Draft Summary

Base Programs Analyses and Policies (BPAP) Work Group Meeting

Durham, North Carolina

March 13, 1997

I.	PURPOSE

The BPAP work group held a face-to-face meeting on March 13, 1997 in Durham, North Carolina.

On March 13 work group discussed the Control Strategies, Maintenance Plans/Contingency Measures, and New Source Requirements issue papers. In addition, a joint session was held with the National and Regional Strategies (NRS) work group. The Reasonable Further Progress (RFP) and Control Strategies papers were discussed in the joint work group session.

On March 14 work group members discussed the BPAP General Mobile Source issue paper with the subgroup and participated in other issue paper discussions led by NRS and Science and Technical Support (STS) work groups and subgroups. Summaries of the NRS and STS issue paper discussions are provided elsewhere by those work groups. A summary of the General Mobile Source BPAP work group discussion with the subgroup is provided.

II.	PARTICIPANTS

BPAP Work Group Sessions

BPAP Work Group

Attendees:

Joe Paisie, co-Chair, Vincent Brisini, Richard Chastain, Richard Dworek, Steve Gerritson, Dennis Lawler, Arthur Lee, Richard Long, Arthur Marin, Chuck Mueller for Herb Williams, Bob Palzer, Steve Pezda, Jim Ralston, Greg Schaefer, Dick Schoeneberg, Jean Vernet, and Mel Zeldin.

Work Group Members Not in Attendance:

Jerry Golden, co-Chair, David Baron, John Crouch, Gregory Dana, Jeff Gabriel, Rich Halvey, Robert Kappelmann, Barbara Lee, William Luneburg, Brock Nicholson, Richard Phelps, Jim Salvaggio, and Eric Skelton.

Joint BPAP/NRS Work Group Session

NRS Work Group

Attendees:

David Mobley, co-Chair, Environmental Protection Agency (EPA)/OAQPS

Don Theiler, co-Chair, Wisconsin

Joe Belanger, Connecticut

Bruce Craig, NGSA

Nina Dougherty, Sierra Club

Larry Feldcamp, Baker & Botts

Dave Howekamp, EPA Region 9

Dewayne Huckabay, Houston

David Hyder, North Carolina DOT

Dan Johnson, Washington

Donna Lamb, USDA/Forest Service

Sarah Peirce-Sandner, Kodak

Ted Russell, Georgia Tech.

Work Group Members Not in Attendance:

Andrew Aitken, New England Power Service Co.

Mark Brownstein, PSE&G, NJ

Timothy Byrd, Gallo Winery

Cliff Doumas, Mobil

Joe Francis, Nebraska

Mike Frost, Southern Ute Tribe

Stan Hathcock, Webster South

Jon Heuss, General Motors Corp.

David Hyder, North Carolina DOT

John Leary, Western Governors' Association

Amy Lilly, AIAM

Marvin Lowry, Georgia

David Marshall, Conservation Law Foundation

John McManus, American Electric Power Co.

Timothy Method, Indiana

William Miller, Philadelphia

Terry Rowles, Missouri

Lydia Salmon, Kennecott Copper Co.

Christine Shaver, EDF

Jerry Steffy, Harley Davidson Co.

Ted Wernick, Gillette Co.

Thomas Wright, AAMVA

Robert Wyman, Latham and Watkins

Other Attendees

Deborah Amaral, Rebecca Battye, William Battye, Catherine Deininger, Brian Morton, Wendy Vit, and Steve Walata, EC/R Incorporated (US Environmental Protection Agency (EPA) contractor support).

III.	ACTION ITEMS

The RFP paper will be divided into State implementation Plan (SIP) phase RFP and pre-SIP RFP papers. John Silvasi, EPA lead, will develop the issues and options for pre-SIP RFP, which will build from the results of a voting/brainstorming exercise held by the work groups on March 13. Mr. Howekamp, Ms. Spindler, Mr. Johnson, and Ms. Mayer will help with this effort. These pre-SIP RFP issues and options will be presented at the April Federal Advisory Committee Act (FACA) Subcommittee meeting. Since the Environmental Caucus is particularly concerned about this issue, the issues and options will be given to the Caucus for their review. The RFP subgroup will continue to develop the SIP-phase RFP paper.

