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August 12, 2019
Ozone and Particulate Matter Air Standards: EPA Review
The Clean Air Act (CAA) requires the U.S. Environmental 
Notwithstanding air quality progress since 1970, ozone and 
Protection Agency (EPA) to review the standards for 
PM concentrations exceed the NAAQS in some areas 
national ambient air quality every five years. In 2018, EPA 
(“nonattainment areas”). Table 1 lists these NAAQS and 
announced strategies to expedite the National Ambient Air 
the estimated population in nonattainment areas.  
Quality Standard (NAAQS) review process while 
concurrently disbanding a pollutant-specific scientific 
Table 1. Selected NAAQS and the Estimated U.S. 
review panel that has historically advised agency staff 
Population in Corresponding Nonattainment Areas  
during their reviews. Although the CAA allows the EPA 
Administrator to specify the procedures for review of the 
Estimated U.S. 
Primary 
NAAQS, past EPA reviews and revisions have garnered 
NAAQS 
Population in 
Standard 
considerable congressional oversight. This In Focus 
Nonattainment Areas 
discusses the status of EPA’s current NAAQS reviews for 
2015 Ozone 
70 ppb 
124 mil ion 
ozone and particulate matter (PM), which EPA intends to 
complete in 2020, and issues of potential interest to 
2012 Fine PM 
12.0 µg/m3 
22 mil ion 
Congress.  
1987 Coarse PM 
150 µg/m3 
9 mil ion 
Background on Ozone and Particulate Matter  
Source: CRS, as adapted from EPA, Green Book, 
Ozone and PM are two of six principal pollutants referred 
https://www.epa.gov/green-book. Estimated population based on 
to as “criteria pollutants” for which EPA has promulgated 
2010, rounded to nearest mil ion. Data as of May 31, 2019. 
NAAQS under the CAA (42 U.S.C §7408(a)(1)). 
Notes: Units of measure are parts per bil ion (ppb) and micrograms 
Ground-level ozone, the primary component of smog, is 
per cubic meter of air (µg/m3). See 40 C.F.R. Part 50 for detailed 
formed when nitrogen oxides (NOx) react with volatile 
NAAQS. Table presents the most recent PM and ozone NAAQS. For 
organic compounds (VOCs) in sunlight. Ground-level 
other NAAQS nonattainment areas, see EPA’s Green Book. 
ozone is associated with health effects, such as aggravated 
asthma, chronic bronchitis, heart attacks, and premature 
NAAQS Statutory Requirements  
death. EPA has identified natural and anthropogenic 
NAAQS do not directly limit emissions. Rather, NAAQS 
sources of ozone precursors (e.g., NOx and VOCs) and 
are concentration-based standards for ambient (outdoor) 
ozone, including factories, lightning, power plants, 
pollution. Under the CAA, Congress mandated that EPA 
vegetation, vehicles, volatile chemical products (e.g., paints 
establish two types of NAAQS for each criteria pollutant—
and solvents) and wildfires. 
a primary NAAQS, which must protect public health with 
an “adequate margin of safety,” and a secondary NAAQS, 
PM refers to a mixture of solid particles and liquid droplets 
which must “protect public welfare from any known or 
in the atmosphere. PM components may include acids, 
anticipated adverse effects” (42 U.S.C. §7409(b)). Public 
organic chemicals, metals, and soil or dust particles. The 
welfare includes damage to crops, vegetation, property, 
size of PM varies, ranging from tiny particles that can be 
building materials, and climate (42 U.S.C. §7602(h)).  
seen only through a high-power microscope to larger 
particles (e.g., soot or smoke). Exposure to PM has been 
The CAA establishes a framework for EPA to set NAAQS 
associated with adverse health effects, haze formation, and 
based on the “latest scientific knowledge” through a notice-
environmental impacts. The potential health effects include 
and-comment rulemaking process (42 U.S.C. §§7408, 
aggravated asthma, chronic bronchitis, decreased lung 
7409). It requires EPA to review the NAAQS and the 
function, and premature death.  
science upon which they are based every five years and 
then revise the NAAQS if necessary. The CAA also 
Typical sources of fine PM (PM2.5)—measured at 2.5 
requires EPA to appoint an independent scientific review 
micrometers or less in diameter—include direct emissions 
committee composed of seven members, which has become 
from vehicles, smokestacks, and fires. Coarse PM (PM10)—
the Clean Air Scientific Advisory Committee (CASAC). 
generally measuring 10 micrometers or less in diameter—is 
The act directs CASAC to review the NAAQS every five 
often associated with dust from paved and unpaved roads, 
years and recommend to the EPA Administrator “any new 
construction and demolition operations, certain industrial 
national ambient air quality standards and revisions … as 
processes and agriculture operations, and biomass burning. 
may be appropriate” (42 U.S.C. §7409(d)(2)). 
In addition, precursor emissions (e.g., sulfur oxides, NOx, 
and VOCs) contribute to the formation of “secondary PM.” 
