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Other newly obtainable research, summarized in part IV.A.1.b above and part IV.B.1.b of the proposal, present extra evidence of O3 scuba diving all over printed hawaiian shirt impacts on mature bushes, together with a meta-evaluation reporting older timber to be extra affected by O3 than younger trees (U.S. EPA, 2013, p. 9-forty two; Wittig et al., 2007). We moreover note that CASAC “concur that biomass loss in timber is a

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commonplace would result in only 5 sites above 15 ppm-hrs. Based on these statements, these commenters state that the current standard is likely to offer circumstances with no site having a monitor over 17 ppm-hrs and a “minimal number” doubtless exceeding thirteen ppm-hrs (e.g., UARG, p. seventy seven). We disagree with commenters’ interpretation of the modeling data from the 2 completely different assessments. As we summarized in part IV.C.1 of the proposal with regard to the WREA modeling, the modeling estimates are each primarily based on a single set of precursor emissions reductions which are estimated to realize the desired goal situations, which is also the case for the RIA modeling (U.S. EPA, 2014c, pp. 5-40 to five-forty one; see also section 1.2.2 of the 2014 scuba diving all over printed hawaiian shirt RIA). Some commenters disagree with the EPA’s consideration of the Class I areas analysis, stating that it isn’t acceptable for the EPA to judge the level of safety supplied by the current main O3 commonplace under present situations because of the lengthy-vary transport of O3 and O3 precursors to Class I areas from upwind non-attainment areas. It is the view of these commenters that after the upwind areas make emissions reductions to attain the current standard, downwind areas will see improvements in air quality and lowering W126 ranges. In assist of this view, commenters point to several modeling analyses. Some commenters point to air quality modeling performed by an environmental advisor that initiatives all websites to have W126 index values under 13 ppm-hrs when emissions are adjusted such that every one upwind screens are modeled to meet the current commonplace. Detailed methodology, outcomes and references for the commenter’s modeling evaluation were not supplied, precluding a radical evaluation and comparability to the EPA’s modeling.

While the EPA agrees that transport of O3 and O3 precursors can affect downwind monitors, we disagree with commenters regarding the conclusions which might be acceptable to attract from modeling simulations for the explanations famous below. Other commenters stated that the scientific proof does not assist revising the NAAQS, pointing to uncertainty related to interpretation of the RBL estimates with regard to results on older tree lifestages. Some of those commenters’ declare that mature canopy timber experience reduced O3 effects. The EPA agrees that the quantitative data for O3 development effects on older tree lifestages is on the market for a extra restricted set of species than that available for tree seedlings. We notice, however, that this is an space for which there is information newly obtainable on this evaluation. A detailed evaluation of study knowledge for seedlings and older lifestages of aspen shows shut agreement between the O3-attributable reduced development noticed in the older bushes and reductions predicted from the seedling E-R operate (U.S. EPA, 2013, part 9.6.three.2; mentioned in the PA, section 5.2.1 as noted in the proposal, p. 75330). This finding, newly available on this evaluation and documenting impacts on mature trees, improves our confidence in conclusions drawn with regard to the significance of RBL estimates for this species, which is prevalent across multiple areas of the U.S. It is also noteworthy that this species is generally extra sensitive to O3 effects on growth than the median of the 11 species with robust E-R features (as proven in U.S. EPA 2014c, Table 5C-1).

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