UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON D.C. 20460 

 

OFFICE OF THE ADMINISTRATOR

 SCIENCE ADVISORY BOARD

August 10, 2011

EPA-CASAC-11-009

The Honorable Lisa P. Jackson

Administrator

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, N.W.

Washington, D.C. 20460

Subject: CASAC comments on EPA’s Integrated Science Assessment for Ozone and Related 

Photochemical Oxidants (March 2011)

Dear Administrator Jackson: 

The Clean Air Scientific Advisory Committee (CASAC) Ozone Review Panel met on May 20, 2011 

and July 6, 2011 to provide advice on EPA’s Integrated Science Assessment for Ozone and Related 

Photochemical Oxidants (March 2011). The CASAC’s key points are highlighted in this letter, and 

the full consensus responses to the EPA charge questions are enclosed.

The draft Integrated Science Assessment (ISA) covers a wide range of scientific data and the database 

used for the assessment is complex and extensive. The EPA has done a good job of capturing the 

remarkable wealth of information available regarding ozone, its atmospheric formation, and the 

potential for health and welfare effects. The ISA demonstrates that there is substantial new evidence 

since the EPA completed its 2006 Air Quality Criteria Document (AQCD), leading to changes in the 

Agency’s findings of causal determinations. Below, we provide the CASAC’s comments on the 

EPA’s framework for causal determination, its approach for estimating policy relevant background, 

its new findings of causal determinations and other issues. 

Framework for Causal Determination

The CASAC continues to support the use of the EPA’s framework for causal determination that was 

first used in the ISA for particulate matter. This framework provides a comprehensive and transparent 

approach for evaluating causality. Based on long-standing approaches in public health, as brought 

together in a recent National Academy of Sciences (NAS) Institute of Medicine (IOM) report1

 1 National Academy of Sciences Institute of Medicine. Improving the Presumptive Disability Decision-Making Process for Veterans. 

National Academy Press, 2008. 

, the 

framework employs a two-step approach that first determines the weight of evidence in support of 

causation and then characterizes its strength in a standard scheme for causal classification. The 

second step further evaluates the available quantitative evidence regarding concentration-response 

relationships and the duration, level and types of exposures at which effects are documented. The 

EPA’s adoption of this framework has greatly improved the consistency and transparency of its 

assessment as compared to the approach seen in past reviews. The CASAC notes, with appreciation, 
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that the ISA provided a helpful comparison between current findings and the conclusions in the 2006 

AQCD. 

Policy Relevant Background

The ISA’s coverage of Policy Relevant Background (PRB) ozone concentrations is still a work in 

progress in this first draft. The PRB is the concentration that would occur in the U.S. in the absence 

of anthropogenic emissions in continental North America. The PRB includes contributions from 

natural sources everywhere in the world (wildfires, biogenic emissions, lightning) and from 

anthropogenic emissions outside of North America. The PRB calculation is critical because it defines 

the extent to which ozone concentrations can be reduced by U.S. regulations or through international 

agreements with neighboring countries. The CASAC concurs with the Agency that the PRB will need 

to be calculated with models. However, the EPA needs to provide a more specific and precise 

description of how the PRB will be calculated, especially given the biases in modeled ozone 

concentrations in comparison with measurements. To deal with those issues, an approach must be 

devised that is clearly articulated and includes an analysis of model uncertainties. 

Ozone Exposure

The ISA provides useful information on human exposures to ozone and the evidence relating human 

exposure to ambient ozone concentration and the errors associated with exposure assessment; 

however, the characterization of the temporal and spatial variability of ozone could be improved. A 

critical claim of the ISA is that there is “low spatial variability” in ozone concentrations at an urban 

scale and that correlations in ozone exposure and ambient concentration are strong enough to support 

a conclusion that central site monitors provide relevant time series data for health effects estimates in 

epidemiological studies. However, as noted elsewhere in the ISA, ozone is not spatially 

homogeneous in urban areas because of titration with nitrogen oxides (NOx). Furthermore, the extent 

of spatial variability in ambient ozone concentrations varies with the averaging time, with averaging 

times less than a day exhibiting greater variation as compared to longer averaging periods. Similarly, 

associations between ozone exposure and ambient concentrations have been shown to be weak, 

especially for individuals living in poorly ventilated homes. Given that the current standard is based 

on an 8-hour averaging period, the relevance of daily average or four-day average correlations is not 

established. The ISA should more critically address the adequacy of central site monitors for use in 

epidemiological studies and perhaps more fully address potential biases that could result from 

assuming that they are representative of spatial homogeneity and temporal trends. Improved

characterization of ozone concentrations at lower levels (40 – 60 ppb) will need more attention as the 

primary ozone NAAQS is reevaluated. 

Health Effects

With respect to the characterization of short-term health effects, the ISA highlights the broad scope of 

human chamber studies, toxicology studies, and new epidemiologic findings. This ISA covered the 

new evidence on the relationship between ozone and all-cause (non-accidental) mortality and 

concluded that there is “likely to be a causal relationship” between ozone and all-cause mortality. 

This is an elevation of the classification of the evidence over the previous conclusion from the 2006 

AQCD that the evidence was “highly suggestive” of ozone contributing to all-cause mortality. This 

upgrading was well justified by new multi-city studies and new studies examining potential 

confounders (co-pollutants and seasonality) of the ozone-mortality relationship. The CASAC also 

agrees with the ISA’s finding of a “causal” relationship between short-term exposure to ozone and 
3

respiratory effects. New studies support the ISA’s finding of a “suggestive of a causal” relationship 

between ozone and cardiovascular effects. New toxicological evidence also demonstrates an impact 

of ozone on the brain and behavior; hence the ISA’s finding of a “suggestive of a causal” relationship 

between ozone and central nervous system effects is justified. However, as detailed subsequently in 

our responses to charge questions, more description of some of the respiratory effects of ozone, 

especially on lung structure and host defenses, is needed. 

With respect to long-term health effects, the CASAC concurs with the strengthening of causality 

determinations from the 2006 Air Quality Criteria Document. In this ISA, evidence from new 

epidemiologic and toxicology studies supports the finding that the effects of ozone on long-term 

respiratory effects are “likely to be causal” and the evidence on the effects of ozone on the central 

nervous system are “suggestive “ of a causal relationship. Similarly, new epidemiologic and 

toxicological studies support classification for cardiovascular, reproductive, and central nervous 

system effects as “suggestive of a causal relationship.” 

The evidence on short-term effects of ozone exposure is relevant to interpreting some findings on 

long-term exposure to ozone. For the short-term effects, there is an extensive literature from 

epidemiological, human clinical, animal toxicological, and mechanistic studies. The links between 

this literature, as it contributes to the biological plausibility of chronic effects, should be strengthened 

in the ISA, where appropriate. For example, the evidence for long-term effects on respiratory 

mortality is strengthened by the evidence for short-term effects on respiratory morbidity. As the ISA 

correctly notes, the EPA concluded in the 2006 review that associations between short-term ozone 

exposure and respiratory health effects are causal and new evidence since that time strengthens this 

judgment. 

Susceptible Populations

This ISA uses a broad definition of “susceptible populations” as individual and population-level 

characteristics that increase the risk of ozone-related health effects. This definition conflates intrinsic 

or biological factors (such as genetic background, birth outcomes, race, sex and lifestage) with 

extrinsic factors (such as socioeconomic status and time spent outdoors). While the CASAC has 

previously concurred with the EPA’s broad definition of “susceptible subpopulations” as those that 

have a greater likelihood of experiencing health effects related to exposure, it may be useful to refine 

the classification of the factors that define susceptibility under this definition. CASAC recommends 

that the EPA deepen and reorganize the discussion of susceptibility to explain how its definition of 

susceptibility was applied and how the identified susceptibility-determining factors apply specifically 

to ozone. We provide further details in addressing the charge question on susceptibility.

Vegetation and Ecosystem Effects

The ISA maintains its support for the conclusions from the 2006 AQCD that ozone reduces 

vegetation growth, alters vegetation reproduction, causes visible foliar injury, alters leaf gasexchange in vegetation and reduces the yield and quality of agricultural crops. These causal 

relationships continue to be well-established scientifically by the older literature and fully supported 

by new research.The ISA recognizes the key effects and pathways by which ozone impacts 

vegetation at all scales, although the coverage of effects on insect and mammal herbivores due to 

changes in vegetation is rather brief due to a lack of research on these subjects. 
4

Climate Change Effects

Compared with the 2006 AQCD, the ISA draws stronger conclusions for the effects of ozone on 

radiative forcing and climate change. The stronger conclusions are well-supported and largely drawn 

from the 2007 Fourth Intergovernmental Panel on Climate Change Assessment (IPCC) Report which 

ranked ozone as the third most important greenhouse gas after carbon dioxide and methane. The 

discussion of climate forcing due to ozone relative to that of carbon dioxide and methane is 

scientifically sound; however, more attention should be given to methane as the only ozone precursor 

for which control would directly reduce climate forcing. The CASAC also recommends that more 

attention be given to the recent Representative Concentration Pathways (RCP) scenarios of the 

upcoming IPCC Fifth Assessment Report (AR5), since these scenarios will provide the core of future 

assessments of climate forcing for emissions relevant to air quality and they present a very different 

picture than the older emissions scenarios. Given the complex feedback loops between various ozone 

precursors (e.g., a decrease in nitrogen oxides emissions could lengthen the lifetime of methane in the 

atmosphere whereas a decrease in carbon monoxide or volatile organic compound emissions should 

shorten the lifetime of methane), we echo the ISA’s call for research to determine the optimal mix of 

emissions reductions that would act to limit future climate change.

Document Length and Format

Finally, the CASAC was asked whether the ISA, at 996 pages, is too long. A highly useful ISA must 

clearly explain the key studies that facilitate decision-making with regard to the NAAQS as required 

by the Clean Air Act.The encyclopedic nature of this 996-page ISA can be a weakness, making it 

difficult to identify and focus on the most relevant information. While some panelists thought that the 

length was appropriately reflective of the scope of evidence, others offered suggestions for shortening 

the document. All agree that clarity of presentation is of paramount importance and suggestions for 

enhancing the organization and presentation of the evidence may be found in abundance in the 

enclosed individual comments from panel members. In particular, the CASAC underscores a 

recommendation that the text should focus on findings, only discussing methods and models when 

necessary to describe the findings. The CASAC also emphasizes the need for an Executive Summary. 

Currently the “Integrative Health and Welfare Effects Overview” (Chapter 2) is a 66-page overview 

that mirrors the other sections of the ISA rather than integrating across the sections on concentration, 

exposure, dosimetry, mode of action, and health and welfare impacts. Moreover, each section is 

written as though for an expert audience in a narrow domain, and thus the text is challenging for most 

readers. Hence, an Executive Summary of about 10 pages is needed to communicate to a broader 

audience and highlight findings of greatest import. Finally, tables are needed to provide a concise 

summary of the important findings, regardless of the date published. With this addition, the ISA 

could succinctly refer to these tables and reserve space in the text for in-depth consideration of the far 

fewer studies that will be influential as revisions to the NAAQS are considered. 

The CASAC also suggests that the ISA specify the time frame for inclusion of relevant data into this 

cycle of ISA development and review. Moreover, the EPA should say what was done, if anything, 

regarding potentially important information received after that date. 
5

We thank the Agency for the opportunity to provide advice on this ISA and look forward to receiving 

the Agency’s response. 

Sincerely, 

/Signed/

Jonathan M. Samet, M.D.

Chair

Clean Air Scientific Advisory Committee

Enclosures
i

NOTICE

This report has been written as part of the activities of the EPA's Clean Air Scientific Advisory 

Committee (CASAC), a federal advisory committee independently chartered to provide extramural 

scientific information and advice to the Administrator and other officials of the EPA. CASAC provides 

balanced, expert assessment of scientific matters related to issues and problems facing the Agency. This 

report has not been reviewed for approval by the Agency and, hence, the contents of this report do not 

necessarily represent the views and policies of the EPA, nor of other agencies within the Executive 

Branch of the federal government. In addition, any mention of trade names or commercial products does 

not constitute a recommendation for use. CASAC reports are posted on the EPA Web site at: 

http://www.epa.gov/casac.
ii

U.S. Environmental Protection Agency

Clean Air Scientific Advisory Committee

Ozone Review Panel

CHAIR

Dr. Jonathan M. Samet, Professor and Flora L. Thornton Chair, Department of Preventive Medicine, 

University of Southern California, Los Angeles, CA

CASAC MEMBERS

Mr. George A. Allen, Senior Scientist, Northeast States for Coordinated Air Use Management 

(NESCAUM), Boston, MA

Dr. Joseph D. Brain, Cecil K. and Philip Drinker Professor of Environmental Physiology, Department 

of Environmental Health, Harvard School of Public Health, Harvard University, Boston, MA

Dr. H. Christopher Frey, Professor, Department of Civil, Construction and Environmental 

Engineering, College of Engineering, North Carolina State University, Raleigh, NC

Dr. Armistead (Ted) Russell, Professor, Department of Civil and Environmental Engineering, Georgia 

Institute of Technology, Atlanta, GA

Dr. Helen Suh, Program Area Director, Environmental Health, Public Health Division, National 

Opinion Research Corporation (NORC) at the University of Chicago. 

Dr. Kathleen Weathers, Senior Scientist, Cary Institute of Ecosystem Studies, Plant Science Building, 

Millbrook, NY

CONSULTANTS

Prof. Ed Avol, Professor, Preventive Medicine, Keck School of Medicine, University of Southern 

California, Los Angeles, CA

Dr John Bailar, Scholar in Residence, The National Academies, Washington, D.C.

Dr. Michelle Bell, Associate Professor, School of Forestry and Environmental Studies, Yale University, 

New Haven, CT

Dr. David Chock, Independent Consultant, Bloomfield Hills, MI

Dr. William Michael Foster, Professor, Pulmonary and Critical Care Medicine, Duke University 

Medical Center, Durham, NC 

Dr. Judith Graham, Independent Consultant, Pittsboro, NC

Dr. David Grantz, Director, Botany and Plant Sciences and Air Pollution Research Center, Riverside 
iii

Campus and Kearney Agricultural Center, University of California, Parlier, CA

Dr. Jack Harkema, Professor, Department of Pathobiology, College of Veterinary Medicine, Michigan 

State University, East Lansing, MI

Dr. Daniel Jacob, Professor, Atmospheric Sciences, School of Engineering and Applied Sciences, 

Harvard University, Cambridge, MA

Dr. Steven Kleeberger, Professor and Lab Chief, Laboratory of Respiratory Biology, National Institute 

of Environmental Health Sciences, National Institutes of Health, Research Triangle Park, NC

Dr. Frederick J. Miller, Independent Consultant, Cary, NC

Dr. Howard Neufeld, Professor, Dept. of Biology, Appalachian State University, Boone, NC

Dr. James Ultman, Professor, Chemical Engineering, Bioengineering Program, Pennsylvania State 

University, University Park, PA

Dr. Sverre Vedal, Professor, Department of Environmental and Occupational Health Sciences, School 

of Public Health, University of Washington, Seattle, WA

Dr. Peter Woodbury, Senior Research Associate, Department of Crop and Soil Sciences, College of 

Agriculture and Life Sciences, Cornell University, Ithaca, NY

SCIENCE ADVISORY BOARD STAFF

Dr. Holly Stallworth, Designated Federal Officer, Science Advisory Board Staff Office, Environmental 

Protection Agency, Washington, D.C. 
1

Consensus Responses to EPA Charge Questions

1. This first external review draft O3 ISA is of substantial length and reflects the copious amount of 

research conducted on O3. EPA has attempted to succinctly present and integrate the policy-relevant 

scientific evidence for the review of the O3 NAAQS. The panel may note that per CASAC 

consultation on November 13, 2009, considerable discussion has focused on older literature. The 

panel emphasized that important older studies should be discussed in detail to reinforce key 

concepts and conclusions if they are open to reinterpretation in light of newer data and where these 

older studies remain the definitive works available in the literature. In considering subsequent 

charge questions and recognizing an overall goal of producing a clear and concise document, are 

there topics that should be added or receive additional discussion? Similarly, are there topics that 

should be shortened or removed? Does the Panel have opinions on how the document can be 

shortened without eliminating important and necessary content?

This charge focuses on length. Length is an important consideration for the ISA, but not nearly as 

critical as clarity of presentation of a large and complex literature that is being used for regulatory 

purposes. Thus, our comments focus on four approaches to present the knowledge of O3 more 

effectively and succinctly, without regard to number of pages.

• The text should focus on findings, only discussing methods and models when necessary to 

support or describe the findings. The model descriptions in Chapter 3, while necessary, may be 

simplified. Also, there may be too many figures in the Chapter 3 Appendix. The number of 

examples in this chapter may be trimmed down without any significant loss in understanding.

• A reduction in duplication would be helpful. In particular, Chapter 2 duplicates the summaries 

found in the other chapters. In addition, the mode-of-action (MOA) section of Chapter 5 has 

significant duplication of the effects chapters (6 and 7), and, more importantly, this artificial 

separation inhibits a clear understanding of the biological plausibility for some of the effects. 

• The health-related chapters have no tables describing exposure-response relationships, except for 

some of the epidemiological studies. As a result, the text is crowded with information on 

exposures (species, concentrations, durations, responses, levels of exercise, and air quality, and 

cities studied). This detail makes for difficult reading that inhibits understanding of concepts and 

key findings. In many cases, critical information (e.g., whether exercise used in a certain clinical 

study, the exposure duration of a certain animal study) was not provided at all. For clarity, it is 

essential to provide tables of all the literature that should be considered. While this would result 

in many new pages, the text could be reduced by referring to the tables for details.

• The separation between old and new studies causes duplication and restricts cohesive 

understanding. Furthermore, this distinction is artificial because the NAAQS is based on all 

pertinent information, independent of what year it was published. Having tables and utilizing 

them optimally would avoid this problem. For example, complete tables on a particular endpoint 

would facilitate identification of the relatively few key studies, independent of date, which could 

then be described in the text with cross reference to the tables. At present, some of the key 

studies are from the older literature. 
2

2. The framework for causal determination and judging the overall weight of evidence is presented in 

Chapter 1. Is this framework appropriately applied for this O3 ISA? How might the application of 

the framework be improved for O3 effects?

Panel members were largely satisfied with the framework for causal determination. Below we offer 

specific comments to sharpen the discussion of particular terms and issues. 

• The ISA defines “cause” as “a significant, effectual relationship between an agent and an 

effect on health or public welfare” (p. 1-14, lines 1-2). We recognize the historical origins of 

this term, but question whether it is fits well with the specific context of the ISA. This 

definition is ambiguous with respect to whether “significant” refers to the size of an effect 

(perhaps as reflected in measure of statistical significance) or its importance (as estimated by 

its impact on health or welfare). If it is the former, something should be said about the 

level(s) of statistical significance that are used in various places in the ISA; if it is the latter, 

something should be said about what type or level of impact qualifies as significant. Panel 

members are concerned about any definition that would label a small but clearly 

demonstrated effect as less than “significant”; it is certainly important to the affected persons. 

Also, it is not clear what “effectual” means. Does it mean that an effect has in fact been 

demonstrated? That such a relationship is possible? Couching the definition of cause in 

counterfactual terms, as perhaps hinted at in line 5 (page 1-14), is arguably the most 

informative and most usable way to define the term. This approach incorporates the notion of 

“all else being equal” and allows for its application when multiple factors are in the causal 

chain, when there are parallel chains, or both. Clarification of the definition of “cause” may 

have important ramifications in many other places in the draft ISA and provide a clearer 

conceptual basis for the Risk and Exposure Assessment. We recognize that causation has 

long been discussed and we do not recommend that EPA enter into an in-depth consideration 

of the topic. The Agency should, however, provide some further text clarifying the 

implications of the definition offered in the context of interpreting evidence related to 

possible revision of a NAAQS.

• Panel members have some general concerns about the application of the so-called Hill 

criteria for evidence evaluation. In general, we recommend that these criteria be regarded as a 

guide to thinking about the data to ensure that relevant aspects of the data are adequately 

considered and taken as a whole rather than used as a checklist. It is noteworthy that the 

presence of exceptions to each of the “criteria,” except temporality, is still consistent with 

causality. We recommend that the criteria not be ranked in any way; their relative importance 

will depend on the specific context and specific issue under consideration.

• With respect to the definition of “specificity” (page 1-19), does “specificity” refer to one 

cause with many effects or to many causes with a single outcome? Despite examples to the 

contrary (such as cigarette smoking) we believe that Hill’s original intent, and our 

understanding of current use, is that specificity requires that a cause of interest has only one 

effect, or perhaps several related effects. This definition of specificity is meant to screen out 

certain kinds of bias that might cause an apparent increase in a broad range of outcomes. 

Thus, this criterion should be used to direct attention to possible biases, not to diminish 

attention to responses that may have many contributing causes, such as most chronic diseases 

in older populations.
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• “Coherence: is construed too narrowly. The ISA refers to findings among epidemiological, 

toxicological and other experimental studies however it also refers to findings across 

epidemiological study designs.

• Effect modification should be defined (e.g., differences in the effect of exposure [ozone] by 

differences in another factor) before launching into a discussion of how it differs from 

confounding. Also, temperature is presented as a potential effect-modifier, but it might be 

valuable (and less confusing) to contrast how temperature is also (and more importantly) a 

potential confounder. Essentially, effect modification refines our understanding of the effect 

of an exposure while confounding addresses whether an effect is actually present, or what the 

size of that effect is, if present.

Below are some additional considerations relevant to evidence interpretation and methodology. 

• It is important that the ISA be transparent about when the search for new evidence was 

suspended, and that it says what was done, if anything, regarding potentially important 

information received after that time. “Nothing” would be an acceptable answer, but it should 

be specified here, and if any studies are included following a specified cut-off, clear and 

specific justification should be given. This might be addressed in Section 1.5 – Document 

Scope. 

• The shape of the exposure-response relationship is influenced by the degree of measurement 

error, as touched on (page 1-23, line 8). Specifically, measurement error at lower 

concentrations can obscure a threshold and make it appear that a linear relationship extends 

to lower concentrations (Brauer, M. Et. al., 2002. Exposure misclassification and threshold 

concentrations in time series analyses of air pollution health effects. Risk Analysis; 22: 1183-

1193). This might be a particularly important issue for interpreting risks of pollutants, such as 

ozone, that exhibit large degrees of exposure measurement error.

• Although the concept of a “threshold” was not a major focus in Chapter 1, clarity is needed 

on this concept throughout the ISA. EPA needs to thoughtfully consider how statistically 

defined thresholds relate to the range of individual susceptibility to ozone. 

• The observation that publication bias in the case of ozone may not be so important (1-23, line 

27) is contradicted by the work of Bell et al. (Bell ML, Dominici F, Samet JM. 2005. A 

meta-analysis of time-series of ozone and mortality with comparison to the national 

morbidity, mortality, and air pollution study. Epidemiology 16:436-445) showing substantial 

differences in ozone effect estimates from meta-analyses of published studies and multi-city 

study effect estimates. 

• The discussion of susceptibility indicates that the term here will be used in a general sense to 

include both susceptibility and vulnerability, terms that include both disease risk factors and 

factors that increase exposure (page 1-23, line 36) and therefore risk. This usage should be 

made explicit.

• The discussion of adversity is appropriate to include here. There is no discussion, however, 

of the types of endpoints that are more problematic in a discussion of adversity, such as 

markers of inflammation or oxidative stress, for example.
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3. Chapter 2 presents the integrative summary and conclusions from the O3 ISA with detailed 

discussion of evidence in subsequent chapters. Is this a useful and effective summary presentation? 

How does the Panel view the appropriateness of the causal determinations? 

CASAC strongly supports the inclusion of a chapter that summarizes and integrates findings from 

the ISA and that relates these findings to those from the earlier 2006 AQCD. The CASAC had a 

wide ranging discussion regarding the form and placement of such a chapter, offering several 

possible options. For the form of the chapter, options include: (1) a chapter that integrates findings 

across the ISA sections (e.g., concentration, exposure, dosimetry, mode of action, and health and 

welfare effects) with relevant summaries placed at the ends of Chapters 3-10; (2) a brief executive 

summary placed at the front of the document with a subsequent chapter integrating findings; and (3) 

a chapter that combines the summary and integration of findings as an “integrative overview” rather 

than as a detailed summary. For the three options, the Committee suggested that the “integration” 

chapter be placed as either Chapter 2 (as currently presented) or at the end of the ISA. Independent 

of its form and placement, the Chapter should be amended to provide a uniform and sharper focus, 

which would help to minimize repetition and provide a more cohesive and integrated picture of 

ozone and its health and welfare impacts. 

4. In relation to Chapter 3 and its associated appendix, to what extent are the atmospheric chemistry 

and air quality characterizations clearly communicated, appropriately characterized, and relevant 

to the review of the O3 NAAQS? Does the information on atmospheric sciences provide useful 

context and insights for the evaluation of O3 effects on human health, vegetation, ecosystems, and 

climate in the ISA?

a. Is accurate and appropriate information provided regarding techniques for measuring O3

and its components, and spatial and temporal patterns of O3 concentration? 

Yes, the information on measurements of ozone is accurate and appropriate. 

b. Policy Relevant Background (PRB) O3 concentrations are necessary to estimate risks to 

human health and environmental effects associated with exposures to O3 concentrations 

attributable to anthropogenic sources of precursors emitted in the United States, Canada 

and Mexico (i.e., to O3 concentrations above PRB levels). As such, estimates of PRB are 

key to the NAAQS process for O3. Is the evidence related to estimation of and uncertainty 

in PRB presented clearly, succinctly, and accurately? Are there issues related to 

uncertainties in methods for estimated PRB concentrations that have not been addressed 

or should be expanded? 

As expounded upon in individual comments, the discussion of the PRB needs to be bolstered and a 

more specific and precise description added on how the PRB will be calculated for use later in the 

NAAQS process. There are biases in the modeled ozone concentrations in comparison with 

observations. EPA should devise an approach to deal with those biases that is clearly articulated, 

along with capturing the uncertainties that arise from that approach. At present, the discussion of 

uncertainties in the PRB estimation is limited. Important chemical uncertainties that could affect 

model PRB simulations that require more discussion include halogen chemistry (not just in urban 

areas but in the background), isoprene chemistry, and the chemical evolution of fire plumes. Current 
5

models simulating the pre-industrial and early 20th century atmosphere greatly overestimate the 

observed concentrations at the turn of the century. In comparing the modeled ozone with 

observations, EPA should include data from additional PRB relevant long-term data that are not in 

EPA’s Air Quality System (AQS). There needs to be a more quantitative analysis of the contribution 

of stratospheric O3 to ground level O3; this is only noted in passing with a reference to Thompson et. 

al., 2007 (Thompson, et. al., 2007. Intercontinental Chemical Transport Experiment Ozonesonde 

Network study (IONS) 2004: 2. Tropospheric ozone budgets and variability over northeastern North 

America. Journal of Geophysical Research. 112: D12S13). That study may over-estimate this 

contribution in part because 2004 was a relatively low O3 season for the northeastern U.S. An 

additional resource that should be considered is the Canadian Smog Science Assessment (2011, 

Environment Canada and Health Canada report, not yet released). The chapter presents cogent 

arguments for the use of a chemistry-transport model like GEOS-Chem to simulate the PRB time 

series. However, the tendency of a chemistry-transport model to underestimate the upper extreme 

values like the annual fourth highest value poses a significant challenge to describe the PRB based 

on the same metric relevant to the NAAQS for O3. This issue was not addressed in the chapter.

c. Does the discussion of ambient O3 concentrations adequately describe the variability 

attributed to diurnal patterns, seasonal patterns, and spatial differences in both urban 

and non-urban locations? Are the analyses and figures presented in Chapter 3 and its 

associated appendix (section 3.7) effective in depicting ambient O3 characteristics?

The current presentation is useful, but not sufficient. Much of the analysis concentrates on the higher 

ozone levels. However, if the human response to ozone exposure is treated as linear with no 

threshold, low levels are very important in the analysis. Ozone trends and relationships at low levels 

(e.g., 40-60 ppb) are very important because these levels are more prevalent than the higher levels. 

Since the standard is currently proposed for tightening (Proposed Rule, National Ambient Air 

Quality Standard for Ozone, January 19, 2010. Federal Register, 75 (11): 2938 – 3052) more 

interest has developed in levels around 60 ppb. Thus, more attention should be given to ozone levels 

at, and below this level. 

d. Is there additional information regarding oxidants, other than O3, that should be 

included, or is the current emphasis on O3 adequate? 

The current version is adequate as the reader can refer to prior documents such as the AQCD. 

5. Chapter 4 describes human exposures to O3. Is the evidence relating human exposure to ambient O3

and errors associated with exposure assessment presented clearly, succinctly, and accurately? Are 

the results of field studies evaluating indoor-outdoor and personal-ambient exposure relationships, 

and factors affecting those relationships, presented in a manner that is useful for interpretation of 

epidemiologic results? Is the information on modeling O3 concentration surfaces and population 

exposures appropriate for evaluating the utility of these modeling approaches? Do the 

characterizations of temporal and spatial variability of O3 in urban areas provide support for better 

understanding and interpreting epidemiologic studies discussed later? 

Historically, placement of central site monitors away from local NOx sources has potentially resulted 

in concentration profiles that are not fully representative of the whole urban area, given the 

considerable variation induced by NOx titration near or immediately downwind from busy roadways 

or other substantive sources of NOx. Further, studies have shown central site monitors to be 
6

relatively poor proxies of personal ozone exposures, especially for individuals living in poorly 

ventilated environments or who spend little time outdoors. Thus, the chapter should more critically 

address the adequacy of central site monitors for use in epidemiological studies and be more 

forthcoming about potential biases that could result from assuming central site data are 

representative of spatial homogeneity, temporal trends, and personal exposures. Discussion is 

provided about models and factors affecting various microenvironmental relationships, but a 

focused, decisive, and succinct summary of the results of applying the models is lacking.

6. The dosimetry and modes of action of O3 are discussed in Chapter 5. The primary focus of the 

dosimetry discussion is to highlight factors that might lead to differences in dose between individuals 

and between species. Some potential modes of action that may underlie a number of health outcomes 

and that may contribute to the biological plausibility of health effects of short- and long-term 

exposures are described in detail. Is the review of basic dosimetric principles of O3 uptake presented 

accurately and in sufficient detail? What are the views of the Panel on the approach taken in 

Chapter 5 to characterize modes of action for O3-related effects? 

In general, sufficient detail is presented in this chapter to serve as a background for a risk analysis of 

health effects of ozone. The chapter does a reasonable job of including new literature and integrating 

the research available from the 2006 ACQD. A major weakness is the lack of continuity between the 

first part of the chapter on dosimetry and the second part of the chapter on MOA and risk 

assessment. More interpretation/synthesis of key findings is needed to identify scientific evidence 

that could potentially alter the current value of the O3 NAAQS.

Is the review of basic dosimetric principles of O3 uptake presented accurately and in sufficient 

detail? 

With regard to factors that influence O3 dosimetry (e.g., airway geometry, gender and age), the 

chapter does a good job. However, there is little discussion of dosimetric principles and their

application to the interpretation of data and to extrapolation modeling. Also, there is an insufficient 

explanation of essential dosimetry variables (i.e., flux, absorbed fraction, absorption efficiency, 

inhaled dose and net dose) and the interrelationships among these factors. 

It is appropriate that substrate reactions in the extracellular lining fluid (ELF) with O3 have been 

emphasized in both the dosimetry and mode-of-action (MOA) sections of this chapter. These 

reactions are a key factor that links O3 dose with biological dysfunction, cell damage, and 

physiological responses such as altered pulmonary function. The reactions also inform consideration 

of extrapulmonary effects. Some suggestions for improving the integration of this material between 

the two parts of Chapter 5 are given below.

There is limited discussion of species differences in nasal structure and lung morphometry and the 

composition of the ELF together with the cellular composition in the major respiratory tract regions 

(nasopharyngeal, tracheobronchial, and alveolar). Comparative dosimetry linking human to animal

studies needs to be expanded because many relevant mechanistic studies exist primarily in animal 

models. For example, some effects of O3 exposure, such as remodeling in small airways and other 

persistent anatomic changes, have been demonstrated only in non-human primates and rats. 

Understanding these data is essential because such information affects the strength of species 

homology and also illustrates what needs to be taken into account in interspecies dosimetric 

extrapolations. 
7

Given the importance of exercise on physiological responses to ozone, the chapter would benefit 

from an expanded discussion of the relation between O3 uptake and breathing patterns during 

exercise (e.g., how a change from low to moderate exercise level is accompanied primarily by a 

change in tidal volume whereas an increase in breathing frequency becomes more important when 

exercise increases from moderate to heavy levels). Transition from nose to mouth breathing should 

also be discussed in the context of exercise. 

What are the views of the Panel on the approach taken in Chapter 5 to characterize modes of action 

(MOA) for O3-related effects? 

The MOA material is currently a combination of effects descriptions mixed with studies that are 

more mechanistically oriented. The result is excess duplication with subsequent effect chapters and a 

disjointed presentation. For example, understanding the MOA of an effect described in the shortterm effects chapter would require going back and forth between two chapters. It would be more 

cohesive if the MOA for effects (other than the discussion of ELF reactions) were relocated or better 

linked to the corresponding outcome in the effect chapters. The first part of the chapter on dosimetry 

seems disconnected from the second part of the chapter on MOA. An implied link is O3 reactions 

with ELF substrates that simultaneously augment O3 uptake as well as the production of toxic 

byproducts that can reach epithelial cells. The MOA discussion overly relies on an assertion that free 

O3 molecules cannot penetrate a lining layer depth greater than 0.1 μm, leading to the hypothesis 

that O3 effects throughout the respiratory tract must be mediated via secondary reaction products. 

Since the surfactant film that covers almost all of the alveolar epithelial cells is only about 0.02 μm 

in depth, this premise is not valid for the alveolar region. 

If the purpose is actually to convey dose-response considerations, the chapter title should be changed 

and the linkages between dosimetry and MOA should be better developed. The chapter introduction 

would be improved by expanding Figure 5-6 to depict the main factors in dosimetry together with 

key events and pathways for the effects of ozone on the respiratory tract to provide a perspective of 

the complexity of O3 dose-response relationships. The material on reactions of O3 with ELF could be 

reorganized to include a section focusing on issues that are primarily directly connected to 

dosimetric aspects (e.g., the structure of kinetic rate equations, rate constant values of different 

substrates, and diffusion-reaction models that estimate O3 penetration into ELF). We also suggest 

adding another section more concerned with issues that influence MOA (e.g., mechanisms of the O3-

ELF substrate reactions and the toxicology of the possible reaction products).

Too little information from animal studies is brought into the MOA discussion. Throughout the 

chapter, citation of key pre-2006 animal studies would strengthen the extension of MOAs in support 

of the human findings. More interpretation and greater emphasis on the relevance of key findings 

needs to be incorporated into the chapter. Discussion of the effects of O3 on other important 

preexisting conditions such as obesity and facets of metabolic pathways could also be included. In 

addition, the MOA Overall Summary is weak; it does not convey the strength and the importance of 

the findings discussed in the MOA subsections. 

7. Chapter 6 is intended to support the evaluation of human health effects evidence for short-term 

exposures to O3. To what extent are the discussion and integration of evidence on the health effects 

of O3 from the animal toxicological, controlled human exposure, and epidemiologic studies, 

technically sound, appropriately balanced, and clearly communicated? Does the integration of 
8

health evidence focus on the most policy-relevant studies or health findings? What are the views of 

the Panel regarding the balance of emphasis placed on evidence from previous and recent 

epidemiologic studies in deriving the causal determination for short-term O3 exposure and 

respiratory effects (in particular, additional epidemiologic evidence for lung function and 

respiratory symptoms and new evidence for biological indicators of airway inflammation and 

oxidative stress that previously has been largely limited to human controlled exposure and 

toxicological studies)? The majority of new studies that examine the association between short-term 

O3 exposure and mortality focus on specific issues that have been previously identified. Does the 

structure of the chapter adequately highlight the breadth of studies (both older and new) that 

indicate an association between O3 exposure and mortality and provide the underlying rationale for 

the causal determination? Are the data properly presented regarding the credibility of newly 

reported findings being attributable to O3 acting alone or in combination with other co-pollutants 

and regarding the extent that toxicological study findings lend support to the biological plausibility 

of reported epidemiologic associations in reaching a causal determination? Are the tables and 

figures presented in Chapter 6 appropriate, adequate and effective in advancing the interpretation of 

these health studies? 

CASAC concurs with the ISA’s finding of a “causal” relationship between short-term exposure to 

ozone and respiratory effects. We also concur with the ISA’s finding of a “suggestive of a causal” 

relationship between ozone and cardiovascular effects. New toxicological evidence also 

demonstrates an impact of ozone on the brain and behavior; hence the ISA’s finding of a “suggestive 

of a causal” relationship between ozone and central nervous system effects is justified. Specific 

comments on Chapter 6 include the following. 

As recognized in the ISA, clinical studies address ozone alone whereas epidemiological studies 

address broader mixtures of oxidants for which ozone is an indicator. 

Numerous clinical experiments from several laboratories have demonstrated that healthy young 

adults exposed for several hours to O3 during intermittent exercise experience decrements in 

pulmonary function, respiratory symptoms, and lung inflammation. Particularly for those studies 

below the current NAAQS level (75 ppb), it is important that the ISA thoroughly discuss the details 

of the experimental regimens and the statistical as well as the clinical significance of the results. A 

recent chamber study showed that 60 ppb O3 causes pulmonary function decrements in the lungs of 

exercising, young adult, healthy subjects, with some subjects being more responsive than others. 

(Kim CS, NE Alexis, AG Rappold, H Kehrl, MJ Hazucha, JC Lay, MT Schnitt, M Case, RB Devlin, 

DB Peden, D Diaz-Sanchez. Lung function and inflammatory responses in healthy young adults 

exposed to 0.06 ppm ozone for 6.6 hours. Am J Respir Crit Care Med 183:1215-21, 2011). While the 

mean functional decrement was significant statistically, it was not of a magnitude (<2%) that would 

be classified as clinically relevant. The indicator of an inflammatory response [polymorphonuclear 

leukocytes (PMNs) in induced sputum] measured in a sub-set of the study population, was 

significant statistically, at a magnitude of likely clinical relevance, and with a greater response to 

ozone by the male subjects. How much lower, if any, O3 exposures could be and still induce 

pulmonary function changes is open to question, particularly since the clinical chamber studies are 

using exposures of long duration (i.e., 6.6 h) with exercise (i.e., increased minute ventilation) levels 

that surpass those encountered by many occupational workers during a day of heavy to severe 

manual labor and are well beyond those of most healthy individuals. 

