Thursday, January 7, 2010

Here we go!

Well, as expected, the EPA wants to lower the 8hr average standard to between 60-70 ppb. They might as well drop it on down to 40 ppb so that even Alaska will be out of attainment!

This is beyond comment...but I will.

Here is my response to the last reduction in 2008...basically you can take the same comments and adjust them to address the even more ridiculous reductions being proposed now!


An Ozone Update
In an incredible move that defies both logic and understanding of our nation's ozone problem,
the EPA announced today that it is reducing the national 8hr ozone average to 75 ppb., effectively
adding hundreds of small and large cities to their "non attainment list". Despite costs that could total
in the billions of dollars and harm an already stressed manufacturing economy and positive health
results that are very difficult to prove, the EPA agreed to lower the 8hr average standard.
Below are questions that should be asked by everyone to the EPA:
1. How are small, rural areas supposed to lower their 8hr average ozone readings when they are not
contributing any pollution or only trace amounts? How many hundreds of new cities will now fall into
"non attainment"?
2. Why is their no allowance or handicap for urban areas located in the southern parts of our country?
A city like Houston, Texas, which averages over 96 days above 90 degrees, is more likely to have more
high ozone days than Seattle, Washington which averages only 3 days. Also, southern states have
higher UV values. Since UV is part of the formation of ozone, higher levels of UV give southern areas a
better chance of having high ozone days.
3. Exactly how many lives will be saved at what price? Can this be proven? Where is the increase in
hospitalizations data? In Texas, we have not seen data that supports this claim. TCEQ's chairwoman,
Kathleen Hartnett White, also understands the problem with the EPA wanting to lower the standard. In a
letter to the EPA, she argues that such a move would prove too costly and unlikely to improve health in Texas.
She mentions that studies found "no increase in hospital admissions in elderly patients and health effects in
children, respectively, due to ozone."
4. How much of high ozone readings can be attributed to natural causes beyond our control? There is much
documented evidence showing that many variety of trees, including oaks, produce isoprenes, which cause ozone.
In the southeast, there is an imported plant called the kudzu, which is taking over many areas, and releases
high levels of volatile organic compounds, which lead to high ozone.
5. What percentage of our ozone forming pollution comes from industrial plants in China or agricultural burns in
Mexico and what exactly does the EPA expect us to do about it? New data suggests that an ever increasing
percentage of our ozone readings are being impacted from transported pollution from China.
6. How do larger cities, like San Antonio, that produce very little pollution, lower our average to the new standard,
when we generally contribute less than 15% to high ozone days? How do we keep the outside pollution from
reaching us?
7. How does the EPA expect the Gulf of Mexico to lower its ozone levels, when those levels are often
higher than populated areas inland during the summer. No one has explained how that can be accomplished.
8. How does the EPA expect national parks like Joshua Tree National Park, to lower their levels, when only a
handful of people live their?
9. Who will pay for this?
10. Why do none of the health studies (that I have seen), mention pollen counts during the outdoor investigations?
The studies do mention that ozone can increase symptoms to allergens, but do not include pollen counts on any
of the outdoor studies of asthmatics.
11. How many people actually exercise in hot areas of our country when the ozone levels are high? Your are much
more likely to die from heat exhaustion than ozone exposure during the time of day when ozone levels are highest.
12. Where is the link to high ozone and asthma? According to CDC data, there is a higher percentage of asthmatics
in Midland, Texas, where there is very low ozone, compared with Houston.
13. Will the EPA reveal that "vehicle emissions testing" only reduces ozone levels by less than .05 ppb. in cities
as large as San Antonio, TX, with populations of over a million? Will they continue to force people to pay for these
costly annual tests, even though they are essentially non effective, since ozone is not measured in .05 ppb.?
Locally, reducing the standard will throw not only Austin and San Antonio into "non attainment", but Seguin,
La Grange, Fair Oaks, Garden Ridge, New Braunfels, Calaveras Lake, Bulverde, Temple, Round Rock, Corpus Christi,
Victoria and Hallettsville could also go into "non attainment", depending on whether the EPA accepts their ozone
monitoring data.
Here are some sites for ozone information:

Mark Langford

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