This is a preliminary summary. It has been placed on the bulletin board for comments and corrections by the Base Programs Analyses and Policies Work Group members. When their review is complete and this summary is in final form, this warning will be removed.

April 22, 1996, Corrected July 24, 1996

Summary

April 17, 1996 Base Programs Analyses and Policies Work Group Conference Call

I.	OVERVIEW

A conference call was held on April 17, 1996 to continue discussion on the draft issue paper on "Designation Criteria and Implementation Approaches for a New NAAQS".

II.	PARTICIPANTS

Work group:

Jerry Golden-Chair, David Baron, Vincent Brisini, Glen Cass, John Crouch, Steve Gerritson, Robert Kappelmann, Dennis Lawler, Arthur Lee, Callie Videtich for Dick Long, Bob Palzer, Steve Pezda, Richard Phelps, Jim Salvaggio, Greg Schaefer, Eric Skelton, Jean Vernet, Herb Williams, and Mel Zeldin

EPA members and staff:

Joe Paisie-Chair, Sharon Reinders-Team Lead, Tom Braverman, Lee Ann Byrd, John Chamberlain, Denise Gerth, Bill Hamilton, Miki Wayland, and Ken Woodard

Others:

Deidre Farrell for Alan Krupnick, Rebecca Battye, EC/R, Incorporated (EPA Contractor Support)

Work group members not in attendance:

Gregory Dana, Richard Dworek, Jeff Gabriel, Rich Halvey, Brock Nicholson, Don Pickrell, Jim Ralston, and Conrad Schneider

III.	ACTION ITEMS

1)	The next conference call will be on May 1, 1996 from 11:00 am to 12:30 pm, eastern time. The call-in number is (202) 260-7280, access code is 3872#; 50 lines are reserved.

2)	The Federal Advisory Committee Act (FACA) Subcommittee space is now on-line in the Technology Transfer Network (TTN) bulletin board. All work group members should provide Sharon Reinders with their user name so they may have upload capabilities.

3)	Steve Gerritson, Richard Phelps, Jim Ralston, and Eric Skelton have requested written comments on the draft issue paper "Designation Criteria and Implementation Approaches for New NAAQS". They will prepare a revised consolidated second draft. Work group members should send written comments to all four of the issue group members. Greg Schaefer will assist to add regional haze sugestions based on his experience with the Grand Canyon Visibility Transport Commission.

4)	A contractor is organizing the comments received on both the Interim Implementation Policy (IIP) and the outline for the advance notice of proposed rulemaking (ANPR) on implementation. Comments received by EPA on IIP will be distributed to work group members on or about May 1, 1996 for discussion at the May 7-8, 1996 meeting. Resolution of these comments will be the major purpose of the meeting.

5)	A volunteer is needed to work with Greg Schaefer on the new source review issue. If there are no volunteers, an assignment will be made by the next meeting.

6)	A copy of Steve Pezda's issue papers were distributed to the work group members. They were not received by Jim Salvaggio and Arthur Lee and will be resent.

7)	The WESTAR/PM-10 proposal can be released and will be distributed to all workgroup members soon.

8)	David Baron offered to send data from Phoenix to Steve Pezda.

IV.	MEETING SUMMARY

Information Update

1)	The next face-to-face meeting of the Base Programs Analyses and Policies (BPAP) workgroup is scheduled for May 7 and 8, 1996 in Research Trianble Park, NC. A location will be reserved in the near future. The meeting will run from 10 am to 6:30 pm on tuesday and from 8:00 am to 2:00 pm on wednesday. The work group will also meet on May 29, 1996. Information will be distributed in the near future.

2)	Next meeting of the full FACA Subcommittee is Thursday May 30, 1996 at the OMNI Hotel in Durham, NC. Meeting will run from 8:00 am to 5:00 pm. The Base Programs workgroup will meet all day on May 29, 1996, also at the OMNI in Durham, NC.