Pulmonary function, with or without ozone exposure, varies in a given individual as well as between 

individuals. Most human clinical studies compare responses of volunteers exposed to filtered air vs. 
9

responses after O3 exposure. Thus, it would be helpful to include additional information on the daily 

variability of pulmonary function responses of exercising individuals to filtered air exposure. Since 

lower concentrations cause relatively small statistically significant changes, it is important to explain 

all possible major sources of variability.

Numerous factors have significant impacts on the results of toxicological studies. They include 

duration of exposure, pattern of exposure, concentration, exercise (ventilation rates), age and gender 

of subjects, preexisting diseases of subjects, and species and strain of animal. In too many cases, this 

information is not provided, but should be. The separation between old and new studies in this 

chapter leads to a choppy presentation and weak integration. The problem is especially troublesome 

in the case of short-term human clinical and epidemiological studies since they will form the 

predominant bases of the O3 NAAQS review. Also, some important references to human clinical 

studies covered in Chapter 5 are not included in this chapter. These shortcomings could be overcome 

by including tables that summarize the human clinical or animal toxicology literature. Such tables 

would allow brevity of the text and still provide a quick way to evaluate the weight of the evidence 

for particular health effects. 

The graphical presentation of the epidemiologic data (Figures 6-3 through 6-11) frequently relies 

upon a single abscissa with multiple interpretations, depending on the endpoint used in a particular 

study. A less confusing manner of presenting the data is needed.

The epidemiologic results of increased mortality (overall) are quite consistent in direction (not in 

severity) over space, time, and a range of circumstances and study designs, although there are some 

exceptions for single cities or other subgroups. Possible flaws in the evidence being presented are 

adequately discussed. However, the discussion misses the point that a remarkable combination of 

factors would have to affect the reported studies, each in different ways, to decrease the estimated 

effect to be no more than “likely”.

In analyses of the short term effect of ozone on mortality, attention was given to confounding by 

multi-pollutants (PM, SO2). Although the chapter is already quite broad, a clearer summation of the 

information on this sub-topic (co-pollutants, confounding, and mortality) seems warranted.

Sub-topics of interest that could be considered for more emphasis under ozone and mortality, 

include: (a) increases in mortality found to be higher in ethnic populations (page 6-155) and how 

they interact and associate with economic factors (unemployment, education), (b) primary users of 

outdoor public transportation, and (c) housing. These contributors to potential exposure, also impact 

avoidance practices in vulnerable populations.

“Tolerance”, “adaptation”, and “attenuation” are used frequently and sometimes interchangeably. 

These terms need to be defined initially and then used consistently, throughout the document. 

The animal toxicological studies on respiratory structural changes are not adequately discussed. 

When they are mentioned, the discussion is buried, too brief, does not allude to supporting evidence, 

and does not discuss implications for severity of effects in humans. There are dozens of references to 

effects below 0.5 ppm, down to 0.15 ppm and 0.2 ppm in non-human primates, which are not 

included. Including them is important because the structural changes are correlated with 

inflammation and (at higher levels) with functional changes. Such structural changes cannot be 

measured in humans, but are very likely to occur if exposures are sufficient. Such information 
10

contributes to understanding severity of the effects O3. Therefore, it is essential to add this 

information. 

8. Chapter 7 presents important new findings from studies published since the 2006 O3 AQCD 

including studies that examine the relationship between long-term O3 exposure and new onset 

asthma in children, first childhood asthma hospital admissions, increased asthma severity, bronchi 

tic symptoms and respiratory-related school absences. These studies provide evidence in this regard 

based on different genetic variants. What are the views of the Panel on the conclusions drawn in the 

draft ISA regarding the strength, consistency, coherence and plausibility of the evidence for health 

effects for long-term O3 exposure on respiratory morbidity? Limited new data also suggest a link 

between long-term O3 exposure and respiratory mortality; what weight should be placed on this 

evidence in causal determinations? What are the views of the Panel on the conclusions drawn in the 

draft ISA regarding the strength, consistency, coherence and plausibility of the evidence for 

neurological effects resulting from long-term O3 exposure? Are the data properly presented 

regarding the credibility of newly reported findings being attributable to O3 acting alone or in 

combination with other co-pollutants and regarding the extent that toxicological study findings lend 

support to the biological plausibility of reported epidemiologic associations in reaching a causal 

determination? 

Strength of Causality

Overall, the Panel agreed with the causality conclusions in this chapter. The strength of evidence for 

causality is perhaps weakest for all-cause mortality, for which EPA concluded a “suggestive” 

relationship. This conclusion is largely based on a single epidemiological study, with consistent 

supporting evidence from other lines of research, including toxicological research. Further 

description of the mortality study, including its limitations, is needed. The conclusion for evidence 

on all-cause mortality was generally viewed as appropriate, given the single study’s evidence that 

the all-cause relationship is not robust to inclusion of PM. There is stronger evidence for respiratory 

mortality. One panelist noted the logical inconsistency of finding that the evidence was strong for a 

particular cause but weak for all-cause mortality, which necessarily includes all component causes of 

death. EPA should assure clarity as to the approach for considering cause-specific mortality in 

interpreting findings on all-cause mortality. 

The text on evidence for causality of long-term exposure to O3 could be made stronger by drawing 

on literature from other chapters that found consistent evidence for similar health outcomes, albeit 

for a different timeframe of exposure. Specific examples are the findings from epidemiology, 

toxicological, and human experimental studies on respiratory morbidity for a range of health 

endpoints. These findings provide evidence of plausibility for the conclusions in the long-term 

exposure chapter. The chapter could explicitly state the ways in which there is and is not evidence 

for causality, such as whether the limitations relate to sample size, lack of variability in study 

designs, etc. This should be done in the context of evidence for causality, not research needs.

Definition of long-term exposure

Given the wide range of what “long-term exposure” may mean, this chapter would benefit from a 

discussion early in the chapter on how this is defined. Throughout the chapter, the text should 

specify the duration of exposure for each study. This is sometimes provided, but often missing. The 

exposure timeframe should be clearly specified in every table. The “long-term” exposure timeframe 
11

in this chapter ranges from a single day to many years. The inclusion of short-term exposure in this 

chapter is inappropriate. This apparently relates to a decision to keep reproductive health outcomes 

together; however, the remainder of the document clusters studies by exposure timeframe (e.g., 

short-term versus long-term exposure for respiratory mortality) as opposed to clustering by health 

outcome. This structure needs to be revisited to divide the birth outcomes literature by exposure 

timeframe to be consistent with the remainder of the ISA. There are some studies (e.g., 90-day 

exposures) that are included in both the short-term and long-term exposure chapters. The beginning 

text of each chapter should define the duration term.

Co-Pollutants

There should be more discussion and presentation of results on confounders, particularly PM. This 

could be a table that presented side by side the effects of PM alone, ozone alone, and their separate 

effects when they are both in the model. 

Wording choices and presentation

In addition to the exposure timeframe issues mentioned above, there are several wording choices that 

could lead to misinterpretation. One example is the use of “seasonal” in Section 7.2, which would be 

better defined as exposure over a few months, without using the word “season.” There have been 

many “seasonal” studies of short-term exposure to ozone. A second example of a poor wording 

choice is the sentence that “A 10-ppb increment in exposure to O3 elevated the risk of death from 

respiratory causes and this effect was robust to the inclusion of PM2.5” (page 7-20, with similar 

sentences elsewhere in Chapter 7). There is nothing particular about the increment of 10 ppb. This 

needs to be reworded to note that higher levels of ozone were associated with higher risk, or to add 

the numerical central estimate so that the 10-ppb increment is meaningful. Another example is the 

vague use of “relevant” exposure. A careful read and rewrite of this chapter is needed. 

Additional issues

• A short discussion of why current findings differ from those in the previous review would be 

useful. Are prior results fully consistent with current results, given the differences in study 

methods, precision, etc.

• Asthma is a lethal disease, and death from asthma is sufficiently uncommon that it might not 

show up in studies of total respiratory mortality. If the relative risk is high, a relation to O3

might be evident in a mortality analysis focused on asthma. Whether this type of work has 

been done could be mentioned in the text. 

• Many animal toxicology studies were omitted and some are misrepresented. For example, 

page 7-54 summarizes the NTP O3 cancer study in mice and rats. Although the overall 

summary for mice is correct, the details provided are not. 

• Many of the missing references were included in previous criteria documents and could be 

easily incorporated.

• One way to include detailed information on a large number of studies would be to add tables. 

9. Chapter 8 is a discussion of potential susceptibility factors. Are the characteristics included within 

the broad susceptibility categories appropriate and consistent with the definitions used? 

Epidemiological, clinical, and animal toxicology studies have made clear that many intrinsic and 

extrinsic factors contribute to inter-individual variation in the multiple phenotypes of ozone 

responsiveness. In fact, the NAAQS are intended to protect susceptible individuals. Thus, defining 
12

the term susceptible and then addressing the elements in a consistent manner is crucial. The chapter 

defines the term very broadly to include a very diverse set of factors, including genetics and the 

extent of exposure. A similarly broad definition was used in the ISA for Particulate Matter, after 

substantial discussion of the overlapping concepts of susceptibility and vulnerability.

There was substantial discussion by the CASAC Panel as to whether the definition of susceptibility 

put forward was appropriate and useful. For example, tolerance distributions are founded on the 

recognition of innate biological differences that make some individuals respond at a given dose 

while other persons do not. And, as the dose is increased the tolerance distribution becomes 

narrower. Others argued that susceptibility and vulnerability have very different meanings: 

susceptibility factors refer to innate characteristics of the individual that contribute to the response to 

ozone (or other pollutants) while vulnerability refers to factors that influence individual responses 

that are acquired such as living near highways, nutritional status, pre- or co-exposure to ozone and/or 

other pollutants, and socioeconomic status (SES). For ozone (and other pollutants), dose is increased 

at a particular concentration by physical activity, whether associated with outdoor work or exercise, 

be it outdoors or indoors. 

The Panel discussed the issue of susceptibility, giving consideration to the following situations in 

regard to how people could experience increased risk for adverse effects of ozone at a given 

concentration:

1. Intrinsically increased susceptibility: this group of individuals has some individual 

characteristic(s) that increases risk for an effect through a biological mechanism. Examples in 

this category include the presence of underlying disease, young or old age, and genetics. 

Notably, this category is growing as the population ages and non-communicable diseases 

become more common. In general, individuals in these categories would have a steeper 

concentration-risk relationship, compared to those not in the category. There is a range of 

susceptibility for individuals within a category and across categories. 

2. Increased dose at a given exposure concentration: this group of individuals has a greater dose 

of delivered pollutant, given exposure, because of breathing pattern. This category would include 

persons who work outdoors or exercise outdoors. Additionally, by holding an outdoor job, some 

people would have greater exposure (concentration x time), regardless of the delivered dose to 

the respiratory tract. This category is particularly relevant to ozone.

3. Increased risk for an adverse outcome: socioeconomic factors have been cited as one 

determinant of susceptibility. One proposed mechanism is access to and quality of health care. 

For some individuals, e.g., having lower SES, there may be a greater risk for an adverse 

outcome; for example, there may be less favorable medical care to provide treatment for an 

asthma attack or a cardiac event triggered by air pollution. 

These three categories do not include those individuals who might be placed at risk for 

experiencing a greater exposure by being exposed at a higher concentration. For example, 

individuals in lower SES groups might be exposed to higher ozone concentrations due to less 

availability/use of home air conditioners (i.e., more open windows on high ozone days). 

We urge further consideration and refinement of the concept of susceptibility and its application to 

ozone, as the ISA is revised. The very general definition now included in the ISA may prove too 

broad to be useful, particularly in setting the stage for the Risk and Exposure Assessment (REA) and 

the Policy Assessment. Its linkage to the intent of the Clean Air Act with regard to protection of 
13

susceptible subgroups should also be considered. 

Chapter 8 covers what are considered to be the most important known categories of factors that may 

contribute to enhanced susceptibility to ozone-induced adverse outcomes. The 13 major categories 

for discussion included pre-existing disease/conditions (8.1), lifestage (8.2), sex (8.3), genetics (8.4), 

diet (8.5), body mass index (8.6), socioeconomic status (8.7), air conditioning use (8.8), involvement 

in outdoor activities (8.9), race/ethnicity (8.10), physical conditioning (8.11), smoking (8.12), and 

hyperthyroidism (8.13). A framework should be developed for classifying these various categories. 

This chapter does not (and should not) repeat all the studies on susceptible populations contained in 

earlier chapters. However, the rationale for those papers chosen for expanded discussion here is not 

clear. A more concerted effort is needed to identify the definitive papers for each susceptibility class 

and then proceed to describe them, with a very brief cross walk to the larger body of information 

within the other chapters (hopefully contained within tables in the revised ISA).

Are there any key susceptibility factors that were not included and need to be added?

Exposure and dose are included in the definition of susceptibility, but are inadequately treated in the 

text. Exercise is only indirectly and too briefly treated in the sections on children and on outdoor 

activities. At ambient exposure levels, exercise is the single most important driver of the amount of 

ozone inhaled and the delivered dose and hence of the likelihood of causing effects in individuals of 

any age or disease condition. As such, more discussion of the role of exercise and exercise levels 

should be included in Chapter 8.

The Genetics section was well-written, and adequately considers recent genetic association studies in 

human epidemiological and chamber investigations. It should be noted that, due to small sample 

sizes, many of the chamber studies are limited to testing only those potential candidate genes that 

have very high minor allele frequencies in order to obtain appropriate statistical power. Other genes 

with potential impact on ozone-induced outcomes may be important, such as those identified in 

some of the mouse models, but power considerations have limited testing these genes in human 

populations.

It was a bit surprising that the discussion of toxicological studies did not include more thorough 

consideration of potentially important genes other than those mentioned (e.g., Tnf, Nqo1). Recent 

investigations in animal models have implicated additional candidate genes for future investigations 

in human populations, including, for example, 1l10, Mmp9, Il6, Tlr2, Marco, Hsp1a, H2-Aa, Ab1, 

Eb1, Eb2, Ea (histocompatibility genes), Lta, Nos2, and TLR4 and TNF signaling genes such as 

Myd88. A table should be created that identifies these and other genes that have been implicated to 

be important in the pathogenesis (or protection against) ozone-induced lung inflammation and 

injury.

The inclusion of diet as a susceptibility factor was timely and important. Given that this factor was 

not considered in the previous Air Quality Criteria Documents, the authors should have the 

flexibility to cite older papers to give appropriate context. In addition to vitamins C and E, vitamin A 

deficiency has also been shown to have important consequences on ozone-induced inflammation 

(e.g. Paquette, et. al. 1996. Vitamin A deficiency enhances ozone-induced lung injury. Am J Physiol. 

270:L475-82). Caloric restriction (protein deficiency) was briefly mentioned, but this area could be 

better developed by including additional studies such as Kari et. al. (1997. Dietary restriction 
14

mitigates ozone-induced lung inflammation in rats: a role for endogenous antioxidants. Am J Respir 

Cell Mol Biol .17:740-747). 

In general, the chapter would be stronger if evidence from animal toxicology studies were included 

that provides support for the susceptibility characteristic under discussion. A good example is 

Section 8.1.1 Influenza/Infections. The section is only a short paragraph about findings in 

epidemiology studies. However, there are a number of animal studies showing the ability of ozone to 

increase the incidence and/or mortality from respiratory infections, even to exposures as low as 0.08 

ppm O3. Inclusion of such material would strengthen the case for O3 being able to cause similar 

effects in humans.

The chapter summary identifies older age groups as being one of the most susceptible populations to 

O3 exposure. However, the studies discussed in Section 8.2.2 (Older Adults) do not give the reader 

this impression. For each type of effect discussed, both positive and negative studies are typically 

available. This section also provides an example of how the results from clinical and animal studies 

can provide biological plausibility for some endpoints (page 8 – 1, line 33). The evidence may be 

stronger for some endpoints than for others, and this should be the bottom line carried forward to the 

chapter summary.

10. Chapter 9 describes effects of O3 on vegetation and ecosystems. Are the major effects of O3 exposure 

on vegetation and ecosystems identified and characterized? To what extent do the discussions and 

integration of evidence across scales (e.g., species, communities and ecosystems) correctly represent 

and clearly communicate the state of the science? Has the ISA adequately characterized the 

available information on the relationship between O3 exposure and effects on individual plants and 

ecosystems? Are there subject areas that should be added, expanded upon, shortened or removed? 

Are major effects of O3 exposure on vegetation/ecosystems identified and characterized? 

The ISA does a nice job of recognizing the key effects and pathways by which ozone impacts 

vegetation at all scales. There is little additional, relevant literature since the last assessment, 

however, and there has been very little research on the effects of ozone on ecosystems (e.g., 

watersheds). 

New evidence obtained in chamberless exposure systems, including various Free-Air Carbon 

Dioxide Enrichment (FACE) experiments, supports the broad range of conclusions derived from 

earlier Open Top Chamber (OTC) experiments. For clarity, the discussion of this alignment of 

FACE and OTC data could be consolidated. 

The alteration of complex physiological systems, including gene expression, is too often equated 

with direct effects on vegetation, and differences in sensitivity with mechanisms of resistance. 

Responses may be more appropriately interpreted as symptoms of overall sensitivity, reflecting a 

lack of upstream defense. 
15

To what extent do the discussions and integration of evidence across scales (e.g., species, 

communities and ecosystems) correctly represent and clearly communicate the state of the science? 

The chapter does a reasonably thorough job of integrating effects across spatial scales, given the 

limited literature about ozone impacts on ecosystems or landscapes. However, the authors may want 

to consolidate the discussion into fewer, but more vertically integrated, sections, with less repetition 

among them.

It is clear that stomata provide the principal pathway for ozone to enter and impact plants and to 

influence water dynamics at plant and potentially ecosystem scales. There are better references for 

this than cited in the text. The stomatal and gas exchange discussions could be consolidated with the 

discussion of gas exchange, water use efficiency, stomatal control and impacts on water cycling and 

watershed-scale effects. The McLaughlin et al. watershed data (McLaughlin, SB, et. al., 2007. 

Interactive effects of ozone and climate on tree growth and water use in a southern Appalachian 

forest in the USA. New Phytol. 174(1):109-24) and Gregg et al. (Gregg, JW. et. al., 2003. 

Urbanization effects on tree growth in the vicinity of New York City. Nature. 424, 183-187) studies

support arguments about loss of stomatal control however, these observations contrast directly with 

more frequently observed stomatal closure caused by ozone. Further discussion of these 

discrepancies is required.

Arguments regarding measurement height are confused with arguments regarding the ozone 

concentration to which stomata are exposed, and further with uncoupling of stomatal conductance 

and high ozone periods. These are fundamentally different issues that should be separated in the text.

The definition of ecosystem should be strengthened to indicate that ecosystems have boundaries 

(defined by the investigator/study), and that physical exchange and the biotic and abiotic interactions 

are important defining parts of the ecosystem concept.

Has the ISA adequately characterized the available information on the relationship between O3

exposure and effects on individual plants and ecosystems? 

The comparison of exposure-response relationships from the National Crop Loss Assessment 

Network (NCLAN) and National Health and Environmental Research Laboratory of EPA

(NHEERL) studies with recent Soybean--Free Air Carbon Dioxide/Ozone Enrichment (SoyFACE) 

and Aspen Free-Air Carbon Dioxide Enrichment Experiment (Aspen FACE) results is particularly 

useful. It clearly confirms that the approaches are complementary and provide similar results. 

Similarly, the meta-analyses that have been performed since 2006 are quite important to this ISA and 

useful for showing the new evidence. 

The ISA appropriately concludes that ozone is perceived in many ways by plants and cells. Ozone 

and its reaction products interact with reactive oxygen species (ROS) metabolism at several potential 

places. However, it is inaccurate to state that ozone is sensed by specific apoplastic receptor proteins. 

In Chapter 1, much is made of the concept of adverse responses. Yet, the ISA often cites alterations 

without stating in what direction or whether they appear to be adverse. 
16

Are there subject areas that should be added, expanded upon, shortened or removed?

While it is clear that calcium ion (Ca++ ) and mitogen activated protein kinase (MAPKs) and many 

other signaling components are involved in ozone responses, the entire signaling framework remains 

poorly characterized and need not be described in this chapter. 

The coverage of effects on insect and mammal herbivores due to changes in vegetation is rather 

brief. There is inadequate consideration of the interaction between N deposition and ozone response. 

There is no consideration in the ISA of the responses of nonvascular plants (e.g., mosses), lichens or 

lower vascular plants to ozone. Mosses may be of particular significance globally. 

A more critical discussion and interpretation of model approaches and results is needed. The draft 

ISA lists main conclusions from each of a number of studies. However, the models discussed are 

very different in scope and complexity. A critical discussion of their strengths and weaknesses is 

required, perhaps along the lines of that in the previous AQCD.

The consideration of ozone impacts on stomatal conductance and its ramifications at various scales 

could be condensed and consolidated, both for brevity and clarity. A more critical discussion of the 

differences in effects of ozone on transpiration from different models and from different experiments 

is warranted, perhaps focused on likely effects at the watershed scale, addressing the discrepancies.

11. Chapter 10 provides a concise overview of key information regarding O3 effects on climate and UVB exposure. Is there any information regarding the climatic effects of domestically produced O3 on 

climate in the U.S. that should have been included? Is there important new information on UV-B 

effects or other welfare effects such as materials damage that have been overlooked and should be 

incorporated into this chapter?

What are the views of the Panel on the scientific soundness and usefulness of the discussion in 

Chapter 10 on the role of O3 in global climate change and changes in mean global temperatures? 

This chapter is definitely useful in view of recent interest in chemistry-climate interactions and in 

combining air quality and climate goals for environmental policy. The discussion was strong on 

climate forcing due to O3 relative to that of CO2 and CH4, as well as the way it distinguished 

between long-term and short-term greenhouse gases. However, more play should be given to CH4 as 

the only O3 precursor for which control would directly reduce climate forcing as well as 

emphasizing that O3 itself can affect CH4 concentrations (feedbacks). It should also give more play 

to the recent Representative Concentration Pathways (RCP) scenarios of the upcoming IPCC Fifth 

Assessment Report (AR5), since these scenarios will provide the core of future assessments of 

climate forcing for emissions relevant to air quality and they present a very different picture from the 

older Special Report on Emissions Scenarios (SRES) scenarios. In conclusion, the chapter is correct 

in concluding that there is likely to be a causal relationship between tropospheric O3 and climate 

change.

Additionally, there may be important effects of O3 at the regional or continental scale in addition to 

the global scale, as discussed on pg 10-12. Could such regional impacts be additional to the range of 
17

impacts on radiative forcing cited from IPCC? If so, this topic warrants further discussion. There 

could also be effects of climate change on circulation, and thus on mixing of stratospheric O3 into 

the troposphere.

Feedback effects involving vegetation are also important and emphasis on individual species 

responses may be necessary to determine the effects of climate change on ecosystems. For instance, 

individual species may be affected in different ways, reflecting differential responses to climate 

change by these species, including species replacements, even though total ecosystem productivity 

may not be as severely impacted. Thus, measuring or reporting only total ecosystem responses, 

without regard to individual species responses, could underestimate impacts.

There is uncertainty in estimating pre-industrial O3 values. This has implications for modelers, and 

more emphasis should be placed on determining if those overestimates are due to inadequate 

parameterization, or missing chemistry. 

This chapter also pointed out the paucity of studies relating to how increasing tropospheric O3 will 

affect UV-B impacts and consequently most conclusions regarding these effects are tentative. In 

conclusion, we agree with the ISA that there is likely to be a causal relationship between 

tropospheric O3 and climate change brought about through radiative forcing. We also agree with the 

ISA conclusions that tropospheric O3 impacts on human health through climate change cannot yet be 

critically assessed within reasonable uncertainty. With regard to welfare effects, the lack of 

published studies assessing UV-B impacts caused by variations in the column of tropospheric O3

reflects challenges in this area, and in fact, no conclusions can be drawn about these effects at this 

time.

Is there any information regarding the climatic effects of domestically produced O3 on climate in the 

U.S. that should have been included? 

The discussion of climate forcing due to tropospheric O3 was relatively thorough, and except for 

vegetation feedbacks (see above) was comprehensive in its scope and analysis. 

Is there important new information on UV-B effects or other welfare effects such as materials 

damage that have been overlooked and should be incorporated into this chapter?

This chapter thoroughly reviewed the literature on health and welfare effects, and there did not 

appear to be any significant literature that was overlooked or omitted. 
1

Preliminary Individual Comments on the Ozone ISA (March 2011)

Table of Contents

Mr. George Allen...................................................................................................................................2

Mr. Ed Avol...........................................................................................................................................6

Dr. John Bailar.....................................................................................................................................11

Dr. Michelle Bell.................................................................................................................................16

Dr. Joseph Brain ..................................................................................................................................20

Dr. David Chock..................................................................................................................................22

Dr. W. Michael Foster.........................................................................................................................25

Dr. Christopher Frey............................................................................................................................28

Dr. Judy Graham .................................................................................................................................31

Dr. David Grantz .................................................................................................................................52

Dr. Jack Harkema ................................................................................................................................58

Dr. Daniel Jacob ..................................................................................................................................59

Dr. Steven Kleeberger.........................................................................................................................63

Dr. Fred J. Miller.................................................................................................................................65

Dr. Howard S. Neufeld........................................................................................................................72

Dr. Ted Russell....................................................................................................................................80

Dr. Helen Suh ......................................................................................................................................83

Dr. James Ultman ................................................................................................................................85

Dr. Sverre Vedal..................................................................................................................................89

Dr. Kathleen Weathers........................................................................................................................91

Dr. Peter B. Woodbury........................................................................................................................93
2

Mr. George Allen

These comments focus on Chapter 3, specifically section 3.4 (PRB O3) and 3.5 (Monitoring).

Sections 3.2 and 3.3 are well written.

3.4.2: The discussion of PRB ozone is a critical part of the ISA. EPA should include data from 

additional PRB relevant long-term data that are not in AQS. The UNH AIRMAP Mt. Washington (NH) 

summit data are a very rich and unique resource that may be useful in validation of GEOS-Chem. The 

summit of Mt. Washington is at 6300' and about 4500 feet above surrounding terrain. Thus, although the 

elevation is not high relative to western high elevation sites, it is a very good high-elevation site for the

NE – no NE high elevation sites were included in this analysis. These data could be parsed by transport 

regimes to get a better indicator of PRB O3 bounds. These data show a spring peak, but no trend in 

means over a decade (Figures 1 and 2). Two distinct spring intrusion events occur (Figures 3 and 4); 

ground level ozone could be analyzed around the period of these events. Other long-term NE/Eastern US 

rural sites worth consideration that are in AQS: Whiteface Mt. NY (summit 36-031-0002, and base 36-

031-0003, year round), and Shenandoah NP VA.

There needs to be a more quantitative analysis of the contribution of stratospheric O3 to ground level 

O3; this is only noted in passing with a reference to Thompson 2007. That study may over-estimate this 

contribution in part because 2004 was an unusual O3 season for the NE US due to a cool and rainy 

summer, and thus the reported % ozone at ground level from stratospheric ozone would be higher.

The spatial scale for urban area health effect studies is of concern; Boston has only one O3 monitor that 

represents the entire core urban area. Although well correlated, an offset of 9 ppb exists between that 

monitor and one downwind 12 miles.

3.4.2.1, pg 3-31. Woodsmoke in the eastern US and Canada has significant elemental mercury 

concentrations, which is a potent interference for UV ozone analyzers. Assessment of ozone due to 

wildfires needs to take this into account.

3.4.3

Pg 3-31, lines 20-24: Consider using CO as relatively conserved tracer of urban air masses.

Pg 3-31, lines 34-37, pg 3-31 lines 1-4: As noted above, there is a 10-year research grade O3 record at 

the summit of Mt. Washington, NH from the AIRMAP study that should be included in this assessment: 

http://airmap.unh.edu . Data are publically available: http://airmap.unh.edu/DownloadData

Daily plots of all available parameters: http://soot.sr.unh.edu/airmap/archive/

Daniel Jacob’s group at Harvard may be able to run GEOS-Chem to assess its performance for the Mt. 

Washington site - a site that has a very large spatial scale, and thus does not need a small grid size to 

properly model.

Pg 3-33, line 24, and 3-38 and 3-39 tables: Include MtWash as eastern elevated site for this analysis. 

There are 8-10 years of research grade O3 and relevant indicator data (CO, NOy, particle # 

concentration, etc.) that would be very valuable for this purpose.

3.5.2: plots are hard to use - plot 95 %tiles?
3

3.5.3, page 3-46, table 3-4 Agree that O3 specifications and FRM are seriously outdated.

3.5.5.2: I endorse the concept of changing the FRM for O3 to the NO chemilumenescent method.

3.5.6.1 pg 3-52, line 23: NH3 and HNO3 are not measured at NCore sites. SO2 is.

3.5.6.1 pg 3-52, line 30: PAMS sites measure NOy, not NOx (“NO-what”). Actually, they measure 

NOw, since these historical measurements are not robust NOy measurements.

3.6.2.1 pg 3-71, figure 3-25 and related discussion throughout this section: It should be noted that for 

the Boston CSA ozone sites, Blue Hill, the site 10 miles south of Boston (AQS ID 25-021-3003, “East 

Milton”), is quasi-high elevation relative to surrounding terrain, at 630 ft.

http://www.hazecam.net/bluehill.html

and often reads higher than most other Metro Boston O3 sites. This site is not run year-round. Lynn (25-

009-2006), 12 miles NE of downtown Boston, is run year round.

Also - the Boston C.S.A. is very large, including parts of RI and NH; it’s unclear if this is an appropriate 

spatial scale to assess.

Pg. 3-85, line 11: Which sites are A and D for Boston?

3.6.3.2, pg 3-96, fig. 3-43: add similar plots with weekend and weekdays separated out. Are Mondays 

cleaner than Fridays?

General comment:

The Canadian Government recently completed a large report titled:

“Canadian Smog Science Assessment (2011). Source: Environment Canada and Health Canada.”

The report is not yet public but is expected to be available upon request by the end of 2011 to:

Rosa.Wu@ec.gc.ca

There are two chapters that are relevant to the PRB discussion:

CHAPTER 3: Ambient Measurements and observations 

and

CHAPTER 7: Air Quality at the Regional and Local Scale: The What, Where, Why and How of 

Concentration Variations 
4

Figure 1.

Figure 2.
5

Figure 3.

Figure 4.
6

Mr. Ed Avol

General Overview:

The breadth, weight, and size of the first external draft ISA O3 document is testimony to the wealth of 

information available regarding ambient ozone, its atmospheric formation, and the potential for human 

and material exposure and detrimental effects. To be sure, this large document represents a substantial 

summarization of a much larger body of published information. That said, in my opinion, the document, 

is too large, still missing at least two key chapters, and has a third key chapter mis-identified. 

1) The document needs a Summary/Conclusions section, to provide some determination of what 

key points have been presented. 

2) The document is missing a chapter identifying critical gaps/scientific needs. Is there sufficient 

information to address critical topic areas, or are there key gaps in understanding or research that 

need to be addressed? Specific guidance regarding perceived critical gaps could help improve 

the utility and quality of subsequent reviews, by motivating researchers to consider/address 

identified needs. 

3) Chapter to chapter, the document is written in differing detail, layout, and approach. This is not 

surprising, given the broad range of the overall topic and the fact that different authors composed 

different chapters, but there should still be some harmonization of the approach and layout. 

Chapter 5, for example, reviews the current state of understanding in “Dosimetry and Mode of 

Action” by what had been reported up to the 2006 Review, what “recent publications” (post2006) have shown, with periodic summaries of what each section presents, with an overall 

chapter summary (p5-61), and a “gaps in knowledge” section (5-62) – could/should this serve as 

a useful template for each chapter to review what was known as of the last review cycle, what is 

new, what we know think we know, and what we still need to find out?

The section on Adversity (Sec1.6.6, p1-24) raises an important issue in assessment and interpretation. 

With improved analytical capabilities, it is possible to detect much smaller and a wider array of 

biological endpoints...but are they clinically significant, important, or “adverse”? Some perspective on 

what constitutes adversity would seem useful.

Chapter 2, currently entitled” Integrated Health and Welfare Effects Overview” seems out of place and 

not well defined. It currently brings together many different elements of our current understanding of 

ozone, from the chemistry to the animal and human health effects to welfare effects. If it is essentially an 

“Executive Summary” of the document, it should be shorter and placed in the front of the document. If it 

is an integration of the document’s chapters, it should be near the end of the document. Some decision 

needs to be made regarding its purpose, and appropriate modifications to it should be accordingly made.

Chapter 1 (Introduction)

There are sections of the document that could be reduced in size, without loss of document integrity. 

In Chapter 1 for example, the discussion on Causal Determination (beginning on P1-12, Section 1.6 in 

general, p1-14, Section 1.63 in particular) is useful but overly detailed, and could be summarized or 

substantively moved to an appendix attachment. The Summary paragraph (p1-25, Section 1.7) lacks 

much substance – what specific conclusions can be drawn from the information presented? There 

arguably could and should be concise statements based on what was presented that represent essential 

elements to be carried forward.
7

Chapter 2 (Overview)

In Chapter 2, the discussion about Policy Relevant Background (PRB) concentrations (p2-5, Section 

2.1.3 and especially p 2-7, Section 2.1.3.4) provides some useful information but meanders around the 

topic at hand. After laying the groundwork for how this is determined and what affects it, what is the 

best current estimate of the PRB? Has it increased or decreased since the last review? If so, why might 

this have occurred? These questions are addressed later in Chapter 3 (p3-25, Section 3.4), but why 

doesn’t the summary chapter present (just) summary information?

(Specific Comment: The section on Exposure Measurement in Chapter 2 (p2-12, Section 2.2.1.1) is 

misleading, in that it describes one passive sampler (a chemically-coated diffusion filter sampler based 

on nitrite-to-nitrate oxidation) and describes this as if it were the ONLY passive sampler technology 

available. While the commercial sampler described (but not identified by manufacturer) may well be 

widely used, it likely is not the only passive sampler in use).

Chapter 3 (Atmospheric Chemistry)

The Chapter 3 discussion on Policy Relevant Background and estimating PRB (p3-25, Section 3.4) is 

interesting but perhaps too extensive for this focused summary. Could this be more effectively 

summarized and defer some of these details to an appendix? (This is admittedly more of a packaging 

and presentation issue than a factual or substantive one, but the important points can get lost in pages 

and pages of discussion, citation, and discourse). In a similar manner, the Chapter 3 section on Air 

Monitoring (p3-40, Section 3.5) contains a great deal of instrumentation performance/specification data 

(for example,p3-44, Sections 3.5.2.1 and p3-46, Section 3.5.3) that would seem more appropriate in an 

appendix. With respect to p 3- 48, Section 3.5.5.2, it seems inappropriate to specifically review a 

specific manufacturer’s instrument in this ISA. Wouldn’t a better approach be to discuss the class of 

instruments or measurement technique?

The Chapter 3 air monitoring section boxplots and figure representations of O3 concentrations are 

interesting, informative, and helpful. The figures on pp3-98 and 3-99, in Section3.6.4 (Associations 

with Co-Pollutants) is especially insightful...but once again, at the end of the chapter, there is no 

summary , no conclusions, no drawing together of key issues or identification of critical gaps.

(Specific Comment: P3-4, Section 3.2, lines 9-16 discuss nocturnal low-level jets (LLJs), but to the 

casual reader, this could be misconstrued to be aircraft rather than wind flow; a few more words of 

clarification would help avoid confusion).

Chapter 4 (Charge Question 5) (Exposure)

(A better summary is needed): The presented chapter is informative and well-referenced, but major subsections lack any focused summary, and the collective chapter lacks a concise set of conclusions. 

Section 4.6 (p4-21 to p4-25), which is entitled “Summary and Conclusions”, is itself almost four pages 

in length. Rather than rehashing what was previously presented, key perspectives should be brought 

forward into a short listing of objective findings.

For example, the one-and-one-half pages “summarizing” Exposure Measurement (Section 4.6.1, p4-21) 

could be arguably collapsed into six statements:

(1) passive badges are widely in use and provide ppb detection levels, when appropriately used; 

(2) Small active samplers, either based on chemical oxidation or uv detection, are also available;
8

(3) indoor/outdoor ratios are driven by air exchange rates (due to a general lack of indoor sources of 

ozone) and are generally in the 0.1-0.4 range; 

(4) personal exposure and ambient ozone concentrations are moderately well-correlated (0.3-0.8) 

and are related to activity patterns, housing characteristics, and season; 

(5) central-site monitor concentrations are representative of day-to-day changes in average personal 

exposure; 

(6) central site concentrations tend to over-report personal exposures, due to time spent indoors (and 

low indoor penetration of ozone).

In a similar way, Section 4.6.2 (p4-23, Exposure Modeling) might be summarized by presenting a short 

table, listing the various models (or model types) presented (stochastic, land-use regression, spatial, or 

APEX, SHEDS, etc) with a summary of application, strengths, and weaknesses. 

(POPULATION PROXIMITY TO OZONE MONITORS & SPATIOTEMPORAL VARIABILITY): 

There is often a systematic difference in the nature of urban vs rural ozone exposures, due to local NO 

titration of ozone in urban areas. Ozone tends to be “peakier” in urban areas, and more broad and drawn 

out, in terms of sustained ambient levels, in more rural areas. This has exposure and dose implications 

for urban and rural populations. These issues are not captured in the current document, and are not likely 

to be, if the focus is only on the urban exposure.

(INTRA COMMUNITY VARIABILITY OF OZONE CONCENTRATIONS): The research and 

regulatory communities have generally considered ozone to be a regional pollutant, with minimal local 

variability, but our group’s studies (and many others) have repeatedly encountered the diminution of 

ozone levels caused by NO titration near busy roads and fresh combustion sources... could a finer 

spatially-resolved sampling approach identify biologically meaningful differences in ambient ozone 

levels, or is it purely an academic or engineering exercise in measurement performance? 

The section/chapter summaries should be developed with a clear focus on how the information provided 

or developed would be applied in interpreting epidemiologic studies. How does the presented work 

improve our knowledge, or application of it? How would information, perhaps currently identified as 

being “unavailable”, materially move the science and understanding of that science forward?

Chapter 5 (Dosimetry)

This chapter has a great deal of information, organized in a somewhat different way from most of the 

other chapters, but perhaps in an ultimately more useful one. Whatever the organizational approach, 

there should be some consistency across chapters.

Chapter 6 (Short-Term Effects)

This chapter, which reviews the available information on short-term effects of ozone exposure, covers a 

very large data base. Yet a different organizational approach has been used in this presentation, 

organizing by successive sub-topics first (be it respiratory, cardiovascular, etc, health outcome) and then 

integrating historical and recent information.

