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Ex Parte Meeting Summary:  Ozone NAAQS

Date:  December 19, 2007, 10:00 – 11:00 am. 

Attendees: 

Visitor: 

William Godsey

P.O. Box 1904

Longview, TX 75606

Phone:  903-753-8200

Fax:  903-753-3844

Mobile:  903-720-7855

Email:  bill.godsey@geologicenvironmental.com

Geo Logic Environmental Services, LLC

EPA attendees: 

George Gray, ORD

John Vandenberg, ORD

Ila Cote, ORD

Debra Walsh, ORD

Mary Ross, ORD

Tim Benner, ORD

Pamela Williams, ORD

Lydia Wegman, OAQPS

Summary of discussion:  

Mr. Godsey is representing his company.  He stated his concern regarding
lack of justification (human health effects and environmental effects)
for possible lowering of ozone NAAQS.  He stated concern about
determination of policy relevant background.  He stated lowering of
NAAQS will undo a lot of good that has been done and doesn’t serve
country and Houston area.  He stated lots of controls in place via EPA
actions (Region 6) but limits as to what else can be done and EPA will
lose credibility if NAAQS lowered.   He made reference to “Rochester
study”.  He indicated Rochester study was submitted to docket and
should be considered. He is not aware of new studies except one
(didn’t say which one) on ozone that might justify a revised standard.
 He questioned if sufficient new science was available to justify new
NAAQS.  He stated there was no scientific community consensus on the
scientific basis for revisions to the NAAQS.  He stated it would be
morally and ethically wrong to lower the standard.  He stated that EPA
funding of studies on ozone led to a perception of bias.  He did not
provide any new scientific information.  He did not provide any written
materials during the meeting. 

Dr. Gray: NAAQS standards based on Administrator judgment (per Supreme
Court). NAAQS based on human studies, epidemiological studies, all
considered in making NAAQS decisions.  He provided brief summary of
approaches used in controlled human studies.  He stated he wouldn’t
pre-judge administrators decision and pointed to the basis for NAAQS
decision is based on various EPA documents that have been reviewed by
CASAC and that CASAC had urged the Administrator to revise the NAAQS. 

Lydia Wegman pointed out that the Clean Air Act specifies that program
implementation costs cannot be considered in establishing the NAAQS.
Further, she pointed out that the CASAC was unanimous in recommending
revisions to the NAAQS. 

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Bio Sketch (provided by William Godsey):  

William E. Godsey - Professional Geologist

William E. Godsey teaches college level environmental science and
geology, most recently as Adjunct Professor in the Science Department at
LeTourneau University. Mr. Godsey received a Bachelors Degree in
Enviromental Studies and Earth Science and a M.S. degree in
Environmental Studies, both from Baylor University. He is a Professional
Geologist, serving in government and private industry beginning in 1982.

He is President of Geo Logic Environmental Services, LLC, a
multi-disciplined consulting firm staffed by a diverse group of
environmental scientists, geologists and engineers. Mr. Godsey works
intensively with industry, government and attorneys to address
regulatory issues and provide solutions for environmental concerns. He
has extensive experience in petroleum industry in regard to waste
management and enhanced oil recovery with specialization in brine
disposal.

The current interest of Mr. Godsey is the capture and beneficial reuse
of CO2 from lignite and natural gas fired power plants. Godsey is
developing a program to store the CO2 in salt caverns, then use the CO2
to recover additional oil reserves from depleted fields.

