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  • EPA Administrator Scott Pruitt sent a letter to governors on June 6, 2017 to inform them that the Agency is extending the deadline for promulgating initial area designations, by one year, for the 2015 ozone NAAQS. This action will delay the implementation of the new federal ozone standard that was promulgated in October 2015. For more information, please click here. The key reasons given by the Administrator are
  • Fully understanding the role of background ozone levels;
  • Appropriately accounting for international transport; and
  • Timely consideration of exceptional events demonstrations.

Two of the three items relate to the current research activities performed at A.S.L. & Associates. Please see our technical comments about background ozone.


  • Recently on my Facebook page, I published the following concerning the serious proposed cutbacks in US funding for science:

As a senior scientist who has worked in the field of environmental research for 50 years, I can fully recognize the ramifications to the American society if Congress adopts most of Trump's budgetary recommendations. The scientists who are 1/2 to 1 generation behind me, who are associated with universities across the US, still depend upon their funding sources originating from the government (e.g., NIH, EPA, NOAA, NASA, etc.). If their funding sources dry up, they no longer have the ability to continue their research and also train their students. Many of the women and men who are completing their advanced degrees will probably have no jobs available when they graduate. Thus, the chain that allows younger scientists to follow those of us who are senior scientists breaks. Can anyone see any good in this? I personally cannot. Yes, it saves money, but in the long run the US leadership in the scientific world is transferred to others parts of the world (e.g., China, EU, etc.). Should this be worrisome? If you believe in the mantra that we must make America Great Again, then delegating the controlling of diseases, exploring space, developing better technology to control pollutant emissions into our environment, engineering advances, defense innovation, etc. to other countries results in the US having to "import" these advances from other nations, which under stable conditions may be OK but not necessarily during times of crisis. Perhaps one believes that industry will step up and replace all of the government funding for science. Do I think that the funding void will be filled by industry? I don't think so. Industry does not have the resources nor the interest in sponsoring many of the research areas that will have serious funding shortfalls. It would be easy for those of us who are senior scientist to retire and forget about all of this. However, there is something that continues to tug at our sleeves that reminds us that as scientists we always want to "search for the truth in the unknown." If our younger colleagues are going to be seriously hindered by a funding budget that prevents them from continuing their work, then perhaps those of us who long for more quiet times (i.e., retirement) must find the energy to go on for a little while longer.


  • Since A.S.L. & Associates' founder, Dr. Allen Lefohn, participated like others in the first Earth Day on April 22, 1970, we have seen much progress in controlling environmental pollution and improving the Nation's health and welfare (i.e., vegetation). For example, the US EPA began to regulate ozone with the promulgation of a ground-level National Ambient Air Quality Standard (NAAQS) in 1971, with subsequent revisions in 1979, 1997, 2008, and 2015. Following promulgation of the 1997 ozone standard, the US EPA issued a NOx State Implementation Plan (SIP) Call, which reduced regional summertime NOx emissions from power plants and other large stationary sources by 57% in 22 Eastern US states. In addition, the US EPA established national rules that substantially reduced NOx and VOC emissions from on-road mobile sources by 53% and 77% between 1990 and 2014, respectively. Overall, NOx and VOC have decreased in the US by 52% and 39% from all sources since 1990.


  • Changes in the magnitude of national and regional emissions, as well as any long-term changes in international emissions, climate, and inter-annual meteorological variability, can drive shifts in the distributions of hourly surface O3 concentrations. Changes in the distributions of hourly average O3 concentrations can result in changes in the magnitude of exposure metrics used for assessing human health and vegetation effects. Surprisingly, trend patterns in O3 exposure metrics may be in a similar direction as emissions changes (e.g., metrics increase as emissions increase) or may not (Lefohn et al., 2017 - see publications list). Over the past 20-30 years, substantial changes in O3 concentrations have been observed at many sites across the world, likely driven by a combination of the large emissions changes and potentially by shifts in various meteorological conditions. A recent paper by Lefohn et al. (2017) investigated the relationship between exposure metrics, hourly O3 concentration distributions, and emission changes. To achieve this, we analyzed the response of 14 human health and vegetation O3 metrics to long-term changes in the hourly O3 concentration distribution, as measured at 481 monitoring sites in the EU, US, and China. The study provides insight into the utility of using specific exposure metrics for assessing emission control strategies. One important aspect of the study was that trends in mean or median concentrations did not appear to be well associated with some of the exposure metrics applicable for assessing human health or vegetation effects. Additional insights concerning the relationships between emissions reductions, hourly average concentration distributions, and human health and vegetation exposure metrics are discussed in Lefohn et al. (2017) (see publications list).


  • In October 2015, the EPA announced that both the human health and vegetation ozone standards will now be 70 ppb. Prior to that, on November 26, 2014, the EPA Administrator proposed an ozone human health (primary) standard in the range of 65 to 70 ppb and indicated that she would take comment on a standard as low as 60 ppb. The EPA Administrator noted that she placed the greatest weight on controlled human exposure studies, citing significant uncertainties with epidemiologic studies. Reasons for placing less weight on epidemiologic-based risk estimates are key uncertainties about (1) which co-pollutants are responsible for health effects observed, (2) the heterogeneity in effect estimates between locations, (3) the potential for exposure measurement errors, and (4) uncertainty in the interpretation of the shape of concentration-response functions for ozone concentrations in the lower portions of ambient distributions. The health standard is mainly based on the controlled human exposure study of Schelegle et al. (2009) that reported clinical effects at 72 ppb. Dr. Milan Hazucha of UNC Chapel Hill and I (Allen S. Lefohn) designed the ozone hourly exposure regimes used in the Schelegle et al. (2009) study. To the 72 ppb threshold of effects resulting from the Schelegle et al. (2009) study, the Administrator applied a Margin of Safety that helped her establish the ozone health standard below the 72 ppb level. Although the EPA initially recommended a separate exposure metric for the secondary standard, the EPA adopted the 8-hour standard of 0.070 ppm to protect vegetation. The Agency felt that the 3-month, 12-h W126 exposure index used for assessing vegetation effects could be controlled to a level of 17 ppm-h or less by using the 8-hour standard. Industry and environmental organizations are back in court contesting the decision of the 8-hour ozone standard set at the 0.070 ppm level.


  • Background ozone is an important part of the challenge to the 0.070 ppm ozone standard. There is much controversy on what the range of background ozone is in the United States. Our research is indicating that frequent occurrences greater than or equal to 50 ppb that occur at both high- and low-elevation monitoring sites across the US are influenced by transport from the stratosphere to the lower troposphere. The enhanced ozone concentrations that appear to be related to stratospheric transport occur during the springtime and sometimes during the summertime. In addition, long-range transport of Eurasian biomass burning, as well as wildfires in the US, contribute to background ozone concentrations. Estimating the range of background ozone properly is important because the range of background concentrations is used in the EPA's risk assessment for human health and vegetation, as well as assessing the amount of emission reductions required to attain a specific ozone level (i.e., standard). If the actual background level of ozone is higher than EPA estimates with models, then the Agency may overestimate human health, as well as vegetation risks and present inaccurate information to the public and policymakers. Our published material on background ozone can be found here.