On p6-167, a section appears entitled “Adaptation”, referring to the blunted responses in some 

individuals from repeated exposures to ozone. This re-opens a discussion that simmered over 20 years 

ago – is “adaptation” the correct description of the observation? Many at the time felt it was not, and a 

better term was attenuation, toleration, or blunted response, since adaptation implied some positive 

coping change, which this did not appear to be...since by the following ozone season, the blunted 
9

responses had usually disappeared but could be re-developed with repeated exposure (in some 

individuals). Therefore, the statement on line 1 of p6-167 is not strictly accurate, since controlled 

exposures arguably did not demonstrate an adaptive response for respiratory effects, but rather, a 

development of temporary toleration or blunted response.

One especially interesting and potentially valuable section in this chapter is on Confounding (p6-144, 

Section 6.6.2.1). This is one of the few places where multi-pollutant exposures are considered, albeit as 

a “confounder”. Should more be said about multi-pollutant exposures? How is this issue being 

approached?

Chapter 7 (Long-Term Effects)

Long-term exposure effects are addressed in this chapter by evaluating the evidence for a wide-ranging 

list of health outcomes. In this chapter, grouping is by systems – respiratory, cardiovascular, etc. with 

mortality and morbidity as sub-sections. Could similar chapter organization be used for both short and 

long-term effects (Chapters 6 and 7)? Many of the same endpoints are reviewed...

A final conclusions section, summarizing what has been determined through the course of the chapter 

(e.g., suggestive causal for all cause mortality, inadequate for cancer, suggestive causal for CNS, 

suggestive causal for reproductive, etc) would have been helpful.

Chapter 8 (Susceptible Subpopulations)

This is an important chapter, addressing who among us are at greater risk to the effects of ambient 

ozone. Based on previous work with other NAAQS, there ought to be an almost-standardized list of 

characteristics or sub-groups who might be at increased risk, with some possible additions or deletions 

due to some specific attribute of the chemical being considered. The document would profit from the 

inclusion of a summary susceptibility factors table, such as Table 8-2 of the PM ISA (see below), to 

focus the reader on what is known or surmised.
10

The definition of “susceptibility” still seems in evolution...It has been broadly defined here as 

essentially anything that increases the risk of O3-related health effects or anything that modifies O3 

exposure...which seems too broad to me. Beyond the “innate biologicals” (disease status, age, genetics, 

etc), only SES comes to mind as a factor eligible for consideration under susceptibility (since SES is a 

marker for access to health care and a host of other health issues).

How does “Air Conditioning Use” (p8-20, Section 8.8) come to be considered as a susceptibility factor, 

similar to genetics or age or sex or disease status? Notwithstanding the discussion about AC use as an 

indicator of SES or regional temperature, it seems somehow inappropriately placed here. Would 

“proximity to on-road traffic” be considered a susceptibility factor (since higher proximity would likely 

imply a reduction in O3 exposure)? Susceptibility seems to me to be more about involuntary or innate 

biological attributes, rather than operational circumstances that can be readily changed by human 

behavior to reduce or increase exposure. 

In a similar manner, inclusion of “Involvement in Outdoor Activities” (p 8-20, Section 8.9) as a factor 

per se seems incorrect. It seems like the “active agent” is the increased exposure or dose associated with 

being outdoors rather than the act of participating in outdoor activities.

If this is the relevant definition of “susceptibility”, why not add other exposure-modifying factors, such 

as (1) scarves, masks, or personal protective equipment, (2) time spent indoors, (3) percentage of time 

spent oral or nasal breathing, (4) physical location (i.e., proximity to combustion emissions), (5) use of 

personal hygiene products (which may chemically react with O3, affecting one’s “personal cloud”)...? 

The possibilities are seemingly endless...and untenable. I suggest the definition of susceptibility be 

revisited and limited to innately biological or involuntary phenomena (e.g., disease status, age, genetics, 

SES).

Chapter 9 (Environmental Effects on Vegetation and Ecosystems)

(Note that this is well out of my area of expertise, so I comment as a naïve reader)

This chapter begins well, with a summary table (p9-5, Table 9.1) to help guide the reader as to current 

understanding, and (presumably) the chapter content. The section presentations initially seem to follow 

the Table 9.1 tabular summary, focusing on the causal evidence for effects, but then the chapter diverges 

into “Experimental Exposure Methodologies”, before returning to the main topic. Some rationale needs 

to be provided to justify why the discussion of experimental methodologies is even included here.

Chapter 10, Climate Change

(very interesting, relevant, and seemingly focused chapter; no specific comments).
11

Dr. John Bailar

Comments on Charge Questions 2, 7, and 8: Integrated Science Assessment for Ozone and Related 

Photochemical Oxidants

The time available for the review of this assessment has not been sufficient for me to examine any of the 

literature cited. Thus I have taken the descriptions of individual studies and their findings as correct.

Charge Question 2.

The framework for causal determination and judging the overall weight of evidence is presented in 

Chapter 1. Is this framework appropriately applied for this O3 ISA? How might the application of the 

framework be improved for O3 effects?

Section 1.6.1 It is important that this document give the time point at which new input was suspended, 

and that it say what was done, if anything, regarding potentially important information received after 

that time. “Nothing” would be an acceptable answer, but it should be here.

1.6.2 “Cause” is still not well defined. but should be defined in terms of the whole body of evidence, 

not in terms of individual reports. (My own definition is that an agent is a cause if the effect appears 

when the agent is present in some setting, and does not occur when the agent is absent, all other things 

being equal, but there is no reason for you to adopt this if some other definition works better in this ISA 

context. This requires only a little modification in more complex situations such as synergy. My point is 

that I do not see a definition here that I could apply in an unambiguous fashion.)

1.6.4 You give a nod to the S-G report on page 1-20, but I think that is not sufficient. It was published 

some months before the Hill paper, and in my view deserves the credit. More important, perhaps, is that 

“consistency” may well not be one of the most important criteria – that depends on the context of other 

information. What is really critical is the whole body of evidence, not any one criterion in isolation. You 

seem to misinterpret specificity. I have understood Hill’s “specificity” to be non-restrictive -- to refer to 

a single effect (or a group of closely related effects rather than a collection of effects that are not likely to 

have a common cause), but not to require only a single cause, which would be extremely restrictive. Or 

have I misunderstood you? You may want to look at Hill’s original paper on this, as well as the S-G 

report. We may also not agree about lines 14/15 on page 20. For me, a failure to satisfy one or more 

criteria can be as telling as meeting them. Again, the whole body of evidence is what matters.

1.6.5, table re “not likely”. It is a truism that one cannot prove a negative with empirical data. I would 

cast “not likely” in terms of probability and a specific effect size – e.g., “It is very unlikely that X causes 

more than a 10% increase in Y.”

1.5.4.1 “Conditions” may include more than dose or exposure, duration, and pattern. One example is 

simultaneous exposure to a synergistic agent.

A comment in this chapter that experimental evidence may be the strongest once more brings me to 

comment on the need to interpret the whole body of evidence. Experimental evidence may not be 

supreme.
12

It might be worth noting that, for the criteria as a whole, some refer to individual studies, some to 

collections of studies, and some to the entire body of evidence. I see this comprehensiveness as a 

strength.

Charge Question 7.

Chapter 6 is intended to support the evaluation of health effects evidence for short-term exposures to O3. 

To what extent are the discussion and integration of evidence on the health effects of O3 from the animal 

toxicological, controlled human exposure, and epidemiologic studies technically sound, appropriately 

balanced, and clearly communicated?

I am not an expert on the health effects of short-term O3 exposure, and time has not allowed me to 

review the primary literature. Given my dependence on what EPA has presented in this draft, it appears 

to me that the evidence for mortality as a result of short-term exposure to O3 is stronger than “likely”; it 

is compelling.

This view of the mortality data is guided by two broad principles: There can be no heterogeneity in 

effects (interaction, synergy, or effect modification) unless there is some kind of effect to be altered in at 

least some subset of the study population. And, any mortality effect cannot be zero overall if there is an 

effect for some cause, however minor or for some subset of the population, however small, unless there 

is a compensating effect in the other direction for some other cause of death; I have not seen any 

evidence suggesting that O3 exposure is protective against any lethal disease. These principles hold even 

if overall mortality cannot be shown to be elevated; an effect can be real but too small to be evident in 

overall mortality or broad categories of causes of death.

The epidemiologic findings of increased overall mortality are quite remarkably consistent in direction 

(though not in size) over space, time, and a wide range of circumstances and study types, despite a few 

exceptions for single cities or other subgroups. This evidence seems to me to be even stronger than the 

early evidence regarding cigarette smoking and lung cancer, prior to the time “research” sponsored by 

the tobacco industry inserted a few negative findings. The discussion of the possible flaws in the 

evidence is thoughtful and detailed, but seems to me to miss the point that a remarkable combination of 

factors would have to affect the reported studies, each in different ways, to decrease the estimated effect 

to no more that “likely”.

It is worth note that if a distributed lag model holds, the effect estimated for day X includes the effect for 

day X-1 with a one day lag, that for X-2 with a 2 day lag, etc. This argues for an analysis of periods 

longer than days to compare high vs. low O3 levels (and there are other reasons for this, including 

possible cumulative effects and, conversely, possible habituation or delayed avoidance behavior). More 

generally, there should be something here about the combination of daily averages, whether lagged or 

not. What is the cumulative effect of ten days in a row, each with an RR of 1.01? Is adaptation 

important? Do RRs decline over a few days because a susceptible sup-population has been depleted? 

(The text on page 1-167 should mention the possibility of depletion or avoidance, which is suggested, 

though over a shorter interval, by Figure 6-35.)

It would help to add a table showing, for each short-term mortality study, the crude effect and the effect 

after adjustment for PM and any other factors in the reported study. In my experience, when adjustment 

for confounders reduces a crude estimate of an effect by a substantial amount, more and better 

information about confounders etc. (including additional items) is likely to lead to a further reduction; if 
13

the initial adjustment has little effect, using more items and better data is not likely to have much effect. 

The limited information on this in the present report suggests that co-pollutants and other confounders 

do account for some, but not all, of the relation to O3 measures in the crude measures of mortality. 

Does the integration of health evidence focus on the most policy-relevant studies or health findings?

This is clearly a matter of opinion, and in my opinion the focus is largely appropriate. However, if the 

ISA concludes that there is a real, measurable mortality effect at the current exposure limit, or that there 

is no effect near that limit, that finding is likely to drive any overall policy decision about a change in 

regulatory standards for O3. Thus I would reorganize the report to discuss mortality first, and I would 

give it more weight in the various summaries.

An additional point is the need to consider how regulation should address joint actions that are more or 

less than additive. For an artificial example, assume that agent A alone is innocuous, with an RR of 1.0, 

agent B also has an RR of about 1.0, but the combination has an RR of 10.0. How much of that 

increase should be laid on A and how much on B? The answer could have an impact on regulation of 

one or both. While this is artificial, more complicated real-life examples may not be rare. This matter 

should be addressed in the draft ISA report.

What are the views of the Panel regarding the balance of emphasis placed on evidence from previous 

and recent epidemiologic studies in deriving the causal determination for short-term O3 exposure and 

respiratory effects (in particular, additional epidemiologic evidence for lung function and respiratory 

symptoms and new evidence for biological indicators of airway inflammation and oxidative stress that 

previously has been largely limited to human controlled exposure and toxicological studies)?

Evidence is evidence, regardless of whether it was developed yesterday or a decade ago. I would judge 

old and new by the same standards (though this may often mean that the new is better because of 

advances in technology, bigger sample sizes, or other reasons). Also, it is likely that many readers will 

not have ready access to the prior report(s). Thus I would argue for a more complete statement of prior 

results when they contribute in an important way to the present conclusions.

The majority of new studies that examine the association between short-term O3 exposure and mortality 

focus on specific issues that have been previously identified. Does the structure of the chapter 

adequately highlight the breadth of studies (both older and the new) that indicate an association 

between O3 exposure and mortality and provide the underlying rationale for the causal determination?

Avoidance behavior, when for a good medical reason (not just fashion or trendiness), is a health cost. I 

would like to see new evidence about the extent and nature of avoidance behavior, but even with what is 

now available, there should be a bit more emphasis in the summaries here.

Are the data properly presented regarding the credibility of newly reported findings being attributable 

to O3 acting alone or in combination with other co-pollutants and regarding the extent that toxicological 

study findings lend support to the biologic plausibility of reported epidemiologic associations in 

reaching a causal determination?

I believe that they are.
14

Are the tables and figures presented in Chapter 6 appropriate, adequate, and effective in advancing the 

interpretation of these health studies?

In my view they are appropriate, adequate, and effective.

Charge Question 8.

Chapter 7 presents important new findings from studies published since the 2006 O3 AQCD including 

studies that examine the relationship between long-term O3 exposure and new onset asthma in children, 

first childhood asthma hospital admissions, increased asthma severity, bronchitic symptoms and 

respiratory-related school absences. These studies provide evidence in this regard based on different 

genetic variants. What are the views of the Panel on conclusions drawn in the draft ISA regarding the 

strength, consistency, coherence, and plausibility of the evidence for health effects for long-term O3

exposure on respiratory morbidity?

Page 7-6, lines 16/25. What did Clark et al. report finding, weak as that finding may be?

The evidence regarding genetics and asthma would be stronger if it did not rely so heavily on the CHS.

Please add a short discussion of why current findings differ from those in the previous review. Are prior 

results fully consistent with current results, given the differences in study methods, precision, etc.?

Limited new data also suggest a link between long-term O3 exposure and respiratory mortality; what 

weight should be placed on this evidence in causal determinations?

Asthma is a lethal disease, and death from asthma is sufficiently uncommon that it might not show up in 

studies of total respiratory mortality. If the relative risk is high, a relation to O3 might be evident in a 

mortality analysis focused on asthma. Has this been done?

The section on infant mortality is not focused on asthma, and the few positive finding (among many 

negative) might be accounted for by small biases in the data, multiple comparisons problems, and posthoc selection of subgroups.

Overall, I agree with the ISA that, overall, the evidence regarding mortality and long-term exposure to 

O3 is suggestive, but it is not as strong as that regarding morbidity. However, good evidence of an effect 

on potentially lethal conditions adds to the strength of the findings on mortality. The negative findings 

of the six-city study could be the result of having only six points of observation with several potentially 

important confounders or modifiers, as well as the narrow range of average O3 levels, so that even a 

major effect could be missed. Other negative human studies are in general lacking in statistical power, 

have narrow ranges of exposure, or do not examine an appropriate set of causes of death.

What are the views of the Panel on conclusions drawn in the draft ISA regarding the strength, 

consistency, coherence and plausibility of the evidence for neurological effects resulting from long-term 

O3 exposure?

This question appears to refer to Sections 7.4.8.2/3 and 7.5.The ISA concludes, “suggestive or a causal 

relationship”, but I would add that the evidence includes only one human study and that the animal 

evidence was all at exposures well above the current EPA limit.
15

Are the data properly presented regarding the credibility of newly reported findings being attributable 

to O3 acting alone or in combination with other co-pollutants and regarding the extent that toxicological 

study findings lend support to the biological plausibility of reported epidemiological associations in 

reaching a causal determination?

This is a bit difficult me to answer because I have not had an opportunity to review the literature that the 

ISA summarizes, but I am alert to problems of presentation and credibility, and I have found no reason 

here to question any of the descriptions, findings, or conclusions, except as I have noted elsewhere here.

I understand the effect on mortality of adding PM to the O3 model, but what about the reverse? I would 

like to see, side by side, the effects of PM alone, O3 alone, and their separate effects when both are in the 

model. That is that only way to understand whether the apparent effect of either one is in part or totally a 

result of their co-occurrence.

Overall, I concur with the ISA that “there is likely to be a causal relationship between long-term 

exposure to O3 and respiratory morbidity”. I might even make the statement a bit stronger; the evidence 

is really pretty persuasive, though not as strong as for short-term effects. This conclusion is based 

primarily on the epidemiologic evidence, but seems to be fully supported by toxicological and human 

experimental findings.
16

Dr. Michelle Bell

Charge to the O3 CASAC Panel

We ask the Panel to focus on the following questions in their review:

12. This first external review draft O3 ISA is of substantial length and reflects the copious amount of 

research conducted on O3. EPA has attempted to succinctly present and integrate the policyrelevant scientific evidence for the review of the O3 NAAQS. The Panel may note that per 

CASAC consultation on November 13, 2009, considerable discussion has focused on older 

literature. The Panel emphasized that important older studies should be discussed in detail to 

reinforce key concepts and conclusions if they are open to reinterpretation in light of newer data 

and where these older studies remain the definitive works available in the literature. In 

considering subsequent charge questions and recognizing an overall goal of producing a clear 

and concise document, are there topics that should be added or receive additional discussion? 

Similarly, are there topics that should be shortened or removed? Does the Panel have opinions 

on how the document can be shortened without eliminating important and necessary content?

Although the O3 ISA is of substantial length, I find the length of the ISA to be appropriate in 

relation to the body of scientific literature on O3 and the need to summarize the evidence 

thoroughly and accurately. A significantly shorter summary version is needed; however, the 

larger document serves to provide the underlying evidence of ozone’s impacts on human health 

and welfare. The role of Chapter 2 as compared to an executive summary is a bit unclear to me 

as it doesn’t so much integrate as summarize the following chapters. In that sense it’s largely 

repeating information that is elsewhere and could be a separate summary document. 

Alternatively, this chapter needs to be more integrative and does not need to revisit every main 

point of the subsequent chapters. Whether it stays as a summary or is made more integrative, it 

could probably be shortened to less than its current 66 pages.

The text on the history of the NAAQS for ozone may have too much detail. In particular, the 

need to include issues that were raised in court but resolved (e.g., unconstitutional delegation of 

legislative authority) is unclear. (Chap. 1)

The method by which scientific studies were identified is well described overall, with the 

exception of the incorporation of non-peer reviewed studies. For example, see page 1-7 

“Typically, only information that had undergone scientific per review and had been published or 

accepted for publication were considered. . .” This is vague, but central relating to the quality of 

studies. (Chap. 1)

The section on estimating policy-relevant background concentrations implies that the approaches 

used are identical to those used previously (see first sentence of 3.4.3). A better way to state this 

would be that the methods used are still the state-of-the-art approaches, and to present only the 

new estimates, without this level of detail. This section could be shortened (Section 3.4.3). 
17

In comparison to its importance and length of other chapters, Chap. 3 is far too long, with figures 

and tables that are not particularly useful for the underlying messages of the ISA and lengthy 

appendices. As an example, there are 15 figures comparing observed and GEOS-Chem estimates 

for ozone, but the discussion on these figures only relates to the model, not to our understanding 

of ozone and health or welfare effects, or the underlying science behind ozone formation. The 

point of these figures is not clear. The meaning of this chapter is unclear, especially given its 203 

pages. At the very least, a substantial number of tables and figures from this section need to be 

cut. This chapter is disproportionately long compared to its importance.

Section 3.3 could be cut entirely or greatly reduced. The importance of regional air quality 

modeling to the ISA needs to be better described, including its relation to the rest of the 

document. It seems odd to have an entire section on a tool rather than on underlying principles 

(i.e., our understanding of the chemical and physical transformation of ozone and its precursors). 

The ISA does not have primer sections on other tools and methods (e.g., biostatistical modeling) 

that apply our scientific understanding, but has a very large section on atmospheric modeling. 

This section also presents a somewhat narrow view of air quality modeling, with heavy emphasis 

on CMAQ and almost no discussion of how well CMAQ actually estimates ozone levels.

13. Chapter 7 presents important new findings from studies published since the 2006 O3 AQCD 

including studies that examine the relationship between long-term O3 exposure and new onset 

asthma in children, first childhood asthma hospital admissions, increased asthma severity, 

bronchi tic symptoms and respiratory-related school absences. These studies provide evidence in 

this regard based on different genetic variants. What are the views of the Panel on the 

conclusions drawn in the draft ISA regarding the strength, consistency, coherence and 

plausibility of the evidence for health effects for long-term O3 exposure on respiratory 

morbidity? Limited new data also suggest a link between long-term O3 exposure and respiratory 

mortality; what weight should be placed on this evidence in causal determinations? What are the 

views of the Panel on the conclusions drawn in the draft ISA regarding the strength, consistency, 

coherence and plausibility of the evidence for neurological effects resulting from long-term O3

exposure? Are the data properly presented regarding the credibility of newly reported findings 

being attributable to O3 acting alone or in combination with other co-pollutants and regarding 

the extent that toxicological study findings lend support to the biological plausibility of reported 

epidemiologic associations in reaching a causal determination? 

I agree with EPA’s assessment of the degree of evidence on causality for long-term exposure to 

ozone and respiratory effects (“likely to be a causal relationship”) and central nervous system 

effects (“suggestive of a causal relationship”). For readers who are unfamiliar with this literature, 

key questions will relate to the reasons for the lack of stronger evidence. The ISA O3 could 

discuss these issues relating to whether more conclusive evidence would need to rely on larger 

sample size, different types of studies, further research, evidence across multiple study designs, 

etc. (in Section 2.4.2 and Chap. 7) This text could refer to the guidelines used to assess causality 

in Chap. 1.

The text on the relationship between ozone exposure and birth outcomes in Chapter 2 could be 

misinterpreted to indicate that there is a lack of studies, whereas there have also been some 

studies that did not identify an association (e.g., for ozone and low birth weight). A more clear 

way of describing this evidence would be to note that studies are inconsistent, rather than list the 

limited studies with evidence in Section 2.4.2.3. This is done in more detail in Section 7.4.
18

There have been additional recent articles that review and summarize methodological issues on 

air pollution and birth outcomes that could be referenced in Section 7.4, page 7-27 (e.g., 

Woodruff TJ et al. 2010).

Assessment of the biological plausibility of effects for long-term O3 exposure can gain 

information from the evidence for short-term effects of related health endpoints. This could be 

further discussed and highlighted in the ISA in Chapter 7. As an example, the evidence for 

respiratory effects on mortality is strengthened by the evidence for respiratory morbidity. As the 

ISA correctly notes, EPA concluded at the 2006 review that associations between short-term O3

exposure and respiratory health effects are causal and new evidence since that time supports this 

claim. This includes a range of study designs (epidemiology, animal models, controlled human 

exposure). Although that research is for short-term exposure, it contributes to biological 

plausibility of respiratory impacts from long-term exposure, especially as a range of health 

responses have been noted (airway inflammation, decline in lung function, respiratory 

symptoms, hospital visits, emergency room visits). In general, the causality of long-term 

exposure could borrow information from the studies of short-term exposure, where appropriate, 

to note consistencies or inconsistencies.

Given the wide range of what “long-term exposure” may mean, this chapter would benefit from 

discussion early in the chapter on how this is defined. The long-term exposure section considers 

exposure over several months or spatial comparisons across cities that have different annual O3

levels. The wording used to describe exposure timeframe and the lack of specifications is a large 

problem in this chapter. The underlying analysis of causality seems appropriate, but it will be 

difficult for most readers to assess and compare the evidence without knowing the exposure 

periods.

Throughout the chapter, the text should specify the duration of exposure for each study. This is 

sometimes provided, but missing in several places. For example, the first sentence of 7.2.3 does 

not indicate whether children’s lung function was assessed in relation to their lifetime exposure, 

recent years, or some other timeframe. Another example is on page 7-13 where “chronic 

exposure” is discussed. There are a few examples where the timeframe of exposure is not 

specified at all (e.g., Section 7.2.7, Section 7.3.2). The exposure timeframe should also be 

specified in tables or figures (e.g., Table 7-1 and Table 7-7); this is done nicely in Tables 7-2 to 

7-5. 

Some of the infant mortality studies do not present an exposure timeframe at all (see Section 

7.4.9.4) and the inclusion of exposure timeframes of a single day in the long-term exposure 

chapter is very confusing (see Table 7-6). I recognize this is a challenge EPA has confronted in 

previous summaries of research on ozone and other pollutants, but the current structure needs 

improvement. The lack of specification of what “chronic” and “long-term” exposure means 

contributes to this problem.

The causality evidence for long-term exposure to ozone and mortality may be the weakest 

endpoint as it is based on a single study, so I think the “suggestive of a causal relationship 

between long-term O3 exposure and all-cause mortality” (page 7-62) is appropriate; however, 

another study found no association (see Section 2.4.2.6, Section 7.3.2). More description of these 

studies study would be useful to help evaluate causality given the heavy weight on a single 

study.
19

For Table 2-3, word “no studies” as “no studies at that time” when referring to the lack of 

evidence for the previous O3 AQCD.

The use of “seasonal” in Section 7.2 would be better defined as exposure over a few months, 

without using the word “season.” There have been many “seasonal” studies of short-term 

exposure to ozone. Although the document notes that “the term seasonal was used in these 

studies as a measure of a long-term exposure of several months,” there appears no benefit to 

adding potential confusion by using the word seasonal to refer to exposure over several months. 

The broad range of “long-term exposure” definitions in this chapter adds to this potential 

confusion as the chapter does include short-term exposures.

In this chapter, distinctions between cross-sectional studies and other studies is very useful. More 

emphasis could be placed on the cohort studies as opposed to the cross-sectional studies. The 

CHS has information on the study subjects’ individual-level exposure, not just community 

information, so the 2nd sentence of 7.2.3, showing results by community-level ozone, may not be 

the best presentation of results.
20

Dr. Joseph Brain

Answer to Charge Question 6 (Chapter 5)

General Comments:

This chapter, like the entire document, is encyclopedic. There are a large number of references. Most of 

the relevant ozone publications in the last 5 years are here. Surely, the multiple authors of this document 

need to be congratulated for being inclusive. At the same time, this encyclopedic feature is sometimes a 

weakness. It is hard to focus on evidence which might ultimately alter the recommended value for the 

ozone standard. 

I am ambivalent about the use of having a section entitled “Recent Publications.” One the one hand, it is 

convenient to have them here and segregated from the earlier literature. On the other hand, it is 

unfortunate that these new references are not better integrated into the historic literature. Especially, 

these sections appear to be an annotated bibliography. They list the references and say a bit about each 

article, but rarely do they indicate a particularly important paper and explain why it’s important. There is 

not enough integration and critical analysis. 

It would be valuable if each “Recent Publications” section would end with a brief comment on how 

these recent publications make a difference. For example, I applaud the sentence at the beginning of 

5.1.3.2 which concludes that the studies reviewed are in agreement with previous studies and “do not 

change the dosimetry conclusions of the last document.” That kind of critical analysis is very helpful. 

These same suggestions apply to comparable sections later in the document entitled “New Cellular and 

Molecular Insights.” A clear statement of conclusions at the beginning or at the end of each section with 

this title would be helpful in putting the literature into perspective.

I appreciate the way in which the list of references and in the text itself, every reference has an 

identifying number which permits the reader to locate it. That makes this document more useful.

Major Comments:

1. I draw attention to section 5.2.9.5, Adaptation. One of the hallmarks of oxidant injury, especially 

ozone, is the phenomenon of adaptation. There are levels of ozone, or hyperoxia, which produce serious 

injury or even death in naïve animals. However, in animals chronically exposed to lower levels of ozone 

or oxygen, there is morphologic and biochemical adaptation. Subsequent exposures to ozone produce a 

far lower response. This is important in understanding ozone toxicology in humans as well. It also 

relates importantly to different patterns of ozone exposure. Citizens, who rarely see significant ozone 

levels and then suddenly have a two to three day episode of high ozone, may be much more affected 

than those who enjoy steady state ozone exposures all the time. 

2. Another component which should be better developed is the one dealing with co-exposures with 

particulate matter, 5.2.9.6. Yes, there is some evidence for PM modulating ozone responses. This section 

should be broadened to co-exposures of ozone with a variety of other pollutants, such as oxides of 

nitrogen and oxides of sulfur. We need to better understand responses to ozone per se compared to 

responses to ozone, plus other pollutants.

3. In response to Charge Question 6, I believe Chapter 5 does a good job of describing differences in 

retained dose of ozone among different individuals and among species. They also do a good job of 

describing generic mechanisms which make measured short and long-term effects of ozone biologically 

plausible. Yes, I believe that the basic dosimetric principles of ozone uptake are presented accurately 

and in sufficient detail. The document does not take a clear position as to what is the ideal and most 

appropriate dosimetric approach. Is it the local absorption/retention of ozone or is it the generation of 

ozone related by-products which are the mediators of injury. 
21

Finally, I believe Chapter 5 does link these biochemical changes to associated phenomenon of 

inflammation and other types of organ injury. An area which could receive more attention is extrapulmonary effects of ozone. What other organs are affected? Do these responses alter our understanding 

of dose response effects in humans?

4. “Gaps in Knowledge” is the title of 5.2.11. I would propose two other bullets. The first would be

-Interacts with co-pollutants

-Is altered by adaptation and the time course of ozone exposure

Minor Comments:

Page 51, Line 17-19

I’m concerned about the phrase “cells protruding from the ELF and surface macrophages.” This seems 

to imply that these cells are not covered by the alveolar lining layer (ELF). Electron microscopic images 

clearly show that the extracellular lining fluid is continuous and covers these cells.

Page 5-9

When discussing the nasal pharyngeal removal, the initial sentence sounds far too certain. The precise 

percentages are significantly influenced by exercise and especially by the choice of pathway. At least, 

the considerable variability among individuals should be acknowledged. 

Also, is there additional information as to how pulmonary uptake and dose is modified by nose 

breathing versus mouth breathing?
22

Dr. David Chock

CHAPTER 4. EXPOSURE TO AMBIENT OZONE

CHARGE QUESTIONS

Chapter 4 describes human exposures to O3. Is the evidence relating human exposure to ambient O3 and 

errors associated with exposure assessment presented clearly, succinctly, and accurately? Are the results 

of field studies evaluating indoor-outdoor and personal-ambient exposure relationships, and factors 

affecting those relationships, presented in a manner that is useful for interpretation of epidemiologic 

results? Is the information on modeling O3 concentration surfaces and population exposures appropriate 

for evaluating the utility of these modeling approaches? Do the characterizations of temporal and spatial 

variability of O3 in urban areas provide support for better understanding and interpreting epidemiologic 

studies discussed later?

The Chapter describes clearly and generally quite accurately the understanding to date in the 

relationships between human exposure to ambient ozone and errors associated with exposure 

assessment. The results of field studies evaluating indoor-outdoor and personal-ambient exposure 

relationships, and the factors affecting those relationships, are well described, but there are issues that 

need further elaborations and modifications (See below). These results are useful in the design of 

epidemiological models. The Chapter describes the modeling of concentration surfaces and of 

population exposures adequately, but there remains a lack of sufficient data to (1) properly evaluate the 

concentration surface models at spatial scales that are less than inter-monitor distances, and (2) refine 

activity patterns to build more robust exposure models. The descriptions of temporal and spatial 

variability of ozone represent our current knowledge well and should help ascertain the scope and design 

of epidemiological studies and help interpret their results. There are more detailed, specific issues that 

are presented below.

Ozone in the lower troposphere is a secondary pollutant, predominantly formed by photochemical 

reactions between hydrocarbons and oxides of nitrogen in a time scale of a few hours or longer, 

depending on the reactivity of the hydrocarbons involved. Therefore, we expect it to be rather uniform in 

a spatial scale on the order of, say, 10 or more km. But ozone is also a rather reactive oxidizing agent. It 

reacts quickly with NO, and contributes to aging of materials and living things. So, unlike the lessreactive secondary PM2.5, there are significant reductions of ambient ozone concentrations at and 

downwind of major roadways, with a spatial scale of meters to maybe hundreds of meters or more, 

depending on the emission rates of NO and wind velocities. And indoors, ozone would be scavenged 

rather quickly unless the air exchange rate with outdoor air is high. So, even though both ambient PM2.5

and ozone are secondary pollutants, their spatial concentration patterns need not be similar in a 

populated urban environment with spatially uneven NO sources. For ambient ozone, one can envision a 

relatively flat terrain punctuated by many trenches and valleys along different roadways whose depths 

and extents depend on the NO emissions from the vehicular traffic and local wind fields. One also needs 

to note that increasing the averaging time would increase the smoothness of the spatial pattern of ozone 

concentrations. In this connection, a 2010 paper by Sarnat, et al. (385852) concluded that PM2.5 and 

ozone are spatially more homogeneous and thus the health effects are less sensitive to the choice of 

ambient monitors, as compared to primary pollutants like CO and NO2. First, note that a large portion of 

NO2 concentration comes from the titration of ozone by NO near the emission sources. But equally if 

not more important, the authors used different averaging times to characterize the pollutant 

concentrations, 24 hours for PM2.5, 8 hours for ozone, and 1 hour for CO and NO2. This would 

inadvertently and preferentially increase the smoothing of the spatial distributions of PM2.5 and ozone 
23

relative to those of CO and NO2. Nevertheless, the value of the paper is not diminished because the 

paper in effect smoothes out the intra-day spatial variability in order to study the health effects of ozone 

concentrations based on their inter-day variability.

Because of the rather complicated ozone spatial pattern in the urban environment, information on the 

activity and location patterns of individuals, the proximity of their homes to major roadways, and the 

indoor-outdoor air exchange rates of their homes become relevant to reliably determine their ozone 

exposures. The Chapter indicates that indoor ozone concentrations are generally considerably smaller 

than outdoor ozone concentrations. But it reports only one correlation number, 0.58, which is from a 

study in the Los Angeles area conducted by Avol, et. Al. (018270) (page 4-4, line 34). It would be great 

if the authors include more of such correlations from studies in other cities. The Chapter describes quite 

thoroughly the observed relations between ambient ozone concentrations measured at monitors and 

people’s exposures to ozone. The correlations between ambient ozone concentrations and personal 

exposures of ozone vary considerably, but are generally in line with expectations. In particular, the 

correlations with ambient ozone concentrations increase from subject-specific exposure, to pooled-group 

exposure to community-averaged exposure even though the actual ozone exposures are generally 

significantly lower than the ambient concentrations. This finding indeed supports the use of ambient 

ozone concentrations as a surrogate for average personal ozone exposure, a finding that is critical to 

establishing the relevance of community health effects studies.

In the description of personal-to-ambient ozone ratios, the authors need to include the work of Suh and 

Zanobetti (677202), which indicates extremely low slopes between 24-hour personal and ambient ozone 

concentrations for both fall and spring in Atlanta. Also, in the description of the correlations between 

personal exposure of ozone and of co-pollutants, the Chapter authors’ attribute the paper’s finding of a 

higher correlation coefficient of 0.14 between personal ozone and personal PM2.5 to the regional nature 

of ozone and PM2.5 (page 4-8, lines 8 to 12). But this may be a bit of a stretch because the paper also 

shows a low and insignificant correlation coefficient between personal and ambient ozone (no number 

given) and between personal ozone and ambient PM2.5 (a value of 0.08). 

The Chapter describes three approaches that have been used for concentration-surface modeling: spatial 

interpolation including inverse-distance weighting and kriging; empirical-statistical modeling including 

land-use regression; and chemistry transport modeling. The interpolation approaches are useful only if 

the pollutant concentrations are expected to be spatially smooth. This would not be the case for ozone 

concentrations near NO emission sources like major traffic areas. The land-use regression approach 

could provide greater spatial granularity, but it would require frequent retuning to fit different local 

conditions and emissions. Only the chemistry-transport modeling has a more solid physical basis. 

However, the required rather detailed emission inventories are generally not available presently, and the 

parameters used in the model, like eddy diffusivity, may need to be retuned for the relevant grid

resolution. Furthermore, the predicted results may need to be rescaled to be consistent with the observed 

concentrations at the monitors. The Chapter authors have done a good job describing the state of the art 

developments. There is one minor point that needs to be removed. In describing the work of Brauer et al. 

(156292), the authors include their own opinions, which was not validated by the paper’s authors, that 

the inverse-distance weighting approach would be expected be favored since ozone is a secondary 

pollutant (page 4-13, lines 32 to 33). Note that ozone is a reactive secondary pollutant that is sensitive to 

local NO emissions. This sensitivity cannot be ignored in large urban areas.

The Chapter highlights the important developments of many exposure models by the EPA. These 

models couple a human activity database with a concentration-surface model. The Chapter highlights 
24

two main sources of uncertainty: activity pattern database, including children’s activities, and 

concentration surface model. In the latter, improved information on the ozone concentrations nearroadways would be an important step forward, and this kind of improvement need is best satisfied by 

chemistry-transport modeling. The Chapter authors also highlight a very important point: the need for 

the deployment of high sensitivity personal exposure monitors to shorten the sampling time and to lower 

the ozone detection limits for low indoor ozone concentrations.

In the description of the exposure measurement errors, the Chapter authors indicate that the association 

between heart rate variability (HRV) and either ambient or personal ozone or PM2.5 were similar and 

attributed these similarities to the regional nature of both ozone and PM2.5 (page 4-17, lines 28 to 29). 

These conclusions ignore the finding of Suh and Zanobetti (677202) that the associations were 

insignificant to begin with, which may be attributable to the possible lack of a causal link between HRV 

and either ozone or PM2.5, regardless of their spatial distributions. But even regarding the latter, the 

insignificant associations between the HRV indicators and PM2.5 are generally similar between ambient 

and personal exposure, but those between the indicators and ozone are mostly of opposite signs between 

ambient and personal exposure. More important, the actual correlation between personal and ambient 

PM2.5 reported in the paper is 0.63 and significant and that between personal and ambient ozone is 

insignificant and no value is given. These results support the regionality argument for PM2.5, but not for 

ozone, even though it does not rule out the fact that ozone is a regional pollutant subject to varying 

degrees of local variability.

In the discussion of spatial variability, the Chapter authors describe the finding of Sarnat et al. (385852) 

that the choice of monitor may have little impact on the results of ozone epidemiologic studies (page 4-

19, lines 18 to 26). Note that, as mentioned earlier, the use of different averaging times for ozone and for 

CO and NO2 in the study may have contributed to this conclusion. If the same conclusion is reached 

based on an identical averaging time for all pollutants of interest, then the case presented by the paper’s 

authors would be strengthened.

In the seasonality discussion, the Chapter authors present a cogent argument that studies conducted 

during the ozone season in periods when communities are likely to have high air exchange rates are 

likely to have less exposure error than those conducted during winter. (pages 4-20, lines 10 to 15).

The Chapter authors rightly point out that use of microenvironmental models in epidemiological studies 

has a disadvantage of needing an independent comparison with measured exposure levels (page 4-21, 

lines 11 to 16). In fact, it defies scientific principles to draw conclusions from a statistical 

epidemiological model that is based on numbers generated from an unverified or unevaluated model like 

a microenvironmental model. This kind of practice has indeed occurred.

In the Chapter conclusions, the authors again highlight the similarity of the associations between HRV 

indicators and either ambient concentrations or personal exposures of ozone and PM2.5 in the Atlanta 

study, and attribute this similarity to the regional nature of both pollutants. As pointed out earlier, the 

description of the finding of the Atlanta study is inaccurate and the attribution is misleading.
25

Dr. W. Michael Foster

Comments on ISA – specifically for Chapter 6 (assigned):

Overall there is a tremendous amount of information in this particular chapter and includes 176 pgs of 

text, 37 Figures, 45 Tables, and 27 pgs of References cited. Several 

Chapters do not even include 50 pgs of text!