Control Strategies subgroup conference calls are from 4:00 - 5:00 p.m. Eastern Time every Wednesday.

The following is a potential agenda for the April 8 and 9, 1997 FACA Subcommittee meeting in Falls Church, VA: Integrated Implementation timeline piece; Control Technology Matrix; Control Strategies - framing of the issues; Transportation Conformity - background; and Emissions Inventory/Modeling paper - EPA position paper.

IV.	MEETING SUMMARY

DAY ONE -- MARCH 13, 1997

Joint BPAP/NRS Work Group Session (9:15 - 12:00)

Reasonable Further Progress

The issue paper for discussion was RFP. The RFP subgroup has divided the RFP issue into a SIP phase and a pre-SIP phase. To address SIP-phase RFP, which is the period after the SIPs under the new/revised national ambient air quality standards (NAAQS) have been approved, the subgroup is developing a flow chart of an iterative RFP process. This joint work group discussion focussed on the pre-SIP phase, which is the period between NAAQS promulgation and SIP approval. The two key questions are when and where should pre-SIP RFP occur.

Options for pre-SIP RFP actions are: (1) develop SIP submittal for the new NAAQS (e.g., modeling, developing emissions inventories, monitoring, etc.); (2) avoid emissions increases from new stationary sources; (3) implement national measures, which could include mobile, area, and stationary source measures; (4) implement state measures; (5) implement voluntary measures. Ms. Peirce-Sandner explained that the paper's options build from the SIP development option by combining this action with one or more of the other actions.

The pre-SIP RFP portion of the paper assumes that RFP measures would be implemented once the Area of Influence (AOI) and Area of Violation (AOV) have been identified. It also assumes that RFP would be implemented in both the AOI and AOV, unless the AOV demonstrates that the violation is a function of overwhelming transport.

Mr. Gerritson said the "AOV Boundaries" issue paper has not been resolved. Some work group members feel that defining AOV boundaries is not necessary for starting the planning process. The papers should be consistent. Mr. Silvasi replied that the RFP paper does not imply that the boundary of AOVs must be defined before RFP starts. An analysis must be conducted to define the preliminary AOI, and a subset of the preliminary AOI must eventually be defined as the final AOI. Because this process may be lengthy, the issue is: should emissions increase during this interim period, and, if not, what should be done about it. The environmental community has expressed its position that the Regional Air Management Partnership (RAMP)-AOI planning approach raised by the Subcommittee is unacceptable unless something happens during the period before the new SIPs are in place. Ms. Peirce-Sandner recalled that at the February 20, 1997 FACA Subcommittee meeting David Hawkins was also concerned that 3% per year, which the Interim Implementation Policy (IIP) proposes to keep in place in existing ozone nonattainment areas, will not be sufficient progress toward attainment of the new NAAQS. One option is to apply pre-SIP RFP requirements to all AOIs and AOVs regardless of their historical attainment status.

Mr. Paisie thought the issue was based on fine particulate matter (PMfine) in particular. Emission reductions may not occur for at least six years. Although planning in the interim may be a sensible starting point, planning does not reduce emissions.

Mr. Gerritson said states, particularly those impacted by transport, are also concerned about this issue. He disagreed that progress would not be made for six years. Once a violation has been identified, states put SIPs in place within about 27 months.

Mr. Theiler asked if the paper assumes that pre-SIP RFP would be required in the preliminary AOI. The distinction between the preliminary and final AOI is critical. Work group members continue to have differing views of RAMPs, preliminary AOI, and final AOI. The preliminary AOI will not be subject to control requirements, and the final AOI will be required to implement controls.

Mr. Huckabay suggested dividing the pre-SIP period into two phases: before and after the identification of the final AOI. RFP could be different in each of these two phases. One approach could be that the problem cannot be made worse in the preliminary AOI (e.g., an emissions cap) and that the final AOI must begin to make progress toward attainment.

Mr. Theiler explained a concept that he had proposed in an October 8, 1996 memo entitled "Reasonable Further Progress Requirements in the AOI/AOV Areas." During the pre-SIP period, IIP requirements would be applied to all new nonattainment areas as they are identified. These areas could be thought of as temporary nonattainment areas. For instance, newly designated ozone areas would be required to make 3% per year reductions, unless they can demonstrate that they are impacted overwhelmingly by transport. Ms. Vernet noted that classifications and accompanying control requirements would be different for the newly designated areas.