Communication Issues

May 7-8, 1996 Meeting

Joe Paisie provided an overview of the agenda for the May 7-8, 1996 meeting. A substantial number of comments have been received on the IIP and will be discussed during the meeting. The members are to develop recommendations/responses, find and bridge the gaps, and if possible, conclude the first issue paper. It's crucial to have a revised draft of both documents at the conclusion of the meeting. The goal is to deliver both of these documents to the Coordination Group in advance of the Subcommittee meeting scheduled for May 30. Updates on the ozone and PM NAAQS reviews will be on the agenda. Contractor support will be used to summarize the comments received and these will be distributed to the work group members on or about May 1, 1996. To maximize effectiveness, the meeting on May 7, 1996 start at 10 am and end at 6:30 pm. On May 8, 1996 the meeting will start at 8:00 am and end at 2:00 pm.

At this time there are no plans for other FACA work group meetings on May 7-8, 1996.

May 29-30, 1996 FACA Subcommittee Meeting

The next FACA Subcommittee meeting is currently scheduled for May 30, 1996 at the Omni Hotel in Durham, North Carolina. The BPAP workgroup will meet all day on May 29, 1996.

EPA Bulletin Board

The FACA Bulletin Board area is on-line. The public has full access to read and download posted information. Only the Subcommittee and work group members can upload information. All work group members should provide Sharon Reinders with their user name so they may have upload capabilities.

Issue Papers

A volunteer is needed to work with Greg Schaefer on the new source review issue paper. If there are no volunteers, an assignment will be made by the next meeting.

Steve Gerritson will put a revised version of the "Designation Criteria and Implementation Approaches for New NAAQS" issue paper on the bulletin board. He is looking for additional written comments.

Steve Pezda's issue papers on population weighting of monitors and on the use of a too close to call designation were distributed. There was discussion on whether population exposure is an implementation issue. Jerry Golden commented that the document was more of a position paper and not an issue paper. In its current form the document does not capture a broad range of options. Bob Kappelmann stated that all of the alternatives should be considered and then a reason provided for selection of one recommendation.

Issue Paper Discussion: Designation Criteria and Implementation Approaches for New NAAQS

Summary of Comments Received Steve Gerritson provided an introduction to the revised document. Despite the previous discussions, only two sets of comments were received, one from OAQPS/Joe Paisie, and the other from Mel Zeldin. He requested the other work group members to provide him with written comments. Eric Skelton received additional comments from David Chock and Steve Pezda. These two sets of comments were not received by Steve Gerritson or Richard Phelps.

Steve Gerritson summarized the comments received from OAQPS, mainly that the paper attempts to address too many issues. Specifically it should be refocused to the framework of designations: What is the purpose of the designation? What is the basis of the designation? and What is the size of the area that will be designated? These three themes will be gleaned out of the current document and the remaining issues will be addressed within other issue papers.

There was discussion on ensuring that these other issues are not overlooked.

Steve Gerritson had prepared some notes in response to the written comments he had received. He read the notes aloud.

"The background discussion will be expanded to include the role of transport in ozone, the uncertainties of PM-fine, and the possibility of interaction. Also discussed: The shortcomings of the current designation system, the pros and cons of using modeling in combination with monitoring to make designations, the need for data for PM-fine prior to making designations, and the need for incentives to expand the monitoring networks.

Designation Options:

For ozone:

option 1. Current system of designation where the violations occur, coupled with identification of sources as "planning areas".

option 2. Designation of "non-attainment sites" where the violations occur, coupled with regional "planning areas".

option 3. Designation of "attainment achievement areas", in which it is recognized that violations may occur.

option 4. Creation of additional ozone transport regions.

For PM-fine:

Recommendation: All areas begin as "unclassified." After two years, initial tentative designations made based on monitored data. (Questionable or "too close to call" areas remain "unclassified.") Data collection and modeling (if a model is available) continues.

option 1. Those areas which have an obvious problem after two years are designated non-attainment.

option 2. Those areas which have an obvious problem are designated as "research-intensive," with more monitoring and modeling (if possible) as well as mitigation required."