1) a fair amount of text description is devoted to the concentration pattern of controlled lab 

exposures of human to ozone and whether a square-wave (S-W) or triangular (variable 

concentration) format for ozone concentration was utilized (pgs. 6/6 - 6/7, Fig. 6-2). Of equal 

importance is likely some text should be devoted to differences in controlled laboratory 

exposures whereby the subjects are exposed in a walk-in chamber facility or via a face-mask 

exposure system (ref. 093690). The face-mask system excludes any scrubbing out of nasal 

inhaled ozone by the URT, and carries with it then, the potential to deliver a high deposition 

fraction to the LRT. Any Figures in the chapter, where results from these 2 delivery modalities 

were combined, should likely be footnoted, and/or the results to exposures listed separately.

2) with respect to Fig. 6-2 (pg. 6/10 of the text), it is not obvious to me why a decrement in excess 

of 10% in the FEV1 is being identified in the respective panels of ozone concentration. The 

rationale for selecting a 10% change as a “threshold” for a response to a given concentration of 

ozone should likely be expressed. For example if a decrement greater than 15% is selected, the 

frequency of responder subject to a given ozone concentration decreases considerably. The text 

provides 2 refs for the 10% rationale (044889 and 626521) and suggests that changes in FEV1 ≥ 

5% are clinically meaningful; discussion on the threshold for defining a functional response, 

may be helpful. 

3) text refers frequently to children and adolescents as being highly susceptible to ambient ozone 

due to lung size, and perhaps increased time spent outdoors. It would likely be helpful to add to 

the text (pgs. 6/13 – 6/14 and 6/35) reference to controlled lab studies in children to ozone: for 

example: Koenig JQ et al, 1985, 1998; McDonnell WF et al, 1985; and Linn WS et al, 1997) as 

these would add validity to the supposition that children are more susceptible to ozone.

4) to address the issues over male vs. female and sensitivity to ozone, the ref by Weinmann GC et 

al, 1985, in a controlled lab exposure setting to ozone with longitudinal data set, has been 

overlooked and should be added to the text (pg. 6/14). Likewise, to address issues over subjects 

habituated to cigarettes and their sensitivity to ozone, the controlled lab study with longitudinal 

data set ref by Emmons K et al, 1991, has been overlooked.

5) in description of repeated exposures to ozone in controlled lab studies, the report by Foster WM, 

et al, 1996, and which identifies systemic outcomes (perpheral blood monocyte activation state, 

serum a-tocopherol, respiratory frequency of the breathing pattern, that during or following 

repetitive exposures to ozone do not adapt in response to a variable ozone concentration 

(triangular), seems to have been overlooked. As well the report by Frank R, Liu MC, et al, 2001, 

also appears to have been overlooked, and is a helpful ref as substantiates that small airway 

functional changes persist during repetitive ozone exposure in controlled lab setting.
26

6) at issue is whether CS treatment of asthma cohorts are protective in controlled lab exposure 

studies (pg. 6/30), and a helpful ref that has been overlooked would be the report by Holz O, et 

al, 2005 that was accomplished in healthy subjects (non-asthmatics) and evaluated for protection 

provided by comparing inhaled and orally administered GC. This is helpful as provides 

comparison of the GC in a respiratory tract free of inflammation at pre-exposure.

7) at issue is the description in the text under a toxicology section (pgs. 6/41-6/42) that in referring 

to rodent models where the provocative exposure concentrations in testing scenarios may be in 

the 1-3 ppm range, that these “high” dose models are helpful for mechanism for understanding 

perhaps airway hyper-responsiveness, but have “questionable” relevance for extrapolation to 

airway responses in humans exposed to ambient levels of ozone. Two issues arise: human 

subjects undergo increased MV due to exercise during controlled exposures (which in fact may 

have durations of 50 min per hr over several to 6 h periods of exposure), are required for 

initiating functional changes. Given that the rodents are not exercised during exposures and thus 

do not elevate MV, and that is well known that the deposition fraction of ozone in the rodent 

respiratory is roughly 40-45 % (ref: Wiester MJ et al, 1988) where as in the human, 90-98 %, 

exposure concentrations of 1-3 ppm in rodent models are highly relevant for translation to human 

studies. 

8) a topic that seems underserved in the text is the issue over airway neuronal effects that occur 

during ozone exposure, either ambient or controlled lab settings. Thus text perhaps should be 

devoted briefly to this area, and include refs from both the clinical and toxicology literature; for 

example refs dealing with parasympathetic nerves (Beckett WS, et al, 1985), Krishna MT, et al, 

1997; Taylor-Clark TE, et al, 2010; Nishiyama H, et al, 1998; Graham RN, et al, 2001; Hazbun 

ME, et al, 1993; Zhou S, Sunday ME, et al, 2010; Evans CM, et al, 2000; Coulson FR, et al, 

2003.

9) with respect to descriptions of ozone exposure and general effects of the immune system (pg. 

6/73), the understanding of surface expression on lung macrophages of surface receptors called 

toll-like receptors (TLRs), which can recognize foreign pathogen-associated moldeular patterns 

(PAMPS), has become a topic of ghigh interest with respect to ozone exposure, alveolar 

macrophage function, and innate immunity (refs: Kleeberger SR, et al, 2000; Li Z, et al, 2010).

10) with respect to Fig. 6-19: % increase in respiratory-related hospital admission and ED visits for 

all yr and seasonal analyses, it might be helpful to separate in the Figure the listings of All 

subjects, from Senior aged, from children. A significant part of the text has been devoted to 

acknowledge that children may be more susceptible to ambient ozone, and thus to emphasize 

this, one would expect the hospital admissions, etc to be higher in this group with respect to a 

health effect. As well it would seem that there should be available more ref citations than those 

provided at this point in the text by Steickland (ref. 624878) and Orasso (ref. 202800).

11) with respect to Summary and Causal Determination, section 6.2.9 (pgs. 6/97 – 6/100) a concerns 

arises. The text states on 6/98, that “recent controlled human exposure studies found functional 

response enhanced in subjects with elevated BMI” as such, this is an overstatement, as the 

suggestion of higher risk to ozone in subjects with high BMI is based, at this point, entirely on 

retrospective analysis (as correctly stated in the text on pgs. 6/15 – 6/16) and not designed 

laboratory studies. Although attractive concept, at this time a controlled human lab study is 

warranted.
27

12) with respect to ozone-induced effects on cardiovascular-related proteins, the report by 

Weinmann GC, et al, 1995, demonstrated that fibrinogen titers were significantly elevated in 

bronchoalveolar lavage fluids sampled at delayed time point following controlled lab exposure 

ozone, and should likely be an addition the refs in this section. 
28

Dr. Christopher Frey

Charge Question 3: Chapter 2 presents the integrative summary and conclusions from the O3 ISA with 

detailed discussion of evidence in subsequent chapters. Is this a useful and effective summary 

presentation? How does the Panel view the appropriateness of the causal determinations?

An integrative overview is important and necessary. The integrative review will be read by most persons 

who read the ISA and will serve as perhaps the sole point of contact between the reader and the ISA. 

Thus, careful consideration should be given as to the audience. A key shortcoming of this chapter is that 

each section is written for an expert audience in a narrow domain, and thus for most readers, most 

sections of the ISA become nearly unreadable.

Since there are detailed chapters on specific points in other parts of the document, it seems unnecessary 

to attempt to provide detailed technical information in the summary. A true “integrative overview” 

should not be highly detailed, but rather should present the key findings from other chapters. This draft 

misses the mark in attempting to provide detailed information from specific studies, but without proper 

citation, and inexcusably sending the reader on a wild goose chase for figures and tables in other 

chapters that are cited but not shown in Chapter 2.

Chapter 2 needs to be self-contained with respect to including whatever figures or tables are central to 

the integrative findings. Furthermore, it is not necessary for the figures and tables that could be included 

in Chapter 2 to be duplicative of figures and tables in other chapters. The figures and tables themselves 

should also be integrative and provide an overview, rather than details.

Section 2.1 seems to be of about the right length although I encourage attempts at shortening any and all 

sections of this chapter. I appreciated an upfront statement of the key point at the beginning of a section, 

which is not done consistently throughout the chapter. For example, in Section 2.1.1.1, the key point that 

the photochemical processes are well understood as of the 2006 ACQD was helpful in setting the tone 

for the review given in this brief section.

Section 2.1.5 and its subsections make a lot of references to specific figures in other chapters, which is 

frustrating for the reader. If the information in the other figures is important to the integrative summary, 

then create figures in Chapter 2 that subsume (but not simply copy) the information, and do so in an 

integrative manner.

Some sections seem to be data dumps with no particular effort at integrating the results to key findings. 

For example, Section 2.1.5.1 discusses a few examples of correlations among monitors, but no effort is 

made to generalize from the evidence regarding findings. For example, under what situations are high 

correlations expected? Under what situations do low correlations occur (e.g., titration of O3 near 

roadways by primary NO?).

As a matter of style, I dislike having consecutive headers with no introductory or transition text, as is the 

case in the cascade of Sections 2.2, 2.2.1, and 2.2.1.1. In an integrative summary, there should be some 

theses statements given in the introductions to a given level of a section before presenting supporting 

details.

As an example of reader difficulty in reading this chapter, Section 2.2.1.2 comes across as a bit of a data 

dump confounded by use of informal jargon that loses the reader. For example, the term “slopes” is 
29

undefined. Slope of what versus what? It is also not very clear what the point is of this section. Is the 

goal here just to list a bunch of results without integrating or synthesized to some key points? Examples 

of possible findings here would be explaining conditions under which there are strong correlations with 

other pollutants, and conditions under which there are weak correlations.

Rather than including a lot of data from multiple studies in long paragraphs, please consider 

summarizing the studies in tables or graphics and using the text to infer/synthesize key trends or other 

supportable generalizations. If the data do not support (or falsify) a hypothesis, it is also useful and okay 

to explain that the data are inconclusive.

In Section 2.2.3, the term “exposure error” should be defined. Consider the audience. If this is an 

integrative overview chapter, it will be read by persons of varying expertise, and not all readers will 

have expertise in all areas.

The first sentence verges on being a run-on sentence, and is debatable. Ozone cannot possibly have 

“relatively low spatial variability across an urban area” if it is subject to titration from primary NOx 

emissions, especially from large roadways. Whether there is variability depends on the spatial resolution 

over which differences are being evaluated. Given that there is typically a significant population living, 

working, or going to school near such roadways, there is the potential for significant micro-scale 

variability.

I am not a fan of paragraphs that are 30+ lines long. In rewriting this chapter, I recommend that 

consideration be given, for each section, to what are the key points to be made, with at least one 

paragraph per key point, and with at least one paragraph that is truly integrative.

As the reader gets to pages 2-18 and 2-19, there is a sea of very dense text with few paragraph breaks. 

What are the key integrative overview points? Details are in the other chapters.

Some points are made but then dropped. For example, page 2-22, lines 23-24 raises what seems like a 

potentially important point of avoidance behavior in response to air quality advisories. However, there is 

no discussion of the implication of this statement. For example, if this behavior is occurring, then it 

would tend to reduce the strength of the concentration-response relationships inferred from 

epidemiological studies not because of absence of health effects, but because the air is so bad that people 

are avoiding it. This could lead to bias and mischaracterization.

Some specific comments:

Page 2-5, line 7 “condensed” mechanisms is not very clear. “simplified” mechanisms may be better.

Page 2-13, line 10: what is the averaging time upon which the correlation of 0.58 is based?

Page 2-13, line 39: what is meant by “central –site monitors are representative of day-to-day changes” 

The more specific finding appears to be that relative changes in central site monitor concentrations are 

correlated with relative changes in exposure concentrations. This could be made more clear.

Page 2-17, line 21: replace “challenged with” with “exposed to”
30

Charge Question 5: Chapter 4 describes human exposures to O3. Is the evidence relating human 

exposure to ambient O3 and errors associated with exposure assessment presented clearly, succinctly, 

and accurately? Are the results of field studies evaluating indoor-outdoor and personal-ambient 

exposure relationships, and factors affecting those relationships, presented in a manner that is useful for 

interpretation of epidemiologic results? Is the information on modeling O3 concentration surfaces and 

population exposures appropriate for evaluating the utility of these modeling approaches? Do the 

characterizations of temporal and spatial variability of O3 in urban areas provide support for better 

understanding and interpreting epidemiologic studies discussed later?

Overall, this chapter was useful and contained appropriate and relevant material. I especially like 

Section 4.2 and the clear derivation of the relationship between exposure and ambient concentration.

In terms of technical issues, perhaps the key point in this chapter is a claim that there is “low spatial 

variability” in ozone concentrations at an urban scale, and that moderate correlations in ozone exposure 

and ambient concentration are strong enough, to support a conclusion that central cite monitors provide 

relevant time series data for health effects estimates in epidemiological studies. However, as mentioned 

in various places in the document, ozone is not spatially homogeneous in urban areas, such as because of 

titration with NOx near roadways. Furthermore, the temporal correlations are described as “moderate” 

but are relatively weak (if you plot data that have a 0.58 correlation, for example, the pattern will appear 

to be fairly random), and only become strong if the averaging time is increased to several days. Given 

that the current standard is based on 8-hour averaging, the relevance of daily average or four day 

average correlations is not established. The chapter should more critically address the adequacy of 

central site monitors for use in epidemiological studies and perhaps be a bit more forthcoming about 

potential biases that could result from assuming that they are representative of spatial homogeneity and 

temporal trends.

As with Chapter 2, there are some stylistic improvements needed that would enhance readability. For 

example, there is a paragraph that is 36 lines long starting on page 4-6. Surely, the authors can organize 

the thoughts better than this, by identifying some key points and writing shorter paragraphs to address 

each of the key points.

Section 4.3.3.2 has a horrible introductory sentence that gives the reader very little idea of the points to 

be made in this section. What follows appears to be a data dump of studies. Here again, organizing the 

idea into key points, with one paragraph per key point, would help. Putting data into summary table 

would be easier on the reader. Before diving into details, provide a thesis statement or some indication 

to the reader of the topic or point to be made.

The discussion of micro-environmental models is generally good, and section 4.4.2 appropriately 

identifies that one of the key limitations of these models are related to individual activity data.

The summary and conclusions section should be rewritten. There should be text between headers to 

introduce the purpose and content of each section and provide appropriate transitions. This section 

should be shorter, avoid repeating points, and more crisply state the key findings and conclusions. Thus, 

there should be less emphasis on summarizing and more emphasis on synthesizing.
31

Dr. Judy Graham

GENERAL COMMENTS NOT SPECIFIC TO A CHARGE

1. I am very impressed by this draft. I have several comments, but they do not detract from all the 

excellent parts and the hard work that went into developing this document. Congratulations to all 

involved, including scientists, engineers, assessors, managers, editors, and production staff.

2. HERO is fantastic. I understand that copyright laws inhibit providing full access by everyone. 

However, some papers are particularly important (e.g., the key references used by OAQPS, the 

ATS definitions of clinical significance of pulmonary function changes, any unpublished papers 

used). Please consider the possibility of obtaining copyright permission to make these publically 

available. 

3. The database for O3 is extremely large and complex, requiring an unusually high degree of 

insight to describe and interpret well. I am concerned about whether this draft has had adequate 

external input and peer review. Eight of 27 authors are external; 1 of 11 contributors is external; 

and 10 of 35 reviewers are external. This should not be interpreted as a criticism of the EPA staff 

involved. I know many of them and fully recognize that while several of the EPA staff are 

internationally recognized experts in O3, most do not have scientific expertise in this area. Thus, 

external experts play a major role for insuring the quality of the ISA. I also know several of the 

extramural scientists involved and have great respect for them. The CASAC Ozone Review 

Panel has a collection of experts, but the magnitude of the database is quite large and, at least for 

myself, I don’t claim knowledge of the details of every key toxicology paper. A broader 

collection of external experts would offer greater assurance that the original papers have been 

critically interpreted correctly. This is even more important due to the brevity of the descriptions 

of many of the papers. As a first step, I recommend listing the authors, contributors, and 

reviewers according to the chapter they addressed, as was done for the 2006 AQCD. It was clear 

in the 2006 AQCD that the authors, contributors, and reviewers represented an array of worldclass experts (EPA and external). As a second step, I recommend using additional external 

experts to assist in making revisions to the ISA and reviewing the next draft prior to the 

document being reviewed again by CASAC.

4. The O3 database is unique because of the concordance of human clinical, epidemiology, and 

animal toxicology at ambient or near-ambient exposures. This makes the O3 database especially 

compelling about health risks, particularly for susceptible subpopulations. This ISA attempts to 

bring all these study approaches together in the organization and summaries. However, the 

animal studies are not given sufficient attention to contribute to a fuller understanding of the 

severity of effects. Each approach has its strengths and weaknesses. Animal toxicology is strong 

because it is causally linked and can study effects (e.g., lung morphology) not measurable in 

humans. Its weakness is that extrapolation to humans is required, and this has quantitative 

limitations. However, these limitations are outweighed by the strengths. I will offer specific 

comments in the following comments that expand on this point.

CHARGE QUESTION 1: This first external review draft O3 ISA is of substantial length and reflects 

the copious amount of research conducted on O3. EPA has attempted to succinctly present and integrate 

the policy-relevant scientific evidence for the review of the O3 NAAQS. The Panel may note that per 

CASAC consultation on November 13, 2009, considerable discussion has focused on older literature. 

The Panel emphasized that important older studies should be discussed in detail to reinforce key 

concepts and conclusions if they are open to reinterpretation in light of newer data and where these 

older studies remain the definitive works available in the literature. In considering subsequent charge 
32

questions and recognizing an overall goal of producing a clear and concise document, are there topics 

that should be added or receive additional discussion? Similarly, are there topics that should be 

shortened or removed? Does the Panel have opinions on how the document can be shortened without 

eliminating important and necessary content?

General Comments

1. Any collection of knowledgeable reviewers will have different opinions about what to add or 

subtract. Thus, there is no “correct” answer to this charge question. At best, we can only offer 

suggestions.

2. This charge focuses on length. Length is an important consideration, but not nearly as important 

as clarity of presentation for the various audiences using the document for various purposes, 

particularly regulatory purposes. Thus, although there are several opportunities for shortening, 

they have little value per se. In some specific cases, to be noted later, I will recommend some 

targeted shortening and lengthening in my comments related to charge questions.

3. It is extremely important

4. Throughout, the old studies (i.e., those presented in previous documents) are summarized, and 

the new studies are discussed in more detail. The goal of this artificial separation was to keep the 

to add tables of effects to this ISA. This draft ISA has no human 

clinical or toxicology tables. There are several very good epi tables/figures, but some of the 

existing ones only have exposure information, without an indication of the effects. The text is 

quite complex due to the number of studies. The text often represents a good, but very 

inadequate, attempt to describe study parameters and outcomes. When the text is complete (e.g., 

species, strain, sex, age, ppm, exposure pattern, time of examination, parameters, lowest 

concentration showing effects), the findings and interpretation are obfuscated. A table would 

permit the text to be more qualitative. Also, when a number of studies with different details and 

different outcomes are presented, it is extremely difficult to get a handle on the weight of the 

evidence. Tables would reduce this problem. Having all the studies (old and new) in a table 

(ranked by exposure rather than by date of publication) enables a shorter integration of the body 

of work in the text. The human clinical sections of chapter 6 offer an excellent argument for this. 

There are several dozens of studies at very relevant concentrations with very relevant response 

measures and effects. There is a lot of information that contributes to susceptibility factors and 

exposure-dose-response, but it is buried. In some cases, such information is missing (e.g., 6-43 

L32ff) due to the overly brief summary of the studies in the 2006 AQCD. In many cases, one 

would need to look at the underlying references to get an understanding. Tables would solve this 

major problem. Page 6-134ff provides a good example; the one paragraph talks about CNS 

effects in the older study, without providing any information at all on exposures (except for a 

concentration regression from one epidemiology study). The epidemiology sections of Chapters 

6 and 7 have tables. Some are extremely useful (e.g., the ones showing the outcome and study 

details). Some should be expanded. For example, Table 6-9 on p6-33 only has study 

characteristics without indicating results. The results are buried in the text. Making this change 

would require significant effort. Probably, the easiest approach would be to expand the tables 

from older AQCDs. If you do this, please be aware that the 2006 AQCD is missing some 

important studies cited in the 1996 AQCD. Also, after the tables are created, it is important for 

them to be in reasonable proximity to the text discussion of the papers cited there. For example, 

the tables should not be in a separate document or separate chapter. I appreciate that the authors 

are under a great deal of pressure to keep the number of pages down. Tables would increase the 

number of pages. But, they are fundamental to clarity and understanding. Imagine a research 

paper in which there were no tables or figures of data. The paper would either be very long 

because the same information was spelled out in the text or the paper would be useless.
33

length of the document under control, but unfortunately this ISA does it at the expense of 

understanding the exposure-response effects of O3. EPA regulations need to be based on key 

studies, underpinned by supporting evidence. In some cases, the key studies are buried because 

they are old, and less important studies get space just because they are new. A preferred 

approach is to include tables of all the high quality and relevant studies and use the text to 

discuss the key studies fully with a shorter discussion of the supporting studies, independent of 

their year of publication. 

5. One approach is to delete all discussion related to research needs. At present, such discussion is 

spotty throughout; sometimes saying nothing for major needs, sometimes saying something 

about minor needs. Such research needs should be a separate effort.

Specific Comments

1. In my opinion, there is excessive duplication, especially with the summaries. Also, there is 

excessive duplication between discussions of MOA, effects, and susceptible populations. Some 

of these overlaps are necessary. None do any real damage. However, the length of the document 

is affected. Examples and suggested changes follow:

a. The purpose of Chapter 2 is not clear. It is well-written, but duplicates subsequent 

summaries exactly. Because it has an inadequate discussion of exposure-dose-response, 

no references, tables, or much specificity, it is not useful. Chapter 2 could be deleted 

because of its exact duplication to chapter summaries or entirely revised.

b. In some cases, the attempt at brevity can cause misunderstanding and be a show-stopper 

to some readers. This typically happens when human studies are described with an 

concentration but without an indication of whether exercise was involved (e.g., 2-17. 

L20). Add the exercise statement with an adjective (e.g., moderate, heavy). In many 

cases, animal studies are described with no indication of the exposure duration (e.g., 2-

26 L8; 2-46 L22). Minimally, the term acute, subchronic, and chronic should be used.

2. One approach to shortening is to have a major editing effort to catch minor duplications. I won’t 

cite them all here. One such example is on p1-18 in which there is excessive duplication in the 

area between L3 and L24. Another example is 5-7 L35-38; true, but generic and already said in 

introductory sections.

3. One approach to shortening is to focus more on results than the tools (e.g., methods, models) 

used to obtain the results. Indeed, the tools need to be described, but in some cases (especially 

chapter 3) the discussion focuses on the tools (models), with very little discussion of the 

modeling results.

4. One approach to shortening is to delete the artificial separation between “old” studies of previous 

documents and the “more recent work”. Actually, my greater concern is that such an artificial 

separation makes the ISA intellectually “choppy”, hard to understand, and does not provide the 

full picture of exposure-dose-response. This is a far greater problem than length. In virtually all 

cases, it is necessary to compare the old with the new, causing reiteration of the basis of 

comparison. There could be value in identifying those conclusions that are changed or 

unchanged from the previous document. If unchanged, a sentence or 2 would suffice. If changed, 

then a more rigorous discussion would be needed. Some examples of problems are:

a. 5-6 under “recent publications” discusses older work L34ff. Mudway and Kelly (1998) 

are in both places.

b. 5-14 L26 is in the “old” section, but contains a 2007 study. 5-15 L4 is in the new section 

but discusses “past studies”

c. 5-20 L1-16 (new section) is a study by Tsujino et al, 2005, described in some detail, 

including the statement on L13 that the model is limited in such a way that I think it has 
34

little (or no) value to the conclusions. Thus, some valuable old studies are truncated, but 

new studies are described in detail, sometimes beyond their value.

d. 5-40 is “new” material. However, older studies are included.

5. Chapter 5 contains BOTH dosimetry and MOA. There is no reason to put them together. The 

MOA should be integrated with its related concept/item. For example, MOA of interaction of O3 

with ELF would stay in dosimetry, but MOA of inflammation would be in the effects chapters. 

The MOA section 5.2 has several instances of describing effects, rather than MOA, as well as 

instances of having to describe the effect which is discussed later (i.e., duplication). In some 

cases, the effect referenced is not discussed later in the appropriate effect chapter. I recognize 

that this is very difficult to untangle because some MOAs (e.g., inflammation) are a pathway to 

several effects. Some examples follow:

a. 5-8 L1-2. This is a very important concept, but no details are provided here under dose. 

The reader is then referred to the MOA section for these details.

b. 5-30 L35 ff. Over half a page is devoted to effects of O3 on sRaw, with emphasis on 

effects. It’s a stretch to see why this is in the MOA section. Many, but not all, of the 

references are in Chapter 6, leading to duplication.

6. When studies are cited in the text, important parameters to the outcome need to be included, 

either in new tables or the text. For example, the text should always indicate whether the humans 

were exercising or not, and if so, whether it was light, heavy, etc. (p3-37 L2 and several other 

places it doesn’t). 

CHARGE QUESTION 2: The framework for causal determination and judging the overall weight of 

evidence is presented in Chapter 1. Is this framework appropriately applied for this O3 ISA? How might 

the application of the framework be improved for O3 effects?

Specific Comments

1. 1-10 L6ff. These statements that animal studies are normally very high is generically true for 

toxicity testing, but NOT for O3. Most of the O3 effects of concern are observed in animals at 

<0.5 ppm; many are observed <.2ppm. Considering dosimetric differences, these are roughly 

equivalent to human ambient exposures. The text (L8) goes on to say that “Such studies” (i.e., 

those are very high concentrations) were considered. Earlier (1-9), the text has a better 

description of the use of animal studies. The bottom line is that O3 animal studies at 

environmentally relevant concentrations are fundamental to causation and the range of effects. 

Thus, I suggest L-7 sentence (“Due to...response) be deleted.

2. 1-24 L21ff. This whole subsection is “Concepts in evaluating adversity.” This is one of THE 

most important sections of the document and further explanation would be helpful to users. 

Specifically, please explain the ATS official statement about adversity, as relevant to O3, in 

some detail. 

Minor Comments for EPA’s consideration, but not needing discussion at the meeting

1. 1-15 L22. Consider adding “and ethical constraints”. This change covers the limitations 

discussed in the immediately following text. 

2. 1-18 ff This section reduces the value of animal toxicology studies, relegating it to insights and 

MOAs.

a. L4. Consider making this paragraph more relevant to O3 by adding “the effects of O3 on” 

before “human physiology” and deleting “putative” on L5.
35

b. Add a thought somewhere in this area about being able to detect and describe effects that 

can’t be measured in humans, such as morphological changes, birth defects, and tumors. 

This contributes significantly to understanding severity of effects.

c. L 10-13 The limitations of animal-to-human extrapolation are correctly described, but the 

strengths of such extrapolation are not even mentioned. For example, a discussion of 

homology should be included. 

d. L12 and L17. What “hormonal regulation”. Maybe there are new studies I’m not aware 

of or the ISA has a different definition. It’s easier to just delete it and add “respiratory 

tract biochemistry”. 

3. 1-23 L38 Add “activity patterns” and “exercise levels” to the list of factors that influence 

exposure. These are quite important and likely to be more important that some of the others 

listed.

CHARGE QUESTION 3: Chapter 2 presents the integrative summary and conclusions from the O3

ISA with detailed discussion of evidence in subsequent chapters. Is this a useful and effective summary 

presentation? How does the Panel view the appropriateness of the causal determinations? 

General Comments

1. Whether it is useful and effective is dependent on the audience. As mentioned in my response to 

Charge Question 1, I believe much of this chapter is highly duplicative, doesn’t describe 

exposure-dose-responses, has no research references, and therefore should be deleted or revised 

significantly.

Specific Comments (Note: Since much of Chapter 2 is an exact duplication of material in the main 

chapters, the problems identified below are also relevant to their correlated chapters)

1. 2-2 L5-7 This language refers strictly to concentration-response but then goes on to include and 

exposure duration, which is NOT part of concentration and ignores exposure patterns/dose rate. 

Both concepts need to be clarified. The inclusive language on L5 would be to say “exposuredose-response”. The expanded form would define each term and include the concept of delivered 

dose and exposure pattern/dose rate. Another example of this problem is on 2-34, L22 which 

starts as C-R, but then adds C-V-D.

2. 2-16 L24 and many other places. Respiratory tract anatomy and dosimetric regions are not 

defined consistently. “Deeper” has no scientific meaning. Create a standard terminology and 

stick to it (RT, URT, NP, LRT, NP, TB, A or P), going into more detail when needed (e.g., 

PAR).

3. 2-31 Section 2.5.1 on “potentially susceptible populations”. Where is the discussion of exercise 

and greater exposures (as a function of activity pattern) as factors? It is implied with the 

statement of “air conditioner use”, but these two factors are probably greater susceptibility 

factors than genetic polymorphisms. Susceptibility of children has less than one line, which is 

way too little. 

4. 2-29 L29ff. This sentence talks about dietary deficiencies. It is too “summarized” and sounds 

stronger than the data. An additional sentence referring to the database (e.g. deficient and then 

supplemented). 

5. 2-36 Table 2-3. For airway hyperresponsiveness. Why aren’t human studies mentioned for the 

2011 ISA. As is, it appears that the newer data refute the older conclusions on this important 

point. 

6. 2-36 Table 2-3. Symptoms are not discussed in the preceding text of Ch 2.
36

7. 2-44 L15 I see no evidence that animal tox and human clinical data support mortality in epi 

studies. Even the chronic animal studies have no mortality at reasonable concentrations. This is 

too big a stretch.

Minor Comments for EPA’s consideration, but not needing discussion at the meeting

1. 2-2 L25. Delete “potential”. The effects are real.

2. 2-16 L16-28. Please add a sentence or two about extra-pulmonary effects.

3. 2-18 L19. Delete “may” and insert “of laboratory animals” before may. There is no doubt about 

it in animals.

CHARGE QUESTION 5: Chapter 4 describes human exposures to O3. Is the evidence relating human 

exposure to ambient O3 and errors associated with exposure assessment presented clearly, succinctly, 

and accurately? Are the results of field studies evaluating indoor-outdoor and personal-ambient 

exposure relationships, and factors affecting those relationships, presented in a manner that is useful for 

interpretation of epidemiologic results? Is the information on modeling O3 concentration surfaces and 

population exposures appropriate for evaluating the utility of these modeling approaches? Do the 

characterizations of temporal and spatial variability of O3 in urban areas provide support for better 

understanding and interpreting epidemiologic studies discussed later? 

Specific Comments

1. 4-10 L9-10. This cites Anderson and says that “these [referring to previous lines] reaction 

products may have health effects in addition to, or greater than, those from O3 itself.” Firstly, 

the Anderson studies used simulated indoor air chemistry of VOCs and studied sensitization 

potential. They did not use O3. Thus, this citation does not support this sentence. The significant 

problem is that use of the words “in addition to or greater than” implies either additivity or 

synergism or that these compounds have greater potency. The Anderson paper does not support 

that. It could be changed to say that many of these reaction products have effects themselves, 

opening the possibility of interactions. 

2. 4-14 L26ff. Why is this section so brief? It should be expanded to give some examples of the 

results of applying the models. I realize that the OAQPS Exposure Assessment will provide a 

great deal of such results, but this section could add a few figures or tables.

3. 4-17 L1-6. Why is this section so brief? The Georgopoulos paper is not discussed in the 

previous AQCD, so it especially should be expanded here or criticized to provide a rationale for 

dismissing it.

4. 4-17 L32 ff. This new exposure model by NERL sounds exciting. It is appropriate to insert this 

clue at this draft stage if you expect it to be referencable at the time of subsequent ISAs.

5. 4-16. Figure 4-2. This figure is not needed and could be deleted for brevity. 

6. Please add a figure(s) that shows hourly personal exposure with variability—or something that 

gives the reader a feel for exposure patterns.

Minor Comments for EPA’s consideration, but not needing discussion at the meeting

1. 4-15 L15. Delete the word threshold since this gets confounded with the whole risk concept of 

threshold

2. 4-15 L38. Is a publication likely to be available during the draft life of this ISA.? If so keep it.

CHARGE QUESTION 6: The dosimetry and modes of action of O3 are discussed in Chapter 5. The 

primary focus of the dosimetry discussion is to highlight factors that might lead to differences in dose 

between individuals and between species. Some potential modes of action that may underlie a number of 
37

health outcomes and that may contribute to the biological plausibility of health effects of short- and 

long-term exposures are described in detail. Is the review of basic dosimetric principles of O3 uptake 

presented accurately and in sufficient detail? What are the views of the Panel on the approach taken in 

Chapter 5 to characterize modes of action for O3-related effects? 

General Comments

1. This chapter contains BOTH dosimetry and MOA. There is no reason to put them together. In 

my response to Charge 1, I argue for the MOA being integrated with its related concept/item. 

For example, MOA of interaction of O3 with ELF would stay here, but MOA of inflammation 

would be in the effects chapters. The current organization also leads to excessive duplication (see 

my response to Charge #1). 5-27 L17ff is another good example. It begins with effects and 

proceeds to talk about thickness of the ELF and mechanisms of reactions, etc.

Specific Comments

1. The Dosimetry section is fundamental to understanding animal-to-human extrapolation and intraindividual susceptibility. However, the figures are inadequate to display the key points, and some 

key points are not discussed at all or too briefly. For example:

a. 5-12 L14ff. This section on inter-individual variability is woefully inadequate in its lack 

of attention to age (only about 2 sentences on 5-13, L29). This would be the place to 

bring together concepts of preexisting disease states (e.g., asthmatics ELF). For example, 

having a figure of age-related dosimetry would be more useful than several of the other 

figures used.

2. In my view, Section 5.1.4 (5-16) “Species Homology, Sensitivity, and Animal-to-Human Dose 

Extrapolation”, is one of THE most important sections in the ISA because it: 

b. provides a scientific plausibility for human effects,

c. is fundamental to considering adversity in human studies, 

d. is crucial to assigning causality, 

e. and demonstrates a range of effects (e.g., chronic lung morphological changes) that 

cannot be measured in humans. 

Thus, I find it unacceptable that this section is only 3 1⁄2 pages long (after I ignore the figure that 

doesn’t add much). My recommendation is to expand it significantly; independent of what year 

the pertinent research was published.

3. 5-1 L1ff. The difference between concentration, exposure, and dose should be carefully defined 

here, given the propensity of some to use them interchangeably. For example, in L6 one 

definition of dose is actually concentration and this is not correct. Consider using Zartarian, 

Bahadori, and McKone, JESEE, 2005:15, 1-5 

http://www.nature.com/jes/journal/v15/n1/abs/7500411a.html . This paper is a summary of a 

WHO effort that was also adopted by the International Society of Exposure Science to 

standardize exposure terminology.

4. 5-1 whole page and throughout: Respiratory tract anatomy and dosimetric regions are not 

defined consistently. “Deep” has no scientific meaning (e.g., L17). What are (5-11 L4) upper, 

central, and lower airways? Create a standard terminology and stick to it (RT, URT, NP, LRT, 

NP, TB, A or P), going into more detail when needed (e.g., PAR). Fig 5-1 on 5-3 could be 

modified to be clear on this. The current figure doesn’t add much. Technically informed people 

already know it. Non-technical people would probably be better off with an understanding of the 

total RT. For example, 5-10 has a header saying “pulmonary O3 uptake and dose”. Later “lungs” 

are referred to. Pulmonary is alveolar. Lungs are LRT. This language must be more precise 

because some dosimetry studies included the URT and some didn’t.
38

5. 5-13 L8ff. This says “Variability in local dose may be attributed to ...physiology”. This is 

incomplete—variability is also significantly dependent on anatomy and biochemistry of the 

epithelial lining layer.

6. 5-16 L5. Greater care has to be taken with citing effect studies. For example, Emmons and 

Foster, 1991 is not cited in Chapter 6, but Frampton et al 1997 is.

7. 5-16 L17. This summary section talks about “major sources of variability in absorption of O3.” 

However, the list does not mention surface area, which is an important concept for deposition in 

children.

8. 5-17 L10-12. It is essential to add a reference here. Do you mean Gong et al. 1998? If so, it was 

at 0.3ppm. The sentence seems odd since humans can’t really be exposed to “very high” levels.

9. 5-19 Figure 5-5 adds nothing. It would be helpful to use a figure of exposure-responses, 

comparing different species (including humans)---in Chapter 6.

10. 5-21 ff The MOA section 5.2 is VERY uneven in presentation of exposure characteristics (i.e., 

male or female, animal species; concentrations, exposure patterns/durations). Having all 

information for each study in the text would be far too distracting. Thus, there should be a table 

with all the information and then a summary in the text (species and qualitative description of 

exposure duration; adding details like sex when the study made such comparisons).

11. 5-29 L6ff. Please add comments on systemic possibilities. For example, consider adding “and 

perhaps systemically” to the end of the sentence on L10. 

12. 5-22 L3 ff. This is a discussion of attenuation, but why is it under Section 5.2.3 “Activation of 

Neural Reflexes”. Then p 5-38 L24 (under Section 5.2.4 (injury and inflammation) goes on to 

discuss attenuation. These are other examples of the confounding of effects and MOA. The 

major story of attenuation is that it occurs for some effects, but not for others, may even 

contribute to effects, and is not long-lived. The MOA is interesting and contributes to 

understanding, but is not THE story. Thus, it belongs in Chapter 6. Virtually every section has 

similar examples, but I will not recount them all here. Moving all the MOA (except that part 

dealing with dosimetry) to the sections on effects will solve these problems. 

