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No, I think that this rating just has an extremely high bar for what it considers failing. If I read this right you could fail by having 10 orange days over 3 years.
To support this they state,
So 21 orange days in 3 years represents 98th percentile and they are looking at 99th, so 10 days sounds about right.
I think 35 ug/m^3 is AQI 100...
Ooooo that does make more sense!
I suppose the bar is set for like, aiming for people to be living in good conditions 100% of the time. If they're not in good conditions basically at any time then they're failing them.
10 days is low enough that the wildfires could be the main cause of the data change?
Could be, the article says it's due to heat, drought, and wildfires