EPA’s Review of the NAAQS 
PM2.5 contains a much greater portion of secondary particles 
Beyond the aforementioned CAA requirements, procedural 
than PM10 does. 
aspects of the NAAQS review are generally at the 
https://crsreports.congress.gov 
Ozone and Particulate Matter Air Standards: EPA Review 
discretion of the EPA Administrator. Historically, the 
recommended that EPA either reappoint the CASAC PM 
agency has undertaken a multi-step process to review each 
panel or appoint a new panel with similar expertise to 
NAAQS. Each NAAQS review typically begins with a 
inform the PM review. CASAC stated that the “breadth and 
planning phase in which EPA seeks public input and 
diversity of evidence to be considered exceeds the expertise 
develops an Integrated Review Plan (IRP). The IRP maps 
of the statutory CASAC members” (letter from CASAC to 
out the schedule and process for the review and identifies 
EPA, April 11, 2019).  
policy-relevant science issues to guide the review.  
CASAC also recommended “substantial revisions” to the 
EPA then reviews the relevant scientific literature published 
Draft PM ISA, finding that it did “not provide a sufficiently 
since the last NAAQS revision and summarizes it in a 
comprehensive, systematic assessment of the available 
report currently known as the Integrated Science 
science.” CASAC members did not reach consensus as to 
Assessment (ISA). The ISA compiles information about 
“whether there is robust and convincing evidence to support 
sources of the pollutant, exposure pathways, empirical 
the EPA’s conclusion that there is a causal relationship 
evidence regarding the causality link between exposure and 
between PM2.5 exposure and mortality” (CASAC letter).  
adverse health effects, and other topics. The ISA is intended 
as the scientific foundation for the EPA Administrator’s 
EPA replied that it would make “necessary adjustments” to 
assessment of whether the NAAQS sufficiently protect 
the PM ISA while finishing the PA by fall 2019 and 
public health and welfare. EPA solicits public comment 
reaffirmed its goal to complete the PM review by 2020. 
and, historically, multiple CASAC reviews before finalizing 
EPA has not formed a new PM-panel nor convened an 
it.  
Ozone panel. In its letter to CASAC, EPA stated it plans to 
make a “pool of subject matter consultants” available to 
The final ISA informs EPA’s preparation of the Risk and 
provide feedback on the PM and ozone reviews to the 
Exposure Assessment (REA), which presents quantitative 
CASAC chair “in a manner consistent with the Federal 
estimates of exposures and health risks under defined air 
Advisory Committee Act” (letter from EPA to CASAC, 
quality scenarios. As with the IRP and the ISA, EPA has 
July 25, 2019). 
sought CASAC and public comment on the REA. 
The current ozone review began in 2018, marking the first 
Subsequently, EPA prepares a Policy Assessment (PA), 
NAAQS review initiated in the current Administration. To 
which summarizes information from the ISA and REA and 
date, EPA has released a draft ozone IRP and projected that 
provides the Administrator with options regarding the 
the review will last a little over two-and-a-half years. The 
indicators, averaging times, statistical form, and numerical 
previous ozone review lasted about seven years. EPA will 
level (concentration) of the NAAQS. EPA solicits comment 
not develop a new REA in the current review. Instead, EPA 
on the PA from CASAC and the public, then finalizes a 
plans to fold “REA-related analyses” into the PA (EPA, 
decision on the NAAQS standard through the rulemaking 
Draft IRP for Review of the Ozone NAAQS). EPA also 
process. The agency proposes a decision—to retain or to 
plans to issue drafts of the ozone ISA and PA by October 
revise the standard—after considering information in the 
2019 for “simultaneous review by the CASAC” and the 
ISA, REA, and PA and the advice of CASAC. 
public, which “should conclude” by end of 2019 (EPA 
letter). This approach differs from previously completed 
EPA Restructuring of the NAAQS Reviews 
reviews, in which EPA has considered CASAC input and 
The NAAQS review process has evolved over time, with 
public comments on the ISA as it developed other 
multiple Administrations introducing procedural 
milestone documents—for example, the PA. 
modifications intended to streamline the process, improve 
transparency, or strengthen the scientific basis. In 2018, 
Issues for Consideration 
EPA announced plans to streamline NAAQS reviews and 
Congress, in its oversight capacity, may consider whether 
obtain CASAC advice regarding background pollution and 
or not the EPA’s current approach meets the CAA 
potential adverse effects from NAAQS compliance 
objectives to review the NAAQS and the science upon 
strategies. Historically, EPA has not requested CASAC to 
which they are based in a timely manner.   
advise the agency with respect to adverse effects from 
NAAQS compliance strategies, although it is among the 
EPA’s proposed modifications to the NAAQS review 
topics listed in CAA Section 109(d)(2)(C).  
process underscore the tension between competing 
concerns. Some stakeholders, interest groups, and Members 
Under its CASAC charter, EPA may form subcommittees 
of Congress have criticized the timeliness of past NAAQS 
or workgroups, such as pollutant-specific panels, to serve 
reviews, which routinely have not been completed within 
under CASAC. Past panels, which included individuals 
the five-year review cycle. Others have raised concerns 
with expertise in specific pollutants, assisted with the 
about whether EPA’s NAAQS decisions have been based 
NAAQS reviews. In 2018, EPA disbanded the Particulate 
on research that reflect the latest science and that the 
Matter Review Panel, which was formed in 2015, and 
scientific basis is rigorous and unbiased.  
directed the seven-member CASAC to assist EPA with the 
reviews for the 2012 PM and 2015 ozone NAAQS on an 
Kate C. Shouse, Analyst in Environmental Policy   
expedited timeline.  
Robert Esworthy, Specialist in Environmental Policy   
Some stakeholders and interest groups have raised concerns 
IF11288
about the lack of pollutant-specific panels. CASAC 
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Ozone and Particulate Matter Air Standards: EPA Review 
 
 
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