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The SIP Iconoclasm

June 13, 2012

Scientists are predicting in the near future that what happens outside the U.S. might be as relevant to ozone levels we experience in the U.S. as what actions we might take inside the U.S. (see below).  Is this mind blowing?

For North America ground-level O3 concentrations, [. . .] changes in emissions of O3 [ozone] precursors outside the region may be as important as changes within the region.” –2010 United Nation’s Hemispheric Transport of Air Pollution Report (see http://www.htap.org/activities/2010_Final_Report.htm)

Our whole current system is focused on addressing domestic sources in order to achieve the NAAQS.  Our whole current system places the ultimate responsibility for addressing ozone on the States—who do not have the constitutional authority to address this part of the problem.

If the actions taken outside the U.S. might be as relevant in the future to improving ozone levels in the U.S. as actions taken inside the U.S., shouldn’t we then be focused on something other than rolling out program after program to address domestic emissions?    Shouldn’t we have an air quality management process that is designed to acknowledge and address this part of the problem?

The world is changing.  We must change with it.  Time to transform the SIP process.  We can make it happen.

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