Mr. Belanger suggested addressing the two parts to RFP: when progress starts and when actual progress is measured. He was concerned that not requiring controls until final AOIs are identified would reward delay. One option is to push the RFP baseline date back so that an area is already behind when it is identified as a final AOI. In other words, the area would incur a liability that the final AOI would eventually have to pay off. Ms. Peirce-Sandner said she would add "incur liability by an early baseline" to the list of options.

Ms. Lamb said the Integrated Implementation subgroup has discussed what happens if the dates are different for ozone, PM, and regional haze. Regional haze SIPs are due very early. The subgroup is considering linking regional haze progress with later ozone and PM progress requirements. She wondered if this concept could be part of the liability approach.

Mr. Belanger commented that, if national measures are those that apply to particular areas (e.g., reformulated gasoline (RFG) or New Source Review (NSR)), most of the options fall off. Being designated as a preliminary AOI should not carry any burden. Mr. Huckabay distinguished between the two kinds of national measures: those that affect all states and those that affect designated areas.

Mr. Fichthorn objected to overlaying the IIP with additional requirements. He was particularly concerned about applying RFP to areas that are currently in attainment. The statute defines RFP as an element of the SIP. The legality of pre-SIP RFP should be assessed. EPA could do some things, national measures for instance, outside of the SIP process. Mr. Lee asserted that the work groups are spending too much time addressing the interim period. RFP should not just be applied everywhere a problem has been identified.

Mr. Lauer said the timeframe is problematic due to the lack of PMfine data. Determining the attainment status of PMfine areas by 1999 is impossible. Ms. Peirce-Sandner responded that the timelines are based on the March 13, 1997 "Regional Air Management Partnerships and Areas of Influence" paper. Mr. Theiler explained that the paper's timeline reflects the ideal scenario. It assumes sufficient data will be available. Obviously, if data are not available, the dates will be pushed back.

Ms. Dougherty commented that national measures, such as Inspection and Maintenance (I/M) and diesel measures, could be put in place upon promulgation. In addition, states can do simple things immediately based on existing ozone knowledge. These early actions can help areas to avoid being designated. Mr. Gerritson agreed that national measures are not tied to dates. Mr. Lauer suggested some form of NSR in the interim period.

Mr. Schoeneberg said states are currently having problems implementing I/M programs. The only way to get it going in this interim period would be a Federal implementation plan (FIP)-type process.

Mr. Howekamp suggested that measures be developed parallel to the planning. Measures do not happen instantly. Mr. Lawler added that measures must be phased in. Even "easy" measures must be backed with data. Even if RFP measures do not kick in during the interim, the planning could start.

Several members argued that existing programs will result in progress in the interim period. Mr. Pezda noted that the present ozone and PM-10 measures will reduce PMfine. Mr. Dworek said the IIP, Maximum Achievable Control Technology (MACT), and Titles IV and V will reduce emissions in the interim. Until more monitoring data, including speciated data, have been collected, it will be difficult to do anything. Building the database must be the first step.

Mr. Belanger suggested developing a method for rewarding areas that do things right away. For instance, the percent reduction could be increased each year an area delays. This would be an incentive to act early.

Ms. Peirce-Sandner summarized that the group is mostly concerned about the assumptions of when and where pre-SIP RFP would occur. She believed most of these concerns are addressed in the existing options.

The work group members participated in a voting exercise for the pre-SIP options. Participants voted for the options using dots which were color-coded to represent their sector (e.g., environmental, academic, etc.). Participants modified their vote by commenting on when and where the option should occur. They could vote as many times as they wished. The results of the exercise will be used to flesh out the pre-SIP RFP portion of the issue paper.

Control Strategies

This joint work group session focussed on the Control Strategies issue paper. Mr. Johnson reported that the Control Strategies subgroup held a conference call on March 11, 1997. The participants struggled with the scope and content of the issue paper on the call. He presented an overview of the current air quality management process and reminded work group members that the FACA process has been charged with determining how this process could be improved.

A graphic illustrating linkages among the issue papers was presented. The control strategies issue was shown to be central to all of the other issue papers.

Mr. Rosendahl presented the timeframe for the development of the "Control Strategies" issue paper. The paper will be jointly developed by the BPAP and NRS work groups. The morning discussion will define the scope of the paper, and brainstorming sessions in the afternoon will develop the list of issues to be addressed. The list of issues will be presented to the FACA Subcommittee at the April 8 and 9, 1997 meeting.

The group discussed the mission statement. Mr. Theiler asked what the "integrated air quality institution" would be. RAMPs will not allocate control strategy responsibility. The states in the AOI will do this. He suggested incorporating the concept of ensuring RFP into the mission statement. Mr. Johnson said the issue paper could recommend a list of national measures. The work groups should consider whether the paper should also include recommendations for the other types of control measures.

The group discussed the definition of national measure. Mr. Rosendahl thought national measures are those that EPA is responsible for on at least a 48-state basis. Mr. Theiler modified this definition to be those measures applied uniformly across the 48 contiguous states regardless of classification. This would include automotive standards and MACT but would not include Lowest Achievable Emission Rate (LAER), Prevention of Significant Deterioration (PSD), and I/M. Mr. Palzer agreed with the definition but commented that I/M should be a national measure.

The distinction between local and mandatory measures was discussed. Mr. Johnson said local measures are those above and beyond national measures that will bring an area into attainment. Mandatory measures are those that are applied in selected areas. Mr. Gerritson said local measures are discretionary. Mr. Theiler said if a non-national body has a choice the measure is discretionary. Mr. Johnson added that discretionary does not imply that attainment dates can be ignored. Discretionary measures could build on the floor of national measures.

The group agreed to replace the "national, regional, and local" terminology with "national, mandatory, and discretionary." National measures are applied across the 48 states regardless of classification, and mandatory measures are applied in selected areas. Air quality authorities can choose whether or not to implement discretionary measures.

Mr. Zeldin asked how Reasonably Available Control Technology/Measures (RACT/RACM) fit into the definition scheme since the EPA develops guidance on these measures, but states have flexibility on how to implement them. Ms. Vernet thought it was a sub-definition within mandatory.

Mr. Paisie asked how Ozone Transport Commission (OTC) measures fit into the definition scheme. Mr. Theiler said OTC measures would be considered mandatory, because they are not required in all 48 states. For example, the EPA requirement of 50 percent reduction in nitrogen oxide (NOx) in the ozone transport commission (OTC) region is a performance-based mandatory measure.

Several members supported incorporating flexibility into the scheme. Mr. Pezda suggested developing a provision which allows areas to opt out of specific national measures. For instance, on-board diagnostics (OBD) systems could be substituted for I/M programs. Mr. Ralston said a model rule or performance standard should accompany each mandatory measure. Mr. Theiler said variance procedures can be developed.

Mr. Gerritson asked whether the paper would address the issue of order. Should the national measures or the mandatory/discretionary measures be implemented first? Mr. Johnson told him to suggest the issue in one of the afternoon brainstorming sessions.

Mr. Palzer asked if the paper will address the problem that 25 states cannot adopt regulations more stringent than EPA's regulations.

Mr. Belanger suggested considering national measures that would constitute RFP or could be credited toward RFP.

Mr. Dworek wanted pollution prevention or process improvements to be considered. It does not always make sense to control the regulated source. For instance, controlling the injection process may be more cost-effective than controlling the coke oven.

Mr. Lauer asked who would underwrite the cost for researching and developing these measures. Will these measures be unfunded mandates? Mr. Paisie said the section 105 program is designed to provide support, although is probably not entirely adequate.

The results of the control strategies brainstorming exercise from the February 19, 1997 work group meetings in Washington, D.C. were presented. The work groups supported national mandatory measures, flexible regional measures, and supplemental local measures. These results created some confusion, because they were prepared before the national, mandatory, and discretionary definitions were refined.

A sector-by-sector assessment of the brainstorming exercise was distributed. This analysis showed broad support for national measures. Mr. Lee said the exercise was useful as a brainstorming exercise, but he strongly disagreed with the sector analysis. Ms. Peirce-Sandner said the exercise stimulated creativity on developing options, but she felt that she did not have enough background on some of the issues. Mr. Brisini said the results should be used to push the issue paper and should not be used as recommendations.

The raw data will be posted on the Technology Transfer Network (TTN) Bulletin Board System. The sector analysis will not be posted.

BPAP Work Group Session (1:00 - 5:00)

Control Strategies

The work group discussed the set of definitions. Mr. Gerritson was concerned about what is being allocated. He did not like "reduction target." Mr. Brisini asked what the point of mandatory controls would be if areas are not designated or classified. He prefers the term "prescriptive."

Mr. Zeldin asked what happens if there is a list of recommended measures and EPA does not do what it is supposed to do. If states don't act, they are subject to sanctions. Would the states be required to make up the reductions?

Mr. Schaefer commented that in the RFP brainstorming exercise that morning, there were a lot of market-trading ideas. Do the definitions change for a market-trading program?

Mr. Pezda suggested adding something about voluntary measures and cost-effectiveness.

Mr. Dworek said the existing baseline is being implemented and should be recognized.

Referring to the mission statement, Mr. Pezda said the generation of a list of national measures alone is inconsistent with the line about allocation.

The order of implementation was discussed. Mr. Paisie said in the past national and local measures have been implemented in parallel. Mr. Lee said there are problems with the delegation of authority in the current system. The regulated community has seen this problem a lot. Mr. Dworek said the top priority should be sources that have not done anything yet.

Mr. Rosendahl said the paper could come up with a set of criteria or principles that a regional planning group could look at as it assessed the problem. Ms. Vernet gave an example: if there is trading, should national guidelines be established?

Mr. Ralston asked if the work group has thought about emission reductions versus air quality indicators. If an area implements I/M by 1998, it could get credit in the 1996 plan.

Mr. Palzer favored national measures that are consistent across the nation. He would like an old source review translated to a technology floor.

Maintenance Plans/Contingency Measures

Ms. Nikbakht and Mr. Cole presented the preliminary draft of the issue paper.

Mr. Palzer asked if maintenance emission inventories use actual or permitted emissions. Actual emissions may be significantly lower than the permitted emissions. Ms. Nikbakht explained that the baseline is developed on actual emissions. However, some flexibility is allowed by using permitted emissions for the projection inventories. Mr. Palzer asked if all permitted emissions were emitted, would the area still maintain the standard? Ms. Reinders replied that sources can emit more than the maintenance emission inventory would allow. The attainment year inventory consists of the actual emissions in the air that show attainment. However, there is close to zero chance that all of the sources that emit ozone precursors would operate at peak permitted levels all at the same time and cause an exceedance or violation of the NAAQS. Mr. Cole said actual emissions are based on enforceable permit and production rates.

Mr. Palzer was concerned about contingency measures in maintenance plans. Usually contingency measures are something being adopted by the legislature. However, the paper indicates that some contingency measures are permissible without having authority. In response to a question, Ms. Reinders explained that contingency measures for maintenance plans do not have to be adopted prior to a violation triggering their use.

Ms. Nikbakht said these contingency measures are permissible if they have the authority in place. The mandatory measures need legal authority. Some measures do not have to have legal authority to be included as contingency measures for a maintenance plan. Most maintenance plans contain a laundry list of measures which do not always need to be adopted first. Ms. Reinders said the regulatory agency will have to have legislative acknowledgment and approval for all measures. A select few, such as I/M, had to get authority. All the contingency measures are part of the SIP and are enforceable. Mr. Ralston added that to be SIP approvable, plans must include a list with schedule of when the measures would be adopted.

Mr. Ralston commented that the question on the relationship with transportation conformity does not add anything to the issue paper. Transportation conformity looks at a 20-year span, while the maintenance plan only looks at a 10-year span. How could changes be made to one or the other? If the maintenance plan is adjusted, would the transportation conformity plan have to be adjusted as well? How are violations and adjustments accounted for? Mr. Schoeneberg said air quality planners and transportation planners have different frames of reference. The models are not there yet to handle a 20-year span. Ms. Nikbakht said the issue may be addressed by the "Transportation Conformity" paper. The group agreed that the question should be delegated to the "Transportation Conformity" paper.

Mr. Gerritson said the paper should address issues in the context of the AOI/AOV concept. The current process requires three years of data. The fourth highest is the design value, and the area is stuck with it. With multi-year averaging, how will designations occur? Will a set or a rolling three-year average will be used? If a rolling average is used, areas will flip-flop in and out of attainment. What happens to contingency measures?

Mr. Schoeneberg said contingency measures assure a continual ratcheting down of control measures. The new standards will be so stringent that there will not be any reductions left to include in a contingency measure.

Ms. Nikbakht asked if the paper should address episodic and voluntary measures. She gave several examples of voluntary programs that are not enforceable. Mr. Woodard said voluntary measures, especially residential wood combustion voluntary curtailment, would be mandatory when the voluntary program did not get the required results. Ms. Videtich said an ozone control program is for the entire year. PM, on the other hand, is a seasonal problem. Each winter can expect a four- or five-day period with high levels of PM. Mr. Ralston said EPA favors continuous over episodic. It is hard to predict high levels of ozone. The lack of monitoring data makes predictions even harder. Mr. Lee would like the paper to address episodic reductions. He said whether or not episodic controls would be enforceable is an issue. Ms. Baldridge said EPA cannot approve a SIP based on voluntary measures. How would it be enforced? Mr. Gerritson said the problem with episodic control strategies, especially when dealing with ozone, is that, at best, models can only predict high levels of ozone in advance. By then, the chemicals that cause the high concentrations are already in the atmosphere.

Mr. Schoeneberg asserted that voluntary measures are simply "window dressing" that do not serve any purpose other than to make people feel good. If a measure is not real, there will not be a commitment. They should be kept out of SIPs. Ms. Nikbakht responded that voluntary measures would supplement SIP contingency measures

Ms. Videtich said voluntary measures should not be ruled out. Denver has a voluntary, episodic wood burning program that gets 87% compliance. Denver has received SIP credit for the program. Mr. Marin said an area cannot tell ahead of time how effective voluntary measures will be.

Mr. Ralston said a before and after study should be conducted to see how people deal with voluntary measures. Mr. Brisini commented that the main variable in such a study would be the educational and financial level of the people involved with the voluntary measures. There should be an effective outreach program for the new NAAQS. The EPA should take the opportunity and responsibility to educate people on what is expected from the new standards. The EPA will need to get buy-in from the population or will not get the reductions later.

Mr. Palzer said mandatory measures without enforcement results in low compliance. Mr. Brisini said people must be given a chance to participate in a voluntary program. If the participation is below that which is necessary to reach attainment, the program can always be made mandatory. The public needs to have a say in what is happening.

Mr. Zeldin asked if a contingency measure be withdrawn in response to a new national measure and placed back into the contingency measures bin. That is, can a measure be taken off the table and used in the future as long as the replacement measure provides equivalent air quality benefits? Ms. Baldridge responded that a SIP modification would take care of that. Mr. Ralston added that such an approach would violate the "savings" clause. If an area uses a measure, the measures cannot be used again. This is less important if there is no target level.

Mr. Gerritson said under the current scheme, nonattainment boundaries are fixed. Reductions must come from within the nonattainment area. Could a contingency measure be used to expand the area of the AOI? This could be considered as an alternative to increasing levels of control. Mr. Zeldin said it would be a contingency process instead of a contingency measure. Mr. Ralston said it would involve EPA in a greater role than before. Mr. Pezda noted that if the AOI is defined properly, an expansion of the AOI would not be needed.

Mr. Palzer said one contingency measure for one pollutant could worsen another problem. The paper should acknowledge that possibility and refer to the "Integrated Implementation" paper.

Mr. Palzer said whether woodstove curtailment is voluntary or mandatory, it seems appropriate to have a ban on open burning during the same period. He is concerned with contingency measures that do not have the necessary authorities. Having measures that rely on a non-existent statutory authority in a maintenance plan is not a good policy.

Mr. Palzer said it should not be okay for a maintenance plan to drop a measure used to bring an area into attainment with a standard. For example, a measure was used to reduce the threshold of a major source from 100 TPY to 40 TPY. The maintenance plan is allowing the threshold for major sources to revert back to 100 TPY. The area may grow and this may cause the area to become nonattainment again. Why justify certain requirements in the SIP that are dropped for the maintenance plan?

