DATE:	March 24, 1997

SUBJECT:	Draft Summary from March 5, 1997 Base Programs Analyses and Policies Work Group Conference Call.

This summary was prepared for work group review. Please communicate any comments or revisions to Sharon Reinders at 919/541-5284 or reinders.sharon@epamail.epa.gov.

Draft Summary of Base Programs Analyses and Policies Work Group

March 5, 1997 Conference Call

I.	OVERVIEW

The Base Programs Analyses and Policies work group (BPAPWG) held a conference call on March 5, 1997 to review action items from the February 20 and 21, 1997 FACA Subcommittee meeting and to give status reports of the New Source Review (NSR), Integrated Implementation, Reasonable Further Progress (RFP), and Control Strategies issue papers.

II.	PARTICIPANTS

Base Programs Analyses and Policies Work Group

Joe Paisie, Co-chair, Jerry Golden, Co-chair, Vince Brisini, Richard Chastain, Shawn Connelly for Barbara Lee, Gregory Dana, Richard Dworek, Steve Gerritson, Robert Kappelmann, Arthur Lee, William Luneburg, Chuck Mueller for Herb Williams, Brock Nicholson, Steve Pezda, Richard Phelps, Jim Salvaggio, Greg Schaefer, Eric Skelton, Jean Vernet, and Mel Zeldin.

Work Group Members Not in Attendance

David Baron, John Crouch, Jeff Gabriel, Rich Halvey, Dennis Lawler, Dick Long, Arthur Marin, Bob Palzer, Jim Ralston, and Richard Schoeneberg.

Other Attendees

Rebecca Battye and Wendy Vit, EC/R Incorporated (EPA contract support)

III.	ACTION ITEMS

A joint National Regional Strategies Work Group (NRSWG) and BPAPWG meeting will be held on March 13 and 14, 1997 at the University Regal in Durham, North Carolina. It will begin at 8:00 a.m. on March 13 and will end in the mid-afternoon on March 14. The hotel address, meeting agenda, and other meeting materials will be distributed to the work group via e-mail.

Several BPAPWG members supported incorporating the "too close to call" concept into one of the issue papers or leaving it as a stand-alone paper. Mr. Paisie will check on the Coordination Group recommendation concerning the status of the Too Close to Call issue paper. He will also make the EPA's Natural Events Policy (5-96) available to the work groups.

The Rewards and Sanctions paper will be updated by condensing the number of options and including the pros and cons of each.

An ad-hoc monitoring incentives group conference call will be held on March 6, 1997 from 1:00-2:30 EST.

Mr. Schaefer will contact Bruce Craig concerning the NRSWG's proposed revisions to the New Source Review (NSR) issue paper.

Mr. Schaefer and Mr. Lee will represent the BPAPWG at the March 14, 1997 Integrated Implementation subgroup meeting.

The Control Strategies subgroup will hold a conference call on March 11 from 4-5 p.m. EST and will have a breakfast meeting on the morning of March 13, 1997.

Ms. Byrd, Mr. Dworek, Mr. Halvey, Ms. Wayland and Mr. Nicholson will meet, possibly on March 13, 1997, to decide what the Monitoring Plans paper should address or if it should be folded into the monitoring incentives effort.

IV.	CONFERENCE CALL SUMMARY

Classifications

Mr. Skelton reported that there was no consensus among FACA Subcommittee members on how the Classifications of Designated Areas Under New NAAQS paper should be revised. Mr. Paisie suggested putting the Classifications paper on hold until the Area of Violations (AOV) Boundaries and Control Strategies papers have been further developed.

Mr. Pezda emphasized that classifications may be needed in areas that "flip flop" in and out of attainment due to extreme meteorology ("too close to call"). Mr. Skelton indicated that extreme stagnation and natural events, such as dust storms, are examples of conditions that may deserve special consideration. These situations could require public notification, but should not throw an area into nonattainment status. Mr. Zeldin believed that the too close to call concept is part of the standard-setting process and should not be addressed as part of the implementation. Mr. Paisie said the EPA's Natural Events Policy (5-96) addresses the subject. He will make the policy available for the work groups.

Mr. Gerritson, Mr. Pezda, Mr. Lee, and Mr. Phelps maintained that the concepts from the Too Close to Call paper should be included in one of the issue papers or left as a stand-alone paper. Mr. Golden and Mr. Phelps suggested the Treatment of Areas in Which Air Quality Trends Indicate the Risk of Becoming an AOV issue paper as a possible place to include them, but Mr. Pezda proposed the Attainment Dates paper. Mr. Golden thought too close to call should be incorporated into the Classifications paper. Mr. Paisie noted that the Coordination Group had made a recommendation concerning the Too Close to Call paper and that he would check on what the recommendation was.

Rewards and Sanctions

Mr. Gerritson reported that the FACA Subcommittee supported the general concept of rewards and sanctions but did not give specific direction regarding the issue paper. He proposed condensing the background discussion and listing ideas, which would not be intended as an inclusive list. Instead of recommending specific ideas for rewards and sanctions, the paper would recommend that the EPA develop a rewards and sanctions policy for approving states ideas. States would benefit from an improved process; they will develop their own creative rewards programs. He questioned whether FACA should recommend options that are beyond EPA's power, such as tax credits which require legislative action in each state. Mr. Pezda supported this approach.

