MARCH 3, 1997

Good afternoon. My name is J. Dale Givens and I am the Secretary of the Louisiana Department of Environmental Quality. Thank you for allowing me the opportunity to provide testimony on the proposed changes to the National Ambient Air Quality Standards for ozone and particulate matter.

Louisiana, in partnership with the Environmental Protection Agency (EPA) has been very successful in improving air quality through the implementation of the Clean Air Act. Today Louisiana meets five of the six National Ambient Air Quality Standards (NAAQS) for criteria pollutants with only ozone remaining. Our ozone nonattainment parishes have decreased from 20 to 5. We have met our obligations under the 1990 amendments of the Clean Air Act (CAA), completing all required emission reductions. We have submitted the required ozone attainment demonstration plan. As required by the CAA, complete implementation of the attainment plan will be accomplished in 1999. At that time, we expect to be in full compliance with the present ozone standard. Already, as a result of substantial emission reductions in place, air monitoring data show marked decreases in ozone. Louisiana is on a successful course for cleaner air.

Louisiana supports the establishment of National Ambient Air Quality Standards (NAAQSs) which are necessary to protect human health and which are based on sound technical and scientific data. In the setting of the standards, the EPA has stated that it cannot consider economic or technological feasibility of attaining the standard. We have therefore concentrated our review of the proposal based on the underlying health science including the EPA staff paper and the independent scientific advisory reports. Based on our study of these documents, Louisiana supports the EPA position that an 8-hour standard is more appropriate for a human health-based standard than the present 1-hour standard. Louisiana also agrees that the form of the standard should be concentration based.

The EPA's staff paper recommends 0.09 ppm as the upper level of an 8 hour standard that would reduce estimated exposures of the at risk populations sufficiently to provide some margin of safety against pulmonary inflammation and increased susceptibility to pulmonary infection. Louisiana supports a level of the standard set at 0.09 ppm as the 3 year average of the annual third highest maximum 8 hour average ozone concentration. As we appreciate the underlying science for setting the new standard, little or no public health benefit would be gained by setting the standard at 0.08 ppm rather than 0.09 ppm.

In addition, Louisiana favors the proposal made by a number of CASAC members for an expanded air pollution warning system which could be implemented for sensitive individuals who could then take appropriate exposure avoidance action. CASAC pointed out to the EPA that this idea would be easy to implement since many areas of the country already have an infrastructure in place to designate ozone action days when voluntary emission reduction measures can be taken. Tulsa Oklahoma already has such a program in place. For a number of years the Baton Rouge area has operated a program to apply administrative emission controls to industrial sources during periods when ozone levels are expected to be elevated. Efforts to develop a community ozone action day program were begun last summer in Baton Rouge. This effort is expected to continue this summer and is supported by the public.

These are our initial comments regarding the primary standard being proposed for ozone. We are continuing to review the entire proposed set of changes which includes the secondary standard for ozone, the changes to the particulate matter standard and the implementation proposal for both pollutants. Due to the large volume of documentation associated with these proposals, it will take time to properly review them and the support documentation in order to provide additional comments.

Thank you for the opportunity to comment and your attention to the concerns of Louisiana.