

Earthjustice (2015). Comments of American Lung Association Appalachian Mountain Club Center for Biological Diversity Clean Air Council Earthjustice Environmental Defense Fund National Parks Conservation Association Natural Resources Defense Council Sierra Club on EPA’s Proposed Revisions to the National Ambient Air Quality Standards for Ozone. https://earthjustice.org/wp-content/uploads/20152003201720ozone20naaqs20proposal20cmts20ala20amc20cbd20cac20ej20edf20npca20nrdc20sc.pdf

Chicago

Earthjustice. Comments of American Lung Association Appalachian Mountain Club Center for Biological Diversity Clean Air Council Earthjustice Environmental Defense Fund National Parks Conservation Association Natural Resources Defense Council Sierra Club on EPA’s Proposed Revisions to the National Ambient Air Quality Standards for Ozone. 2015. https://earthjustice.org/wp-content/uploads/20152003201720ozone20naaqs20proposal20cmts20ala20amc20cbd20cac20ej20edf20npca20nrdc20sc.pdf.

Wikipedia

{{cite press release |author=Earthjustice |title=Comments of American Lung Association Appalachian Mountain Club Center for Biological Diversity Clean Air Council Earthjustice Environmental Defense Fund National Parks Conservation Association Natural Resources Defense Council Sierra Club on EPA’s Proposed Revisions to the National Ambient Air Quality Standards for Ozone |date=17 March 2015 |url=https://earthjustice.org/wp-content/uploads/20152003201720ozone20naaqs20proposal20cmts20ala20amc20cbd20cac20ej20edf20npca20nrdc20sc.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{earthjustice2015comments, author = {{Earthjustice}}, title = {{Comments of American Lung Association Appalachian Mountain Club Center for Biological Diversity Clean Air Council Earthjustice Environmental Defense Fund National Parks Conservation Association Natural Resources Defense Council Sierra Club on EPA’s Proposed Revisions to the National Ambient Air Quality Standards for Ozone}}, publisher = {Earthjustice}, year = {2015}, month = mar, url = {https://earthjustice.org/wp-content/uploads/20152003201720ozone20naaqs20proposal20cmts20ala20amc20cbd20cac20ej20edf20npca20nrdc20sc.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }