EPA expects an additional 14 million to 32 million people would live in non-attainment areas under the proposed revised standard. The full costs of meeting this standard would be orders of magnitude higher than EPA's estimated costs of partial attainment. Based on our review and analysis of EPA's proposal, we offer the following recommendations. EPA should not proceed with promulgation of the proposed standard. There may be adequate basis for changing the averaging time and form of the standard.
More effective alternatives are available for addressing the potential ill effects of ozone.
Non-regulatory approaches are available to achieve the public health benefits targeted by this rule. Ozone levels are heavily influenced from year to year by meteorological conditions. EPA observes that the lowest national mean level of ozone was recorded in 1992, and the highest in 1988. Ozone is associated with respiratory problems, particularly in sensitive individuals. It is also credited with reducing the harmful effects of ultraviolet rays.