13. 5-39 L1 ff regarding attenuation has some problems. 

a. The Tepper et al 1989 paper is cited. The next sentence says: “Thus, the inflammatory 

response resembled that of the ...function...which was attenuated.” The “thus” is not 

correct. Tepper reported that inflammation was NOT attenuated. The abstract of his paper 

says “Acute ozone (O3) exposure in humans produces changes in pulmonary function 

that attenuate with repeated exposure. This phenomenon, termed adaptation, has been 

produced in unanesthetized rats. Rats exposed to O3 (0, 0.35, 0.5, or 1.0 ppm) for 2.25 h 

for 5 consecutive days showed an increased frequency of breathing and a decreased tidal 

volume on Days 1 and 2 of exposure at all O3 concentrations. However, by Day 5 these 

breathing responses to O3 were diminished in rats exposed to 0.35 and 0.5 ppm, but not 

in rats exposed to 1.0 ppm. In addition, a flow limitation in smaller airways was observed 

after the second day of exposure to 0.5 ppm O3 that initially attenuated and then 

disappeared by the fifth day of exposure. In contrast to these findings, a light microscopic 

examination of fixed lung tissue sections from rats exposed to 0.5 ppm indicated a 5-day 

progressive pattern of epithelial damage and inflammation in the terminal bronchiolar 

region. A sustained 37% increase in lavageable protein was also observed over the course 

of the 5-day exposure regimen to 0.5 ppm. Lung glutathione increased initially, but it was 

within the control range on Days 4 and 5. Lung ascorbate was significantly elevated 

above control levels on Days 3 and 5. These data suggest that attenuation of the 

pulmonary function response to O3 occurs in laboratory rats with repeated exposure 

while biochemical and morphologic aspects of the tissue response continue to progress.”
39

b. The text goes on to say what Christian et al, Hackney et al, and Horvath et al found. 

Please recheck the accuracy of these summaries. I did NOT go back and read the papers, 

but I think that the Christian et al one was quoted correctly. But the Horvath and Hackney 

ones may not have been. 

14. 5-43 L3-30. This is a good story. However, how does it relate to humans? Is there homology? 

Please be explicit.

15. 5-24 L14ff. This asthma MOA story has a lot of references, some of which are NOT in chapter 8 

(I didn’t check them all, but an example is Kreit et al 1989). All the effect studies need to be in 

the effect chapters. If you retain the MOA story here in chapter 5, so be it, but make sure the 

effect chapters are complete.

16. 5-57 L35 ff. This section on preexisting diseases doesn’t discuss MOA. It discussed sensitive 

subpopulations. It appears to be stretching for antioxidants, but it just doesn’t belong here.

17. 5-58 L27 ff. This section on life stage is predominantly effects. 

18. 5-60 L17ff. Adaptation is raised AGAIN in this chapter. The result is very disjointed.

19. 5-61 L1ff. This one-paragraph section on co-exposures doesn’t belong here.

20. 5-62. Figure 5-6. This figure has some good and some questionable elements. A schematic is 

often useful, but this one is not. Acute and chronic mechanisms can differ, but this schematic 

says nothing about the exposure duration. This schematic has solid and dotted lines to indicate 

“greater certainty” vs. “emerging interest”. The decreased pathogen clearance leading to 

impaired host defense was part of the very first O3 CD (circa 1970), but here it is indicated as 

“emerging”. Inflammation and injury has a solid line to immune system modulation. What is 

immune system modulation (parts would be solid, but parts would be dotted). Also, why is it 

yellow? Also, one of the most important effects is injury (remodeling), which is therefore 

deserving of its own box.

21. 5-62 L3ff. Delete “Gaps in Knowledge”. Research needs, either need, to be included everywhere 

as appropriate or nowhere.

Minor Comments for EPA’s consideration, but not needing discussion at the meeting

1. 5-2 L6. Do you really want to say adverse here and not lots of other places?

2. 5-19 L2. What is “overtly”?

3. 5-24 L5. The Long et al study is at odds with other studies. Why? Were methods different? Or is 

it the species and higher concentration?

4. 5-28 L31ff. This is a summary paragraph that belongs on the next page under 5.2.2.1.

5. 5-76 Tepper et al 1989 is one of the most important papers in understanding the impact of 

attenuation on health risk. HERO has the citation, but not the abstract or paper. The abstract is 

available http://www.ncbi.nlm.nih.gov/pubmed?term=tepper%2C%20js%201989

6. The structure of the MOA section is uneven within itself and compared to other sections. 

Specifically, many subsections start with the “old” material, without such a label, and then have 

a label for “new”.
40

CHARGE QUESTION 7: Chapter 6 is intended to support the evaluation of human health effects 

evidence for short-term exposures to O3. To what extent are the discussion and integration of evidence 

on the health effects of O3 from the animal toxicological, controlled human exposure, and epidemiologic 

studies, technically sound, appropriately balanced, and clearly communicated? Does the integration of 

health evidence focus on the most policy-relevant studies or health findings? What are the views of the 

Panel regarding the balance of emphasis placed on evidence from previous and recent epidemiologic 

studies in deriving the causal determination for short-term O3 exposure and respiratory effects (in 

particular, additional epidemiologic evidence for lung function and respiratory symptoms and new 

evidence for biological indicators of airway inflammation and oxidative stress that previously has been 

largely limited to human controlled exposure and toxicological studies)? The majority of new studies 

that examine the association between short-term O3 exposure and mortality focus on specific issues that 

have been previously identified. Does the structure of the chapter adequately highlight the breadth of 

studies (both older and new) that indicate an association between O3 exposure and mortality and 

provide the underlying rationale for the causal determination? Are the data properly presented 

regarding the credibility of newly reported findings being attributable to O3 acting alone or in

combination with other co-pollutants and regarding the extent that toxicological study findings lend 

support to the biological plausibility of reported epidemiologic associations in reaching a causal 

determination? Are the tables and figures presented in Chapter 6 appropriate, adequate and effective in 

advancing the interpretation of these health studies? 

General Comments

1. I only skimmed the epidemiology sections so my comments do not include them, except as 

noted. 

2. The causation statements are very well supported scientifically. Many have been well established 

for many years. This answer leads to the key questions (focusing on susceptible subpopulations) 

that require more attention, namely, what exposures are sufficient to cause the effects of interest 

and what is the severity of the effects at these effective exposures. I can find some answers to 

these questions interspersed in the text, but clarity on these issues would be very helpful. I 

recognize that adversity has policy implications vis-à-vis the CAA requirements. I am requesting 

a more extensive discussion of clinical interpretation of the effects in the human clinical studies. 

The epi studies are a bit easier to interpret (e.g., going to the ED or getting admitted to hospital is 

a relatively clear estimation of the severity/impact of exposures). 

3. Some important human studies cited in Chapter 5 (e.g., Bates et al, 2009 and Emmons and Foster 

1991 deal with smokers) are not cited here, but Frampton et al 1997, also on smokers, is in 

Chapter 5 and 6. Why? I suspect it is due to the confounding of MOA in too many places. I 

recommend comparing all the Chapter 5 MOA literature citations to the citations in Chapters 6 

and 7 and asking if some papers have not been fully used. The optimal approach, as mentioned 

above, is to move all the Chapter 5 MOA to the relevant effect chapters/sections.

4. With rare exception (some of the epi tables, e.g., Fig 6-3 supplemented with table 6-2) the tables 

are wholly inadequate, the reason being that there are no tables for clinical and toxicological 

studies. My comments in response to Charge Question 1 go into more detail on this. But, here 

are a few examples out of many:

a. 6-7 L7. The Schelenge et al studies are quite important, but there is no indication of 

whether exercise was used and if so, at what level.

b. 6-18 Table 6-1 sets forth key attributes of several epi studies but, at least to me, is 

deficient without another column of effects. This problem exists throughout.
41

c. 6-43 L32 ff summarizes the 2006 AQCD material on human clinical studies on 

pulmonary inflammation. A number of studies are referenced, with no indication of C, D, 

or V.

5. The artificial separation between old and new studies and MOA and effects leads to a choppy 

presentation and weak integration. My comments in response to Charge Question 1 go into more 

detail on this. The problem is especially troublesome in the case of human clinical and epi 

studies since they will form the predominant bases of the NAAQS. It is important to understand 

the whole scientifically valid database which has dependencies on C, D, and V. So giving details 

on new studies and just sweeping all the older ones into a few sentences doesn’t allow the 

needed integration.

6. The animal toxicological studies on respiratory morphological/morphometric changes are not 

adequately discussed. When they are mentioned, the discussion is buried, too brief, does not 

allude to supporting evidence, and does not discuss implications to severity of effects in humans. 

There are dozens of references to effects below 0.5ppm, down to 0.15 and 0.2 in non-human 

primates that are not included. The result of this problem is that the story of structural changes 

does not come through. It is correlated with inflammation and (at higher levels) with functional 

changes. Such structural changes cannot be measured in humans, but are very likely to occur, if

exposures are sufficient. Such information contributes to understanding of severity. Therefore, it 

is essential to add this information. Most of these studies are older, so the easiest approach might 

be to identify morphological studies discussed in the 1996 and 2006 AQCD that are not included 

here, add the details to a table, and create a 2-3 paragraph discussion of the findings and their 

implications to humans.

Specific Comments 

1. (This comment is a duplicate to that under the next Charge question on Chapter 7.) There is some 

confounding between Chapters 6 and 7 with regard to whether the studies were short- or longterm. For example, some 90-day studies were in both places. Prenatal exposure studies are in 

both places. The beginning text of each chapter should define the duration term. In some cases, 

duplicate discussion may be of value, but this could be part of the discussion (e.g., time trend for 

respiratory tract morphometric changes). The whole of the literature on neonatal exposures 

should be in one chapter or the other. 

2. 6-2 L6 Insert “non-asthmatic” before children (the original language conflicts with L35)

3. There are a number of problems with inconsistent use of terms. This leads to confusion. 

Examples follow:

a. 6-2 L11. This is the beginning of a repetitive use of the terms tolerance, adaptation, and 

attenuation as synonyms. The terminology is quite important because full understanding 

is essential to interpreting the severity of repeated exposures. One problem is that for O3, 

the term tolerance has been used historically to represent repeated low concentration 

exposures of animals that protect against subsequent exposure to very high levels of O3 

or other selected air pollutants. To avoid confusion, it is best to not use it. The use of the 

terms adaptation and attenuation has some precise differences and has been contentious, 

given the implications of the terms. It would be best to define them, and then use these 

definitions consistently.

b. 6-6 L1 ff. The terms square-wave and constant are used interchangeably. Also this area 

uses the word dose to mean CxDxV. Other areas are more careful about this. Continuing 

down, L22, the word “average” triangular exposure is used. What is the definition of 

average? Is it CxD or CxDxV? Also address this issue to Figure 6-2 on p6-10.
42

c. The term adverse or adversity is used in a few places (e.g., 6-138 L15). This results in 

two problems: (1) If it is used in one place but not other places, it implies that these other 

places are not adverse and we can ignore them; and (2) adverse has not been defined here 

and in any case, isn’t it reserved to a policy determination?

4. 6-2 L12. Add a new sentence to express the concept that attenuation does NOT occur for other 

types of effects. This is important because the current text incorrectly implies that successive 

exposures are no problem. Also, discuss the possibility that attenuation contributes to the 

persistent changes by “allowing” more O3 to penetrate and deposit to sensitive lung areas (e.g. 

PAR when rapid-shallow breathing switches back towards normal).

5. 6-2 L25. Consider changing “unknown” to “still speculative”. There are some suggestions, so 

unknown is not proper. Also, what about the concept that repeated respiratory infections might 

contribute to COPD?

6. 6-3 L22. This defines “O3 induced” as “effects that have been corrected for...filtered air 

exposures.” This is a significant problem because throughout the subsequent text, effects and 

O3-induced are both used. Thus, the L22 statement implies that when “effects” is used, it has not 

been corrected. Also, why present any study results as “uncorrected for FA responses” (6-98 

L5)? Without FA controls, the results are very difficult to interpret and use.

7. 6-4 L1. Add the concept that a shift to oronasal affects the pattern of deposition of O3 dose, 

which could be quite important. The current text implies that the only difference is a decrease in 

URT scrubbing.

8. 6-7 L18. This discussion of the Schelegle et al 2009 study is quite important because it goes 

down to 60 ppb, at which no statistically significant group effects were observed. Question: did 

EPA evaluate the quality of the statistics on this paper? Did the study have adequate power to 

detect effects? What exercise levels were involved?

9. 6-7 L30ff. This paragraph, going over to the next page, is a summary of the relationship between 

concentration and FEV1, considering all the human clinical studies. It needs further exploration. 

For example, since the importance of CxDxV is well established in acute human clinical FEV1 

studies, was there a difference in V or CxDxV in the studies described? Perhaps the CxDxV 

differences were responsible for the lack of statistical significance of the Schelengle study. 

10. 6-5 Figure 6-1 is helpful. More such figures would be helpful. Look back at the 2006 AQCD for 

suggestions.

11. 6-10 L10. This defines “clinically meaningful” changes of FEV1, citing ATS 1991. The public 

version of HERO does not have this paper. The reference in Chapter 1 also refers to ATS 

definitions of meaningful, but cite 1985 and 2000 documents (also not in the publically available 

HERO). This is quite important, so it is necessary to go deeper into the discussion of clinically 

meaningful, preferably in summary sections.

12. 6-10 L14. This says that the data from these 2 studies are unavailable. The reason for the Adams 

1998 data unavailability was provided earlier. The reason for the Schelengle et al 2009 being 

unavailable to EPA should be stated also. Apparently, the OMB A110 rules are not applicable, 

but what about the implications relative to the Information Quality Act? If these studies are used 

as a basis of the NAAQS, they need to be publically available and preferably peer-reviewed. If 

desired, there is precedence for having a group of expert’s peer-review such studies.

13. 6-11 L17. An adjective is needed before “effects”. Consider “spirometric”.

14. 6-13 L19-20. The term “increased risk” is used. Explain why decreased symptoms in these 

groups would lead to increased risk, especially considering the decreased effects of O3 on the 

elderly. I can see why a lack/decrease in symptoms in children would result in them not avoiding 

exposures that would lead to functional deficits. 
43

15. 6-15 L2ff. This paragraph should be balanced with a discussion of the improvements happening 

in people/animals that were dietary deficient originally.

16. 6-16 L7ff. Add Tepper et al 1989 to the end of the discussion since it is more definitive of 

persistence of effects.

17. 6-39 L1-2. This one sentence is totally insufficient to describe the older literature. The acute 

pulmonary function literature in animals is not especially important, but it adds background to 

the human clinical studies. Referring to a table would suffice.

18. 6-40 L4 ff. This new study (Cremillieux et al 2008) is intriguing because of the types of 

measurements (imaging); the intermittent vs. continuous exposure; and the finding of an 

obstructive pattern of effects (rather than the expected restrictive pattern). I did not read the full 

paper. Comparing the ISA text to the available abstract raised questions. The abstract says no 

change in inspiratory capacity, but the ISA text says no effect on lung capacity. Also, the ISA 

says that the effects of intermittent exposure were “more prevalent and severe.” From the 

abstract, they were more prevalent, but the abstract doesn’t mention severity. The abstract also 

doesn’t say whether the difference in prevalence was statistically significant. Because all these 

differences from the abstract and the relatively unique findings could be important the full text of 

the paper should be rechecked with an expert in animal lung function and structure after O3 

exposure and the ISA text should be expanded a bit.

19. 6-41 L27ff. This section references the Depuydt et al. (1999) study. I checked the abstract and it 

says that the exposure was for 4 hours so this should be added to the text. I also checked the 

2006 AQCD to see if it had more, but this study was only briefly cited in the tables and even 

more briefly in the CD text. I strongly recommend that this study be fully evaluated by an expert 

in such toxicology studies. I must question observing such at effect at 0.05ppm for 4 hours. It is 

out of sync with other studies on this topic. If it is a scientifically sound finding, the discussion 

needs to be significantly expanded. If not, an appropriate critique should be added or the paper 

not used.

20. 6-42 L30ff. This discussion of adaptation needs a reevaluation. 

a. L32 says “some adverse effects caused by acute exposure are absent after repeated...” 

Do you really want to use the word “adverse”. Also, it is true, but the story here is 

misleading because it does not go on to say that other effects don’t adapt.

b. The whole paragraph is a rehashing of what is in the previous 2 pages and doesn’t add 

anything.

c. The last sentence on this paragraph (6-43 L3) should be deleted because it is wrong (and 

adds nothing). The interest in pursuing intermittent exposure protocols dates back to UC 

Davis studies in the 1980’s. It’s important to give due credit to the pioneers.

21. 6-43 Section on humans and inflammation. The Corradi et al 2002 study (0.1ppm for 2 hr causes 

increases in breath markers of inflammation) is cited in MOA, but why not here also?

22. 6-43 L9. Reconsider the word “persist”. The time course of inflammation is very complex during 

and after acute exposure, as is discussed on the next page. Persist implies a steady state. 

Consider saying “is still observed for at least...”

23. 6-43 L32ff onto next page. This is a very unsatisfactory summary of the older literature on 

human clinical studies of inflammation. It has no details at all. A new study has details, with no 

ability to determine how it integrates with the older studies. Furthermore, 6-44 L4-5 emphasis is 

placed on the fact that inflammation responses “not elicit significant spirometric responses.” 

First, it is correct to say that they were not associated with spirometric changes. Elicit has a 

causation element. In any case, inflammation is important in its own right (e.g., roles in host 

defense, pathogenesis), even in the absence of spirometric changes.
44

24. 6-44 L7ff This discusses the time course of inflammation in humans. Consider using figure 6-4 

in the 2006 AQCD.

25. 6-56 L31. This quotes a study at 0.01 ppm. Please recheck the reference. The abstract says 

100ppb, which would be 0.1ppm. The EPA portal-HERO does not have the full text of this 

paper.

26. 6-57 L3. The Vancza study is cited. The discussion should be expanded to include more about 

the influence of age and sex. It is noteworthy that the researchers measured dose as O18, 

allowing a better evaluation of dose differences in the groups. The age story is complex, but 

important given the methods used.

27. 6-59 Section 6.2.4. This is the section on respiratory symptoms and medication use, but it is only 

epi. Symptom responses in human clinical studies should be cross-referenced.

28. 6-71 L27ff. This emphasizes physical removal. The concept of bactericidal activity of AMs 

needs to be incorporated here in the introduction (briefly since it occurs again on the next page 

under AMs).

29. 6-72 Section 6.2.5.2 on AMs Bactericidal activity needs to be mentioned as one of the primary 

functions.

30. 6-72 L2ff. This area is a good example of excess detail on new studies and the difficulty of 

summarizing old studies in such as way as to provide the range of effects. The Weissbecker work 

cited on L24 should be deleted since it was in vitro with no knowledge of comparable in vivo 

dose (in vivo, high concentrations are required to affect viability). This work was not cited in the 

previous 2 documents, perhaps for that reason. Other studies of value described in the 2006 

AQCD (e.g., Bhalla 1996 on chemotaxis and Cohen et al, 2001 and 2002, on superoxide anion 

production) were not included here. The Cohen work could be correlated with the Hurst studies. 

The Dohm et al 2005 should be deleted since it is on marine toads and extrapolation from rats 

and mice is difficult enough. The Klestadt et al, 2005 should be deleted since it is an in vitro 

study with unknown in vivo correlations and other in vivo studies on chemotaxis could be added 

(e.g., Bhalla). The Mikerov et al. 2008 work should be examined further with a view towards 

deletion because of the high in vitro exposure of surfactant proteins. It needs to be tied in or 

deleted. Minimally, it should be described further. The Devlin et al 1991 study on AM 

phagocytosis should be expanded because it is in humans (and got fewer lines of discussion than 

the toads).

31. 6-73 L29ff. This says “A relatively large body of evidence shows that O3 increases susceptibility 

to bacterial infections. The text then proceeds to summarize this large body in 4 sentences, with 

no references, except for a “new” study at 2ppm. This is totally inappropriate. As said on 9-74 

L1 (with no reference), the lowest observed effect was at 0.08ppm. This is deserving of more 

discussion, references (Coffin et al 1967 and Miller at al, 1978; see 1996AQCD for full 

reference), and a correct summary the increase in mortality is in streptococcal-induced mortality, 

not just mortality. This is an egregious example of ignoring the earlier work. For example, the 

Coffin et al was the basis for the very first O3 NAAQS (as Ox) and remains one of the lowest 

effective concentrations of O3.

32. 6-74 L3ff. For brevity, delete the work at 2ppm; it adds nothing.

33. 6-98 L6. This says “uncorrected for FA response.” This whole issue of uncorrected needs to be 

more carefully presented. For example, 6-5 L3 (Adams 2006) does not mention uncorrected, but 

6-9 L20 (Adams 2006) does mention uncorrected. Also, one is tempted to ignore research 

without appropriate controls. However, the discussion on 6-9 L23 makes comparisons showing 

that the uncorrected data are likely to be more conservative. Throughout, every time uncorrected 

data are discussed, they should be placed in context of whether they tend towards being more or 

less protective conclusions.
45

34. 6-100 L3. It says “continuum,” which is commonly defined as some kind of progression, with A 

leading to B and B leading to C. However, he list of effects is not necessarily progressive. 

Indeed, they are all observed (in multiple studies), but some are no connected, as in lung function 

decrements and inflammation. Thus, delete “potential continuum” and insert “understanding” or 

something like it.

35. 6-101 L4. This says O3 is not transported “to extrapulmonary sites to any significant degree.” 

This is at odds with Chapter 5 which basically says that O3 doesn’t get beyond the epithelium 

and may not even get to the epithelium. Thus, this section in Chapter 6 needs to be revised to be 

consistent.

36. 6-101 L24. The Fakhri et al 2009 study is discussed. This discussion should be revisited. The 

text implies an antagonism between O3 and CAPs and does not discuss the overall HRV. The 

paper says: “The primary analysis, change in HRV indices between the start and end of the 2-hr 

exposure period, yielded no consistent differences between the exposure categories (Table 2). HF 

HRV showed a statistically significant increase for the CAPs-only exposure (p = 0.046) and a 

similar trend for O3 exposure (p = 0.051) when compared with filtered air...However, when 

analyzing the CAPs mass concentration relationship for exposures with O3 (i.e., CAPs + O3 and 

O3 alone), there was a suggestion of negative dose–response slopes (Table 3) between CAPs 

mass concentration and several HRV indices.” In addition, they evaluated the asthmatics in their 

study, but this is not mentioned in the ISA.

37. 6-102 Table 6-23 does not have Dockery et al 2005. Why not? In any case, the table is not 

helpful since it doesn’t have results.

38. 6-128 L24. This sentence refers to CVS changes in humans “at very high O3 exposures”... so 

caution must be used in interpreting animal studies “(Section 6.3.1)”. I couldn’t find these 

studies here or in the 2006 AQCD. Even without knowing what papers are being referred to, it’s 

fairly safe to assume that many of the animal studies were at a higher concentration than the 

human studies. Not knowing of these human studies, I am reluctant to agree with the conclusion 

offered in the text.

39. 6-128 L28. The Bloch et al dog studies are mentioned. This is an unpublished report and in not 

contained in the publically available HERO. I know they were careful researchers and perhaps 

some of the data are contained in other published reports with Trent Lewis as the senior author. 

Thus, something needs to be done in keeping with the goal of only using peer-reviewed studies. 

Perhaps the EPA report was peer-reviewed or could be given to a panel of experts for peerreview. 

40. 6-129 L1. This says “high concentration O3...”, without providing the concentration. Thus, this 

paper is, for all practical purposes, useless. Again, a table is needed.

41. 6-133 L18 says increase HR and L19 says bradycardia. L19 and 20 say it is “uncertain if this 

effect is also observed in humans.” Please be more precise in the animal study statements and the 

comparison to humans, especially.

42. 6-134 L29ff. This paragraph summarizing the 2006 AQCD on CNS is totally insufficient. It talks 

about epi effects with no significant details, calling it “adverse”. The rodent studies are described 

in 2 sentences with no indication of what the species, O3 concentration, exposure duration, or 

specific endpoints were. Thus, there is no way to compare them to the new studies to better 

understand the weight of the evidence. The 2006 AQCD refers to studies showing effects at 

0.12ppm in animals, further indicating the need for fuller presentation. This area is an excellent 

example of the need for tables. As additional examples, all the Tepper et al (1982. 1983, 1985) 

papers should be discussed because they found effects of 6-hr exposures to 0.12ppm in rats and 

0.2ppm in mice on running wheel behavior. The Tepper (and a few other) behavioral references 

can be found in the 1996 AQCD (not in the 2006 AQCD). The discussion in the 1996 document 
46

discusses a potential MOA of avoidance of irritation, etc., without direct effects on the CNS per 

se. Thus, this issue needs to be explored further.

43. 6-135 L32ff. This section discusses potential relationships between relevant O3 exposure of rats 

and Alzheimer’s. Thus, it is very important to discuss fully and precisely. This section should 

therefore be revisited. Why are these studies “consistent with Alzheimer’s incidence in the 

elderly”. Incidence is a frequency of new cases. There are still significant questions beyond this 

word choice.

44. 6-137 L1ff. This paragraph discusses CNS effects on offspring of rodent’s exposure during 

pregnancy. There is no discussion of the scientific issue of exposure, vis-à-vis windows of 

susceptibility. One of the studies discussed here did not indicate when the exposure was 

delivered. Also, the word “adverse” in used several times in this paragraph.

45. 6-137 L13 and 6-138 L12. Both places say that “levels as low as 0.3 ppm” had CNS effects in 

utero. The paper indicates that lower concentrations were not tested. Therefore, there is no basis 

for the phrasing. For example, if they had tested 0.2ppm, there might have been effects. Thus, 

just state the effective concentration used.

46. 6-138 L15. I agree with the conclusion “suggestive of a causal relationship”. However, I am 

concerned about the use of “adverse” as an adjective for effects. What is adverse? Is there some 

reference about clinical significance of these changes in rodents that could be cited?

47. All the extrapulmonary sections need to be revisited for concordance of discussion of MOA 

regarding extrapulmonary mediators. I don’t disagree with any particular sentence. The problem 

is the differences in presentation throughout.

Minor Comments for EPA’s consideration, but not needing discussion at the meeting

1. 6-6 L32. Adams 2006 is the reference, but there are 2, necessitating an a and b.

2. 6-8 L6 Please untangle the Kim et al study since it was statistically significant.

3. 6-8 L31 The McDonnell ref has a typo.

4. 6-12 L25 So far, this is the first time I noticed “in this well designed study...” Do you really 

want to say that. What about all the others—were they not “well designed”.

5. 6-14 L34. There is nothing “pseudo” about it.

6. 6-15 L32. It says “better”, implying that the others were poor in some way.

7. 6-40 L4. The discussion of Farraj belongs under section 6.2.2.2 unless only the non-sensitized 

animal are discussed here.

8. 6-40 L6-7. This last sentence should be deleted. It is true, but bears no relationship to the 

preceding material. 

9. 6-42 L5. This says, “Thus, recent ...monkeys, guinea pigs, and mice...” However the preceding 

discussion of the recent studies does not mention monkeys.

10. 6-43 L6. Insert “increased” before “epithelial”

11. 6-58 L8. This is the only place I recall seeing in which the FA concentration (0.02) was reported. 

Either do it for all or none, except if it was a key factor in the study itself.

12. 6-71 L15. Just say 0.2 and higher. Saying 1.0ppm is OK if you are sure there are no studies at 

higher concentrations.

13. 6-73 L6 call 90 days sub-chronic.

14. 6-128 L15 Consider deleting “and other photochemical oxidants” because they are not discussed 

here.

15. 6-133 L27 This summary says “leading to the reported cardiovascular pathologies.” Pathologies 

is a very strong word; far too strong for this database in animals. Thus change to “effects.” 
47

16. 6-135 L30 specify that the increase in glutathione was in the brain. 

17. 6-136 L24. Unless you calculated dose, change to concentration-dependent.

18. 6-138 L18 Insert “drug-induced” before sleeping time.

CHARGE QUESTION 8: Chapter 7 presents important new findings from studies published since the 

2006 O3 AQCD including studies that examine the relationship between long-term O3 exposure and new 

onset asthma in children, first childhood asthma hospital admissions, increased asthma severity, 

bronchitic symptoms and respiratory-related school absences. These studies provide evidence in this 

regard based on different genetic variants. What are the views of the Panel on the conclusions drawn in 

the draft ISA regarding the strength, consistency, coherence and plausibility of the evidence for health 

effects for long-term O3 exposure on respiratory morbidity? Limited new data also suggest a link 

between long-term O3 exposure and respiratory mortality; what weight should be placed on this 

evidence in causal determinations? What are the views of the Panel on the conclusions drawn in the 

draft ISA regarding the strength, consistency, coherence and plausibility of the evidence for 

neurological effects resulting from long-term O3 exposure? Are the data properly presented regarding 

the credibility of newly reported findings being attributable to O3 acting alone or in combination with 

other co-pollutants and regarding the extent that toxicological study findings lend support to the 

biological plausibility of reported epidemiologic associations in reaching a causal determination? 

General Comments

1. I only skimmed the epidemiology sections so my comments do not include them, except as 

noted. 

2. I support the causality conclusions, with one However, I an expanded discussion the animal 

toxicological data would offer more support to the conclusions and, more importantly, assist in 

interpreting severity observed in human studies. In particular, the first sentence on animal tox 

studies (7-14) dismisses all rodent data. This is wrong. In particular, there are a number of 

excellent chronic animal studies not cited or discussed too briefly that show numerous types of 

morphometric changes, some of which are irreversible; findings that can’t be measured in 

humans. Dosimetric comparisons of these rat studies to humans are possible, but not done. The 

discussion of interspecies homology is inadequate. The discussion on the effects of age and 

exposure pattern on respiratory tract morphometry is inadequate, resulting in losing whole 

concepts about the effects of O3. See specific comments below for details of the foregoing. 

The exception is (7-62 L19) “... the evidence is suggestive of a causal relationship between 

long-term O3 exposures and all-cause mortality”. I am not familiar enough with the epi studies to 

comment on them. However, I know of no such evidence from the human clinical and animal 

toxicology studies. Thus, it is important to expand significantly on this part of the discussion.

3. The discussion of animal toxicology studies throughout is insufficient because so many key 

studies were omitted and some are misquoted. For example, there are at least 3 major studies of 

seasonal effects, but only one is referenced. There are several on age, but only 1-2 are 

mentioned. Thus, although I fully support the weight-of-evidence evaluation that relies on animal 

studies, I support it based on what I know, not on what is restricted to the references presented. 

More specific comments on this topic follow. Briefly, it is essential to make sure all of the key 

animal tox studies of the 1996 and 2006 AQCDs are included here. This can be done with 

significant use of tables. I included the 1996 AQCD because it has some key studies not included 

in the 2006 AQCD. 

4. As I have mentioned under all other charge questions I addressed, the separation between old and 

new literature is artificial and results in a suboptimal understanding of the whole of the findings. 
48

Specific Comments

1. (This comment is a duplicate to that under the previous Charge question on Chapter6.) There is 

some confounding between Chapters 6 and 7 with regard to whether the studies were short- or 

long-term. For example, some 90-day studies were in both places. Prenatal exposure studies are 

in both places. The beginning test of each chapter should define the duration term. In some cases, 

duplicate discussion may be of value, but this could be part of the discussion (e.g., time trend for 

respiratory tract morphometric changes). The whole of the literature on neonatal exposures 

should be in one chapter of the other. 

2. 7-14 L14ff. This first paragraph is the introduction to the section of animal tox studies of 

structure and function. The first few sentences generally dismiss animal studies. Indeed, 

quantitative extrapolation is difficult, but qualitative extrapolation is generally accepted if the 

database is strong enough. As a superficial general statement, subchronic and chronic studies 

(<0.5ppm) from several laboratories of several species of mice, rats, and non-human primates 

have shown similar morphometric changes, many of which would be considered “adverse”, at 

least for that population studied. Given the similarities among all these species and their 

similarities to humans, it is very likely that these same effects could occur in humans, if exposure 

was sufficient. Homology is strong. Quantitative extrapolation requires understanding of both 

interspecies dose and sensitivity (e.g., repair mechanisms). Dosimetric extrapolation for rats is 

advanced and could be developed for some of the key studies .

a. Thus, the first sentence is incorrect when it says that “considerable controversy 

surrounds the extrapolation of data generated by rodent toxicology studies...” This 

implies the studies are of no value. I don’t know of any “controversy” among 

knowledgeable people (even with different points of view) about the concepts of 

homology. Most informed people acknowledge the uncertainties involved in quantitative 

extrapolation. So even the word “controversy” is wrong. It would be accurate to discuss 

the issues of certainties AND uncertainties in both qualitative AND quantitative 

extrapolation.

3. 7-15 L23. Add “where dosimetric models indicate the dose is higher” to the end of the sentence. 

This is important because it adds evidence of the accuracy and value of dosimetry models. 

4. (NOTE: this comment could be made for virtually all of the sections including animal toxicology 

descriptions ) 7-14 ff. Many key studies are not cited in this section; and according to HERO, 

they were not even on the list of considered but not used. I only cross-checked a few. There 

probably are many more. The easiest way to check is to compare this ISA text to the 2006 and 

1996 AQCD. Unfortunately, the ones I identified are also missing from the 2006 AQCD. It is 

NOT necessary to include each and every paper in the text. It is necessary to include all relevant 

papers in tables and use the text for papers that demonstrate key concepts of interest or suggested 

in humans (e.g., age, seasonal exposures, daily patterns of exposure, irreversible effects, 

correlated endpoints, and fibrotic changes). The few I identified to explain my point are (see 

1996 AQCD for full citations): 

a. Chang et al (1991, 1992)rats; simulated urban pattern of a base of 0.06 O3, on which was 

superimposed a spike rising to 0.25; 78 wk exposure, with periodic exams and postexposure evaluation to assess recovery; advanced morphometric methods. Shows 

complex pattern of time course of effects during and after exposure ceases.

b. Barry et al (1985) rats; 0.12ppm for 6 wk; Compared morphometry of 1-day old and 6 

wk old (at start of study). Some age effects.

c. Pinkerton et al (1995) rats 0.12ppm, 20 mo. Epithelial and interstitial effects
49

d. Tyler et al (1991) rats; 0.25ppm; “continuous” and “seasonal” exposure regimens over 18 

mo showing impacts of on-off exposure regimens, approximating the real world of 

winter-summer sequence. In some cases, patterns equal (even with lesser “dose”); in 

other cases, seasonal had different effects.

5. L23 ff. The Plopper studies of adult and infant non-human primates are described well and are 

extremely important. Therefore, it would be of great value to add additional references from 

different studies (in rats and non-human primates) that support many of the findings. These 

supportive studies are provided in the 1996 and 2006 AQCDs. This could be done briefly, with 

reference to tables that will be added. 

6. 7-17 L7-26. This whole paragraph describes acute studies (on the order of hours), although this 

is a long-term exposure chapter. These studies are already in Ch 6. The goal of this paragraph 

was apparently to provide references to rodent studies of age to buttress the Plopper studies. This 

could be done better by citing the several subchronic and chronic rat studies that are not included 

here (see my comment earlier with references).

7. 7-17 L27ff. This is a summary paragraph. I fully agree with the first sentence. However, I am 

concerned about the claim on L30 that the functional and structural changes are “due to 

persistent inflammation.” Some animal studies show a time-course shift away from acute 

inflammation and more towards interstitial changes (including increases in fibroblasts). Any 

statement of “due to” is complex and dependent on an evaluation of multiple studies, most of 

which are not even described here. The implications of the next sentence (L31) are true, but not 

strictly correct because it refers to “these findings”, referring to references of one excellent set of 

studies. If the reference were expanded as recommended above, the sentence would be correct.

8. 7-19 L6. The phrase “protective adaptation” was used. The interpretation is that longer-term 

seasonal exposures have no effect. The Carey study referenced had effects in both the acute and 

seasonal group, so there were still effects of concern. This area goes on to quote the Harkema 

study (L7) to 0.3ppm. I used the link to read the paper and the paper was at 0.15ppm for 6 or 90 

days (8h/day). The Harkema study showed effects at 6 days, but not 90 days. There are all sorts 

of exposure duration/pattern studies not cited here, so care must be exercised in only citing 2. 

Furthermore, the adjective “protective” needs to either be deleted or justified.

9. 7-19 L8-10. The Schmelzer study is on BAL, whereas the paragraph is on nasal effects. 

10. 7-20 L30ff. This is the summary and causal determination section for respiratory effects. The 

summary of toxicological evidence is quite insufficient, probably because the base offered in the 

text is weak (as opposed to the database, which is strong). In addition, the summary should be 

fully integrated, rather than separating the old and the new for just these 2+pages.

11. 7-25 L1. Briefly explain ApoE mice (i.e., model of atherosclerotic lesions) and the strengths and 

limitations of this animal model.

12. 7-26 ff. The whole section 7.4 on reproductive and developmental effects should be reviewed by 

an epidemiologist expert in this area, if this has not already been done.

13. 7-26 L26-27. This causality statement refers to “relevant” exposures. What is “relevant”. Also 

other causality statements don’t have such an adjective. Therefore, delete it to avoid confusion.

14. 7-27 L37. This says that the studies didn’t identify specific pollutants and their concentrations. 

Thus, why include them if there is no way to track to O3? Consider deleting them.

15. 7-28 L1ff. Studies of sperm counts and related indices are very difficult methodologically. 

However, there is no discussion about the quality of the studies. Please add a discussion.

16. 7-29 L8. This says “...O3 was no longer significantly associated with IVF failure.” OK. 

However the next sentence says that O3 had effects. This sentence therefore needs to be deleted 

or the study results challenged.
50

17. 7-29 L21. This animal study on spermatogenesis should be moved over to the section on sperm 

(p 7-27 7.4.1).

18. 7-34 L6. I did not read the entire epi section. When I look at this summary of studies that are 

characterized as inconsistence, I fail to see evidence for the hypotheses of effects. First, there 

may be no consistent effects. Where is the evidence for “decreased in utero oxygen supply, 

...changes in blood viscosity...” etc.?

19. 7-44 L23 ff. This was an interaction study with 1ppm O3 (intermittent for 1 month) and 0.48 mg 

particulate matter delivered intratracheally, repeatedly. The unrealistic nature of this exposure 

regimen needs to be discussed and taken into account in the interpretation.

20. 7-54 L32ff. This section summarizes the NTP O3 cancer study in mice and rats. Although the 

overall summary(L36) for mice is correct, the details provided above are not. There were 

differences between the “lifetime”-exposed and the 2 yr-exposed mice that are not discussed. 

The same NTP study had rats (7-56, L3) but only Boorman et al is cited (this is correct, just add 

the NTP reference). Because this is the most complete and rigorous study on the topic, it should 

be discussed in more detail. The easiest approach would be to add the information to a table (see 

the text and tables in the 1996 AQCD). Also, this well-conducted study did not find effects on 

mortality, which should be stated given the later conclusions about chronic O3 exposure and 

mortality.

21. 7-56 L32ff. This discusses the Kim and Cho studies and says that a 10% incidence of oviductal 

carcinoma was observed at one point in time. The text raises questions about this. Since these 

investigators used the same mouse strain as the NTP study, add a reference to the NTP study 

which found no statistically significant increase in tumors at any site other than the lung.

Minor Comments for EPA’s consideration, but not needing discussion at the meeting

1. This chapter needs editorial “clean-up”. Specifically, sometimes the text has a couple of 

sentences describing a study, but doesn’t give the ref and exposure information until the end.

2. 7-20 L9. Insert “macrophage” after “alveolar”.