The above notes have not yet been reviewed by the other work group members.

The ideas raised a lot of discussion. Specifically, there are not a lot of options for PM. David Baron would like to include the option of assuming a percentage of PM-10 is PM-fine. Also, could areas with PM-fine data be designated right away? He is concerned that the present document will result in delay because years of monitoring data are needed prior to making a designation. Also this approach does not encourage monitoring.

Eric Skelton responded that Spokane has PM-fine data but there are problems. First, the data were not collected using a Federal Reference method. Second there is tremendous variability between the PM-10 and PM-fine measurements. One cannot draw a correlation from these data. One cannot project attainment or non-attainment for PM-fine based on their PM-10 data. Greg Schaefer reiterated the variability in the PM-10 versus PM-fine data. He read out some comparisons of the correlation of PM-fine to PM-10 data. For Denver it ranges from 12 to 87%, for Sheridan from 4 to 97%, for Phoenix from 11 to 54%, and for Wyoming from 14 to 86%. Eric Skelton would also like Steve Gerritson's paper to address additional options for PM.

There was a suggestion that PM-10 data could be used to set priorities. One could also look at the source mixes in PM-fine monitored areas to set priorities.

Steve Gerritson stated that some of these options were in the original paper and raised opposition from members during the last teleconference. He mentioned that there are not enough PM-fine monitors in the east. He also said the IIP addresses the concern about not making progress during the period when the PM-data are being collected. He requested written comments.

The discussion shifted to ways to encourage monitoring. Joe Paisie stated that as long as a non-attainment designation is perceived as a negative, it is a disincentive for monitoring. Vince Brisini stated that the OTC baseline recommendations for NOx included a set of protocols. That is, NOx monitoring data are used if available. In the absence of NOx monitoring data, a conservative emission factor estimate will be used. Designations are based on the most conservative estimates. Eric Skelton advocated the concept of a monitoring SIP. Under this scenario, States are required to set priorities on where and when monitoring will occur. Eric Skelton would like this concept added to the issue paper or developed as a separate issue paper.

Steve Pezda asked for caution prior to making a designation prematurely. An area exceeding the NAAQS may be the result of an upwind source. Joe Salvaggio said the basic focus of the issue paper should ensure that the designations are not too narrow. Don't exclude the effects of transport. David Baron stated that all PM-fine emissions are not due to transport, some is mobile sources and local combustion sources.

Vince Brisini also noted that other programs are resulting in reductions of the precursors. These reductions need to be recognized or acknowledged. Arthur Lee wants to be sure that the need for more data is recognized. Richard Phelps wants an analysis of source contributions. He points out that relying on existing data, and in the absence of a FR method for PM fine, is very speculative.

There was a general discussion on the availability of PM-fine precursor data and analyses of PM-fine emissions. David Baron mentioned that source specific data are available for Phoenix. He will send it directly to Steve Pezda. Greg Schaefer also has data that he could distribute. Mel Zeldin has a 1995 data set fully speciated for PM-fine that is almost ready for distribution. This data set shows spatial variation all across the LA basin. Based on an earlier comment, he mentioned that a small portion is sea salt in the monitored data but only at the 80-mile offshore platform site used to establish background.

Joe Salvaggio cautioned against using western data to explain what is happening in the east. LA is not representative of other areas.

Joe Paisie summarized some of the concerns that should be addressed. What is the purpose of the designation? What is the relationship between the source and receptor? How or should the designation reflect the situation where one area is causing downwind nonattainment but itself is 'attainment'? Is designation the only tool or is something else needed, for example the GCVTC or OTC.

Dennis Lawler suggested adding a discussion on whether the Clean Air Act allows these options. (Because the EPA has examined the Act and found it contemplates a variety of different options,) Joe Paisie suggested that the options and recommendations be defined by the work group first and then related to the Act.

A comment was made that visibility is missing from the issue paper. Greg Schaefer offered to assist based on his experience with the the GCVTC perspective.

The WESTAR paper can be released and will be distributed to all work group members soon.