Mr. Pezda said the paper should consider costs and benefits.

New Source Requirements -- Phase II Issues

At the August 27 and 28, 1996 face-to-face meeting in Durham, North Carolina, the BPAP work group decided to defer PSD, fine versus coarse, and permitting issues in the "New Sources: Considerations for the Implementation of New Air Quality Standards/Regulations" paper to Phase II. Mr. Schaefer provided an overview of these Phase II issues and options. The issues pertain to PM, not to ozone.

PSD Increments

Mr. Palzer was concerned about the use of PM10 as a surrogate for PM2.5 because the ratio of PM2.5 to PM10 varies depending on the area, season, etc.

Mr. Ralston did not believe that models can differentiate between ammonium sulfate formed in a stack versus that formed outside. Mr. Schoeneberg said perhaps a commitment for monitoring, modeling, inventory resources should be made up front. Mr. Gerritson said if this resources clause were added to option 2, he would buy-in to it.

Permitting

Mr. Ralston asked how a permit would be issued when no stack-test methods exist. Is the issue how to determine if a source is a major source? Mr. Schaefer replied that the issue is how will major sources be permitted.

Ms. Lamb said air quality related values (AQRV) for Class I areas should also be modeled.

The group agreed that the permitting issue should remain in the paper.

Fine versus Coarse

Mr. Schaefer explained that PM2.5 monitors have some potential for intrusion of the tail of the coarse mode. Because the PM2.5 monitoring Federal reference method (FRM) is mass-based, a few coarse particles can throw off PMfine measurements significantly.

Mr. Lawler restated the issue: should both the coarse and fine particles be considered before a permit is granted, or should only one of the pollutants be controlled? Ms. Lamb said different approaches could be used on a source-by-source basis.

DAY TWO -- MARCH 14, 1997

General Mobile Source Measures

Fuels

Mr. Hyder asked about the north-south boundary for Reid vapor pressure (RVP) requirements. Mr. Rawdon said the boundary is not strictly geographical. Oregon, for example, is considered a "southern" state. (Note: the boundary is based on meteorological considerations.)

Ms. Videtich asked why new nonattainment areas cannot opt in to the RFG requirement. Ms. Hawk responded that Congress was very specific in the language it used in the Clean Air Act (CAA) to designate which areas are eligible to opt in--it is not clear why. Mr. Rawdon commented that the CAA also does not allow mandated areas that are subject to RFG to opt out. Voluntary areas are eligible to opt out, while the 10 mandated areas appear to be ineligible to opt out.

Mr. Marin suggested examining whether the California provision to adopt a more stringent fuel formulation could be applied elsewhere. For instance, could an AOI have this option? Ms. Hawk said a state could adopt a "designer" fuel through a waiver of preemption [211(c)(4)(C) of the Act]. In order to obtain the waiver, the state would have to show it is necessary to achieve the NAAQS. It could be a legal issue. Mr. Pezda said having different fuels standards for different areas is very costly for the fuels and automobile industries.

Mr. Schoeneberg commented that RVP regulations took care of significant amounts of hydrocarbons. He asked what the effect of RFG has been on hydrocarbons. Mr. Brisini replied that a Southeast Pennsylvania stakeholders group has assessed the impacts of RVP versus RFG. Jim Salvaggio of the BPAP work group may have this information.

Mr. Rawdon explained Petroleum Administrative Defense Districts (PADD). Five PADDs recognizing differences in the refining infrastructure have been established for producing and distributing fuels. Fuels are not distributed over large differences. In the context of the RAMP/AOI construct, the PADD(s) covered by the various planning regions should be considered. Midwestern PADDs, for example, are relatively small and less sophisticated. They are less capable of producing and distributing multiple types of fuels.

Mr. Schoeneberg suggested addressing diesel fuels in addition to gasoline. Mr. Pezda said all alternative fuels, such as compressed natural gas, methanol, etc., should be addressed.

Mr. Hyder asked how RFG will affect NOx. Ms. Hawk said Phase II will require 5 - 7 percent NOx reductions per year starting in 2000.

Mr. Marin suggested adding the ability to go beyond RFG (e.g., NOx performance standards) as an issue.

Mr. Pezda requested that cost be added as an issue.

Federal Measures

Mr. Fichthorn asked about marine engines and aircraft standards. Ms. North replied that a gasoline marine engine rulemaking, which targets hydrocarbons, was completed last year. Diesel marine engines and vessels may also be regulated. The EPA is currently evaluating how the Agency will approach this category. Aircraft emission standards are under development internationally. The EPA is participating in the international forum and is not pursuing a separate effort.

Mr. Rawdon said this paper should present a timeline or bulleted list of current or in-the-pipeline federal mobile measures. This could allay some of the work group concerns about nothing happening during the pre-SIP phase. Ms. North will distribute a chart to the work groups. Mr. Marin noted that, although such a list would be useful, the bulk of the reductions will not accrue before 2004 (the end of the pre-SIP phase).

Mr. Huckabay said determining where emissions decreases are offset by vehicle miles travelled (VMT) growth is important. Ms. North agreed, noting that current federal measures address emission rates rather than use and sales.

Mr. Schoeneberg said another issue is the consistent ageing of the fleet. More than 35 percent of the VMT comes from cars greater than 10 years old. In Europe the average vehicle age is significantly greater than in the U.S., but Europe has extraordinarily high maintenance standards.

Several members questioned the purpose of the issue paper. Mr. Huckabay said the background information might be useful for targeting measures. For example, light-duty truck (LDT) sales are increasing, but they are not regulated as much as cars. Mr. Marin wondered if the intent is to comment on proposed rules. Ms. North responded that the background information summarizes "where we are" and that it is up to the work groups to decide which direction to take the paper.

Mr. Pezda noted that truck emissions are difficult to project into the future. He stated that the paper should address a wide range of factors affecting what is appropriate for vehicles, such as climate change efforts.

Mr. Schoeneberg said the paper could address the effect of the new Federal Test Procedure (FTP), which should provide a more accurate representation of in-use emissions. Ms. North replied that the paper has a paragraph on it. Mr. Marin commented that the new FTP will be reflected in MOBILE6.

Mr. Pezda suggested adding a discussion of the PNGV. This partnership between the automobile industry and the government will focus on safety and environmental issues. One goal is to develop an 80 mpg automobile.

Mr. Wolcott said suggestions from the February 19, 1997 control strategies exercise indicated fairly broad support for national measures. An approved California SIP may offer suggestions.

Inspection and Maintenance

Mr. Marin asked what the purpose of the paper is. He wondered if this FACA has the level of expertise to make a recommendation. This FACA process should be linked with the transportation FACA. Mr. Wolcott said issues could include: where should I/M apply, should I/M be the same everywhere, should RAMPs decide where it should apply? There are also some OBD issues. OBD is less intrusive than I/M and is hoped to lower costs. However, people may not get their car fixed when they see the light, and mechanics may not fix the right problem. Mr. Paisie added that the 2/19/97 control strategies exercise showed that work groups do support some kind of in-use mobile source program. The issue for this paper is what would an in-use mobile source program look like, especially under the new standards and proposed RAMP/AOI approach. Mr. Rawdon noted that vehicles can move in and out of AOVs and AOIs.

Mr. Huckabay was concerned about mobile source emissions being based on modeled results and not on actual conditions.

Mr. Ralston said heavy- and medium-duty I/M should be considered as potential strategies. Mr. Pezda suggested expanding I/M to address lawn mowers and chainsaws in addition to on-road.

Mr. Schoeneberg said re-entrained highway dust is a major PMfine source. Current estimates show that re-entrained dust overwhelms the tailpipe numbers.

Mr. Schoeneberg asked whether deterioration observations apply solely to hydrocarbons or to both hydrocarbons and NOx. Better hydrocarbon performance may come at the cost of increasing NOx. Mr. Wolcott was unsure whether the comments are pollutant-specific. He will look into it.

Mr. Ralston asked about the office of mobile sources (OMS) research into deterioration of heavy duty and light duty. Mr. Marin said one problem is the test cycles. The first step is to better instrument vehicles to find out what they are actually doing. NOx does not deteriorate much on heavy duty.