3. 7-27 L5. Please clarify. For example, why “indirect effects on the mother’s health”. What about 

direct effects on the pregnant or lactating woman’s health that result in indirect effects on the 

fetus/infant.

4. 7-29 L25. This summary statement needs to be its own paragraph. Furthermore, The phrase “low 

doses” should be removed since they were concentrations, not doses, and what is “low”. Since 

the studies showing effects were at 0.8 and 1ppm, “low” is not appropriate.

5. 7-44 L31. The Plopper studies should stay in the other sections where they were discussed (e.g., 

7.2.3). This section is on birth defects and deals with prenatal exposure, which was not included 

in the Plopper studies.

CHARGE QUESTION 9: Chapter 8 is a discussion of potential susceptibility factors. Are the 

characteristics included within the broad susceptibility categories appropriate and consistent with the 

definitions used? Are there any key susceptibility factors that were not included and need to be added? 

1. The definition of susceptibility (8-1) is very good. It includes susceptibilities related to the 

magnitude/duration of exposure and health/genetic factors. However, the text that follows does 

not seriously include the exposure side (see specific comments section below). A specific 

exposure and dose subsection should be developed.

General Comments

2. This chapter is extremely important because the “average,” “healthy,” “sedentary” person is not 

at significant risk from “typical” ambient exposures. In contrast, susceptible subpopulations are 
51

of significant concern. Therefore, having a clear description of the following for each 

susceptibility “group” is crucial to interpretation of risk (note: in many cases this information is 

provided):

a. What is the prevalence of this group in the general population (this is especially 

important for the genetic polymorphisms; and for different exercise levels). Consider a 

table for this.

b. What is the nature and severity of the risk. For example, where is the discussion that even 

if COPD patients are not more affected in terms of % reduction in FEV1, what is the 

impact of their having less reserves to cope with this “similar” change in FEV1. What is 

the number of hospital admissions for asthmatic children? What does a 5, 10, 20 % 

change in FEV1 in healthy exercising young people mean to their well-being?

c. What is the concordance of human clinical, epi, and animal tox data for this group?

d. Does this group have characteristics that result in greater exposure and/or dose?

3. This chapter does not (and should not) repeat all the studies on susceptibles contained in earlier 

chapters. However, the rationale for those chosen for expanded discussion here are not clear. A 

more concerted effort is needed to identify the definitive papers for each susceptibility class and 

then proceed to describe them, with a very brief cross walk to the larger body of information 

within the other chapters (hopefully contained within tables in the revised ISA).

4. I’m not clear about the criteria used for the discussion, vis-à-vis old and new. I strongly 

recommend that the full story (not essential to have all the referencess, as per my comments 

above) be provided for each susceptibility group, independent of date of publication. For 

example

a. 8-6, L15-16 says “Recent epidemiological...” Is there old epi evidence on this point? 

What’s the story?

b. 8-6 L22 says “no recent evidence...controlled human...or toxicological studies.” It then 

goes on to discuss recent epi. What about supporting old evidence? What’s the story?

c. 8-7 L27 is about lifestage and overemphasizes new studies. What’s the story?

1. 8-3 L1ff. Please add a cross-reference to animal infectivity studies. 

Specific Comments

2. 8-3 L12. This says that asthmatics had no increased susceptibility.

3. 8-8 L31. This says comparable O3 doses. Please define dose.

4. 8-8 L38ff. This refers to dosimetry modeling by age. It should not be buried.

5. 8-23 L30ff. This summary identifies populations “that are most susceptible...” . However, it 

includes older age groups and doesn’t talk about younger age groups. Also, why aren’t those 

with higher exposure identified as a group?

6. 8-24 L13ff. This talks about “individuals involved in outdoor activities...in a recent study...no 

effect modification was observed.” The next line summarizes old studies that disagree. So, what 

was the weight of the evidence. What study—what is meant by “effect modification?”

Minor Comments for EPA’s consideration, but not needing discussion at the meeting

1. 8-10 L 4This talks about senescent rats, but the section on older adults is below it.

2. 8-18 L20. This says “at more relevant doses”. What were the irrelevant doses and if they are 

irrelevant, why are they even included? 
52

Dr. David Grantz

Charge Question #10; re: Chapter 9 (effects of ozone on vegetation and ecosystems)

Note: Locations in the text are referenced as [chapter-page/line].

Are major effects of O3 exposure on vegetation/ecosystems identified and characterized? 

The ISA does a nice job of recognizing the key effects of ozone on vegetation at all scales. An important 

point is made repeatedly, that new evidence obtained in chamberless exposure systems supports the 

broad range of conclusions derived from earlier Open Top Chamber experiments. It is therefore 

appropriate to pursue the analyses of ASPEN and SOY FACE experiments in the context of the 

NCLAN- and NHEERL-derived C-R relationships for crops and trees. The NCLAN studies imposed 

mostly chronic and relevant exposures, contrary to the implication in the text (2-55/22-23). It may be 

preferable to conclude (9-56/25) that the new data “...lie within the range predicted by the metaanalysis...”, rather than that they “...support the meta-analysis...”. This overall conclusion appears to be 

contradicted at 9-56/20-21, where alternative wording might be, “...enclosed fumigation systems or 

growth chambers. This did not appear to alter the sensitivity as previously suggested for OTC exposures 

(e.g. McLeod and Long, 1999...”. 

For clarity, the various references to this alignment of FACE and OTC data could be brought together in 

section 9.3.1 (9-18/19). For greater accuracy, it should be noted that for some crop species, the NCLAN 

relationships are probably conservative, since current varieties in many cases are more ozone-tolerant 

than those in production during NCLAN.

There is a tendency to equate alteration of complex physiological systems with direct effects. Following 

from this is a tendency throughout the chapter to equate differences in the sensitivity of various 

responses to mechanisms of resistance, as for the cutleaf coneflower (9-46/2), symptomatic and 

asymptomatic leaves (9-40/28), and gene expression (9-31 to 9-32). These responses are more 

appropriately interpreted as symptoms of overall sensitivity, reflecting lack of upstream defense. This is 

correctly evaluated for sapling beech trees (9-32/25-28), in which greater genetic response is considered 

to indicate greater sensitivity, rather than the reverse. In Arabidopsis (9-32/8-10) greater transcriptional 

response is stated to indicate only that upstream defenses (leaf boundary layer, stomatal response, 

canopy structure, cuticle morphology, metabolic??) are weaker in the WS than Col-0 genotype.

To what extent do the discussions and integration of evidence across scales (e.g., species, communities 

and ecosystems) correctly represent and clearly communicate the state of the science? 

The chapter does a thorough job of integrating effects across scales. However, in many cases the 

division of the discussion among the various sections dilutes the arguments. The authors may want to 

consider consolidating the discussion into fewer, but more vertically integrated, sections, with less 

repetition.

Reproductive effects and yield

The knowledge gap in yield suppression (9-11/19) is exactly the same one that remains in reproductive 

effects (in those species in which economic yield is a reproductive part). The text at 2-53/24-27 does not 

actually address whether these are direct or indirect effects on reproduction; and it may not be important 

for purposes of this chapter to resolve this. Stresses of all types alter reproductive behavior in annual, 
53

perennial, determinate, and indeterminate species. If the reproductive effects are caused by source-sink 

perturbations caused by ozone impacts on vegetative tissues, then they are not really distinct 

reproductive effects. The data at 9-50/7 indicate effects on vegetative productivity and indirectly on 

reproductive development, and only then on yield. The Black et al. papers (9-19/18-22) are not 

definitive in this regard, demonstrating compensatory responses, but not necessarily direct effects on 

reproductive structures. In these studies, ozone effects on the exposed stalk (9-50/11-18) might be direct 

or might reflect reduced local photosynthesis and source strength. Effects on the second, unexposed 

stalk may reflect a source-sink disruption, or phytohormone signaling of sink load, rather than a stress 

specific signal. It is not clear (9-55/22), that reproductive organs are particularly sensitive. Effects on 

pollen tube growth are more definitive evidence of direct reproductive effects.

Carbon and water 

The stomatal and gas exchange discussions in Chapter 2 could be consolidated (2-52/1-9, 2-54/26-37). 

Water cycling represents scaling of stomatal conductance and section 2.7.3.2 could be combined with 

the earlier discussion of stomata and gas exchange. The watershed data strongly support the earlier 

arguments about loss of stomatal control, and contrast directly with the typically observed stomatal 

closure caused by ozone. These arguments would have greater impact if made in one place. 

Similarly in Chapter 9, various sections (9-40-41; 9-75/16-39) might be combined with the discussion of 

gas exchange, water use efficiency, stomatal control, etc. The scale of observation is less important here 

than the integrated ozone impact on leaf area, leaf conductance, and photosynthetic capacity. These 

interact in complex ways that are not captured in the discussion. At 9-75/34, an increase in stem 

hydraulic conductance is possible, but unlikely, and no mechanism is suggested. Unchanged hydraulic 

conductance referenced to reduced leaf area, and a possible increase in the water potential gradient due 

to increased solar exposure, turbulence, and stomatal conductance of the remaining leaves may be more 

accurate. The invocation of water use efficiency at 9-75/29, is probably appropriate due to the changes 

in stomatal and photosynthetic properties detailed above, but may require greater explanation. 

The reference to McLaughlin et al. 2007 (9-45/31) would inform the arguments regarding stomatal 

control, though the measurements were indirect (sap flow and stem diameter) and the ozone effect was 

derived from a multiple regression. Changes were likely driven by altered stomatal regulation, and did 

correlate with independent stream flow data. Loss of stomatal control is also suggested by Gregg et al. 

as a cause of reduced growth in rural versus urban trees. The Gregg et al. data (9-22/25; 9-23/36) 

demonstrate an ozone response through comparison of OTC and rural/urban exposure gradient data (9-

41/23; 9-45/31), but do not demonstrate parallel physiological responses in the OTC and gradient 

studies, contrary to the text (9-23/37). In the field, stomatal conductance was measured on young leaves, 

while only in the OTCs were responsive older leaves measured. In any case, the Gregg et al. data are 

more difficult to interpret than their frequent reference in the text implies. The rural trees (with putative 

loss of stomatal control), exhibited greater rates of photosynthesis, but lower biomass, than urban trees, 

and the ozone impact was much greater than expected from previous experiments.

The controversy over whether direct ozone impacts on photosynthesis affect stomatal conductance or 

vice versa, continues, and is important. This could be clarified (2-52/1-9). The mode of action of ozone 

impacts on photosynthesis (2-54/27-28) is not well known, and only effects (not mechanisms) are 

documented in section 9.4. In general modest stomatal closure will only reduce photosynthetic rate 

significantly (by reducing intercellular CO2) in C3 plants, yet ozone reduces photosynthesis in C4 plants, 

too. The arguments at 9-45/26 do not demonstrate direct effects on stomatal guard cells. Wang et al. 

specifically state that both stomatal and non-stomatal impacts were involved. Kitao et al. show mainly 
54

stomatal effects, but state that in shade leaves, both are involved. A stomatal limitation of photosynthesis 

may be demonstrated by showing reduced intercellular CO2, but only if photosynthesis is unchanged, 

which is unlikely in a C3 plant with declining intercellular CO2. Photosynthesis and stomatal 

conductance can decline together, with no change in intercellular CO2. It is often hard to tell from these 

measurements which effect is primary. The definitive test is derived from a photosynthesis vs. 

intercellular CO2 response curve. 

The data of Paoletti and Grulke 2010 (9-46/2) show that stomatal properties may predispose snap beans 

to ozone sensitivity. However, the tolerant snap bean altered its stomatal response kinetics in response to 

ozone to become more sluggish than the sensitive line, which weakens the argument for the importance 

of this parameter. This paper does not deal with cutleaf coneflower, as implied in the text. The 

coneflower experiments (Grulke et al., 2007 (9-46/2)) do not demonstrate protective stomatal properties, 

since the plants were already exposed to ozone prior to measurement. The stomatal differences may 

have been symptoms rather than mechanisms of ozone sensitivity in the co-occurring but genetically 

contrasting individuals. The conventional wisdom is cited (9-83/9-10) that fast growing, high stomatal 

conductance species are most sensitive, but this contrasts with a previous conclusion (9-49/18), that slow 

growing species exhibited greater ozone sensitivity (of the allometric coefficient).

It is clear that ozone reduces translocation of sugar and growth of distant sinks such as roots. At 9-

49/12-26, this is obscured by leading with reference to the conflicting literature. The variability is real, 

but should be placed in context by reference to the summaries provided by Andersen 2003, Grantz et al. 

2006, and Wittig et al. 2009. 

Elevated CO2 has been shown experimentally to offset ozone effects, and vice versa. The text (9-13/15) 

implies that only model evidence suggests this. A possible additional reference could be cited (9-41/25-

33), Volin et al., 1998, New Phytologist 138: 315 – 325. 

Dose modeling

The use of exposure at 9-102, where flux is really under discussion, contrasts with the careful distinction 

made at 9-92/19-20 between flux and exposure. In the modeling scenario (9-92/19-32), temperature, 

humidity and soil water are required to model, not measure, stomatal conductance. Thus there is no 

requirement to measure intercellular ozone concentration. In any case, Laisk et al., 1989 (Plant Physiol. 

90: 1163-1167) demonstrated that this concentration is near zero. A major limitation to modeling ozone 

dose is the relationship between stomatal conductance and poorly characterized environmental 

parameters. The major limitation to modeling impact from dose is poorly characterized temporal and 

spatial variability in sensitivity to ozone. Both depend on diurnal characterization of ozone 

concentrations. At high elevation and rural sites the diurnal profile of ozone concentration is relatively 

flat or may peak at unexpected hours. This leads to alternate modes of stomatal uptake, associated with 

nocturnal opening and with predawn opening (a putative blue light response). This could be further 

detailed here. 

Semi-direct effects of ozone on reproduction (9-95/1-25) might also inform the relationship between 

fluxes and impacts and the flux (Level II) approaches (9-98/7). Phenology, time of day, and seasonality 

are key and currently poorly characterized determinants of impact. The peak in stomatal conductance in 

mid-morning is usually associated with lower VPD than in the afternoon in high VPD environments, or 

with soil drought. Otherwise conductance may be bell shaped over the day. The Panek 2004 study was 

in a summer-drought, western coniferous forest. The Grulke et al. 2002 study indicates the importance 

of microhabitat. However, the next sentence, “The decoupling of conductance and higher ambient ozone 
55

concentration... mesic... xeric..” refers to the early arguments for a flux approach, but does not seem to 

follow from the references and reasoning presented here.

It is clear that stomata provide the principal pathway for ozone to enter and impact plants. There are 

better references for this (9-109/22), Fuentes et al. 1992, Agricultural and Forest Meteorology, 62, 1-18; 

Massman and Grantz, 1995; Leuning et al. 1979, Atmospheric Environment, 13, 1155-1163; Reich 1987, 

Tree Physiology, 3, 63-91; Wesely et al. 1978, Boundary-Layer Meteorology, 15, 361-373; Wesely et al. 

1982, Atmospheric Environment, 16: 815-820, might be considered.

The discussion at 9-110/10-17 is confusing and not wholly correct. Arguments regarding a consistent 

measurement height are confused with arguments regarding the ozone concentration to which stomata 

are exposed. There is an ozone gradient in trees and also in crop plants from this reference height to the 

ground (including through the understory vegetation in a forest). Different leaves are in contact with 

different ozone concentrations. The question (line 14) regarding uncoupling of stomatal conductance 

and high ozone periods is not relevant here. The text requires careful revision.

Has the ISA adequately characterized the available information on the relationship between O3

exposure and effects on individual plants and ecosystems? 

In Chapter 1, much is made of the concept of “adverse” responses. Yet, in many locations in the ISA 

there are references to “alterations” without stating in what direction, or even if they might be 

deleterious. The summaries in Chapter 2 and section 9.2 rarely identify the direction of change, and as a 

result do not adequately summarize the subsequent discussion. The discussion of SOD and POD in 

sensitive and tolerant tobacco genotypes (9-39/30 – 33), states only that measurements were made, with 

no consideration of whether changes in any direction were observed. An interesting exception which 

should be emphasized for its novelty (9-30/19-20), is the demonstration that both up and down 

regulation of SIPK (salicylic acid induced protein kinase) increases tobacco sensitivity to ozone (i.e. a 

deleterious alteration no matter which way it changes). 

Signalling pathways and antioxidants

The ISA appropriately concludes (2-50/9) that ozone is perceived in many ways by plants and cells. 

Ozone and its reaction products interact with ROS metabolism at several potential places. However, the 

further conclusion (2-50/5-6; 9-24/9) that ozone is “sensed” by specific “apoplastic receptor proteins” 

which “still remain(s) elusive” is unwarranted at this time. While the initial site of attack by ozone 

remains unknown, it appears certain to be in the apoplast, which can be stated with greater certainty (9–

37/6). It appears that there is no “sensor” in any conventional sense. The concept of Foyer and Noctor 

(2005) that oxidative stress is a misnomer and that ozone is just part of the normal oxidative metabolism 

of plants, is quantitatively false. Plants in high ozone environments do not perform well, indicating that 

this is outside the normal range of signaling metabolism. The concept was a metaphor for understanding 

(much as suggested by Sandermann earlier) that ozone plays into existing signaling pathways that 

evolved as biotic defense mechanisms. The oxidative burst is widely recognized to be component of 

plant defense against pathogens, calling for greater certainty than “thought to be” (9-38/1-8). 

Consequences of the signaling pathways seem to lead to the most damage, rather than the raw oxidative 

potential of ozone. The ISA appropriately reverts to a paradigm associated with oxidative stress and 

interaction with these pathways at 9-29/27-31. The concept of an ozone sensor is premature and 

potentially wrong. 
56

2-50/34, the role of JA (jasmonates) is more complex than suggested. JA does not just antagonize ET 

and SA, it has impacts on abscission, directly on growth and allocation, and other effects that are not 

well understood. A reference for the role of ABA in antagonizing JA (9-7/2) would be helpful here 

(possibly Ludwikow and Sadowski, 2008, currently referenced at 9-34). 

Changes in gene expression, particularly at single loci, do not necessarily indicate much about response 

at the plant scale. Proteome results support some genetic changes but not others (9-6/30-32). For 

example (9-5/12-15) it is not clear that these changes scale to responses at plant or community level, due 

to compensatory changes and to genotypic changes that have little phenotypic expression, due to gene 

redundancy or other mechanisms (9-25/11-13).

There is no experimental evidence (9-40/8-12) that plants cannot maintain elevated antioxidant levels. 

Theoretical energy costs may argue against it, but there is little evidence that maintaining carbon in 

these pools is limiting. It may be that other, more stable, protective systems arise over time. The strength 

of the oxidized glutathione transport system across the plasma membrane is a key component of the 

regeneration of reduced glutathione. Therefore the fraction present in the apoplast and its redox status 

are only partially responsible for the strength of the ascorbate defense system. The functional limitation 

of the ascorbate pool is not sufficiently described (9-38/24-25) to allow a conclusion whether, or not, 

other antioxidants may be involved. 

Subject areas that should be added, expanded upon, shortened or removed 

The consideration of ozone impacts on stomatal conductance and it ramifications at various scales could 

be condensed and consolidated, for brevity and clarity.

While it is clear that Ca++ and MAPKs and many other components are involved in ozone responses (9-

30/3-16), it is not clear that the entire signaling framework must be described in this chapter. It may be 

sufficient to note how ozone enters these existing pathways and the havoc that these pre-programmed 

responses can cause, quite apart from the oxidizing potential of ozone, itself. This establishes 

plausibility, without getting tangled up in interacting pathways that remain very poorly characterized.

The coverage of effects on mammals due to changes in vegetation is rather brief. There may be 

digestibility studies, if not actual feeding studies, related to dairy or beef production. There are ongoing 

feeding studies on rabbits, but these are not yet published. Similarly, the coverage of effects on insect 

herbivory is rather brief. An older paper of relevance here (9-87/12-23), is Summers et al., 1994, J. 

Agric. Entomol. 11: 181-187, showing increased aphid growth at elevated ozone.

Specific comments:

Chapter 2 could use a brief Executive Summary, or the chapter itself could be condensed into such a 

summary. The redundancy (minus the references) with later chapters is substantial.

At 2-51/23-27, and in section 9.4.5.2, it is important to differentiate root from shoot respiration. The 

mechanisms and consequences are likely to differ.

2-53/14, perhaps “pasture” would be a better word than “hayfields”.

Stomatal conductance is not a rate (9-17/8). Transpiration is a flux with a rate.
57

9-13/28, insert “transpirational” to modify “water” at end of line, as this was the only aspect of 

ecosystem water loss that (apparently) did increase. In Figure 9-1, “water production” could be replaced 

with a more appropriate descriptor, perhaps runoff, stream flow, or watershed yield.

Fig. 9-34, the line labeled “control” is defined as “ROS control measurements”, which is unclear.

The alleged methodological problems of Perry et al. 2007 should be consolidated at first mention, and 

deleted from the subsequent two locations.

The protocol at 9-35/37 was “eXogenous” rather than eNDogenous application of MeJA.

At 9-49/32, seed quality should probably be a 5th category, distinct from yield. 

9-55/32, it is incorrect to characterize 79.9 ppb as ambient in the study of Grantz and Shrestha (2006). 

The study imposed a diurnal profile similar to a maximal daily exposure, but did so on a daily basis. 

This treatment is considerably in excess of ambient exposure.

9-58/37, typographical error, probably should read “...84% of the variability in the relative feed 

value...”

9-64/25-26, it is unclear what is meant by “ozone enhances negative effects of ozone”. 

9-84/25, over-representation of vegetation (128%) is not intuitively obvious, greater explanation would 

be helpful.

9-89/9-11, it is unclear how an over-temperature represents a hypothermic response. This needs to be 

clarified, or a typographical error corrected.

The Grulke et al. 2007 references should be a or b, since there are two such references.
58

Dr. Jack Harkema

Chapter 5: Dosimetry and Mode of Action

Q. Is the review of basic dosimetric principles of O3 uptake presented accurately and in sufficient detail? 

A. Yes.

Q. What are the views of the Panel on the approach taken in Chapter 5 to characterize modes of action 

for O3-related effects? 

A. I think this is a good approach/addition. I think some brief text describing how Figure 5-6 was 

derived would be helpful (e.g., why some things were included and others not)? Figure 5-6 does not 

include GAPs in Knowledge as identified in 5.2.11 (e.g., MOA for systemic effects?)

See comments below.

General Comments:

In general, the overall format for this chapter is appropriate and the text is clearly written. The author(s) 

have thoroughly reviewed the recent literature and have included the most pertinent recent studies. The 

chapter, however, could be improved by:

• More emphasis on recent studies (2006-2010)

• More concise description of past studies with more summarization of overall conclusions from 

the previous ISA

• Specific descriptions of the important results of key studies before 2006 could be placed in an 

appendix and referenced in the shortened main text

• Description of the GAPs in knowledge should be expanded and other areas identified (e.g., 

effects of ozone:1) on other extrapulmonary organs such as the liver, gut, and gonads; 2) in the 

context of multi-pollutant exposures; 3) effects of ozone on facets of the metabolic syndrome 

including obesity, diabetes, and hypertension)

• Inclusion of the effects of ozone on other important preexisting conditions such as obesity and 

facets of the metabolic system could be highlighted (e.g., studies by Shore SA et al.)

• More co-referencing of other ISA chapters

• Addition of past and recent results for other photochemical oxidants where appropriate

Specific comments/questions:

Author(s) need to be careful in their wording of ozone’s promotion of allergic airway disease (avoiding 

the term “causing asthma” when it is not appropriate).

Does ozone really interact directly with cell membranes of some cells in vivo (e.g., macrophages) as 

alluded to in some parts of the text? Or is the interaction predominantly secondary reactive by products? 

References should be provided.
59

Dr. Daniel Jacob

1. Chapter 3 of ISA, Atmospheric Chemistry and Ambient Concentrations (Charge Question 4)

I found chapter 3 of the ISA to be overall very well informed and up to its task. Specific comments are 

below. The most important comments relate to determination of the PRB and trends in background 

ozone. These are indicated by asterisks.

3-6, line 20: stratospheric intrusions are not a significant source of NOx.

3-6, lines 20-34: Smith and Mueller (ACP 2010) should be cited for a recent perspective on natural NOx 

emissions in the US.

3-6, lines 20-34: it should be acknowledged that natural NOx emissions are most important in summer 

when ozone is of most concern.

3-7, line 33: 26% must be a typo, it’s inconsistent with figure 3-2.

3-8, lines 1-12: Kopacz et al. (ACP 2010) should be cited for the apparent bias in NEI05 CO emissions 

having a large seasonality, possibly reflecting cold start emissions in winter.

3-8, line 14: I’m surprised that natural CO emissions could be that high. Or does it include oxidation of 

biogenic VOCs?

3-8, line 33: CFCs would be VOCs by this definition. The proper definition of VOCs is precisely what 

the acronym says it is – gaseous organic molecules.

3-14, lines 1-2: Wise and Comrie (AE 2005) actually show a strong positive correlation of ozone with 

temperature in the SW US.

3-14, lines 25-29: the description of low-NOx and high-NOx regimes is not precise. At very low NOx 

(cf. zero NOx), VOC oxidation is in fact a sink for radicals (through peroxide formation). “Free 

radicals” is presumably meant to describe HOx, but NOx species are also radicals. Ozone production is 

limited by the supply of HOx radicals in both the low-NOx and high-NOx regimes.

3-15, line 22: OPE depends on many other factors including solar radiation, VOCs, and ozone: cf. 

Hirsch et al., JGR 1996.

3-16, lines 1-10: should cite satellite work on using HCHO/NO2 column ratios from GOME and OMI to 

diagnose NOx-limited and NOx-saturated regimes. See Martin et al., GRL 2004 and Duncan et al., AE 

2010.

*3-25, section 3.4: either in this section or in section 3.2 there should be some discussion of three major 

chemical uncertainties that could affect model PRB simulations: halogen chemistry (not just in urban 

areas but in background), isoprene chemistry, and the chemical evolution of fire plumes. It should be 

noted that current models simulating the pre-industrial and early 20th century atmosphere greatly 

overestimate the observed concentrations at the turn of the century.
60

*3-27, lines 12 and 37: it is essential to discourage the notion that PRB could be measured. On line 12, 

“PRB conditions” should be changed to “PRB-relevant conditions”. On line 37, TH cannot be applied to 

“PRB conditions” if only because of US anthropogenic contribution to the northern mid-latitudes 

background ozone. On the flip side, it is important to recognize the importance of measurements at 

background sites to test model PRB values. These measurements present challenges to the PRB models 

in terms of reproducing high observed values and correlations. In particular, Parrish et al. ACP 2010 

should be cited for suggesting that surface ozone in the Sacramento Valley could have an unexpectedly 

large background concentration based on correlations with ozonesonde data at Trinidad Head.

*3-27, line 12 and beyond: The importance of measurements at background sites for testing PRB models 

must be stressed, at the same time one must also stress that these sites are in general not representative 

of the US. Ozone concentrations measured at Trinidad Head are representative of...Trinidad Head.

*3-29, line 3, and elsewhere: use the + sign when indicating a positive trend.

3-36, line 9: I don’t understand, “too high by only 5 and 3 ppb”.

*3-37, lines 20-27: these statistics illustrate that models have a difficult time capturing the high extremes 

of the ozone distribution and this would have implications for PRB estimates, for example with regard to 

stratospheric intrusions at mountain sites or fire plumes. Some different strategy or screening would be 

needed for such exceptional events.

3-50, lines 11-30: the limitations of satellite observations with regard to vertical resolution should be 

stated.

*3-93, lines 1 and beyond: the increasing trends of ozone over the US west coast need to be mentioned 

here (they were mentioned earlier in the chapter in the PRB context). I have heard talks from EPA 

scientists about rising ozone in national parks in the west, although I don’t know of a peer-reviewed 

publication. if these trends are robust they should definitely be mentioned. Such rising trends would be 

of particular concern in meeting a tighter NAAQS.

2. Chapter 10 of ISA, The Role of Tropospheric Ozone in Climate Change and UV-B Effects 

(charge question 11)

This chapter is definitely useful in view of recent interest in chemistry-climate interactions and in 

combining air quality and climate goals for environmental policy. Overall I found it to be very well 

informed. I think that it should give more play to methane as the only ozone precursor for which control 

would effectively reduce climate forcing. It should also give more play to the recent RCP scenarios of 

IPCC AR5, since these scenarios will provide the core of future assessments of climate forcing for 

emissions relevant to air quality and they present a very different picture than the older SRES scenarios. 

Below are specific comments. Important comments are flagged by asterisks.

*10-3, line 24: the IPCC SRES scenarios are now considered obsolete. I understand that they should be 

described in this chapter as the literature is based on them. But more attention should be given to the 

RCP scenarios, and they should be mentioned in this paragraph.

10-5, Figure 10-1: feedback from climate change should apply to the emissions of ozone precursors.
61

10-8, lines 18-19: is there any evidence of increasing ozone in the SH? Is there any evidence of 

increasing tropical biomass burning?

10-8, line 37: for bromine effects on ozone cite Yang et al., JGR 2005. The Parrella paper doesn’t exist.

10-8: Ordonez et al. GRL 2007 should be cited for a natural explanation of decadal ozone trends at 

northern mid-latitudes.

10-11, lines 14-18: it may be better to cite the IPCC values for emission-based RF.as a community 

consensus.

10-12, line 30: but there’s no SW radiation over the Arctic in winter. Isn’t it a general feature of 

greenhouse warming to be most intense at high latitudes in winter?

*10-13, section 10.2.6: I think that the concept of emission-based RF should receive more play because 

it is so relevant to ozone. It makes the point in particular that only methane controls provide climate 

benefit. I suggest including (or at least commenting on) Figure 2.22 of IPCC AR4, which shows that 

present-day methane emissions are more important than CO2 emissions in driving climate change over a 

20-year time horizon, in part because of methane as a precursor of ozone.

*10-14, lines 21-34: I think that it would be useful to include a figure of 21st-century RCP projections of 

global emissions for AQ-relevant species. Also it would be worth mentioning that the RCP scenarios 

provide continuity with the previous SRES scenarios in terms of overall radiative forcing: RCP8.5 ≈ A2, 

RCP6 ≈ A1B, RCP4.5 ≈ B1. However, the projections of emissions for AQ-relevant species are very 

different.

10-16, line 15: isoprene does not systematically decrease ozone under NOx-limited conditions. 

3. Air Quality Considerations in the REA document (chapter 2 and chapter 3)

This chapter of the REA document provides the atmospheric basis for the exposure analyses. I am 

concerned about the use of 2008-2010 ambient data for the exposure analyses because 2009-2010 are 

considered to be low-ozone years for reasons having to do with meteorology and possibly the economy. 

2006-2008 would be much more representative. In addition, the available PRB calculations from GEOSChem are for 2006-2008, and temporal coincidence is very important for sites where the PRB can make 

a large contribution to total ozone concentrations as in the intermountain West. If EPA decides to keep 

2008-2010 as basis for its exposure analyses then GEOS-Chem PRB calculations will be needed for that 

period. However, a better option is to use 2006-2008. 

Also, the EPA needs a strategy for correcting GEOS-Chem biases in PRB estimates. I think that it is 

useful to distinguish between two types of biases:

• Regional biases, such as in the Southeast US in summer where the model background is too high. 

A simple correction (and probably good enough) would be to use regionally representative sites 

(such as CASTNet) and attribute GEOS-Chem biases relative to observations proportionately to 

PRB and to North American sources. More sophisticated corrections are possible by comparing 

model and observed frequency distributions of ozone at these sites but they may not be any more 

accurate.

• High-ozone events in the observations that may be related to PRB and that the model doesn’t 

capture. From my inspection and understanding, I think that these happen only at mountain sites 
62

in the West and are associated with stratospheric intrusions or wildfire influences not captured 

(or excessively diluted) by the model. From my analysis of model vs. observation statistics (and 

this will be reported in the Zhang et al. [2011] paper describing the GEOS-Chem PRB 

calculation), the model can properly capture the overall frequency of events > 70 ppb but fails 

above 75 ppb. Individual inspection of these events in the observations may be necessary to 

screen for PRB influence.

A few other specific comments:

2-5, line 4: proper reference is Wang et al., AE2009, instead of Bey et al.

2-6, lines 26-28: according to the IPCC AR5 RCP scenarios methane is not projected to further increase 

in the future. These scenarios may turn out to be wrong, but one cannot just assume that methane will 

continue to increase.

3-17, lines 23-30: I’m surprised that not more attention is paid to near-roadway exposure. The report 

states that ozone would be lower because of titration by NO to NO2, which an uneducated reader might 

assume would reduce exposure, but in fact ppb for ppb NO2 is no better than ozone.
63

Dr. Steven Kleeberger

Chapter 8 Populations susceptible to ozone-related health effects

Are the characteristics included within the broad susceptibility categories appropriate and consistent 

with the definitions used?

Initially, the authors of the chapter clarified the meaning of ‘susceptibility’ for the purposes of 

the ISA to eliminate confusion that has arisen in previous ISA documents for other NAAQS pollutants. 

That is, susceptible populations include susceptible, vulnerable, and at risk sub-populations. This was 

very helpful moving forward.

The authors then did a very good job capturing what are considered to be the most important 

known categories of factors that may contribute to enhanced susceptibility to ozone-induced adverse 

outcomes. The 13 major categories for discussion included pre-existing disease/conditions (8.1), 

lifestage (8.2), sex (8.3), genetics (8.4), diet (8.5), body mass index (8.6), socioeconomic status (8.7), air 

conditioning use (8.8), involvement in outdoor activities (8.9), race/ethnicity (8.10), physical 

conditioning (8.11), smoking (8.12), and hyperthyroidism (8.13). Broadly, the 13 categories could be 

considered intrinsic (8.1-8.6, 8.10, 8.13) and extrinsic (8.7-8.9, 8.11, 8.12) susceptibility factors. Some 

of the categories could be collapsed to be more inclusive, e.g. involvement in outdoor activities and 

physical conditioning; pre-existing disease/conditions and hyperthyroidism and smoking. However, with 

the given structure, the authors were consistent with the broad meaning of susceptibility and how the 

various factors may influence responses to ozone exposure.

Are there any key susceptibility factors that were not included and need to be added? 

In the "Lifestage" section, the authors briefly mention in utero exposures and effect on lung 

function and immune response in animal (mouse and rat) models. It should be more strongly emphasized 

that pre-term neonates represent a particularly susceptible population, subject to injurious effects of air 

pollutant exposure as the exposures may disrupt normal fetal developmental processes. Epidemiological 

studies have also reported associations of air pollution exposures (including ozone) with affected 

reproductive outcomes including intrauterine and infant mortality, preterm birth, low and very low birth 

weight, intrauterine growth restriction, and birth defects. Perhaps pregnancy should be considered a 

temporary ‘pre-existing condition’ and adverse outcomes are reproductive/birth parameters. 

The Genetics section was well-written, and adequately considers recent genetic association 

studies in human epidemiological and chamber investigations. It may be worthwhile stating that, due to 

small sample sizes, many of the chamber studies are limited to testing only those potential candidate 

genes that have very high minor allele frequencies in order to obtain appropriate statistical power. Other 

genes with potential impact on ozone-induced outcomes may be important, such as those identified in 

some of the mouse models, but power considerations have limited testing these genes in human 

populations.

It was a bit surprising that the discussion of toxicological studies did not include more thorough 

consideration of other potentially important genes besides those mentioned (e.g. Tnf, Nqo1). A number 

of recent investigations have implicated additional candidate genes that could/should be considered for 

future investigations in human populations, including for example 1l10, Mmp9, Il6, Tlr2, Marco, Hsp1a, 
64

H2-Aa, Ab1, Eb1, Eb2, Ea (histo-compatibility genes), Lta, Nos2, and TLR4 and TNF signaling genes 

such as Myd88. Perhaps a table should be created that identifies these and other genes that have been 

implicated to be important in the pathogenesis (or protection against) ozone-induced lung inflammation 

and injury.

The inclusion of diet as a susceptibility factor was timely and important. Given that this factor 

was not considered in previous AQCDs, the authors should have the flexibility to cite older papers to 

give the factor appropriate context. In addition to vitamins C and E, vitamin A deficiency has also been 

shown have important consequences on ozone-induced inflammation (see e.g. Paquette, et al, Am J 

Physiol 270:L475-82, 1996). Caloric restriction (protein deficiency) was briefly mentioned, but this area 

could be better developed by including additional studies such as Kari et al (Am J Respir Cell Mol Biol

17:740-747, 1997). 

Minor comments:

Table 8-1. ‘Obesity could be included in the table as it is a potentially highly prevalent risk factor.

Page 8-4, lines 14, 15. Formatting errors.

Page 8-4, line 34. ...asthmatics to, on average, experiences... should be ...asthmatics, on average, 

experience...

Page 8-4, line 38. ‘Only study’ should be ‘Only one study’.

Page 8-7, line 3. Formatting error.

Page 8-7, line 4. ...and atherosclerosis were noted... should be ...and atherosclerosis was noted...

Page 8-9, line 11. Epitheliar should be epithelial.

Page 8-11, line 16. ...85 year of age... should be ...85 years of age...

Page 8-15, line 6. ‘individuals with both GSTM1 genotypes’ is a bit confusing since individuals can 

have only one genotype. Sentence should be re-written to state individuals with either genotype.

Page 8-15, line 35. It is not clear why Nrf2 was stated as a possible susceptibility factor. No references 

were cited, and this transcription factor has not been well characterized for responsivity to ozone.

Page 8-16, line 1. Inf-1 and Inf-2 should be identified as quantitative trait loci, not genes.
65

Dr. Fred J. Miller

Chapter 5: Dosimetry and Mode of Action

The dosimetry and modes of action of O3 are discussed in Chapter 5. The primary focus of the dosimetry 

discussion is to highlight factors that might lead to differences in dose between individuals and between 

species. Some potential modes of action that may underlie a number of health outcomes and that may 

contribute to the biological plausibility of health effects of short- and long-term exposures are described 

in detail. 

Is the review of basic dosimetric principles of O3 uptake presented accurately and in sufficient detail? 

There is actually very little presented about the dosimetric principles of O3 uptake aside from a 

discussion of what biomolecules O3 react with in the ELF and in the tissue. There is no discussion of the 

physical and chemical factors involved in gas transport and mechanisms that result in the penetration 

into and removal of O3 in various regions of the respiratory tract. The roles of convection, bulk flow, 

laminar versus turbulent flow, effective axial diffusion, radial diffusion, solubility, and Henry’s-Law are 

among the topics that should have been discussed if the principles determining O3 uptake were to be 

accurately and sufficiently presented. There is limited discussion of species differences in nasal structure 

and lung morphometry and the composition of the ELF together with the cellular composition in the 

major respiratory tract regions (extrathoracic, tracheobronchial, and alveolar). This information affects 

the strength of species homology and also illustrates what needs to be taken into account in interspecies 

dosimetric extrapolations.

