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` An understanding of the nature of ozone pollution will help to understand why an impact analysis is so vitally important to understanding the impacts of the ` Project. Ozone, the principal element of smog, is a secondary pollutant produced when two precursor air pollutants — volatile ROG and NOx — react in sunlight. (American Petroleum Institute v. Costle, 665 F.2d 1176, 1181 (D.C. Cir. 1981).) ROG and �— NOx are emitted by a variety of sources, including cars, trucks, industrial facilities, petroleum-based solvents, and diesel engines. The human health and associated societal costs from ozone pollution are extreme. In proposing a new rulemaking limiting emissions of NOx and particulate matter from certain diesel engines, U.S. EPA summarized the effects of ozone on public health: �. A large body of evidence shows that ozone can cause harmful respiratory effects, including chest pain, coughing and shortness of breath, which affect people with compromised respiratory systems ►- most severely. When inhaled, ozone can cause acute respiratory _ problems; aggravate asthma; cause significant temporary decreases in 6-54 lung function of 15 to over 20 percent in some healthy adults; cause cont. inflammation of lung tissue, produce changes in lung tissue and structure; may increase hospital admissions and emergency room visits; and impair the body's immune system defenses, making people more susceptible to respiratory illnesses. (66 Fed. Reg. 5002, 5012 (Jan. 18, 2001).) Moreover, ozone is not an equal opportunity pollutant, striking hardest the most vulnerable segments of our population: children, the elderly, and people with respiratory ailments. Id. Children are at greater risk because their lung capacity is still developing, because they spend significantly more time outdoors than adults — especially in the summertime when ozone levels are the highest, and because they are generally engaged in relatively intense physical activity that causes them to breathe more ozone pollution. Id. Ozone has severe impacts on millions of Americans with asthma. While it is as yet unclear whether smog actually causes asthma, there is no doubt that it exacerbates the condition. See 66 Fed. Reg. 5002, 5012 (Jan. 18, 2001) where the U.S. EPA points to"strong and convincing evidence that exposure to ozone is associated with exacerbation of asthma-related symptoms." Moreover, as U.S. EPA observes, the impacts of ozone on"asthmatics are of special concern particularly in light of the growing asthma problem in the United States and the increased rates of asthma-related mortality and hospitalizations, especially in children in general and black children in particular." 62 Fed. Reg. at 38864. In fact: 41 L