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EPA Staff Paper Recommends Tightening Ozone Standards

Environmental Protection Agency staff scientists are recommending tightening the nation’s ground-level (tropospheric) ozone standards. In a final paper submitted as part of the current review of national air quality standards, the staff concluded that the current primary ozone standard is not adequate to protect public health.

EPA staff made this recommendation based on an expanded body of epidemiological and human effects studies that show significant ozone health effects occur even in areas with ozone levels below the current standard. The paper recommends a range of levels for the EPA administrator to consider in setting the primary ozone standard, extending from below 0.080 ppm down to 0.060 ppm.

The previous draft of the staff paper identified options that included retaining the current standard of 0.084 ppm, along with a range of alternative levels down to 0.064 (the lowest level analyzed), with a focus on a level of 0.07 ppm.

The final staff paper also recommends specifying the level of the standard to three decimal places. Ozone air quality measurements have advanced sufficiently to now reflect that level of precision.

The staff also recommends a different secondary standard to protect against ozone damage to public welfare, including damage to plants, concluding that even when the current primary standard is attained, significant environmental effects continue to occur.

Instead, the paper suggests a standard based on a cumulative, weighted total of 12-hour (8 am – 8 pm) exposures over a 3-month period within the growing season to adjust for the differences in the way plants respond to ozone exposure as compared to humans. The recommended range runs from 21 parts per million-hours to 7 parts per million-hours.

The assessments, conclusions and recommendations included in the staff paper are staff judgments. They do not represent agency decisions on the ozone standards. EPA will propose action on the ozone standards by June 20, 2007 and take final action by March 12, 2008.

Ground-level ozone is formed by reactions of volatile organic compounds (VOCs) and oxides of nitrogen (NOx) emitted from mobile (e.g., cars, trucks) and stationary (e.g., power plants) sources. These reactions are most likely to produce high levels of ambient ozone during periods of high temperature and high solar radiation during the summer months.

The Clean Air Act requires EPA to periodically review its air quality standards to ensure they continue to protect health and the environment, and to update the standards if necessary. EPA last updated the standards for ozone in 1997.

In December 2006 in a unanimous decision, a Federal court of appeals struck down a 2004 EPA ruling that had loosened the existing 8-hour ozone standard. The court ruled that the EPA violated the Clean Air Act by relaxing those limits to levels in excess of 0.09 ppm. (Earlier post.)



Rafael Seidl

150,000 troops in Iraq, global warming all around us and the US auto industry teetering at the edge of bankruptcy...

So yeah, clearly America's #1 problem right now is ground-level ozone. If that's really such a serious issue, why is it OK for John Q. Public to use laser printers and photocopiers all day long?

Perhaps the cap & trade system for coal- and gas-fired power stations needs to be tightened up before the finger is pointed yet again on gasoline-powered LDVs with three-way catalysts.

Admittedly, legacy MDV/HDV diesels do present an NOx problem, but that is already being addressed.


Ye-e-e, global warming all over you…


Because, clearly, the EPA controls the US military and the auto industry.


If they want the auto industry to work on CO2 emssions and fuel efficiency, they have to cut them some slack on other pollutants and allow them to focus on either CO2 if you are worried about global warming or MPG if you want to focus on energy security.

But decide, and give them a clear direction.


Mahonj, you have it backwards. In the American system, the auto companies decide, then they give congress a clear direction. Over the past couple decades, the auto industry has decided that 350hp, 6500 lb SUVs are easier to make money on than efficient vehicles. CO2 and MPG are pretty much the same thing, but Detroit hasn't cared a whit about either global warming or energy security until recently, and then only because reality finally slapped them in the face.


Silly me.
Just a European.



Detroit Big Three, Big Oil, Big Farmaceutical, Wal Mart, McDonalds, Agro lobby, Wall Street, Coca Cola, Military/defence, EPA/CARB, Chevron/Ovonics, Utility companies, Big Coal , Nuclear lobby, OPEC, neocons, Microsoft…

Kinda crowded in Washington, DC.


I would have put Pepsi Co. before Coca-Cola. Pepsi Co is larger even if Coca-cola tastes better.

Rafael Seidl

Mahonj -

much the same dynamic as in the US applies to Germany's auto makers. They appear to have been successful in getting Chancellor Merkel and EU Industry Commissioner Verheugen (both Germans) to quash a hard-line proposal by EU Environment Commissioner Stavros Dimas (a Greek) to mandate a per-corporation new vehicle fleet average of just 120 g CO2/km by MY 2012

ACEA, the European auto maker's association, is now not expected to meet its voluntary commitment of 140 g CO2/km by MY2008, reflecting a 25% reduction across the board relative to 1995 levels. JAMA and KAMA, the counterparts to ACEA for Japanese and Korean brands, were granted an extra year to meet the same target, on a similar basis.

