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. The rest of our comments are organized as follows. We review EPA's statutory obligations, its interpretation of those obligations, and the factors EPA relied on in making its policy judgment regarding the appropriate standard to protect public health and welfare. This review suggests that because EPA bases its policy judgment on a narrow set of criteria, the resulting rule is likely to result in public health and welfare outcomes contrary to EPA's expressed intent. EPA's own regulatory analysis, summarized in the first part of this section, concludes that the costs of implementing the proposed standard will exceed the benefits.