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OTAG at Odds with Environmental Justice

The Ozone Transport Assessment Group, after two years of deliberation, is meeting this week in Chicago to begin formulating an ozone control plan. OTAG favors a strategy of massive NOx reductions, ignoring the clear scientific evidence that predicts it will increase, not decrease, ozone levels in urban areas. I am deeply concerned that OTAG will recommend a strategy that is fundamentally unjust.

My concern began when I studied the landmark 1991 National Research Council report "Rethinking the Ozone Problem in Urban and Regional Air Pollution." While this report concluded that an NOx reduction strategy will be most effective in reducing ozone levels overall, it also warned repeatedly that NOx reduction is predicted to actually increase ozone levels in some urban areas. Here are two of many such warnings:

* "Ozone is predicted to decrease in response to NOx reductions in many urban locations. [However,] models show that ozone concentrations rise in some urban cores, such as New York City and Los Angeles, in response to NOx reductions, but decrease in downwind areas."

* "The combined [volatile organic compound and NOx reduction] strategy leads to decreased population exposures in all regions of the Northeast corridor except the New York City area, but 43 percent of the corridor's population lives there."

New York City is out of attainment with the ozone standard, so if an NOx or combined reduction strategy increases ozone, it obviously cannot produce attainment. Failure to attain triggers economic sanctions imposed by the Environmental Protection Agency, not to mention the possible health effects of increased exposure. I do not see how OTAG can recommend a strategy that is predicted to increase pollution levels in places like New York City, to be followed by sanctions on its residents because of this increase. This issue is referred to as the problem of "disbenefits," when pollution levels actually go up, or of "residual nonattainment" when they do not go down enough to achieve attainment and avoid economic sanctions. The science is absolutely clear that cutting NOx is predicted to produce disbenefits and residual nonattainment.

Worse yet, as the models have improved, the predicted extent of disbenefits and residual nonattainment has grown dramatically. New York, Chicago, Atlanta, Philadelphia and many smaller OTAG cities are now predicted to suffer under an NOx reduction or combined strategy. OTAG's 1996 "Review of Recent Ozone Measurement and Modeling Studies in the Eastern United States" is full of predictions of disbenefits. OTAG's web pages, which present the most recent results, show even more.

There's a lot of talk these days about "environmental justice." For OTAG to recommend an ozone control strategy that is predicted to increase pollution in urban areas, plus dooming people to economic sanctions for nonattainment, would be an ultimate form of injustice.

--David Wojick