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Contrary to the implications of the commenters, although the Administrator took into consideration the potential for antagonistic results on public welfare from visible foliar harm, she placed weight totally on progress-related wood leo all over printed laundry basket results of O3, both in her proposed choice on adequacy and with regard to proposed judgments on what revisions would be acceptable.

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Although we recognize that CASAC’s comments on the W126 index were supplied within the context of its suggestion for a secondary normal of that type, we discover them to additionally relate to our use of the W126 metric in evaluating the magnitude and extent of vegetation effects that might be anticipated and conversely the extent of safety that could be offered beneath different air high quality circumstances. In feedback on the primary draft PA, the CASAC stated that “discussions and conclusions on biologically relevant publicity metrics are clear and compelling and the concentrate on the W126 form is appropriate” . With regard to particular wood leo all over printed laundry basket aspects of the W126 index, the CASAC concurred with the second draft PA concentrate on “the biologically-relevant W126 index accumulated over a 12-hour interval (8 a.m.-8 p.m.) over the 3-month summation interval of a single yr resulting in the maximum worth of W126” (Frey, 2014c, p. iii). Based on these concerns, the PA concluded it to be applicable to retain the present indicator of O3 and to contemplate a secondary standard kind that is an average of the seasonal W126 index values (derived as described in part IV.A.1.c above) across three consecutive years (U.S. EPA, 2014c, part 6.6). In so doing, the PA recognized that there’s limited data to discern differences in the degree of safety afforded for cumulative development-associated effects by potential alternative W126-primarily based requirements of a single-yr kind as compared to a three-year type (U.S. EPA, 2014c, pp. 6-30).

The PA concluded a 3-yr form to be applicable for a standard meant to supply the specified stage of safety from longer-time period results, including these associated with potential compounding, and that such a form might be concluded to contribute to greater stability in air quality management packages, and thus, larger effectiveness in achieving the specified level of public welfare protection than would possibly result from a single-12 months kind. (U.S. EPA, 2014c, part 6.6). In support of their view that the current standard offers sufficient protection and should not be revised, some commenters described their considerations with any consideration of visible foliar damage in the decision regarding the secondary standard. These commenters variously stated that visible foliar damage can’t be reliably evaluated for adversity given lack of available information, just isn’t an opposed effect on public welfare that have to be addressed through a secondary standard, and is not instantly relatable to progress suppression (and the EPA’s use of RBL captures that impact anyway). Additionally, some state that any related ecosystem providers results are not quantifiable. In sum, the view of these commenters is that it’s not applicable for the Administrator to position any weight on this O3 impact in determining the adequacy of the present normal. As an preliminary matter, the EPA agrees with the remark that the current proof doesn’t embody an method for relating visible foliar harm to development suppression, as acknowledged in section IV.A.1.b above. Further, we notice that, similar to selections in previous O3 evaluations, the Administrator’s proposed decision in this evaluation acknowledged the “complexities and limitations within the proof base regarding characterizing air high quality situations with respect to the magnitude and extent of threat for seen foliar harm” and the “challenges of associated judgments with regard to adversity of such results to public welfare” (seventy nine FR 75336; December 17, 2014).

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