American
Lung
Association
Environmental
Defense
December
2,
2003
The
Honorable
Michael
Leavitt
Administrator
U.
S.
Environmental
Protection
Agency
Ariel
Rios
Building
1200
Pennsylvania
Avenue,
N.
W.,
1101A
Washington,
D.
C.
20460
Dear
Administrator
Leavitt:

The
American
Lung
Association
and
Environmental
Defense
respectfully
request
that
the
U.
S.
Environmental
Protection
Agency
issue
8­
hour
ozone
nonattainment
designations
that
are
based
on
protective,
comprehensive
boundaries.
In
1997,
EPA
strengthened
the
ozone
national
ambient
air
quality
standard
to
improve
protection
of
children
and
other
vulnerable
populations
against
decreased
lung
function,
respiratory
ailments,
and
hospital
admissions
and
emergency
room
visits
for
asthma
attacks
and
other
respiratory
disease.

The
ozone
health
standard
was
subject
to
a
multiyear
legal
challenge
by
industry
and,
ultimately,
was
affirmed
by
a
unanimous
Supreme
Court
in
2001.
The
designation
of
air
quality
areas
under
the
federal
Clean
Air
Act
is
the
first
pivotal
step
in
carrying
out
this
more
protective
air
quality
standard
for
ozone.
Simply
put,
the
nation
cannot
effectively
address
the
pressing
public
health
impacts
of
ozone
without
protective
air
quality
management
boundaries.

Our
organizations
have
conducted
a
detailed
examination
of
state­
recommended
ozone
nonattainment
designations.
The
results
of
our
analyses
are
enclosed.
In
short,
a
number
of
the
recommendations
omit
areas
containing
significant
population
where,
in
all
likelihood,
numerous
people
are
exposed
to
ozone
air
pollution
that
violates
the
health­
based
standard.
Moreover,
several
recommendations
omit
surrounding
areas
with
air
pollution
sources
that
contribute
to
violations
of
the
8­
hour
ozone
standard.

These
omissions
and
other
deficiencies
in
the
state
recommendations
contravene
the
Clean
Air
Act,
EPA's
long­
standing
boundary
policy,
sound
science,
and
basic
common
sense.
We
are
deeply
concerned
that
the
failure
to
provide
protective
nonattainment
designations
for
the
health­
based
8­
hour
ozone
standard
will
postpone
critical
air
pollution
reductions,
delay
timely
attainment
of
the
standard,
and
prolong
the
exposure
of
children
and
other
vulnerable
populations
to
unhealthy
levels
of
ozone
air
pollution.
Sound
science
and
decades
of
ozone
air
quality
planning
and
management
experience
demonstrate
that
comprehensive
boundaries
are
a
necessary
predicate
 
indeed
a
bedrock
foundation
 
to
address
the
far­
reaching
sources
and
scope
of
harmful
ozone
air
pollution.
With
your
steadfast
leadership,
we
can
put
the
nation
on
the
path
to
realize
the
public
health
protections
that
the
ozone
standard
was
designed
to
achieve.

Sincerely,

John
Kirkwood
Fred
Krupp
President
and
CEO
President
American
Lung
Association
Environmental
Defense
Enclosures
