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February 11, 1996

To: Norm Possiel, EPA

In regard to your response to my notice of putting my version of your map on the web:

You first say: "I certainly appreciate your ability to publicly convey important information concerning the predicted impacts of control programs."

Thank you for the compliment. In return let me say that you are widely respected by the modeling community, an opinion I share. I also respect the attempts you have made to raise the issue of NOx reduction disbenefits, in the face of ignoration.

But then you say: "However, there are two problems with what you have presented which lead to a complete misinterpretation of the model results. First, the legend in your rendition of EPA's map is incorrect and does NOT match my original copy. For example, the areas you label as having ozone "GREATER than 125 ppb which got worse" (red areas on your map) are actually areas with ozone LESS than 125 ppb. In fact, the predicted ozone levels in these areas in both the base case AND after the projection to 2005 are well below 125 ppb (and in most cases even below 100 ppb)."

Here you are simply mistaken. The red areas on my map correspond to the dark blue areas on yours, and are labeled identically. These are the areas in which the ozone concentration is LESS (to use your capitalization convention) than 125 ppb but it gets worse. This is precisely the area of concern, as it encompasses an estimated 50,000 square miles of disbenefits, much of which is heavily populated.

Moreover, if the proposed 80 ppb 8 hour standard is enacted much of this area will become out of attainment, as noted in the staff draft for the new standard. I have long held that it is wrong, and probably unconstitutional, to punish these people with sanctions, because for them attainment is impossible. As an aside let me note that the CASAC is at fault here. They have failed to consider the null hypothesis, namely that there is no level of tropospheric ozone that is both risk free and attainable.

You then say: "Second, we believe that the predicted increases in ozone which you refer to are due to growth in emissions that is forecast to occur in the Southeast and NOT the application of CAAA controls as you contend. In fact, the correct version of the map shows that the Clean Air Act programs are predicted to REDUCE ozone levels over the vast majority of the Eastern U.S., including areas now above 125 ppb."

Thus you raise two issues. One the accuracy of the map, the other its interpretation. As to the map, the original was distributed by EPA at the June 1995 OTC meeting. Our version is faithful to the original, except we could not figure out your global projection so our cell locations may differ a little. We changed the graphic so it works in grayscale, a deep shortcoming of the original. In fact the failure of EPA's maps to be readable in reproduction has contributed greatly to the general ignorance of the threat of disbenefits.

If the original is incorrect (but I don't think it is) please email me a correct gif and I will change my web page. However, I have yet to see a map of NOx reduction that does not show significant ozone increases. Also, I don't believe that people forecast to experience increases in ozone will take comfort in the fact that others, no matter how "vast" their area, will benefit. And the difference is not vast. Also, given the uncertainties in the model, the area you label as "no change" should more properly be labeled as "could go either way", as you did in earlier maps.

As to the interpretation, I cannot agree that the disbenefits in the Southeast are due solely to increases in emissions, unless that is the only region in which you project increases. In which case I think you are mistaken, for there is bound to be economic growth in other regions of the country, or doesn't EPA think so? I think that the concentration of ozone increases in the Southeast is due to the nature of the 1988 episode. This is the shortcoming of using specific past episodes to forecast the future, as OTAG proposes to do. But the matter is easily settled. Make me a run with controls but no increases.

You know as well as I that reducing NOx is bound to increase ozone somewhere in the system. As one prominent atmospheric scientist put it to me "everyone knows this". George Wolff called it a consensus in his landmark article. Who gets poisoned just depends on the episode. As I have said before, NOx reduction is experimental medicine without consent of the patient.

I welcome your response.

With best regards,

David


February 12, 1996

To: ozone group

From: dwojick@shentel.net (David E. Wojick)

Subject: My map

My greater than and less than 125 ppbs in the legend were indeed incorrect, as Norm Possiel pointed out. They were simply reversed, and have been corrected on these pages. Sorry for the confusion. More to the original point however, the massive areas of disbenefits remain, and this is without the additional NOx cuts that EPA is contemplating. Moreover, if the 80 ppb & 8 hr standard kicks in much of the red area will be in nonattainment.


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