9/19/07 Meeting to discuss commenters’ views on Ozone NAAQS Proposal

Location:  EPA/OAR offices, Washington, D.C.

Attendees:

Robert L. Kappelmann, P.E., Energy and Environmental Policy Consultant

Bradley H. Spooner, P.E., MEAG Power (Municipal Electric Authority of
Georgia)

Hilary Sills, FMEA (Florida Municipal Electric Association), JEA
(Jacksonville Electric Authority), and MEAG (Municipal Electric
Authority of Georgia) Power

Janet McDonald, OAR

Erika Sasser, OAR/OAQPS

Dana Hyland, OAR

Commenters’ offered the following comments on EPA’s June 20, 2007
proposal to revise the national ambient air quality standards for ozone:

Policy Relevant Background—PRB

EPA has underestimated PRB, and therefore overestimated the controllable
risk and underestimated the costs of reaching attainment

Weaknesses in Health Effects Evidence

Ozone Mortality:  scientific evidence is not clear on this
point—linkage with ozone mortality is weak

Bell study—correlation between ozone and hospital admissions exists
only in 6 of 95 cities, and not in LA

EPA’s planned changes to the NAAQS review process will be helpful to
ensure review of all relevant science—Right now, EPA can’t be sure
most recent information has been incorporated.  EPA should not revise
ozone standards at this time, because too much uncertainty in the
current scientific evidence.  Wait until it has gone through the new
NAAQS review process.

EPA needs to consider the implications from a public policy standpoint. 
Cost to utilities of implementing additional NOx reductions will be high

Reference to Dr. Roger McClellan’s testimony before Senate EPW
Committee

If EPA revises the standard at this time, it should certainly not go
into the lower end of the range

Possibly eliminate the rounding loophole, so go from 0.084 to 0.080
ppm—this is effectively a 5% tightening of the standard.  Going into
implementation of the 1997 standard, people did not expect that standard
to be rounded to 0.084—0.08 was understood to mean 0.080 ppm, so
eliminating that “fudge factor” now might be appropriate