  • For several years, A.S.L. & Associates has had an on-going effort to better understand the range and frequency of occurrence of background ozone levels that may not be affected by emission reduction strategies. In a paper published in May 2001, the research team consisting of Allen Lefohn, Samuel Oltmans, Tom Dann, and Hanwant Singh discussed that background ozone levels were higher and that the natural short-term variability was more frequent and greater than previously believed. The authors are associated with the following institutions: A.S.L. & Associates, NOAA, Environment Canada, and NASA, respectively. In our 2001 paper, we concluded that hourly levels greater than or equal to 50 ppb occur more frequently as a result from natural sources than previously believed. In 2006, the US EPA defined Policy-Relevant Background (PRB) for ozone as those concentrations that would occur in the United States in the absence of anthropogenic emissions in continental North America (i.e., the United States, Canada, and Mexico). PRB concentrations include contributions from (1) natural sources everywhere in the world and (2) anthropogenic sources outside the United States, Canada, and Mexico. In 2008, we published results, using empirical data, confirming that at some locations in the US, PRB ozone concentrations are greater than or equal to 50 ppb. In late September 2009, the National Research Council released the report, Global Sources of Local Pollution. In the report, the Committee states that modeling and analysis supports the finding that Policy-Relevant Background (PRB) is 20-40 ppb for the United States. Unfortunately, the NRC conclusion does not agree with the peer-review literature using empirical data that hourly averaged PRB ozone concentrations are greater than or equal to 50 ppb. Although spatially low-resolution models have been exercised and indicated that conclusions reached by Lefohn et al. (2001) were incorrect, our current research and the results published by other research groups support the conclusions reached by Lefohn et al. (2001) that PRB ozone concentrations are greater than or equal to 50 ppb at both high- and low-elevation monitoring sites. Clearly, low-resolution models are unable to adequately capture the important processes that are important for characterizing PRB and therefore, underestimate policy relevant background concentrations. The latest results using GEOS-Chem models continue to underestimate PRB ozone concentrations. An Internet-based slide presentation is available for purposes of previewing our paper. Also please be sure to check out the answer to our quiz that identifies the month in which the highest 8-hour daily maximum concentration occurred for the 4 remote ozone monitoring sites. Additional information on background ozone concentrations can be found in the Air Quality Analyses section of our Table of Contents. In-depth discussions are provided on this very important topic.


Click here to find out more information about W126Some historical perspective is important in understanding the background concerning the events that led to the EPA's Administrator's decision on revising the 8-hour ozone standard. On March 12, 2008, the EPA Administrator announced a decision on the human health and vegetation ozone standards. At that time, EPA revised the 8-hour "primary" ozone standard, designed to protect public health, to a level of 0.075 parts per million (ppm). The previous standard, set in 1997, was 0.08 ppm. EPA decided not to adopt the cumulative exposure index as the vegetation standard (i.e., secondary ozone standard). Although the EPA Administrator recommended the W126 index as the secondary ozone standard, based on advice from the White House (Washington Post, April 8, 2008; Page D02), the EPA Administrator made the secondary ozone standard the same as the primary 8-hour average standard (0.075 ppm). On May 27, 2008, health and environmental organizations filed a lawsuit arguing that the EPA failed to protect public health and the environment when it issued in March 2008 new ozone standards. On March 10, 2009, the US EPA requested that the Court vacate the existing briefing schedule and hold the consolidated cases in abeyance. EPA requested the extension to allow time for appropriate EPA officials that were appointed by the new Administration to review the Ozone NAAQS Rule to determine whether the standards established in the Ozone NAAQS Rule should be maintained, modified, or otherwise reconsidered.


  • The range of suggested values for the W126 ozone vegetation standard is in part historically based on the recommendations that were made at a Workshop that took place in Raleigh, North Carolina in 1996. To better understand what took place at this workshop, please click here. The EPA recommends an accumulation over a 12-hour (8 am – 8 pm) exposure period over a 3-month period giving greater weight to exposures at higher levels of ozone. Our analyses and peer-reviewed published papers indicate that such a secondary ozone standard, in the proposed form, would overestimate vegetation effects. For information about why the use of a 12-hour versus a 24-hour accumulation period would contribute to the inconsistency problem of the W126 index, please click here. You can learn more about the subject of vegetation effects by visiting our Table of Contents web page.


  • Lefohn, Shadwick, and Oltmans (2010) have statistically quantified in a paper published in the peer-reviewed journal, Atmospheric Environment, a site-by-site trending analysis for the period 1980-2008 and 1994-2008. Lefohn et al. (2010) point out that many ozone monitoring sites show no statistical changes over time as well as a small number of sites show increases in trending. Please see the publications list for the citation.

