CATF Comments on Draft 8-hr Ozone NAAQS Regulatory Text
September 5, 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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Fact Sheet on 8-hr Ozone Implementation Proposal
August 1, 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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CATF Comments on 8-hr Ozone Implementation Proposal
August 1, 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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Press Release – EPA's Smog Proposal Falls Short of Protecting the Public
August 1, 2003
The latest federal proposal promising to help clear up the nation's smog and soot problems will fall far short of its goal, environmental groups said today. A coalition of groups is submitting formal comments later today criticizing the Environmental Protection Agency's (EPA) proposed "options" for implementing the 1997 8-hour ozone standard. The groups said the EPA proposal would actually weaken protections against smog.
Despite increasing evidence that long term exposure to lower levels of ozone can cause dangerous and sometimes permanent lung problems, the EPA is proposing to give polluted metropolitan areas more time and more loopholes to avoid taking the steps needed to protect public health.
"What we need is clean air, but what the EPA is offering is more delays and more opportunities to game the system," said Ann Weeks, Legal Director at CATF. "EPA was given the task of implementing strong new ozone standards, and they've come back with proposals that would leave the public breathing more smog – not less."
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Oral Testimony of Ann Weeks on EPA's Proposal to Implement the 8-Hour Ozone NAAQS, Alexandria VA
June 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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Ozone Implementation Rule: Proposed Rule Preamble on Implementing the 8-Hour Ozone National Ambient Air Quality Standard, 68 Fed. Reg. 32,802
June 2, 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 nonattainment 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 nonattainment 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.