Most of the dosimetry material centers on factors influencing uptake such as depth and route of 

breathing, the importance of interindividual variability in O3 uptake, regional experimental uptake data 

in humans, and factors that influence attempts to correlate measures of internal dose with response in 

human experimental studies. If this is what the Agency means by dosimetric principles, then the chapter 

comes closer to meeting its objectives.

What are the views of the Panel on the approach taken in Chapter 5 to characterize modes of action for 

O3-related effects? 

The MOA material is a combination of effects descriptions mixed in with studies that are more 

mechanistically oriented. Very little information from animal studies is brought into the MOA 

discussion. For example, Section 5.2.3. on Activation of Neural Reflexes goes on for 4 pages describing 

human study results and then in Section 5.2.3.1 on New Cellular and Molecular Insights, animal studies 

are first brought into the discussion. If some pre 2006 animal studies were cited along the way that 

support the human findings, the cases for the MOAs would be stronger. The same can be said for other 

sections.

The figure on page 5-62 depicting the key events and pathways for the effects of ozone on the 

respiratory tract would be more useful if it was placed at the beginning of the MOA discussion as part of 

an introduction. Perhaps the section numbers could be included with the boxes; that way if a reader is 

interested in a particular aspect of one of the MOAs, they could go directly to the material. And the 

figure could be retained at the end of the chapter as part of the overall summary. In addition, the MOA 

Overall Summary is weak, as it does not convey the strength and the importance of the findings 

discussed in the MOA subsections.
66

Other points relevant to the MOA presentation and material are included below in my general and 

specific comments.

Preliminary General Comments

• While the chapter combines material on the dosimetry and mode of action (MOA) of O3, there is 

no particular reason why they should be combined. The chapter organization comes through as if 

the pairing of the two was an afterthought. As the ISA meeting last week, Dr. Jim Ultman 

provided an example of how the chapter might be organized to better tell the story of exposuredose-response and how MOA fits into the story.

• The dosimetry chapter discusses various human study results and basically concludes, “this study 

shows that O3 does that”. Almost every one of these revelations is a confirmation of what 

mathematical O3 dosimetry models predicted 10 to 20 years earlier. More inclusion of references 

to the modeling papers would strengthen the presentation of the human dosimetry findings as 

was done in the material on “Pulmonary Ozone Uptake and Dose”.

• Whatever happened to the Agency criteria that to be included in the Criteria Document (and now 

the ISA document) studies needed to be at or below 1 ppm O3? Or if higher levels were included, 

at least the investigators went down in exposure concentration. I find it ridiculous to cite papers 

at 3 parts ppm O3 for several hours and talk about how they contribute to our understanding of 

mechanisms or modes of action. Such high exposures have no relevance to the real world and 

invoke “fictitious findings” (for example, the Williams et al. (2007) study exposing mice to 3 

ppm O3 for 3 hour would have “blown away” the lungs of the mice and allowed O3 to directly 

react with the blood – what relevance can one possible assert to mode of action of O3 at 

environmental exposure levels?).

• In a number of sections, the text appears to be a stringing together of statements or findings from 

the original authors as sentence after sentence has a string of references at the end of the 

sentence. The frequency of references actually interferes with reading the material.

• In the MOA material, the authors need to be careful about making statement that a study shows 

one species is more sensitive to O3 than another. A good example of this can be found on page 5-

34 starting at line 20. The text states that Dormans et al. (1999) exposed rats, mice, and guinea 

pigs to O3 and found guinea pigs to be the most sensitive with respect to alveolar macrophage 

elicitation and pulmonary cell density in the centriacinar region. And mice were most sensitive to 

bronchiolar epithelial hypertrophy ... and the list goes on. Such statements about sensitivity are 

simply not valid unless there is normalization to the dose received. One species may remove 

more O3 than another in the nasopharyngeal region or one species may receive a greater 

pulmonary dose. The author of this paragraph points out the problem 9 lines later! Why waste 

text describing something that is not valid?

• Throughout the MOA material, the O3 exposure level and duration needs to be included more 

often. As an example, on page 5-53 starting on line 21, the study by Arito et al. (1990) is cited as 

showing O3 can induce several cardiovascular effects in animals exposed to O3. One might have 

an initial reaction of “So What?” Only by going to HERO do you find out that very low 

exposures of 0.1 to 0.2 ppm O3 were used for 5 days in rats. These results clearly have relevance 

to humans and clearly offer insight into a MOA for O3.

• In multiple places, the text asserts that Pryor et al. (1992) show that O3 cannot penetrate an ELF 

layer more than 0.1 microns in thickness and, thus, effects of O3 on epithelial cells must be due 

to secondary reaction products. This assertion is more appropriate for the mucous layer than it is 

for the surfactant layer. But even for the mucous layer, the beating of the ciliated cells ensures 

that the layer is not stagnant and increases the chance that some O3 may be able to react directly 

with epithelial cells. In the alveolar region, 98 % of the alveolar epithelium is covered by an 
67

ultrathin (< 0.02 μm) surfactant layer (see Miller, Toxicol Lett 82/83:277–285, 1995). The 

surfactant layer pools in the corners of the alveoli during part of the breathing cycle leaving only 

a monolayer film of surfactant over the cells, thereby allowing the cells to be in almost direct 

contact with O3 in the gas phase. Moreover, the surfactant layer normally only approaches a 

thickness of 0.1 to 0.2 μm over Type II cells and in crevices, and, Type II cells cover only about 

5 % of the alveolar surface area. Thus, there is ample opportunity for O3 to react directly with 

both cell types in addition to forming reaction products with constituents of the surfactant layer.

Specific Comments

Page, line Comment

5-2, 25 The statement that the mucous coating becomes patchy in the distal 

conducting airways is highly debatable. The method used to fix the lung 

specimens greatly influences the results. The most accurate method to 

preserve the lining lay involves both blood and gas-phase fixative methods. 

To my knowledge, Mercer’s study was the only one meeting these criteria, 

and he showed that the layer was continuous even in the terminal 

bronchioles. 

5-2, 27 The sentence beginning with “The progressive thinning ...” needs to be 

reworded. The authors are trying to refer to the radial distance from the 

center of the air phase to the ELF, but the way the sentence is currently 

worded implies they are talking about the axial distance into the lungs.

5-3, 1 Suggest inserting the word “mediating” before “...O3 toxicity in the 

airways.”

5-6, 33 Is the reaction rate constant for GSH stated correctly? If it is, can it be 

converted to the same units as shown for UA and AH?

5-7, 38 The part of this sentence “... and to prevent penetration of O3 deeper ... is 

not correct. Effective axial diffusion ensures O3 penetration deeper into the 

lungs while the radial gradient locally affects tissue toxicity.

5-9, 15 As the senior author of the paper referenced here, I object strongly to 

calling our O3 dosimetry model limited because the URT was not included. 

We normalized dose to a per microgram of ozone entering the trachea. One 

only needs to specify the concentration at the beginning of the trachea in 

order to use our model for lower respiratory tract absorption of O3. The 

fraction of O3 removed in the extrathoracic (ET) region in human 

experiments is given in Table 5-2 for various human studies and later on 

the chapter cites Hatch as determining about 50% of the inhaled O3 being 

taken up in the ET region of rodents. So if resting humans breathe 116 

μg/m3 (i.e., 60 ppb) and one uses the fractional nasal removal value of 

Gerrity et al. (1988) of 0.36, then 74 μg/m3 arrive at the start of the trachea. 

So for the dose patterns we show for humans, multiple the values by 74 and 

you have the predicted dose to the tissue in the various LRT generations.

5-9, 18 The discussion here does not include Wiester et al. (1987) where only 40% 

in the total respiratory tract was measured over a concentration range from 

0.3 to 1 ppm O3. Has this study been discredited? If not, then it should be 

included to reflect that there is not complete agreement in the published 

literature about how much O3 is removed in the head in animals. The 

Wiester et al. ((1987) study also would affect the statement on page 5-20 
68

starting at line 18 where pulmonary uptake is discussed.

5-11, 16 A caveat needs to be added here. The sentence “increased fB will shift .... 

respiratory airspaces” is only correct if tidal volume increases.

5-12, 7 This correct statement is why exercise imparts effects of O3 exposure 

sooner. It should be captured in the chapter summary.

5-14, 6 Clarify what is meant by lower airways. FEV1 does not reflect only a lower 

airway effect.

5-14, 24 If this really is present thinking (i.e., ... linearity of the dose relative to 

ventilation relationship has not been carefully studied.), it is incorrect as 

shown by Miller et al. (1985). Comparing the heaviest exercise simulation 

to the one for normal respiration showed a 10-fold increase in total mass 

uptake. The increase was distributed unevenly in that the tissue and 

mucous layer of the tracheobronchial region had mass increase by about a 

factor of 1.4, while the surfactant layer and alveolar tissue had uptake 

increase by factors of 5.2 and 13.6, respectively. 

5-14, 26 The Sawyer et al. (2007) study was on nasal uptake. HERO did not have 

the full paper. How was the lower airway uptake determined?

5-15, 6 The model described by Taylor et al. (2007) only had one bifurcation. A 

significant amount of text is devoted to this paper. However, some caution 

is appropriate because the pattern of airflow downstream is impacted by the 

flow 2 bifurcations upstream as also shown by Schroter and Sudlow.

5-15, 33 Is it supposed to be “< 0.05”?

5-16, 19 The authors state that to date studies have failed to show that the large 

differences in biological response between subjects can be explained by 

differences in uptake. This reviewer has commented previously on why this 

has likely been the case in view of the Overton et al. (1996) paper on the 

role of TB expansion and volume on O3 uptake. The following is taking 

directly from that paper “Variability in PAR dose, as a function of TB 

volume already described, has significant implications for human studies, 

particularly those conducted at low exposure levels where measured 

changes are expected to be minimal. Individual responses to a given O3

level are highly reproducible (McDonnell et al., 1985). McDonnell and 

coworkers (1993) found that there is significant interindividual variability 

in changes in FEV1 that correlation analyses ascribe to exposure level and 

to the age of the subject. Alternatively, though, a portion of the variability 

observed may simply reflect the variability in TB volume that was likely 

present among the subjects. Since anatomical dead space, which includes 

TB volume, can be measured, future clinical studies involving reactive 

gases would be more powerful if dead space is controlled or adjusted for in 

selecting subjects, thereby allowing exposure-response curves to be 

translated into dose-response curves. Exercise tends to reduce variability 

among subjects in PAR dose. Thus, controlling for dead space may also 

become more important in clinical studies using extended exposure periods 

(6-8 h/day) with levels of exercise considerably lower than those used in 2-

h exposure studies in the past.”

5-16, 32 Of course rodents have few terminal bronchioles – they have smaller lungs. 

However, the terminal bronchioles are not the site of major O3 absorption –

it is the bronchiolar-alveolar duct junction. The morphometry studies of 
69

Crapo and Cheng definitively show this.

5-16 The species homology section falls short of including enough material that 

shows how homologous species are for the effects of ozone on the 

respiratory tract. Additional figures could be added that would help drive 

this point home. For example, a figure with 2 panels showing monkey 

tissue dose of 18-Ozone measured by Hatch and colleagues in one panel 

and the predicted tissue dose pattern in humans from Miller et al. (1985) in 

the other would show the reader homology between these species. 

5-17, 3 Species differences but not the site may affect the amount. It is the 

respiratory bronchioles in primates and humans and the bronchiolaralveolar duct junction in rodents.

5-17, 6 How does a lower body temperature affect the amount of O3 dose to the 

lungs? The amount of temperature drop is not enough to affect the air 

phase diffusion coefficient for O3.

5-20, 16 The space devoted to this paper is too much. The model structure is far 

from being realistic.

5-21, 20 The text states “Although the O3 molecule is consumed and may not reach 

the apical plasma membrane of airways and alveolar epithelium, ......” is 

an overstatement as far as the alveolar region is concerned. During 

breathing, the 98 % of the alveolar epithelium that is covered by an already 

ultrathin (< 0.02 μm) surfactant layer pools in the corners of the alveoli, 

thereby allowing some cells to be in almost direct contact with O3 in the 

gas phase. Moreover, the surfactant layer normally only approaches a 

thickness of 0.1 to 0.2 μm over Type II cells and in crevices, and, Type II 

cells cover only about 5 % of the alveolar surface area.

5-22, 8 The statement that O3 does not diffuse very far into the mucous layer is 

overall a correct one. However, since the cilia are bathed in the aqueous 

layer and beat at 1200 beats per minute, the layer is far from stagnate and 

may allow some O3 to come into direct contact with epithelial cells in the 

TB region.

5-27, 17 The authors state that an important consideration is the non-uniformity of 

the injury response to O3. Both Mercer and colleagues and Pinkerton and 

coworkers have shown that this is due to the variability in tracheobronchial 

path length and the volume of all the acini attached to a given terminal 

bronchiole. This is why pathologists describe non-uniform injury when 

slides are cut randomly through lung tissue, particularly at low exposure 

levels. 

5-28, 1 The statements here about where maximal effects occur are exactly in 

accord with dosimetry modeling predictions. This is an example of why the 

general comment was made to cite the modeling papers more at various 

points in the MOA discussion.

5-30, 18 This excellent paper by Schelegle et al. (2007) should be expanded upon in 

the discussion. There are a number of good points shown in their 

publication.

5-32, 11 Why all the listing of references up to 30 years old? This comes across as 

the MOA only bears insight after all of this time.

5-48, 3 This is an accurate and powerful statement that should be highlighted in the 

chapter Overall Summary (Section 5.2.10).
70

5-53, 21 Here is an example of the need to include the O3 exposure levels and 

durations. The Arito study involved 5 days of exposure of rats to only 0.1 

to 0.2 ppm O3 that found the cardiovascular effects described here.

5-56, 14 Are the authors not aware of the 2011 publication by Kim et al.? The whole 

paragraph on this page goes on about GSTM1 involvement but does not 

mention the negative finding of no relationship to PMN percentage to O3

exposure at 60 ppb reported by Kim and colleagues. This recent 

publication showed that GSTM1 has no role in modifying the effects of 

neutrophilic inflammation at environmentally relevant exposure levels. 

5-58, 13 Here is another example of where the O3 exposure level and duration 

would have been useful. The cited study involved 0.42 ppm for 1.5 hours. 

So increased body mass index (BMI) is not likely a risk factor at 

environmentally relevant exposure levels given the small but significant 

effect seen for females by Bennett et al. (2007). 

5-61 The MOA Overall Summary section is very weak and does not reflect the 

strength of the findings discussed in the subsections. The current section 

comes across as “the authors ran out of gas”.

Chapter 8: Populations Susceptible to Ozone-related Health Effects

Chapter 8 is a discussion of potential susceptibility factors.

The characteristics included are consistent with the definition of susceptibility presented on the first 

page of the chapter. Providing EPA’s definition of susceptibility was critical for evaluating the material 

included in the chapter. As a statistician and familiar with the concept of tolerance distributions, I 

personally do not like the Agency’s definition of susceptibility; tolerance distributions are founded on 

the recognition of innate biological differences that make some individuals respond at a given dose 

while other persons do not. And as the dose is increased the tolerance distribution becomes narrower.

Are the characteristics included within the broad susceptibility categories appropriate and consistent 

with the definitions used? 

Exercise is only indirectly treated as part of the sections on children and on outdoor activities. At 

ambient exposure levels, exercise is the single most important driver of the amount of ozone inhaled and 

the likelihood of causing effects in individuals of any age or disease condition. As such, more discussion 

of the role of exercise and exercise levels should be included in Chapter 8. This should extend to 

covering how minute ventilation levels greater than about 35 L/min in adults leads to oronasal breathing 

and an increase in LRT absorption due to bypassing much of the filtering efficiency of the nose.

Are there any key susceptibility factors that were not included and need to be added? 

Preliminary General Comments

• The chapter would be made stronger if evidence from animal toxicology studies were included 

that provide support for the susceptibility characteristics under discussion. A good example is 

Section 8.1.1 Influenza/Infections. The section is only a short paragraph about findings in 

epidemiology studies. However, there are a number of animal studies showing the ability of 

ozone to increase the incidence and/or mortality from respiratory infections, even to exposures as 

low as 0.08 ppm O3. Inclusion of such material would strengthen the case for O3 being able to 

cause similar effects in humans.
71

• The chapter summary identifies older age groups as being one of the most susceptible 

populations to O3 exposure. However, the studies discussed in Section 8.2.2 (Older Adults) do 

not give the reader this impression. For each type of effect discussed, both positive and negative 

studies are typically available. This section also provides an example of how the results from 

clinical and animal studies can provide biological plausibility for some endpoints (see the 

discussion starting at line 33 on page 8-11). The evidence may be stronger for some endpoints 

than for others, and this should be the bottom line carried forward to the chapter summary.

• The rambling style of the presentation of studies in various sections makes the material difficult 

for the reader to take away the bottom line about the importance of some of the susceptibility 

characteristics being discussed.

Specific Comments

Page, line Comment

8-4, 9 Why would one even discuss an epidemiology result based on an N of 4? 

8-8, 1 Lung development (i.e., airway branching, addition of alveoli) is completed 

between ages 6 and 8. This is different from lung growth, which continues 

until ages 18-20.

8-14, 18 As noted in the Dosimetry and Mode of Action chapter, why isn’t the Kim 

et al. (2011) study discussed? Their study shows GSTM1 does not play a 

role in O3 responses at environmentally relevant exposure levels.

8-18 Section 8.7 on Socioeconomic Status should make clear to the reader that 

SES is an indicator variable reflecting such things as access to health care, 

quality of housing, and pollution gradient.

8-23, 3 Smokers are most likely less responsive to O3 due to increased mucous 

production and because most of the endpoints studied do not reflect 

alveolar level insults.
72

Dr. Howard S. Neufeld

Chapter 2

I believe this chapter adequately sums up the evidence and conclusions presented in later chapters. It is 

well written, although it is somewhat lengthy for a summary chapter. My main recommendation would 

be to provide the reader with a two page (max) executive summary, complete with tables of known 

causality. 

Of particular usefulness are the concluding statements at the end of each section which summarize the 

findings and provide the reader with the state of causality for that process. I found very little factually 

with which to take issue. There are a few places where some clarity of wording might improve the 

document, but these would be relatively minor changes. In general, this is a good integration and 

summary of the remaining chapters in the ISA.

The policy relevant background section (2.1.3) is particularly well written, and the definition of PRB, 

for those not familiar with this parameter, is excellent and easy to understand. 

Section 2.1.5.4, on Hourly Variations, states that for most locations, diel maxima of ozone occur in midafternoon and minima at night. This seems to ignore high elevation ecosystems, where just the opposite 

can and does occur. Data from the Smokies and other high elevation locations around the world often 

show flat profiles over time, and sometimes the maxima can occur at night instead of during the day. 

Because so many sensitive plants may be located at high elevations, I think a distinct discussion of high 

elevation ozone patterns warrants more discussion and elaboration. It is also not clear to me whether diel 

patterns at high elevations have remained unchanged over the past 20 years like that for low elevation 

sites.

I can’t comment to any great extent on the sections concerning human responses to ozone, as that is 

outside my areas of expertise, but even so, they appear to be well constructed, and to take into 

consideration most, if not all, sources of variation and effects with respect to ozone exposure. My only 

comment is that by section 2.4, I think the document should make it more clear whether the responses 

being discussed were obtained using acutely high exposures (unrealistic with respect to known ambient 

levels) or were obtained using near ambient exposures. 

The tables (2.1, 2.2, and 2.4) provide the reader with quick summaries of the ISA conclusions, and are 

very useful. It might be nice to reiterate the category definitions beneath each table so readers are 

reminded of the degree of certainty with which EPA considers ozone as a cause for each item 

mentioned. 

In Section 2.5.1, potentially susceptible populations, I wonder whether any studies have been done on 

class/economic distinctions with respect to ozone exposure. In this vein, I’m thinking about whether 

certain classes of people are disadvantaged by income or race, which causes them to live in areas that 

predispose them to higher pollutant exposures. For example, wealthy people living on the coast of 

California would be exposed to lower ozone than those further inland or in the central valley. I didn’t 

see any mention of this in the ISA, but certainly, the EPA has studied similar issues with regard to 

environmental justice and the placing of nuclear and toxic waste sites. However, because ozone is often 

a regional phenomenon, it may not be easy to distinguish differences in exposure due to these issues 

over much of the rest of the country.
73

In section 2.5.2, the last sentence seems awkwardly constructed. The first phrase states that single day 

ozone exposures underestimate the public health impact. The second phrase starts off with the 

disclaimer “but” and then states that multi-day effects are limited to the first few days. The way it is 

constructed almost makes it seem as if the latter part is not as important as the first. I would substitute 

“while” for “but” which would give equal weight to both clauses.

I have to admit that I thought Figure 2.1 was less than helpful. It’s too confusing with the colors and 

multi-faceted studies. Is there any way to simplify this? Figure 2.2, in contrast, is much better 

constructed, but you need to define HA/ED visits. Since everything else is spelled out in the figure, just 

spell these acronyms out too. In fact, there is no need for any acronyms in this figure at all.

With respect to welfare effects, I also have a problem with Figure 2.3. I believe the figures are too 

simplified. The leaf panel is simply too cluttered, and all the arrows make it confusing to figure out what 

is going on. Some pathways are covered over by the water vapor arrow. There is no mention of reactive 

oxygen species inside the leaf, nor any distinction between apoplastic and symplastic reactions, even 

though the text extensively discusses these things. Also, C4 plants, which constitute a significant 

fraction of our crop plants, do not have this leaf anatomy, and that difference could have significant 

influences on why most C4 plants appear less sensitive to ozone than C3 plants (if that indeed is true). 

The ecosystem panel uses the term “water production” but in the key to the side uses the phrase “water 

cycling”. Cycling is the more proper term. Ecosystems don’t “produce” water; rather, they use and cycle 

it. A better indication of trophic cascades could be included. As of now, the insects and animals are just 

standing off to the side as if separate from everything else. In conclusion, I think this figure could be 

redrawn to higher standards.

Section 2.7.1 closes with a discussion of ozone-induced changes in stomatal functioning. I don’t think 

sluggish stomata always mean that they do not close after exposure to ozone. Rather, when ozone injury 

is apparent (such as when foliar symptoms are seen), there is a reduction in stomatal conductance which 

may or may not be accompanied by sluggishness. That is, sluggishness doesn’t necessarily occur when 

stomata are as open as in plants not exposed to ozone. Also, sluggishness refers to an inability to either 

close or open, not just close, as stated in the document. Finally, aberrant stomatal functioning often 

occurs in the absence of any visible injury, suggesting that some other factor must be at work to cause 

this effect (and it may not always be due to higher internal CO2). I think the inclusion of a short 

discussion of potential causal factors (besides increased internal CO2) would be welcome.

I agree with most of the rest of this part of Chapter 2. There is a new paper, just accepted to 

Environmental Monitoring and Management (Smith, G., 2011, in press), which summarizes 16 years of 

FIA monitoring of ozone bioindicators. As Smith states, extreme soil moisture deficits decrease foliar 

injury on bioindicators, but in some dry years, soil moisture appears to have less effect on controlling 

injury levels. Soil moisture appears to protect plants against foliar injury no matter what the level of 

ozone exposure. Finally, when soil moisture balance is positive, high ozone generally causes more 

injury. Most importantly, the best correlations with injury were with the N100 (number of peak hours at 

or above 100 ppb) and not with a cumulative index, showing again that peak ozone is critically 

important in determining plant response.

Should Shenandoah National Park be included in the list of parks with bioindicator plants and foliar 

injury (page 2-54, line 19)?
74

With respect to section 2.7.2.2, I simply ask if yield losses with respect to ozone could be reduced by 

farmers either knowingly or unknowingly selecting for ozone tolerant strains of their crops after 

experiencing losses from ozone in previous years. That would alter the exposure/response relationships 

over time.

Also, in this same section, line 22, there is the statement that “most research on the mechanism of O3

damage has used acute exposure studies.” Is this still accurate today? I would have accepted this 

statement 15 years ago, but in my opinion, recent studies have moved to more realistic or near ambient 

exposures. 

I think the jury is still out with regard to sluggish stomata. Section 2.7.3.2 seems confident that reduced 

conductance is the main result of ozone exposure, while admitting that sluggishness does occur. I think 

some compromise needs to be included here. If the weight of evidence is that ozone lowers conductance, 

and only that conclusion is incorporated into models, then the impacts of sluggishness (failure to close 

or open properly) are lost, and the results of studies like McLaughlin et al. (2007), which found that 

sluggishness might be responsible for reducing ecosystem-wide water availability, would not be 

accounted for.

The last word in this same section should be changed from “production” to “use” or “cycling”.

Section 2.7.4.2 discusses night time stomatal conductances. No mention is made of some early studies, 

such as the one by Peter Tobiessen in 1982 (Oecologia) which showed that some early successional tree 

species might open their stomata pre-dawn (and to levels approaching day time conductance’s) or the 

more recent studies by Lisa Donovan. If this is really happening, then it needs to be addressed. Studies 

by Lisa Donovan on night-time conductances, and similar parallel studies using eddy covariance, need 

to be included in the literature review in Chapter 9. Many of these early successional tree species occur 

at high elevations, where ozone is high at night and in the early morning, and they could take up 

appreciable amounts of ozone at those times, assuming there is adequate mixing and deposition to the 

canopy, as discussed elsewhere in the ISA.

Finally, in the section on tropospheric ozone and UV-B (2.8.2), I did not see any mention made of UVB-induced catalysis of elemental mercury in lakes and re-volatilization into the atmosphere. In areas 

subject to acid deposition, where DOC is reduced, and the lakes are made ultra-clear, light penetrates 

further down the water column. If UV-B light is present, it can convert methyl Hg photolytically into a 

volatile form of elemental Hg that then escapes into the atmosphere. If ozone alters UV-B radiation, then 

it could inadvertently affect Hg volatilization and transport within and among ecosystems (See 

Schindler, D.W., 1998. Science). 

Lastly, the summary table at the end is well done, and provides the reader with an expectation of what to 

expect in the rest of the ISA.

Comments on Chapter 9

Much of the beginning of this chapter is word for word, the same as that in Chapter 2. I would shorten 

this chapter by going directly into the specific sections, and leave out all the redundant material. Also, I 

thought that the sections on stomata were too dispersed and redundant. It seems that some reorganization of topics might make the material flow better.
75

In 9.2.2, page 9-6, line 3, it is stated that responses to ozone can be quite rapid, which results from the 

plant’s ability to sense ozone or its breakdown products, which then result in gene activation or down 

regulation. However, some of these responses could occur prior to any gene activation. In fact, gene 

activated responses would generally be slower, given the time required for transcription and translation. 

Might these extremely rapid responses (such as membrane leakiness) simply be physical responses to 

ozone or ROS, and not the product of gene activity? This would make the situation similar to how auxin 

responses are propagated in plants – there is a rapid (10-15 mins.) physical reaction (acidification of the 

apoplast for example) followed by a slower (several hours), prolonged response due to gene activation.

On page 9-7, there is a statement that plants “need to keep antioxidant metabolites in a reduced state” 

and that this “requires a significant shift in C metabolism...”. While this sounds logical, is there really 

any hard evidence showing this from an experimental point of view? I don’t recall any papers that have 

actually tested this idea. Yes, respiration rates do tend to go up, but is there evidence that is because 

plants are attempting maintain their antioxidant defenses, or is it simply a result of foliar injury itself, 

but with no beneficial results in terms of prolonging leaf life span or function? 

Regarding the action of ascorbate, pictured in Figure 9.4, there is no mention of the mini-review on the 

chemistry of ozone-ascorbate interactions by Heinrich Sandermann, which appeared in Biochemical and 

Biophysical Research Communication 366:271-274 (2008). In this review, Sandermann points out that 

reaction of apoplastic ascorbate (or ascorbate in the respiratory lining of the lungs and airways) results in 

the production of a zwitterion that decomposes into peroxy-L-threonic acid and oxalic acid when it 

reacts with ozone. If it reacts with one of the ROS produced upon ozone exposure (singlet oxygen) it 

produces peroxy-ketone. Singlet oxygen can be produced when ascorbate reacts with ozone. Peroxy 

ketones can react with water to yield hydrogen peroxide. These secondary toxicants may affect 

human/animal and plant responses to ozone in ways not yet fully appreciated.

Section 9.4.3.2 ends with a discussion of gene up-regulation and down-regulation by ozone. It would be 

interesting to postulate what differences might exist that cause sensitive plants to react to ozone more 

readily than tolerant plants, if such knowledge exists. That is, what is the molecular basis for differential 

gene regulation by plants that vary in sensitivity to ozone?

For Figure 9.5, there are no labels or units on the Y axis of panel A.

With regard to Section 9.4.4.2, I saw no mention made of Burkey et al. (2006) or Souza et al. (2006) 

with respect to apoplastic antioxidant levels and degrees of resistance to ozone in native wildflowers, in 

particular, tall milkweed. These papers showed a clear association of higher apoplastic ascorbate in the 

reduced state, and reduced foliar injury in the field from ozone for tall milkweed, but not for 

coneflowers or crownbeard. Although correlative only, it is suggestive of the fact that individual plants 

of tall milkweed show fewer foliar symptoms from ozone because they have higher apoplastic ascorbate 

than those plants with reduced amounts which have more foliar injury. Furthermore, tolerant tall 

milkweed plants maintained elevated apoplastic ascorbate throughout the season compared to sensitive 

individuals, which slightly contradicts the statement at the end of section 9.4.4.2 that plants cannot 

maintain elevated antioxidant levels for extended periods of time. Perhaps such patterns are species and 

environmentally contextual. 
76

In Section 9.4.6, there is the statement, on page 9-46, that ozone-sensitive coneflowers “have a set of 

traits, such as a sluggish stomatal response to changes in light intensity, which predispose them to being 

more sensitive to O3 exposure...”. In actuality, there is little evidence for any differences in stomatal 

conductance prior to the appearance of foliar injury between sensitive and tolerant coneflowers 

(personal knowledge on my part, paper in preparation). Such differences in the magnitude and 

responsiveness to environmental variables only show up once sensitive plants show visible foliar injury. 

So it is not accurate to state that there are “predisposing” factors. At this point we simply do not know 

why one individual is sensitive and an adjacent one is not.

Also, in this same section, there is no extended discussion of Nancy Grulke or Elena Paoletti’s work on 

stomatal sluggishness.

In Section 9.5.3.2, page 9-59, line 6, Volk et al. are cited with respect to effects of ozone potentially 

causing shifts in high elevation community species composition. Yet, this study was repudiated later by 

Stampfli and Fuhrer (2010) and this latter study is cited later in the ISA in section 9.6.5.2, on page 9-84. 

Perhaps Section 9.5.3.2 and Section 9.6.5.2 should be made consistent with each other. A recent paper 

(Volk et al. 2011, Global Change Biology 17:366-376) shows an influence of N deposition on soil C 

storage in these high elevation meadows, but no effect of ozone and should be included in the ISA.

Section 9.5.4.4 documents the reported interactions between ozone and N deposition. There is a lack of 

investigations on the interaction between N deposition and ozone responses, which highlights a major 

research deficiency in our understanding of how ozone responses by plants can be modified by other 

forms of pollution. 

There are no reports in the ISA of the responses of nonvascular plants (e.g., mosses), lichens or lower 

vascular plants and their responses to ozone. A quick Web of Science search of papers published since 

2006 brought up five papers on lichens and ozone and one for mosses, but none for ferns. Inclusion of a 

statement that our knowledge of the impacts of ozone on these types of plants has not been a research 

priority in recent years, and a retrospective summary of past conclusions for these types of organisms 

might be helpful here. Mosses cover a vast amount of the earth’s surface, and if they are negatively 

impacted by ozone, this could have an effect on the C balance, and hence global climate.

Most of the ecosystem level studies cited used 2X ambient ozone levels to elicit effects. How relevant 

are those results then, with respect to current and expected levels of ozone?

In Section 9.6.3, line 6, page 9-74, the text reads “...leads to greater stomatal apertures.” This is not 

entirely accurate. It can lead to sluggish stomata which fail to close; but only rarely do they open more. 

Section 9.6.6.1 on species-level responses would benefit by having a concluding sentence that 

summarized the situation. Such a sentence would simply state “that that there is no consensus on how 

insects respond to feeding on ozone exposed plants.”

Section 9.7.3.1 would benefit by inclusion of the Smith paper (see earlier mention) on foliar injury and 

its relation to peak and cumulative amounts of ozone over 16 field seasons. It too found that peak ozone 

concentrations (at or above 100 ppb) seemed highly correlated with the degree of foliar injury found in 

the field; more so than any cumulative index.
77

Section 9.7.3.2. makes no mention of Tobiessen’s early work on nocturnal conductances in early 

successional trees (Tobiessen, P. 1982. Dark opening of stomata in successional trees. Oecologia 

52:356-359) and might be improved by its inclusion. Nor does it reference Lisa Donovan’s extensive 

and recent work on this subject.

In Section 9.7.4.1, Chappelka et al. (WASP 116: 255-260, 1999) documented greater injury in midcanopy black cherry leaves, rather than those at the exterior and most exposed part of the forest canopy. 

This probably resulted from an interaction between canopy location and ozone concentration, where 

fully exposed leaves were more water-stressed and had lower stomatal conductances, while those in 

mid-canopy had slightly lower ozone, but higher stomatal conductances. Such patterns should be reemphasized here, even if reviewed in an earlier document.

Gregg’s data in Section 9.8.3.3 is eye-opening to say the least. If this represents what is happening in the 

field, then certain genotypes of trees have already, or will soon be, eliminated by ozone from the 

landscape (maybe this has already happened in some poplar clones and in white pine – see Berrang and 

Karnosky’s early work on this). That means a decrease in genetic diversity, which can happen without 

any noticeable change in appearance of the forest or other plant community, since resistance genotypes 

would appear visually similar to the sensitive ones that are selected against.

One final comment on something in Chapter 3, page 3-7, line 15. Here, it is stated that coniferous 

forests are the largest source of VOCs nationwide. In the southeastern states, vast swaths of land have 

been converted from hardwood forests to production pine plantations. I wonder if anyone has calculated 

whether this has caused an increase in the VOC emissions in this part of the country compared to what 

was present when it was mostly hardwood forests?

The rest of this chapter is a good summary of the current state of knowledge of how natural and 

agricultural ecosystems respond to ozone.

Comments on Chapter 10

I thought this was a well written summary of both the direct and indirect effects of tropospheric ozone 

on UV-B radiation impacts. I appreciated how this chapter discussed the climate forcing due to ozone 

relative to that of CO2 and CH4, as well as the way it distinguished between long-term and short-term 

greenhouse gases. 

With respect to calculating recent ozone trends, E. Henry Lee et al. (2003, History of tropospheric ozone 

for the San Bernardino Mountains of Southern California, Atmos. Env. 37:2705-2747) had a paper out 

recently comparing trends in California back to the time when ethylene monitors were used and showed 

that they could reconstruct the ozone trends for that period, but I didn’t see it cited in the ISA.

I thought this chapter fairly evaluated the research to date while also pointing out the paucity of studies 

of how increasing tropospheric ozone will affect UV-B impacts. It also got the point across that most 

conclusions regarding these effects are tentative, and, where more is known, that the magnitude of 

effects is likely to be small to moderate at most. I agree with the last conclusion on page 10-28 that “the 

effects of changes in surface-level O3 concentrations on UV-induced health outcomes cannot yet be 

critically assessed within reasonable uncertainty.”
78

Typos Needing Correcting

I only read Chapters 1, 2, 3, 9 and 10 for typos

Note: for ALL figures with legends, they all contain a box after the first sentence or so, which often 

overlaps with other text.

Chapter 1

1-6, line 34 - Change “if” to “of”

Chapter 2

2-4, line 25 – Should it be “hPa” or “kPa”??

2-9, line 13 – Change “This” to “These”. Data are always plural.

Line 32 – there is an overlap of the greater then and the left parenthesis

2-23, line 12 – insert “of” before “antioxidant”

2-36, Table 2-3 – In the short-term section of lung function, second column, the less than and 

parenthesis signs are on top of each other.

2-49, line 8 – insert “that” before “have been”

2-58, line 30 – insert “the” before “Carpathian”

Chapter 3

3-10, line 16 – the symbols after acyl peroxide radicals are messed up.

For many of the figures, using dark blue for the correlation boxes, with black fonts makes the numbers 

impossible to read.

Chapter 9

9-41, line 7, “Acer” should be italicized.

9-48, line 35 – insert “production” after “fine root”

9-51, line 20, “Smokey” is misspelled. There is no “e”, e.g., Smoky. Also, “Mountain” should be 

plural, as in “Mountains” – Great Smoky Mountains National Park

Table 9-2 – all the scientific names in the table should be italicized.

9-53, line 5 – “Asclepias exaltata” should all be italicized.

9-56, line 37 – take out “a” before “the individual”

9-58, line 22 – There is some confusion in units on this line. The sentence states that yields are 

reduced “by -0.38 to -1.63% ppb/v across the five years.” Should that be are reduced “by 0.38 to 

1.63% per ppbv/yr”? That is, take out the negative signs, and correct the ozone unit, and insert 

yr in the denominator.

On this same page, but line 28, “dependant” is misspelled. Should be “dependent”.

9-59, line 4 – change the second “was” at the end of the line to “were”

9-63, line 12 – both Rhizobium and Frankia should be italicized.

9-64, line 25 – I think a word is missing here. The sentence says that O3 may enhance O3

effects. I think the first O3 should be “drought”, right?

9-66, line 7 – Change “on” to “in” before photosynthesis.

9-70, line 11 – “function” should be plural, “functions”

9-71, line 25 – insert “in” before “O3 concentration”

9-72, line 2 – insert “the” before “northeastern”

Line 38 – Change “that” to “than”

9-81, line 5 – insert “the” after “Since 2003”

9-83, line 6 – subscript the “4” in “CH4”

9-86, line 27 – take out the comma after “O3” and put in a space
79

Line 32 – change “have” to “has”. This verb refers back to “performance” on the 

previous line, which is singular.

9-129, line 3 – change “confirms” to “confirm” – should be in the plural form since this verb 

refers back to cottonwood “data”, and data is a plural word.

9-131, line 8 – insert “%” after “17.9”

Note that for ALL references in this (and probably other chapters) that contain scientific names, none of 

them are italicized, and they should be.

Chapter 10 – I did not find any typos in this chapter.
80

Dr. Ted Russell

Review of the Integrated Science Assessment for Ozone and related Photochemical Oxidants (First 

External Review Draft)

Overall, I thought that the ISA is in pretty good shape for a first draft. It is still a bit long in places (see 

below), but that may be unavoidable. My main issue is that I think more attention needs to have more 

information on both the health studies and the air quality analyses at relatively low levels (40-60 ppb) 

and the potential role of confounding when ozone is around those levels. After all, ozone is around those 

levels more often than it is above those levels. 