In MY 2006, the ACEA average was ~160 g CO2/km, down by 11.5% but that is not enough - even if you were to cut the industry some slack because of tougher crash test rules including safety for pedestrians.

Note that the ACEA commitment model called for an equal reduction relative to 1995 levels from each of its members. Historically, German and Swedish cars have featured more powerful engines than those made in France and Italy. The model was designed to avoid distorting these market realities. In effect, it means that each manufacturer actually has a a different fleet average target in terms of g CO2/km, though ACEA has not published these, presumably to avoid heated debates between politicians defending their national champions. IMHO, that was a monumental PR blunder on ACEA's part.

Indeed, the whole point of the voluntary commitment was to nip the EU's earlier efforts at formal fuel economy rules in the bud. Now that the voluntary commitment looks unlikely to be met, the media have latched onto the 140 number and discuss it as if it applied to each manufacturer individually. Mr. Dimas surely knows better, but the French and Italian auto makers were keen to put pressure on their German competitors.

Of course, German car makers should have seen this juggernaut coming and adjusted their product lines accordingly. They now argue, correctly, that forcing a level of just 120 g CO2/km per manufacturer by MY2012 would cripple their business models and lead to massive layoffs. The balance of power in Germany and in the EU being what it is, Mr. Dimas' proposals never stood a chance of passing in its original form, even though they were supported by Germany's environment minister Sigmar Gabriel. Stay tuned for how much it will get watered down once France and Italy decide to chime in.

Note that the German auto makers' product strategy to pursue fuel-guzzling models is itself an unintended consequence of an extremely rigid labor market - back in the 1970s, Germany's constitution was changed to grant labor representatives 50% of the seats on corporate boards, which are mandatory even for small businesses. This gave them enormous clout over all aspects of day-to-day business, including HR policy, product roadmaps, mergers & acquisitions etc. They have used these powers to establish strong job guarantees for their members in return for modest wage increases and largely avoiding industrial action. In addition, the Land of Lower Saxony owns a 20% "golden share" in VW, defined by a special law that may be ruled illegal by an upcoming EU court decision.

As a result of this context, several German auto makers - especially VW - have long suffered severely bloated payrolls. The unions have also forced the industry to source primarily from (expensive) domestic suppliers. A for-profit company can only afford such inefficiencies if its products deliver adequate margins. Small, fuel-saving vehicles do not really fit that bill and are produced only as loss leaders to build brand loyalty. Manufacturing strategies based on platforms or parts bins have helped but tend to complicate subassemblies. Production of the current fifth-generation Golf's initial door design proved famously labor-intensive.

Wolfgang Bernhard's recent attempt to right the ship by drastically cutting VW's payroll were rewarded by his de facto ouster from the corporation at the behest of chairman of the board and former CEO Ferdinand Piech, grandson of Ferdinand Porsche. The paternalistic Piech has long favored accommodation with Germany's unions to confronting them head-on. Former VP of HR Hartz, who later developed a number of labor market reforms for the Schroeder administration, recently entered into a plea bargain related to a scandal in which senior union officials at VW were co-opted through bribes.

Stan Peterson

There is an old observation that "Work expands to fill the time available" and "Idle hands are the Devil's workshop".

What do you expect the bureaucrats at EPA to do when the world has cleaned up the air and met their standards?

Standards that follow the rule that its got to be ten times better than we need, just so no one can criticize us?

Did you really think they would "Just declare victory, and go home."; and head off to the unemployment line?

Naivete` Of Course not!

Its time to tighten a few regulations whether needed or not. It justifies continued existence.
You do know that a few years ago they ruled that all the drinking water in about 10 States in the West had too much Arsenic in it, even though the standard was set in the 1930's and there is zero evidence of a wave of heavy metal poisoning from drinking water at half the old limeit which was ten times stiffer than the level before the doctors could detect any heave metal activity in humans.

Now the standards were changed from 60 ppm to 10 ppm, tougher than anywhere else in the world. The old 60 ppm standard used to be the toughest. The states are gearing up to spend $ billions on new water plants to remove the trace Arsenic.
How much can it really hurt to be extra, extra, extra, extra, safe?

Rafael Seidl

Stan -

the appropriate response would be to redeploy staffers to environmental problems that still need addressing. It's not as if we had run out of them...

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