This is a preliminary document prepared by a subgroup of members of the Base Programs Analyses and Policies Work Group as part of the Federal Advisory Committee Act (FACA) Subcommittee process. It is not an EPA document. It is subject to work group discussion. Interested persons should forward their comments to a member of the Base Programs Analyses and Policies Work Group or the contact person shown below.

This draft issue paper is scheduled to be coordinated with other FACA work groups.

August 3, 1996

Issue Paper 2 on Integration of NAAQS Implementation Programs

Contact:	Robert Kappelmann, 904/632-6249

Draft Do not Quote or Cite

Background

Historically, implementation programs designed to met a NAAQS as well as the related Federal guidance provided to the states focused only on the achievement of that NAAQS without formal recognition of the impact of that program on other NAAQS or related environmental criteria. This was due in large part to the lack of adequate understanding of pollutant transport and secondary pollutant formation chemistry as well as the administrative complexities involved in dealing with integrated NAAQS implementation programs.

In some cases this has lead to increased cost to states in developing and administering overlapping or redundant programs. In addition, industries often face multiple and sometimes conflicting requirements in complying with different NAAQS implementation programs.

The establishment of a new PM-fine and ozone NAAQS along with improvements in the state of the science coupled with demands for more cost effective implementation programs, create the opportunity to consider integration of NAAQS implementation programs.

Issues

(a) Where does it make sense to follow the same (develop integrated) criteria and policies when implementing the ozone, PM-fine and regional haze programs.

1. Monitoring Plans. Benefits could be gained in developing integrated monitoring plans for common precursors. This is especially true in locating monitors to help validate air quality models. Due to the regional nature of Ozone, PM-fine and regional haze, monitoring systems needed to adequately define the problem as well as measure progress often spanned numerous state and local jurisdictions. To achieve optimum results a multi-state integrated approach may be necessary. Limited resources will often require multi-parameter monitoring at many sites. An integrated approach will help determine when a site can meet the modeling and compliance needs for several parameters or prove beneficial for only one.

Issues:	Considering the need for interstate coordination in establishing an integrated monitoring network, how can integrated monitoring network be achieved?

Option 1. EPA would provide guidance to the states on establishing an integrated monitoring network and would rely on a voluntary interstate coordination to implement.

Option 2. EPA would identify boundaries and provide a framework for establishing integrated monitoring networks were appropriate. Coordination and implementation would be through an established interstate association such as STAPPA. SIP approval would depend on a state meeting the requirements of the plan.

Option 3. EPA would establish the appropriate regional integrated monitoring plan and require implementation through the SIP process. State input would be limited to commenting on the plan.

NOTE: If integration requires site relocation, some restrictions on moving historical high monitors will be needed.

2. Integration of Compliance Strategies and Programs. Integration of compliance programs would help eliminate overlapping control programs and help provide certainty to industry as what requirements they must meet. Often businesses will develop compliance strategies to meet one set of requirements only to be faced with a new set of limits on the same emission source a few year later. Many times the first control system must be abandoned well before the end of its useful life and replaced with a system to met a different or tighter standard. If the second set of requirements were known in time, the original system could have been designed for tighter standard and capital expense reduced. In many case one source may impact several NAAQS. For example, fossil fuel combustion emissions of SO2, NOx, and PM will impact PM-fine and ozone NAAQS. It seems to make sense to deal with sources having impacts on several NAAQS with an integrated approach. Administrative cost would be save by both regulators and industry. In addition, integration of NAAQS programs may facilitate emission trading programs.

In addition integration of compliance programs on a interstate basis will help mitigate perceived competitive advantages which may occur with piecemeal control strategies. It is noted that integration of control strategies, doesn't necessarily mean identical control requirements. Western and Eastern regions differ significantly in PM-fine precursor ratios and this would naturally be reflected in each region's integrated compliance strategies.

Issues:	What mechanism can be employed to achieve an integrated compliance strategy and related programs?

Option 1. EPA could provide guidance to the states on integrated compliance strategies an let the states participate as the deem appropriate.

Option 2. EPA could provide specific guidance on when state must employ an integrated approach and require compliance through the SIP approval process.

Option 3. EPA could develop guidance in coordination with the State and local programs. A determination would be made when an integrated approach should be employed. The SIP approval process would be employed to secure compliance with the plan.

3. Compliance timelines and milestones. To the degree that integration of timelines and milestone dates does not delay achieving of a NAAQS, integration may provided significant benefits. Often private industry as well as government deal with one priority at a time. Action taken to achieve on objective may hinder the attainment of another. Integration of timelines will place all compliance related activities in a common program. Identification of future conflicts will be more easily identified and remedied. In addition improvements in the planning process for both the private and public sectors will be enhanced. It should be noted that a common timeline doesn't dictate common dates for all NAAQS milestones. Milestones and compliance objectives for the regional haze program should be included.

Issues:	What parameters should drive the development of and integrated compliance schedule?

Option 1. Health-based objectives of the NAAQS would drive the schedule. Integration of compliance plans would be maximized to the degree it did not jeopardize NAAQS attainment. Expeditious attainment would drive the process.

Option 2. Integrated compliance schedule development would be driven by maximization of cost effectiveness of implementation programs while assuring minimal impact on final compliance dates.

4. Integration of related national programs and initiatives. Consideration should be given to integrating the related mandates associated with other national air programs as well other media programs which share common precursors and primary pollutants. The establishment of linkage between air emissions and water pollution issues such as nutrient loading is accepted but seldom considered in programs designed to achieve water quality standards. Water quality improvement will likely occur from compliance programs design to meet the new Ozone NAAQS. The impact of air emission control systems by-products on national solid waste and water pollution goals should be considered. Integrated control strategies could also take into account new NSR and NSPSs regulations. (This could be addressed in the second phase of the FACA work group process.)

Issue:	How could an integrated multi-media compliance approach be established? (There's an opportunity for a Ph.D. dissertation in this one.)

(b) Where and when does it not make sense to develop integrated ozone, PM-fine and regional haze programs.

In general integration of programs doesn't make sense when it would cause a significant delay in achieving a NAAQS or result in no cost savings. In addition, it would not make sense when there is no linkage between ozone and PM-fine violations and regional haze or where there is no clear relationship with maintaining the standards.

Integration of programs designed to meet the PM-fine and ozone NAAQS make sense in cases were secondary particulate constitute the majority of the PM-fine composition and a nonattainment area for PM-fine cannot achieve the standard by controlling primary PM-fine sources. In cases where violations are due in large part to primary PM-fine, an integrated control strategy would have limited benefit.

Issue:	How is an inappropriate use of integration discouraged?

Option 1. Place responsibility on states and rely on sanctions and penalties for meeting attainment dates to discourage inappropriate use.

Option 2. EPA would establish firm guidance on appropriate use of integrated approaches and would utilizes the SIP approval process for obtaining compliance.