In general, I think Chapter 3 does most of its job pretty well, and some parts may be a bit long. I was 

glad to see that a significant fraction was moved to an Appendix. For the most part, the chemistry and 

transport are relatively well known, and the last ISA did a good job on its description and analysis of 

observational data. I think there are a couple of potential areas that need to be more fully addressed:

1. Relationship between various ozone metrics at lower levels. The likely driving question 

associated with this review process is where in the range of 60-75 ppb, 8-hr average should a 

new standard be set. In part, this will rely on various epidemiologic studies. Various studies have

used different ozone metrics, e.g., 24-, Max 8-, and Max 1-hr averages, and it is important to be 

able to relate those metrics to each other. Some of those studies provide more than one metric 

and that is good. However, for those that don’t, it is important to be able to relate one to another, 

with particular interest in what is happening in the 60-75 ppb range. Thus, a good way to convert 

would be useful. However, the relationship varies between city and between concentration range, 

so a single value to convert is not likely appropriate. (If it is, great, and show this.) Thus, it 

might be useful if EPA looks at how this conversion should be done and provide such in the 

ISA.I might recommend a graph of the 8-hr max compares to 24-hr average for a number of 

cities and the country as a whole. 

2. PRB. The PRB discussion is pretty good, though abbreviated in that it was not apparent what the 

conclusion is (likely because this is a 1st draft and that updated PRB analysis will be done). 

Further, and while I do not know how it is best to address this subject, is that this could be a very 

key issue since the results show that the PRB levels in parts of the country could be similar to the 

levels of a proposed standard, thus suggesting the potential need for changing the form of the 

standard. I suspect that info from the recent PRB workshop will be utilized, assuming that the 

publication is completed and accepted. To me, the fundamental question is how to mix an 

observed quantity with a modeled quantity, particularly a modeled quantity that has apparent bias 

in some locations. Further, it is not apparent that a bias-less product will be developed (if so, 

great). Thus, a question is how one can modify the PRB to remove bias, or how to use the 

simulated ozone that is due to North American emissions, along with observations. At present, I 

think that the former is easier and less open to criticism. EPA should set out a strategy to identify 

the reason for the observed biases. I think this can be done using the adjoint capabilities in the 

model. The knowledge gained from such an exercise can provide some confidence in using an 

adjusted PRB product. In regards to how knowledge of the PRB might influence the 

determination of the form of the standard (or averaging time), it would be good to provide 

additional information on PRB ozone distributions for key urban locations, along with values 

akin to the design value based on 4th highest, 10th highest (etc.), 8-hr ozone. The details could be 

in the Appendices, but summarized in the main report. 
81

Chapter 9 can be shortened, and streamlined to directly address what are the appropriate indicators. This 

ISA, as well as the documents developed in the last review, provide strong support for the linkage 

between ozone and ecosystem damage, and CASAC concurred. What needs to be taken head on is 

which metric(s) is best and why. 

Chapter 10 does a good job of addressing how ozone can potentially impact radiative forcing and hence 

global change. A couple of things are needed to complete some of the thoughts that go along with this in 

terms of standard setting. First, it would be good to also integrate the information from the PRB analysis 

and modeling in to this chapter, e.g., taking on the question of what the impact of the ozone from NA 

emissions. A second issue is how the warming can impact health. Be very careful to note the 

uncertainties associated with assessing how health impacts might be linked to future climate changes. I 

might refer to the Weaver manuscript (BAMS) that discussed the results from many groups.

Some general comments that should be addressed throughout:

1. Given that this document is to be used for policy determination, the staff should be very careful 

to only use studies that have relied upon data and models that are now or have been readily 

available and/or have been independently evaluated and verified. If the staff feels that specific 

references that do not fall in to that category are absolutely necessary, they should identify this 

problem and justify the use of that study within the document. This should be an underlying 

principle for such documents and assessments (and it might extend beyond documents that are 

used for policy setting). 

2. Make very sure that the figures and tables have the appropriate units and metrics specified in 

detail (e.g., “3-yr average of the 4th highest 8-hr maximum daily ozone” as opposed to “ozone”). 

3. It would be good if every chapter had an “overall summary” and “gaps in knowledge” similar to 

Chapter 5.

4. Ozone (and other pollutant) results from models applied to historical cases should be referred to 

as “modeled” or “simulated” as opposed to predicted

Some specific comments:

• 1-2-26: “mobile”

• 1-4-3. I might rephrase “Photochemical pollution (or smog) is a mixture of pollutants, many of 

which are oxidants formed from reactions that take place in the presence of sunlight. 

Historically, ozone has been used as an indicator of photochemical smog, in part because it is 

one of the most abundant photochemical pollutants and it has been demonstrated to have health 

effects.” 

• 1-7-12: You should make explicit the current status of the standard and what it means that the 

Administrator has decided to reconsider in terms of actions taken to meeting an 0.075 standard.

• Chapter 2: the amount of text on the plant impacts is a bit out of balance. . 

• 3-2-5: compounds, as well as particulate matter.

• 3-3-7: ... in the eastern US, concentrations of ozone

• 3-3-28: remove small scale unless you are ready to define it (and it is unnecessary here). 

• 3-4-8: “square kilometers” is not a distance, and a few thousand square km is not that big of an 

area. 
82

• 3-4-15: Make sure you are consistent about the importance of stratospheric exchange throughout 

the document.

• 3-6-14: I do not think compensated is correctly used here. 

• 3-6-34: What is a small amount? 0.05%, 0.5% 5%?

• 3-7-8: Are you saying that wildfires are anthropogenic and contribute 1/6 of the anthropogenic 

VOCs?

• 3-7-28: It is important to note that controls mute the response of CO formation to fuel-oxygen. 

• 3-8-33: I think VOC was defined earlier.

• 3-9-11: “they” is ambiguous.

• 3-9-25: Make sure NOz is defined.

• 3-11-12: “... O3 and other compounds.”

• 3-17-6: We don’t just use finite difference techniques, and there is no reason to bee this specific 

anyway. (also found on 3-19-7)

• 3-17-23: ... about 100 hPa,”

• 3-18-4: “Historically, CMAQ has been...”

• 3-20-40/24: This paragraph raises problems that need to be more quantifiably demonstrated to be 

an issue in the general application of models in practice. Provide citations and relate to 

magnitude of other problems. 

• 3-21-11: Is the MCM considered a benchmark? I would suggest that being shown to reproduce 

the controlled laboratory studies is more of a benchmark. 

• 3-21-38: Provide citations as to the importance of coupling and also what is meant by heavily 

polluted (Beijing or LA?) Be quantitative. From reading this chapter one might get the idea we 

should not use CMAQ because it does not include enough vertical resolution, does not resolve 

the nocturnal jet, the chemical mechanism is flawed and not as good as the MCM, and does not 

generally incorporate coupling. Are you ready to say this?

• 3-23-7: Actually many components are tested individually when possible. 

• 3-25-24/26: Again, this part is speculative and citations are necessary. Should we not use 

CMAQ? 

• 3-33-29: L Should you add low spatial resolution such that elevated sites are not fully captured. 

• 3-33-35: Show this graphically.

• 3-37-6: It is not that the air is too high, it is that the simulated ozone concentrations are too high.

• 3-55-33: A mixing ratio is not, technically, a concentration. You might state this, but then say the 

general practice is to call ppm/ppb concentration. 

• Fig. 3-18: It would be of interest to identify the two outliers. 

• Tables 3-6& 3-7: I don’t see the Max column. 

• Table 3-9: SEARCH monitors year-round. 

• Figures 3-30/35: Possibly a couple more in Appendix. 3-83-20: The AM monitoring site seems 

to be the real outlier to be discussed. 

• 4-14-17/25: The choice of articles cited is rather (extraordinarily) strange. Choose the classical 

and most influential ones. 
83

Dr. Helen Suh

Response to Charge Question 3: Chapter 2 presents the integrative summary and conclusions from the

O3 ISA with detailed discussion of evidence in subsequent chapters. Is this a useful and effective 

summary presentation? How does the Panel view the appropriateness of the causal determinations? 

General Comments

Chapter 2 is an effective and useful presentation of the health and welfare findings for ozone. The 

Chapter clearly and cogently summarizes and integrates findings, successfully relating new findings to 

those from the earlier 2006 AQCD and highlighting whether and how the new findings support or 

contrast these earlier findings. The inclusion of welfare, climate change, and UF-B effects in this 

summary chapter was welcomed. I In general, the Agency’s determinations of causality were 

appropriate, with the exceptions of the causal determinations of “suggestive” for the effects of short- and 

long-term ozone exposure on cardiovascular effects. The causal determinations of “suggestive” for the 

effects of short- and long-term ozone exposure on cardiovascular effects should be better justified or 

possibly revisited. Although findings from toxicological studies provide some evidence of short- and 

long-term ozone impacts on cardiovascular effects, very few epidemiological studies examining ozonemediated cardiovascular effects have been conducted, with their findings inconsistent (as summarized in 

Section 6.3.2.9 and Section 7.3.3) and possibly confounded by PM2.5 or sulfates. Further, substantial 

questions remain regarding the biological mechanisms by which ozone may impact cardiovascular 

health. It is not clear from the criteria described in Table 1-3 whether together the body of evidence is 

sufficient for a causal determination of “suggestive”. 

To serve as a more effective integrative summary, the Chapter would benefit from a reorganization or 

more distinct delineation of the sections, with the primary goal to reduce repetition of health findings. 

Section 2.6 (Integration of Ozone Health Effects) repeats much of the health evidence presented in 

Sections 2.3.2 (Possible Pathways/Modes of Action) and 2.4 (Health Effects). Of the sections, I found 

Section 2.6 to be the best, as it was a cogent and concise summary of our understanding of ozone health 

effects that integrated findings from the different disciplines. Section 2.6 was enhanced further by its 

effective use of tables and figures and by its noting of the ozone levels at which relationships or effects 

were observed. If the Chapter were to be reorganized, it is possible that Section 2.4 and Section 2.3.2 

could be replaced by Section 2.6, with the summary tables of causality determinations (Tables 2-1 and 

2-2) kept at the beginning of Section 2.6. Absent of a reorganization, the purpose of the sections should 

be more narrowly defined to minimize their overlap. 

Specific Comments

• Study Citations: Study citations should be included for the best of the relevant studies and for major 

statements (for example, the sentence beginning “recent studies in humans and animal models...” on 

Page 2-20, line 6-7). Such citations would help connect the summary to later discussions and would 

provide more scientific context.

• Exposure Error: 

o Page 2-13, lines 36-39; Page 2-16 lines 13-15: The document states that “Taken together, results 

from previous and recently published studies indicate that while....O3 concentrations measured at 

central-site monitors are representative of day-to-day changes in average personal O3 exposures. 

This conclusion does not follow the preceding phrase nor is well supported by the scientific 

literature. The agency should either revisit its conclusion or provide a better basis for its 

conclusion.

o Page 2-15, lines 21-25: The phrase beginning “although this may be less of an issue for ozone ...” 

appears to contradict findings of intra-urban, traffic-related variability in ozone levels. Since 

many epidemiological studies are based on MSAs, with populations living in both urban and 

suburban environments, it is not clear that this is less of an issue for ozone as compared to other 
84

pollutants. Further, evidence from Atlanta study may not be directly applicable, given that an 

alternative explanation could be that ozone is not related to changes in HRV in this study.

o Page 2-15, lines 27-29: Even though ozone may exhibit low spatial variability in comparison to 

CO and NOx, ozone may still vary enough spatially to impact epidemiological studies and 

exposure error. Further, issues related to confounding in epidemiological studies have to do more 

with PM2.5, for which spatial variability is less than that for ozone.

• Diagram: Page 2-17, Section 2.3.2: This section would benefit from a flow diagram or other figure, 

such Figure 2-2, describing the possible pathways and modes of action by which ozone causes 

damage. The addition of such a diagram again speaks to the need for possible consolidation of section 

2.3.2 with section 2.6.

• Organization: 

o Page 2-24, lines 4-12: This section includes discussion of ozone-related impacts on respiratory 

mortality, which is misplaced and may confuse the reader with regard to the causal determination 

that follows, which does not include mortality.

o Page 2-25, lines 8-14: This section includes discussion of ozone-related impacts on 

cardiovascular mortality, which is seemingly misplaced. Since ozone-mediated cardiovascular 

mortality impacts were considered in the causal determination for O3 and cardiovascular effects, it 

is possible that this section of the chapter should be reorganized to improve its flow.

o Page 2-28, Section 2.4.2.1: This section should be reorganized to make a clearer case supporting 

the Agency’s causal determination. For example, lines 7-13 should be incorporated into the 

paragraph beginning on line 19, as they discuss the same effects. In addition, the evidence from 

rodents and primates was not introduced in this section, but referred to here. 

o Page 2-29, lines 23-27: The sentence beginning “Although questions exist...” refers to possible 

modes of action, which should have been first introduced in Section 2.3.2.

o Page 2-29, Section 2.4.2.3: Section 7.4.10 is essentially the same section. It, however, 

summarizes and supports the causal determination of the impact of ozone on reproductive and 

developmental effects more effectively in almost the same amount of space. 

• Potential for Confounding: Page 2-25, Section 2.4.1.2: his section should discuss the potential for 

confounding of ozone-mediated cardiovascular effects by other pollutants and acknowledge the 

general lack of studies investigating this issue. 

• Susceptible Populations: Page 2-25, lines 6-8: This sentence about susceptible populations is 

conjecture and should be rephrased. 

• Cardiovascular Effects: Page 2-25, lines 17-19: The literature examining the relation between ozone 

and HRV is mixed. A phrase or sentence to this effect should be added.

• Mortality: Page 2-26, lines 15-18: This section should clearly state whether research post-2006 

more fully established the underlying mechanisms by which ozone contributes to mortality. If so, 

what are these mechanisms?

• Welfare Impacts: Section 2.7 would benefit from the addition of information about the ozone levels 

at which the adverse impacts were observed. 

Climate Change: A summary causal determination table is missing.
85

Dr. James Ultman

Chapter 5. Dosimetry and Mode of Action(rev. 5/19/2011)

This chapter does a good job of integrating new literature on O3 dosimetry and mode-of-action and its 

integration with the literature available in the 2006 ACQD. In general, sufficient detail is presented to 

serve as a background for the health risk assessment. However, the first part of the chapter on dosimetry 

is essentially disconnected from the second part of the chapter on mode-of-action. An implied by link is 

O3 reaction with ELF subtrates that simultaneously augments the uptake O3 and the production of toxic 

byproducts that can reach epithelium. Perhaps an overall chapter introduction should explain why the 

two topics are presented in the same chapter. How about a figure showing the continuum between O3

exposure concentration  inhaled dose  net dose  tissue dose  mode-of-action  health effect?

I think there needs to be one place in section 5.1.3 (Possibly, the paragraph beginning on line 9 on page 

5-8) where all the dosimetry terms used in the chapter are carefully defined and compared. The terms 

you might include are: flux, absorbed fraction, absorption efficiency, inhaled dose, net dose and tissue 

dose. 

The material on O3-ELF reactions as presented in sections 5.1.2 and 5.2.2 are overly redundant. I 

recommend that the former section focus on issues that are primarily directly connected to dosimetric 

aspects (e.g., the structure of kinetic rate equations, rate constant values of different substrates, and 

diffusion-reaction models that estimate O3 penetration into ELF). The latter section should be more 

concerned with issues that influence mode-of-action (e.g., mechanisms of the O3-ELF substrate 

reactions and the toxicology of the possible reaction products).

There is a lack of clarity regarding the effect of breathing pattern changes on O3 uptake. For example, 

figure 5-3 indicates that O3 uptake efficiency among different subjects decreased with increasing 

breathing frequency. The figure caption fails to point out that the subjects were coached to maintain the 

same minute volume. Thus, the decrease in frequency was also accompanied by an increase in tidal 

volume. 

Also, given the potential importance of exercise on physiological responses to O3, I suggest that the 

subsection on “Physical Activity” (page 5-14) more fully discuss the specific breath patterns (e.g.,. 

frequency and tidal volume) associated with different exercise levels. For example, a change from low 

to moderate exercise level is accompanied primarily by a change in tidal volume whereas an increase in 

frequency becomes more important when exercise increases from moderate to heavy levels. Based on 

past dosimetry measurements and dosimetry models, how do these different breathing patterns at 

different exercise levels expected to affect ozone uptake and uptake distribution? 

Page:Line, Table or Figure Specific Comments and Suggestions

5-4:3 Perez-Gil work was published after 2006.

5-7:8 to11 It is unlikely that O3 molecules are reacting in the gas phase since the substrates are 

not volatile. Perhaps, the concept to stress is the large surface to volume ratio of microdrops that may 

promote an interfacial reaction that is not evident from previous studies that used bulk liquid phase 

bioreactors.

5-9:1 Change “lung” to “lung epithelium”
86

5-10:20 to 22 Replace sentence “Uptake...concentration” with “Uptake efficiency is changed by 

a number of variables including O3 exposure concentration, exposure time and breathing pattern. For 

breaths of similar waveforms, respiratory patterns are uniquely described by frequency (fB) and tidal 

volume(VT), by minute volume(MV=fV×VT) and fB, or by MV and VT. Respiratory flow that is directly 

related to MV is less frequently used.:

5-10:25 The statement about Overton’s simulations that “fraction uptake increased with 

VT” does not indicate whether fB, MV or neither were held constant.

5-10:25&26 Subjects in the Ultman study targeted a fixed MV so that increases in VT were 

accompanied by decreases in fB. I think that breathing in Gerrity’s study was unconstrained.

5-10:28 Change “...the lung.” to “the lung at a particular MV.”

5-10:28 & 29 The sentence “While...fB.” is no longer needed if previous suggested changes are 

made.

5-10:30-32 Change the sentence “Nasal...(Fig. 5-3).” to “Nasal O3 uptake is inversely 

proportional to flow rate (Santiago) so that an increase in MV will increase O3 delivery to the lower 

airways. At a fixed MV, increasing VT (corresponding to decreasing fB) drives O3 deeper into the lungs 

and increases total respiratory uptake efficiency (Fig. 5.3).

5-10:32-33 State whether VT or MV (or neither) was kept constant in Overton’s simulations.

5-11: fig 5-3 Change graph and caption labels uniformly to either “uptake fraction” or uptake 

efficiency.”

5-11: 11 to 12 The portion of the sentence “This...inlet air...” is not accurate. Ozone uptake 

fraction (or efficiency) is normalized by the amount of O3 in inhaled air. Thus, when diffusion and 

reaction rates are proportional to O3 concentration, O3 uptake fraction is independent of inhaled O3

concentration. On the contrary, O3 uptake is an unnormalized quantity that will be proportional to 

inhaled O3 concentration when diffusion and reaction rates are linear (Actually, Santiago did find a 

slight negative dependence of uptake efficiency on inlet O3 concentration. Still, one can conclude from 

her results that the transport processes are essentially linear with respect to O3).

5-11: 16&17 The beginning of the sentence “Increased fB will shift the O3 uptake.....” should 

read “Decreased fB at a fixed penetration volume will shift O3 uptake...

5-12:14 &15 The sentence “Similarly...efficient” doesn’t make sense to me since fractional O3

uptake by the respiratory tract is essentially equivalent to O3 uptake efficiency. You might want to 

remove this statement.

5-13:6 This sentence makes more sense if “O3 uptake by the respiratory tract” is replaced 

by “O3 induced responses such as FEV1.

5-15:32 Define MCA, CSA2 and CSA3.

5-16:5 Change “...in smokers...” to “...in smokers during continuous O3 exposure.”
87

5-16:13 Change sentence “Fractional absorption will decrease with increasing fB and 

decreasing VT when MV is held constant.”

5-17:13 Change “structure” to “structure and ELF chemistry.”

5-54:11&18 These sentences are repeated, word for word.

5-55:4 Change “extrapulmonary effects of O3” to “extrapulmonary effects of relatively 

high levels of O3 exposure.

5-61:4 Define CAPS
88

Chapter 6. Integrated Health Effects of Short-Term Ozone Exposure 

This chapter contains a large amount of information, and the authors are to be commended on both the 

organization and the clarity of writing. There are only a few possible improvements that I would like to 

suggest.

First, the exposure-response curve in figure 6.1 that is obtained from McDonnell’s publication provides 

strong support for the response data from laboratory research on humans at low exposure concentrations. 

Thus, more detail concerning the nature of the model and data utilized to estimate the model parameters 

should be given in this chapter.

Second, many of the pulmonary function responses in section 6.2 are reported as pre-to-post exposure 

changes in an endpoint relative to that observed in filtered air; this is referred to as “O3-induced 

response.” Frequently, pulmonary function of subjects who are exercising and breathing filtered air 

improves relative to pre-exposure measurements. Thus, O3-induced response might be significantly 

larger than the corresponding pre-to-post changes in an endpoint. Because of this, I feel that the chapter 

needs to contain some specific information comparing pre-to-post responses to O3 with the 

corresponding O3-induced responses that are referenced to filtered air.

Third, I think that many of the graphs comparing epidemiological studies with different endpoints 

placed above a single abscissa (figures 6-3 to 6-11) are confusing. I think it would be better if studies 

were grouped above different abscissa’s, each having a range of values that is logical for the endpoint in 

question. 

Page:Line, Table or Figure Specific Comments and Suggestions

6-6:35 Remind reader what is meant by “inhaled dose.”

6-6:36 Units on dose rate should be in “ppb per unit time.”

6-8:15 to 17. Does this sentence imply that a threshold exposure concentration is possible?

6-10:10 I don’t think that “clinically meaningful” can be equated to an adverse health 

effect. Can you be more precise in your understanding of this term?

6-13:11 Define SES.

6-19:8 I couldn’t find the values 0.76 and 48 in table 6-2.

6-20: Fig. 6-3: I suggest breaking this down into two graphs with unique units on their abscissa’s. 

The present use of a single absicca that accommodates two different units does 

not help me compare the results of the studies with two different endpoints.

6-27: Fig. 6-6 Please give the rationale in the text for the standardization stated in this and 

several other figure captions. 
89

Dr. Sverre Vedal

Charge Question 2: The framework for causal determination and judging the overall weight of 

evidence is presented in Chapter 1. Is this framework appropriately applied for this O3 ISA? How 

might the application of the framework be improved for O3 effects?

1. Causation. 

Causes do not need to be “significant” (1-14. line 1); the term is also ambiguous. So, this definition in 

essence relies on the term “effectual” (as in effectual relationship) to define causality. Not a very 

informative (as in “cause and effect,” therefore a little circular) or useful definition. Couching the 

definition of causality in counterfactual terms, as alluded to in line 5, is arguably the most informative. 

This incorporates the notion of “all else being equal” and is most readily operationalized, reflecting what 

is attempted in both experimental (e.g., control exposures) and observational (e.g., control of 

confounding) studies. 

2. Confounding and effect modification. 

The concepts of confounding and effect modification are more clearly expressed in this ISA. Including a 

discussion of multiple pollutants in this context (1-16, lines 8-13) is appropriate, but it needs to be made 

clear that what is being developed here is the notion that ozone effects might be confounded by effects 

of other pollutants, which is not clear from the discussion. 

The discussion of effect modification should define it (e.g., differences in the effect of exposure [ozone] 

by differences in another factor) before launching into a discussion of how it differs from confounding. 

Also, temperature is presented as a potential effect-modifier, but it might be valuable (and less 

confusing) to contrast how temperature is also (and more importantly) a potential confounder. 

Essentially, effect modification refines our understanding of the effect of an exposure while confounding 

addresses whether an effect is actually present, or what the size of that effect is, if present.

The discussion of measurement error (1-17, para 3) should refer to ISA Chapter 4, especially 4.5.1 

“Exposure Measurement Error” and 4.6. The discussion here in this context (confounding) is merely 

confusing. The point should be that measurement error that differs in degree across pollutants 

complicates interpretation of individual pollutant effect estimates in multi-pollutant regression models –

effects of pollutants that are measured with less error can dominate effects of other pollutants, even 

though their effects may in fact be weaker.

3. Causality determination and weighing evidence.

The Hill “criteria” are listed in Table 1-2. Coherence also refers to findings across epidemiological study 

designs, not just between epidemiological, toxicological and other experimental studies. It is noteworthy 

that presence of exceptions to each of the “criteria,” except temporality, is still consistent with causality 

(Rothman).

The weighing of evidence to come up with a causality grade is reasonable. This worked reasonably well 

in the context of PM. I like the inclusion of a “not likely to be a causal relationship” category in this 

version – it maintains symmetry.

I’m not sure that studies with concentrations “within an order or two of ambient” (1-22, line 5) 

concentrations are relevant for causality determination. This would imply that for, say, an ozone 

concentration of 0.070 ppm, findings from studies of 7.000 ppm would be relevant. I doubt that. 

4. Effects on human populations.

The shape of the exposure-response relationship is influenced by the degree of measurement error, as 

touched on (1-23, line 8). Specifically, measurement error at lower concentrations can obscure a 

threshold and make it appear that a linear relationship extends to lower concentrations (Brauer M et al. 
90

Exposure misclassification and threshold concentrations in time series analyses of air pollution health 

effects. Risk Anal 2002; 22: 1183-1193). This could potentially be a particularly important issue for 

pollutants such as ozone that exhibit large degrees of measurement error.

I am happy to see a discussion of publication bias included in this ISA (1-23) and the reference to 

Ioannidis, 2008. The observation that publication bias in the case of ozone may not be so important (1-

23, line 27) is contradicted by the work of Bell showing substantial difference in ozone effect estimates 

from meta-analyses of published studies and multi-city study effect estimates. 

The discussion of susceptibility indicates that the term here will be used in a general sense to include 

both susceptibility and vulnerability, terms that include both disease risk factors and factors that increase 

exposure (1-23, line 36) and therefore risk. 

5. Adversity.

The discussion of adversity is appropriate to include here. There is no discussion, however, of the types 

of endpoints that are more problematic in a discussion of adversity, such as markers of inflammation or 

oxidative stress, for example. 

Specific.

1-13, line 15. It is not clear that the type of important evidence would vary by pollutant – It would vary 

if this were based on the availability of evidence for different pollutants, but I would think the important 

evidence should be pretty much the same, given findings across multiple lines in inquiry.

1-15, line 35. While this is true, clinical studies also have the potential of overestimating effects when 

exposures used (concentration or intensity) are seldom experienced in the real world.

1-16, lines 29-31. Drop this unless you intend to be inclusive, since effect modifiers can be found in 

many other settings than these in air pollution epi studies.

1-16, line 33. Some approaches to controlling confounding are very satisfactory. I think what may be 

intended here is that approaches to controlling co-pollutant confounding are not very satisfactory.

Charge Question 5. 

Chapter 4 describes human exposures to O3. Is the evidence relating human exposure to ambient O3 

and errors associated with exposure assessment presented clearly, succinctly, and accurately? Do the 

characterizations of temporal and spatial variability of O3 in urban areas provide support for better 

understanding and interpreting epidemiologic studies discussed later?

4-21, lines 1-5. This makes it seem that exposure measurement issues are not so important for ozone, 

whereas they are probably more acute for ozone than for any other pollutant.
91

Dr. Kathleen Weathers

Question 10: Chapter 9 describes effects of O3 on vegetation and ecosystems. Are the major effects of 

O3 exposure on vegetation and ecosystems identified and characterized? To what extent do the 

discussions and integration of evidence across scales (e.g., species, communities and ecosystems) 

correctly represent and clearly communicate the state of the science? Has the ISA adequately 

characterized the available information on the relationship between O3 exposure and effects on 

individual plants and ecosystems? Are there subject areas that should be added, expanded upon, 

shortened or removed?

In general, I think that this chapter is quite clear, and clearly presented; it describes in some detail the 

major effects and pathways that ozone impacts species and ecosystems. It was helpful that the new 

knowledge-- and to what extent this information supported (or did not) previous ISA conclusions –was 

identified in the text. It appears, however, that there is little additional, directly relevant (to standard 

setting) scientific literature that has been published since the last ISA. Nonetheless, the last part of 

Chapter 9, where the newly-published data and studies were integrated and compared was quite useful.

While a significant part of the chapter was focused on the results from new tools that reveal 

physiological mechanisms of damage due to ozone, and there was some redundancy among sections, I 

did not find it problematic.

General and specific comments:

It would be useful to include a conceptual diagram of how ecosystem processes (the flow of energy, 

materials and information—e.g., productivity and nutrient cycling) have been shown to be, or are likely 

to be affected, based on the research presented. To wit, I found Figure 9.1 to be a bit too simple, 

somewhat misleading and overly descriptive; I think that actual effects on processes at interacting plant, 

community and ecosystem scales could be demonstrated, even when there is still considerable 

uncertainty. Many of the processes shown in the “plant” scale, for example, are those that are central to 

biogeochemistry/ecosystem fluxes of nutrients (e.g., decomposition). Similarly, many of the processes 

outlined in Table 9-1 are linked (reduced productivity and C-sequestration, for example). In fact, later in 

the chapter, Figure 9.7 might be reused and modified to illustrate relative magnitudes of ozone effects 

(based on the literature).

“Scale” should be defined when it is used throughout the document—spatial, temporal, or?

I found water production to be awkward phrasing. Water redistribution might be a better way to 

characterize this “ecosystem service” (page 9-3).

The meta analyses that have been performed since 2006 are quite important to this ISA. They are central 

to “what’s new” in this document. Some clarification about those results is needed, for example, do the 

results from the meta analysis (page 9.8) refer to current annual average ambient concentrations?

9-64: I’m confused about the sentence that starts with “Conversely” on line 25.

9-68: The description and definition of ecosystem could be strengthened. What’s most important is that 

ecosystems “have” boundaries—they are defined by the researcher (or whomever is discussing an 

ecosystem), and are often connected to some physical process (e.g., watershed), but it is an important 

part of the ecosystem concept.
92

I suggest adopting, or at least comparing/examining The Millennium Ecosystem Assessment’s definition 

and description of ecosystem services (9-69).

See my general comment about use of “scale” throughout the ISA. It would be useful to include the 

range of spatial scales inferred on 9-69, line 24.

9-69: I’d get rid of the first line on line 24—it suggests that ecosystem effects are the sum of the (plant) 

parts, which is unlikely to be true. Storage and transformation of carbon in an ecosystem, for example, 

often has much to do with microbial function in the soil as it does with plant fixation and respiration.

9-70: Again—see my comment about scale (line 2)—there’s nothing that suggests that ecosystems have 

to be large in spatial scale.

9-70: “Stand” should be modified, e.g., “forest stand," and, it is not a set spatial scale.

9-71: Zelig. MOSES-TRIFFID, etc. should be very briefly described, or at least classified (as in section 

9.6.2). In fact, Table 9-5 should include both “spatial” scale in the column header and perhaps another 

column for the models that give a descriptor of the type of model. Further, a table of models in the 

ecosystem/landscape section, their classification (in this ISA), and a column that describes the primary 

mechanism invoked (e.g., 9-75, lines 13 and 14) would be a useful addition.

Figure 9-7 could/should indicate that litter quality can be affected (e.g., C:N) in addition to litter inputs 

(amount) to the soil. It’s in the text, and should be in the figure. Further, Table 9-6 might include not just 

the effect on various metals or nutrients (“response” column), but also the carbon nutrient or metal 

effect, if it was reported.

9-82, line 1: This section might start with a brief introduction to mineralization, and then note that 

nutrient cycling is a fundamental ecosystem function. Nitrogen is thought to be the limiting nutrient for 

most temperate terrestrial ecosystems.

9-85: I’m confused that a lysimeter (used to collect soil water) study was used to

examine PLFA profiles. Qualify and/or describe.

The description of the UNECE critical levels and differences between the UNECE and US in setting 

standards and planning targets for reductions is a useful and interesting contrast/discussion.

The Table legend and column labels in Tables 9-11and 9-13 should be clearer in regard to the relative 

numbers (e.g., relative = ratio of elevated to ambient), or convert them to percentages and identify them 

as such.

It would be helpful to add a comparative column in Tables 9-12, 1-13 and 9-14 that contrasts directly the 

methods/results.

And, to further reinforce the results of these comparisons, I suggest adding some measure of “notably 

close” (page 9-135, line 2) in parentheses in the text.

9-125: “Nuisance variables...now there’s a euphemism for the research world!

Adding a column that shows the general result of the meta-analyses listed in Table 9-15 would be useful 

as well.

Overall, I was struck by the fact that there remains a paucity of data and research about the impact of 

ozone in real field situations and/or that is useful to standard setting. The recent biomonitoring results 

and programs notwithstanding; much important monitoring and research is yet to be done.
93

Dr. Peter B. Woodbury 

Chapter 9 Comments

Charge Question: Are the major effects of O3 exposure on vegetation and ecosystems identified and 

characterized? 

In general terms, yes.

Charge Question: To what extent do the discussions and integration of evidence across scales (e.g., 

species, communities and ecosystems) correctly represent and clearly communicate the state of the 

science? 

In general the discussions do represent the state of the science, a few specific suggestions are presented 

below.

Charge Question: Has the ISA adequately characterized the available information on the relationship 

between O3 exposure and effects on individual plants and ecosystems? 

In general terms, yes. The comparison of exposure response from the NCLAN and NHEERL studies 

with recent SoyFACE and Aspen FACE results is particularly useful as it clearly confirms that both 

approaches provide extremely similar results. The fact that these comparisons are so extremely close is 

quite important because it provides very strong evidence that we can have confidence in using these 

exposure response functions to estimate effects across multiple species and varieties and across multiple 

regions of the county.

Charge Question: Are there subject areas that should be added, expanded upon, shortened or removed?

It is difficult to strike the balance of being reasonably comprehensive, but not excessively long. The 

summary in Chapter 2 helps this issue by providing a brief summary of key results. The summary at the 

beginning of the chapter was initially confusing to me, but I think it should be retained because it is 

more thorough than the initial summary in Chapter, and provides key citations.

Additional Chapter 9 Comments

Page-Line

9-74. Table 9-5 should include “modeled” in the title.

9-71. Section 9.6.2.2. A more critical discussion and interpretation of model results would be useful. 

This draft just briefly lists a main conclusion from each of a number of studies. However, the models 

discussed are very different in scope and complexity. Some models represent all vegetation as a single 

“big leaf”. Other studies use detailed physiological models of single trees linked to stand-level models to 

represent competition among individual trees of different species. Not surprisingly, such different 

models produce different results. A more critical discussion focusing on the strengths and weaknesses of 

different approaches would be much more useful.

9-75. A more critical discussion of the differences in effects of ozone on transpiration from different 

models and from different experiments is warranted, focused on likely effects on streamflow at the 

catchment scale. Many such studies are discussed, including studies of tree seedlings, mature trees in 

forests, and various modeling studies. But further critical discussion to clarify reasons for discrepancies 

among such studies is warranted as this is an important topic and with substantial supporting literature. 

9-77. Better resolution for Figure 9-7 and other figures would make them easier to read. Additionally, 

the font on some of the smaller text in figures could be increased.
94

9-77. In Figure 9-7 and many other figures, an erroneous box appears often overlapping with the first 

letter of a sentence.

9-83. A more critical discussion of effects of ozone on forests, including the sacred fir forests in 

Mexico and forests in the Carpathian Mountains is warranted. The text briefly mentions that there are 

potentially confounding variables such as drought, but further discussion of the strength or weakness of 

the evidence for ozone effects is warranted.

9-90. Line 26-28 regarding pheromones does not fit within the subheading topic.

9-96. Line 10. There is a typo here and elsewhere for the citation – see “MEmberson”

9-114. In the legend for Equation 9-2, there is an erroneous box.

9-122. Line 4. Change “between prediction” to “between these predictions”.

9-122. Please clarify the 2 scaling methods. For example, on Line 24, are data from the SoyFACE study 

used in the scaling?

9-123. Table 9-12. Move column headings to match those in Table 9-11.

9-127. Table 9-14. Aligning data on decimal point, eliminating the 10ths place, and adding a comma for 

the thousandths place would improve readability.

9-131. Would it be possible to compare one of more of the recent meta-analyses to the NCLAN and 

NHEERL data by using a concentration metric to interpret the NCLAN and NHEERL results? 

Obviously, this is not as useful as comparing them using a metric such as W126, but would be better 

than no comparison at all.

Chapter 10 Comments

Charge Question: What are the views of the Panel on the scientific soundness and usefulness of the 

discussion in Chapter 10 on the role of O3 in global climate change and changes in mean global 

temperatures? 

In general, this chapter is useful, but this is a complex topic, with many interactions among gases, for 

example ozone concentrations can affect methane concentrations. Additionally, there may be important 

effects of ozone at the regional or continental scale in addition to the global scale, as discussed on Page 

10-12. Could such regional impacts be additional to the range of impacts on radiative forcing cited from 

IPCC? If so, this topic warrants further discussion.

There could also be effects of climate change on circulation, thus on mixing of stratospheric ozone into 

the troposphere, although effects on surface-level ozone might not be large. 

There may be complex feedbacks with vegetation, but there are substantial uncertainties in modeling 

such feedbacks due to limitations of models and heterogeneous responses of different types of 

vegetation to various aspects of climate change. For example, the publication by Sitch et al. (2007) may 

not adequately include the variation in response to ozone among genotypes within a species and among 

species. As discussed in Chapter 9, numerous experimental and modeling studies support the 

observation that in mixed-species communities, some species may increase growth in response to 

increased ozone exposure due to competition with species or genotypes that are more sensitive to ozone. 

Thus it is too simplistic to assume that ozone will decrease the growth of vegetation communities 
95

composed of mixtures of species, growth (and CO2 uptake) may not change if less sensitive species 

grow more quickly when released from competition by more ozone-sensitive neighbors.

As discussed on Page 10-8, models currently seem to overestimate preindustrial ozone concentrations, 

indicating a lack of data, inadequate parameterization, or lack of inclusion of key processes in ozone 

chemistry models. Such uncertainty implies that there is substantial uncertainty about non-anthropogenic 

ozone concentrations. Discussion of this topic in relation to the policy-relevant background may be 

warranted.

The conclusion that there is a causal relationship between tropospheric ozone and radiative forcing is 

warranted based on the scientific literature, as is the conclusion that there is likely to be a causal 

relationship between tropospheric ozone and climate change.

Charge Question: Is there any information regarding the climatic effects of domestically produced O3

on climate in the U.S. that should have been included? 

As mentioned above, further discussion of potential regional and continental effects of ozone on 

radiative forcing and climate may be warranted.

Charge Question: Is there important new information on UV-B effects or other welfare effects such as 

materials damage that have been overlooked and should be incorporated into this chapter?

To my knowledge, the discussion of these topics is adequate.