MEMORANDUM

TO:	Docket for Reconsideration of 2008 Ozone NAAQS (Docket ID No.
EPA-HQ-OAR-2005-0172)

RE:	Meetings with OMB on draft Ozone Reconsideration Notice of Proposed
Rulemaking

	On December 10, 2009 EPA and OMB discussed OMB’s comments on the
draft Ozone Reconsideration Notice of Proposed Rulemaking (NPR) sent to
OMB on October 20, 2009.  In response to requests from OMB, EPA made the
following changes to the notice:  deletion of text that included details
of the history of the exchange between OMB and EPA just prior to
issuance of the final 2008 Ozone NAAQS rule, and clarification of the
nature of the Administrator’s discretion in selecting a primary
standard that is requisite to protect public health with an adequate
margin of safety.  These changes were included in a version of the draft
Ozone NPR sent to OMB on December 16, 2009.

On December 29, 2009 EPA and OMB met to discuss OMB’s comments on the
December 16 version of the draft Ozone NPR.  A representative from CEA
also participated in the discussion.  OMB raised several points on which
they requested the following changes to the notice:  additional
discussion of the benefits associated with the proposed secondary
standard; solicitation of comment on the incremental benefits of the
proposed secondary standard relative to the benefits of the secondary
standard set in 2008; deletion of remaining text that included details
of the history of the exchange between OMB and EPA just prior to
issuance of the final 2008 Ozone NAAQS rule; acknowledgement that there
were differing views on the interpretation of the Adams studies and
EPA’s reanalysis of data from the Adams (2006) study; further
clarification of the nature of the Administrator’s discretion in
selecting a primary standard that is requisite to protect public health
with an adequate margin of safety; and solicitation of comment on the
incremental benefits of a primary standard set within the proposed range
of levels relative to the benefits associated with the primary standard
set in 2008.  These changes were included in a version of the draft
Ozone NPR sent to OMB on December 30, 2009.

On January 5, 2009 EPA and OMB met to discuss OMB’s comments on the
December 30 version of the draft Ozone NPR.  OMB requested two changes. 
The first concerned the description of EPA’s use of the Adams studies
in its rationale for the March 2008 decision.  The second addressed the
characterization of the Administrator’s decision in concluding that
important and significant risks to public health are likely to occur at
the level of the 2008 primary standard and the description of the
evidence considered by the Administrator in reaching this conclusion. 
EPA made changes to address these comments and sent the revisions to OMB
in an e-mail on January 5, 2010.   These changes were also included in
the final version of the draft Ozone NPR sent to OMB later that day. 

