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The Environmental Protection Agency’s Proposed Rule: National Ambient Air Quality Standards for Ozone Open Access

The Clean Air Act directs the EPA Administrator to set “primary,” or health-based, NAAQS at levels that are “requisite to protect the public health … allowing an adequate margin of safety,” based on “air quality criteria [that] shall accurately reflect the latest scientific knowledge useful in indicating the kind and extent of all identifiable effects on public health or welfare which may be expected from the presence of such pollutant in the ambient air, in varying quantities.” §108(a)(2) It further requires the Administrator to set “secondary” (welfare-based) standards basedon these criteria at a level “requisite to protect the public welfare from any known or anticipated adverse effects.” (This comment focuses exclusively on the primary standard.)

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