Ozone Standard Implementation Rule
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09/05/2003
Detailed comments on the EPA's draft regulatory text implementing the 8-hr ozone NAAQS, as filed by CATF and other organizations on Sept 5, 2003.
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08/01/2003
Detailed comments on EPA's proposed implementation rule for the 8-hr ozone standard, as filed filed by CATF and other organizations on Aug 1, 2003.
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08/01/2003
Description of EPA's proposed 8-hr ozone standard implementation policy, the proposal's shortcomings, and the public health imperative for a strong 8-hour ozone standard.
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06/27/2003
Testimony of CATF's Legal Director at the EPA Public Hearing on the Agency's proposal to implement the 8-hour smog standard.
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06/02/2003
CATF has prepared a summary memorandum describing the major options presented by EPA's new plan for implementing the 8-hour national ambient ozone standard, published at 68 Fed. Reg. 32,802. The Agency developed the plan in response to the U.S. Supreme Court's remand of the original 1997 implementation plan to the Agency, in Whitman v. American Trucking Ass'ns, Inc., 531 U.S. 457 (2001). Briefly, EPA offers in the published preamble a series of options for public comment, rather than a concise proposed rule. Indeed, EPA has not to date published proposed regulatory language. The Agency's preference is to implement the new standard under Subpart 2 only in areas that are in non-attainment of both the 8-hour and the 1-hour ozone NAAQS, and for Subpart 1 to apply in all other areas. The result would be to offer to areas in non-attainment of the 8-hour standard, but attaining the 1-hour standard, the maximum in terms of program flexibility and time to attain. EPA also favors additional program flexibility and time to attain the standard even for areas it concedes must be governed by Subpart 2.