Mr. Paisie stated that the EPA does not expect the subgroup to propose a single preferred approach and that a list of options would be acceptable. It would also be acceptable for the subgroup to recommend tax credits or other options that could not be written into Agency policy because they require State action. The Agency would then select which of the proposed options to recommend. Mr. Zeldin said the subgroup should identify the preferred options.

Mr. Dworek favored options that would reduce industry costs while also controlling emissions. He strongly supported the general concept of rewards rather than sanctions.

Mr. Gerritson thought the February 19, 1997 BPAPWG meeting was helpful in identifying negative aspects of some of the options in the current draft. Increasing transportation funding, for example, is one option that could have negative results. Such funds are likely to be diverted to other state agencies and are not likely to be an incentive for state air quality management programs.

There was discussion on the relationship of the Rewards and Sanctions paper to the Economic Incentives paper. The Economic Incentives paper will be split into three papers. There will be Joe Belanger's paper on trading programs, a mobile and area source paper, and a third general paper that will include the rewards and sanctions.

The paper will be updated by condensing the number of options and including pros and cons. Mr. Paisie said the minutes of the Subcommittee meeting should be available soon to expedite revision of the paper.

Monitoring Plans

A background piece for the Monitoring Plans paper was developed by Lee Byrd, EPA, and distributed to work group members. Mr. Nicholson indicated that he would like to brainstorm issues and options for the paper. Possible issues include giving states more flexibility, whether the Photochemical Assessment Monitoring Stations (PAMS) network should be varied, if enhanced monitoring should be required and if so where, priorities for PM fine designations, and meteorological conditions.

Mr. Schaefer advised that the term enhanced monitoring be avoided, as it is controversial and associated with a specific proposed rulemaking that has been tabled.

Mr. Pezda wanted the monitoring paper to address spatial averaging and the location of the monitors. Mr. Paisie indicated that these are technical issues being addressed in the monitoring proposal process.

Several members questioned the purpose of the Monitoring Plans paper, given that the ad-hoc monitoring incentives group is addressing similar issues. Mr. Paisie explained that the objective of the paper is to discuss the monitoring needs for implementing the new ozone and PM NAAQS. Ms. Byrd further explained that requirements for State Implementation Plan (SIPs), including schedules for implementing existing and new requirements, would be addressed. Mr. Salvaggio said the paper's purpose should be to address fundamental monitoring policy issues associated with implementing the new standards. The key issue is does the current network provide adequate data to support the Area of Influence (AOI)/Area of Violation (AOV) approach.

Mr. Nicholson questioned whether the Monitoring Plans paper should be abandoned or whether there were unique issues that it should address. Ms. Lee asked if the paper should address the location of monitors, focus more on the authority (when should monitors be required), or what should states be required to include in the monitoring plans. Mr. Dworek believed that the ad-hoc monitoring incentives group was already addressing many of the issues discussed for the Monitoring Plan paper. However, he was willing to coordinate with Mr. Nicholson if other issues were identified. Ms. Byrd, Mr. Dworek, Mr. Halvey, Ms. Wayland and Mr. Nicholson will meet, possibly on March 13, 1997, to decide what the Monitoring Plans paper should address or if it should be folded into the monitoring incentives effort. Mr. Nicholson requested input from the BPAPWG concerning monitoring issues that may not be covered in other papers.

New Source Review

Mr. Schaefer reported that the NSR paper will be revised. The NRSWG has discussed reformatting the paper. The BPAPWG agreed that the NRSWG should submit an outline of their proposed revisions. Mr. Schaefer will talk to Bruce Craig of NRSWG about this.

The issues, including Prevention of Significant Deterioration (PSD) increments for PMfine, that had been deferred to Phase II will be developed.

Mr. Golden and Mr. Paisie maintained that control strategies should not be decoupled from NSR. Mr. Golden requested that Mr. Schaefer consider the possibility that NSR control requirements would differ according to classification. For example, control requirements may be different for areas with transported versus local pollution. Mr. Schaefer agreed to keep abreast of the control strategies paper to ensure that the two papers are consistent.

Integrated Implementation

Mr. Kappelmann reported that the opportunity matrix paper being developed as part of the Integrated Implementation issue paper is still a "work in progress" and that the subgroup is open to suggestions concerning its direction. Mr. Golden and Ms. Vernet were concerned that the 20-page opportunity matrix paper was too long. Mr. Kappelmann said the subgroup is working on paring down the matrix.

The subgroup is currently considering trading issues, such as crediting multiple-pollutant benefits. They are also developing an implementation schedule consisting of FACA recommendations (e.g., identification of AOVs and AOIs) and statutory dates for ozone, PMfine, and regional haze. This schedule will form the basis for the subgroup's recommendations on how to integrate if the timelines for the three pollutants are not aligned.

Mr. Schaefer and Mr. Lee agreed to represent the BPAPWG at the next Integrated Implementation subgroup meeting to be held on March 14, 1997 in Durham, North Carolina, as Mr. Kappelmann may not be able to attend.

Control Strategies

Ms. Vernet reported that a partial outline of the Control Strategies paper had been completed. She advised that the Classifications paper not be held up for the Control Strategies paper, as it is not likely to be ready for presenting to the FACA Subcommittee before June, 1997. The June presentation should include the timeline for control strategy development and implementation.