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Ex Parte Meeting Summary:  Ozone NAAQS

Date:  December 20, 2007, 1:00 – 1:45 pm 

Attendees: 

Visitors: 

The Honorable James Martin

Governor, State of North Carolina

(representing the National Association of Manufacturers)

EPA attendees: 

George Gray, ORD

Pamela Williams, ORD

John Vandenberg, ORD

Ila Cote, ORD

Mary Ross, ORD

Debra Walsh, ORD

Summary of discussion:  

Governor Martin provided a brief summary of his professional background
(former chemistry professor, Congressman, Governor) and that he had
provided a letter to the Administrator stating he did not support
revising the ozone standard.

Governor Martin stated it was important to focus on the most important
things, which he identified as:

ozone has a natural background

progress had been made to reduce ozone levels around the US, with a few
hundred locations not meeting the standard now

making progress with support of industry was important when costs
exceeded benefits, and countervailing costs needed to be considered
(e.g., to the economy)

Governor Martin then summarized his views related to the science on
ozone:

epidemiology – concerns regarding validity and publication bias

clinical studies – concerns that a clinical study [Adams] at 60 ppb
with some FEV changes and coughing was not the same as 60 ppb in ambient
air. He stated that 60 ppb in the laboratory was like 100 ppb in ambient
air.

costs were 20-25 Billion dollars to meet standards, high cost to economy
at current standard

need to look at real, not imaginary “wolves”

background ozone levels that are discussed in ozone proposal were a
concern, the policy relevant background levels are presented as very
low.   The proposal indicating policy relevant background may be as low
as 20 ppb makes it seem like there is more opportunity to improve air
quality than truly exists.   Spikes in natural background show
variability in PRB, with the 4th worse level being around 75 ppb in 100
cities, thus there was little room for air quality improvement.   

He stated that if the Administrator believes the 20 ppb PRB, then it
would only be logical to set the standard at 22 ppb, and yet nobody
believes this is needed. 

Governor Martin concluded that in his discussions with many governors,
there was a lot of concern about the potential impacts of tighter ozone
standards on state economies.  He stated the Administrator needed solid
evidence to change the standards.

Dr. Gray thanked Governor Martin for his time, noted that the
Administrator had not made a decision on the ozone NAAQS, and that his
comments were appreciated and would be considered. 

    

