Comment Log Display

To Whom It May Concern:

I whole-heartedly support adoption of the proposed regulation to
reduce ozone emissions from devices that are intended to improve
indoor air quality.  It is a fair first step toward control of an
indoor source that I personally believe has several major
drawbacks, including (1) significant population exposure to ozone,
(2) increased population exposure to ultra-fine particulate matter,
(3) increased population exposure to formaldehyde, acetaldehyde,
and other irritating to toxic carbonyls, and general
ineffectiveness at improving indoor environmental quality.

I hope that the regulation is taken as a first step.  The 50 ppb
"standard" has absolutely no scientific basis, and it is a shame
that regulators have fixed on such a number.

I recently developed a formal report on what I believe to be a
sound rationale for selection of a maximum acceptable indoor ozone
concentration increment of 5 ppb, with additional constraints
imposed on ozone emissions due to building occupant exposures to
secondary organic aerosols and formaldehyde.  That report is
attached.  I hope that it is read and considered as part of the
discussion regarding adoption of the proposed regulation and,
hopefully, more stringent future regulations.

With Sincerity -
Richard L. Corsi, Ph.D.
ECH Bantel Professor for Professional Practice
Director, Program on Indoor Environmental Science and Engineering
The University of Texas at Austin (but a Californian by birth and
in spirit).