2This is a preliminary summary. It has been placed on the bulletin board for comments and corrections from the Base Programs Analyses and Policies Federal Advisory Committee Act Work Group. When their review is complete and this summary is in final form, this warning will be removed.

June 14, 1996

Summary

May 1, 1996 Base Programs Analyses and Policies Work Group Conference Call

I.	OVERVIEW

A conference call was held on May 1, 1996 to discuss the issue paper on "Designation Issues for New NAAQS (Issues 1a and 1b) Revised Draft", dated April 25, 1996.

II.	PARTICIPANTS

Jerry Golden-Chair, Joe Paisie-Chair, David Baron, Vincent Brisini, John Crouch, Richard Dworek, Steve Gerritson, Robert Kappelmann, Dennis Lawler, Arthur Lee, Brock Nicholson, Bob Palzer, Steve Pezda, Richard Phelps, Jim Ralston, Jim Salvaggio, Greg Schaefer, Eric Skelton, Jean Vernet, Herb Williams, and Mel Zeldin.

Others:

Beth Friedman, EC/R, Incorporated (EPA Contractor Support).

Work group members not in attendance:

Glen Cass, Gregory Dana, Jeff Gabriel, Rich Halvey, Don Pickrell, and Conrad Schneider.

III.	ACTION ITEMS

1)	There will be a Base Programs work group meeting on May 7 and 8, 1996 in Research Triangle Park, NC.

2)	The next teleconference will be on May 15, 1996 from 11:00 am to 12:30 pm, eastern time. The call-in number is (202) 260-7280, access code is 3872#.

3)	Any work group members that have not sent Sharon Reinders their name and password should do so to receive EPA TTN Bulletin Board upload access. Ms. Reinders will send work group members detailed instructions on TTN access and provide an e-mail "heads-up" of uploads to the Base Programs bulletin board area.

IV.	MEETING SUMMARY

Information Update

1)	Sharon Reinders asked for comments on the March 20 and April 3 conference call summaries. Some members requested more time to review the summaries before they are finalized.

2)	Sharon Reinders asked if any work group members objected to the placement of the results of the work group member survey on the TTN. There was an objection, so the summary will not be placed on the TTN.

3)	The EPA will send the summary of comments received on the draft interim implementation policy to work group members by the end of the week.

4)	Sharon Reinders asked if any of the work group members will not be able to attend the May 7 and 8 meeting in North Carolina. Eric Skelton said he would be unable to attend. Ms. Reinders added that Glen Cass will be absent as well.

Communication

EPA Bulletin Board Access. Jan Kleeman, who is the EPA team leader for the Communications and Outreach Work Group, and Phil Dickerson were available to answer Base Programs Work Group members' questions on use of the EPA bulletin board (via the TTN). There was a general discussion of specific problems. Sharon Reinders will send work group members detailed instructions on TTN access and provide an e-mail "heads-up" of uploads to the Base Programs bulletin board. Mr. Dickerson said that by June or July the public would be able to access the TTN through an internet web page. Mr. Dickerson can be reached at (919) 541-4814 for specific questions.

A suggestion was made that text uploads be made in Wordperfect 5.1 and other EPA-approved software (e.g., Lotus), if possible, to ensure that documents can be easily downloaded.

Issue Paper Development Process

Joe Paisie and Jerry Golden presented a table listing issues, authors, and an issue paper development timeline. They noted that meeting the proposed schedule presents a significant challenge. They requested comments from members on the proposed process. Mr. Golden added that the tight timeline will require members to make comments on individual issue papers directly to the authors.

Steve Pezda asked how a proposed rule will affect implementation issues. Jerry Golden said the issue of the overall schedule versus the Interim Implementation Plan (IIP) will be an issue for the May 7 and 8 meeting. Joe Paisie will provide an update on the ozone and PM NAAQS at the meeting. Sharon Reinders said that because the proposal on implementation follows a year after the proposed rule, the affect on development of implementation issues should be minimal.

Issue Paper Discussion: Designation Issues for New NAAQS (Issue Number 1a and 1b), April 25, 1996

The April 25 revised draft of the issue paper, "Designation Issue for New NAAQS" represents consensus by all but one of the subgroup members. As a result of Base Programs Work Group members comments, the revised draft reflects a focus on nonattainment designations and the size of the nonattainment areas. The document was also reorganized by pollutant. Regional haze has not been addressed.

There was a general discussion of the issue paper process. Should the issue paper be refined to narrow down the options and make recommendations? When is the issue paper complete?

Jim Salvaggio suggested looking at options related to state-by-state SIP planning. There is also a need for broad regional looks at planning. Steve Gerritson agreed the paper should address possible planning mechanisms such as memoranda of understanding, EPA's section 110 authority, or OTAG. Jerry Golden said nonattainment areas would be able to look upwind to identify other area's affecting them via transport. Mr. Gerritson said the current options stop at identification, and an enforcement mechanism is lacking. One member noted that OTAG is a "gentlemen's agreement," and EPA will need to use section 110 or 126 authority to get action. He asked whether changes to the Clean Air Act are needed to enforce interstate cooperation. Other members noted that the discussion of mechanisms is beyond the scope of this issue paper. Joe Paisie suggested adding a placeholder for mechanisms to look at broader geographical areas.

There was a discussion of the use and quality of data in designation decisions. One member noted that PM data should take more into account than monitoring mass. He said speciated component data are needed. Eric Skelton said speciated information is useful, but he does not see how they affect designations, which would be based on the NAAQS. Joe Paisie said speciation data would be needed for planning attainment strategies. Steve Gerritson said whether the standard is appropriate is not an issue for this paper. He added, gross PM is a surrogate for what happens in the lungs. He agreed with another member that PM data affect how big an area should be, and this is referred to in general in the analysis.

David Baron made several comments. He was concerned that the paper has a heavy focus on the problems of monitoring and not enough of the advantages. He said more detail is needed for the PM option 1 about how and what existing data would be used. The size of nonattainment areas needs to be fleshed out further. For example, what about the size of an area where violations occurred? Will the size continue to be based on the consolidated metropolitan statistical area?

One member was concerned that the system of monitoring every six days would lead to one exceedance on a monitored day equating with 6 exceedances for the period.

Brock Nicholson suggested a two-tier system for addressing transport. A two-tier system would address the political problems of addressing a large transport area. He suggested Ozone option 2 include the idea of an assumption of OTAG-like efforts to implement. Joe Paisie said it is important to determine how the responsibilities differ at the local and regional levels.

Jim Ralston supports the focus of the issue paper, and said EPA has a number of mechanisms to implement regional strategies; e.g., PSD, NSPS, and automobile standards. Vincent Brisini noted most of these programs have no affect on existing and newly designated sources.