The Need for a More Robust Ozone Air Quality Standard

The present National Ambient Air Quality Standard for ozone has many statistical problems, including use of extreme values which have inherent large fluctuations, a compliance test that can gradually lower the target of the design value below the standard level, and inconsistencies between the number-of-exceedances criterion and the design value. The above problems can be avoided or minimized by using a more robust statistic, such as the 95th percentile, and applying a statistical compliance test, without sacrificing the stringency of the standard. Analysis of EPA’s ozone data shows that the annual 95th percentiles and their three-year means have less variability than the annual second highest values and the fourth highest values in three years, respectively. A t test for the mean of the annual 95th percentiles is proposed for compliance testing not only to preserve the averaging concept of the present standard, but also to take account of ozone concentration fluctuations in order to increase the stability of the compliance status of a site or a Metropolitan Statistical Area. A procedure is provided to adjust the level of the 95th-percentile standard so that the stringency of the present standard is preserved.