Comment submitted by H. Gluckstern

Document ID: EPA-HQ-OAR-2010-0891-0005
Document Type: Public Submission
Agency: Environmental Protection Agency
Received Date: December 22 2010, at 12:00 AM Eastern Standard Time
Date Posted: December 27 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: December 22 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: February 7 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80bbe23c
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I object to the continuation of allowing emissions reductions attained outside a nonattainment area to count toward states' efforts to meet standards for ozone. The known adverse human health effects of ozone on humans and other animal life have been well-documented for decades. It is important that the persons residing in non-attainment areas derive the benefit of a reduction of harmful ozone within the area in which they live, work or reside. Nonattainment areas are defined by the levels of ozone within those areas for a reason: moving toward attainment provides significant health benefits for those initially within a nonattainment area. Attainment area inhabitants have already benefitted from lower exposure to ozone. Those in non-attainment areas should be afforded more healthy living and working environments by efforts to directly decrease ozone within the nonattainment area, even if the costs to the sources are higher than they would be if applied to a similar reduction witin an attainment area. The proper priority is to attack the nonattainment areas first. Lowering ozone concentration in areas already in attainment is unfair to those whose health suffers from the higher levels.

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