As indicated above, Lefohn et al. (2010) published their trending findings for surface ozone monitoring sites across the United States. Using statistical trending on a site-by-site basis of the (1) health-based annual 2nd highest 1-hour average concentration and annual 4th highest daily maximum 8-hour average concentration and (2) vegetation-based annual seasonally corrected 24-hour W126 cumulative exposure index, they investigated temporal and spatial statistically significant changes that occurred in surface ozone in the United States for the periods 1980-2008 and 1994-2008. For more information about the Lefohn et al. (2010) and Lefohn et al. (2008) (for the period 1980-2005 and 1990-2005) findings, please click here.


Since 1997, we have been discussing the "piston effect" in the peer-reviewed literature (see publications listing). In 1997, we predicted that there would be a leveling off of improvements in O3 concentrations as O3 emission precursors were reduced at some monitoring sites Our prediction apparently has been verified by the most current trends analysis by the EPA. On EPA's web site (www.epa.gov/airtrends/ozone.html), the Agency in July 2016 summarized trends for the ozone periods 1980-2015, 1990-2015, and 2000-2015. Note that the national average for trends for the three time periods were 32%, 22%, and 17%, respectively. Clearly, the trend is slowing down.

The "piston effect", as described in the peer-review literature and on this web site, affects the ability of the nation to attain the 8-hour ozone standard as lower and lower 8-hour standards are established. As we discussed in our original paper, the peak hourly average concentrations are reduced much faster than the mid-level concentrations. This pattern is discussed in our most current publication on trends in the EU, US, and China (Lefohn et al., 2017-see publications list). Clearly the "piston effect" heavily influences the Nation's ability to attain an 8-hour ozone standard as standard levels are reduced. We discuss more about the "piston effect" and how it affects the attainability of the ozone standard in our concerns web area.


  • Over the past years, A.S.L. & Associates and its consultants have commented on the strengths and weaknesses associated with the mathematical and statistical methodologies used in epidemiological studies to link exposure with human health effects. Many of the statistical caveats raised throughout the PM and Ozone Criteria Documents and the PM and Ozone Staff Papers indicate a pattern of inconsistent results that is troubling. Examples of the growing pattern of inconsistent and inconclusive findings include the following:
  • Instability of PM mortality effect estimates resulting from different model specifications of weather effects and time trends.
  • Instability of PM effect estimates resulting from different selections of monitoring sites within cities.
  • Increased heterogeneity of PM effect estimates across cities.
  • Greater diversity of findings among studies and across study areas.
  • Contradictory results from mortality displacement studies.
  • PM effect lags that are inconsistent across cities and across studies.
  • Exposure-response relationships that are inconsistent across cities and across studies.
  • Inconsistencies between short-term and long-term effect studies, such as respiratory effects of fine particles.
  • Contradictory findings among long-term studies.

Additional details about the Team's epidemiological concerns are discussed on our epidemiological concerns web page. The Team's comments on the first draft of the PM Staff Paper were submitted to EPA in October 2003. To read more about our concerns about the first draft, please visit our web page.


  • Sometimes science and politics mixed together become science fiction. Such is the case that occurred, when in September 2002, many newspapers across the United States printed a story summarizing the report, Code Red: America's Five Most Polluted National Parks, which described The Great Smoky Mountains as the nation's most polluted national park, with air quality rivaling that of Los Angeles. For the period 1997-2001, the report claims that the annual ozone exposure was higher at Great Smoky Mountains National Park than at Los Angeles, California. There is a serious technical problem associated with the report and the report's conclusions are flawed. Please read "The Rest of the Story."


  • In 2000, Haywood County, NC experienced its 4th highest 8-hour ozone concentration at 0.085 ppm. On May 1, a daily maximum 8-hour average concentration of 0.089 ppm was experienced. A detailed meteorological analysis suggests that stratospheric ozone played an important role in this ozone episode.


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