2007 Interim Report of the U.S. EPA Global Change Research Program Assessment of the Impacts of Global Change on Regional U.S. Air Quality: A Preliminary Synthesis of Climate Change Impacts on O3.

Filed on regulations.gov — full text not in the inline record.

August 25, 2008 NRDC and EDF Comments on Draft "2007 Interim Report of the U.S. EPA Global Change Research Program Assessment of the Impacts of Global Change on Regional U.S. Air Quality: A Preliminary Synthesis of Climate Change Impacts on O3" Docket No. EPA–HQ–ORD–2007–0983 Submitted electronically at: The Federal eRulemaking Portal: http://www.regulations.gov and via e-mail to: ORD.Docket@epa.gov The Natural Resources Defense Council (NRDC) and Environmental Defense Fund (EDF) appreciate the opportunity to submit comments on the draft document, "2007 Interim Report of the U.S. EPA Global Change Research Program Assessment of the Impacts of Global Change on Regional U.S. Air Quality: A Preliminary Synthesis of Climate Change Impacts on O3," referred to hereafter as the Interim Report, as well as the supporting technical document, "Assessment of the Effects of Climate Change on Regional Air Quality Appendices," referred to hereafter as the Appendices. As organizations committed to protecting public health and ecosystems from environmental harm, NRDC and EDF firmly believe that global warming poses significant human health risks. Worsening air quality is among the most prominent climate change-related health concerns, and the Interim Report synthesizes the results of several key studies of global warming's effect on ground-level ozone smog pollution. Yet while the Interim Report is commendable in its scope and objectives, we believe the final analysis falls short in its potential usefulness to stakeholders, for the reasons described below. The stated intention is to provide an update of the progress made by EPA-funded research in applying climate and atmospheric chemistry models to investigate potential future effects on regional air quality in the US, and to offer a preliminary interpretation of what this improved understanding means for air quality management. But by overlooking specific health impacts results from the EPA-funded studies, the Interim Report stops short of offering the findings that could be most relevant to policymakers and to the American public, who are increasingly concerned about the health risks of global warming. Furthermore, on July 11, 2008 EPA released an Advance Notice of Proposed Rulemaking (ANPR) soliciting public input on applying the Clean Air Act (CAA) to regulate greenhouse gas emissions, if they contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. The Interim Report will presumably inform and serve as an important input to the rulemaking on regulating greenhouse gases pursuant to the Clean Air Act. However, currently the Report is incomplete, failing to address the full scope of the impacts on air quality as manifested in effects on human health, precisely the criteria relevant to the Clean Air Act determination. Because the overlooked climate-ozone (O3) research addresses the possible public health impacts of climate change, these findings should become part of the report in order to offer appropriate background to the ANPR. General Comment NRDC and EDF appreciate the significant amount of time spent by the EPA in preparing this Interim Report, which summarizes and synthesize the results of eight studies funded by the US EPA's Office of Research and Development (ORD) Global Change Research Program (GCRP), in partnership with EPA's Office of Air and Radiation (OAR). This compilation of the findings from those eight research projects pertaining to national and regional effects of global climate change on ground-level ozone concentrations makes an appreciable contribution by projecting a range of future ozone concentrations, and by covering various regions of the continental United States. Based on our knowledge of the climate-ozone literature, the Interim Report accurately captures the main findings with respect to the impact of climate change alone on increasing grou…