Draft Summary

Base Programs Analyses and Policies (BPAP) Work Group Meeting

Durham, North Carolina

May 15 and 16, 1997

I.	PURPOSE

The BPAP work group held a face-to-face meeting on May 15 and 16, 1997 in Durham, North Carolina. Two sessions were held jointly with the National and Regional Strategies (NRS) work group.

The BPAP work group discussed the Control Strategies (5/9/97 draft), Treatment of Areas in Which Air Quality Trends Indicate the Risk of Becoming an Area of Violation (AOV) (5/9/97 draft), Phase II Implementation Strategy for Contingency Measures/Maintenance Plans (5/14/97 draft), New Sources: Considerations for the Implementation of New Air Quality Standards/Regulations Phase II Issues (5/13/97 draft), and General Mobile Source Measures (4/4/97 draft) issue papers. An update on the Environmental Protection Agency (EPA) white paper that had been presented at the April 8 and 9, 1997 Federal Advisory Committee Act (FACA) Subcommittee meeting was also given.

During the joint BPAP/NRS work group session, the Control Strategies issue paper and the national ambient air quality standards (NAAQS) Implementation Process diagram were discussed.

II.	PARTICIPANTS

Attendees:

Jerry Golden, Co-chair, Joe Paisie, Co-chair, Betsy Bartlett for Jim Ralston, Vincent Brisini, Richard Chastain, Dick Dworek, Steve Gerritson, Rich Halvey, John Crouch (via telephone), Dennis Lawler, Arthur Lee (via telephone), Barbara Lee (via telephone), Richard Long, Bill Luneburg, Arthur Marin, Chuck Mueller for Herb Williams, Brock Nicholson, Bob Palzer, Steve Pezda, Rick Phelps, Jim Salvaggio, Greg Schaefer, Eric Skelton, and Jean Vernet.

Work Group Members Not in Attendance:

David Baron, Gregory Dana, Jeff Gabriel, Robert Kappelmann, Richard Schoeneberg, and Mel Zeldin.

Other Attendees:

Bill Battye, Rebecca Battye, Beth Friedman, Wendy Vit and Steve Walata, EC/R Incorporated (EPA contracter support)

III.	ACTION ITEMS

The next BPAP conference call will be held on May 28, 1997 from 11:00 - 12:30 Eastern Time.

The next draft of the Phase II Implementation Strategy for Contingency Measures/Maintenance Plans paper, which will incorporate comments from this meeting, will be ready before May 28, 1997.

The next BPAP work group meeting will be held on June 9, 1997 in Durham, North Carolina. Tentatively, the General Mobile Source Measures paper will be discussed, and a representative from the Transportation FACA will give a presentation. In addition, presentations to be delivered to the FACA Subcommittee on June 10 and 11 will be briefly reviewed. Unless members feel a strong need to meet jointly with NRS, the June 9 meeting will not be a joint work group meeting.

Treatment of Areas in Which Air Quality Trends Indicate the Risk of Becoming an Area of Violation (AOV), Phase II Implementation Strategy for Contingency Measures/Maintenance Plans, and the NAAQS Implementation Process diagram are scheduled to be presented at the June 10 and 11, 1997 FACA Subcommittee meeting.

Papers being presented at the June Subcommittee meeting must be posted on the technology transfer network (TTN) bulletin board no later than June 2.

A BPAP face-to-face meeting may be held in July. This is very tentative.

IV. MEETING SUMMARY

MAY 15, 1997

BPAP Work Group Session

Control Strategies (8:15 - 9:30 a.m.)

Ms. Vernet reviewed the Control Strategies issue paper.

Question 2.1. What is the appropriate mix of prescribed and discretionary measures to achieve a required air quality objective?

Mr. Salvaggio commented that as we move forward to regulations, especially for ozone, prescribed measures create local opposition. Locals react differently to something they are told to do, as opposed to the measures for which they provide input during development. A prescribed measure may not be applicable to local variables. Some measures are less effective in Philadelphia than in Pittsburgh, for example. Prescribed measures may end up being disruptive rather than providing air quality benefits.

The group discussed the hypothesis for question 2.1. Mr. Halvey asked why the "as expeditiously as practical" phrase had been added to the first sentence of the hypothesis. Mr. Marin argued that the phrase is necessary, citing the example of fuel strategies. Implementing six different fuel strategies in different areas does not make sense. Mr. Pezda agreed. He gave another example of a county that wants its own mobile source standards. He does not care what the specific words are as long as the concept is retained. Mr. Paisie said if the phrase is stricken, the hypothesis presents nothing more than business as usual. Mr. Keithley contended that the system has worked in the past. Local problems have been solved by local solutions based on a menu of options offered in guidance. Ms. Vernet said this option is in the paper.

Mr. Salvaggio said the Clean Air Act (CAA) has been very successful in reducing ozone. Public exposure to ozone has been substantially reduced in Pennsylvania. The question is how to reduce the remaining or residual ozone. Programs like Reformulated Gasoline (RFG) and Inspection and Maintenance (I/M) have been extremely difficult to implement.

Mr. Palzer commented that prescribed measures are based on air quality considerations. If the work groups support the hypothesis, they are ignoring the original working assumptions. He disagrees with the hypothesis. Ms. Vernet clarified that the working assumptions suggest that flexibility is key. Mr. Salvaggio said the fact that the work group is debating this shows that the work group has not reached closure on this issue. Mr. Palzer's concern about ensuring that things are done should be addressed.

Mr. Halvey said backstops are needed. In the 1970's the whole process was simply not sophisticated enough. It is hard to argue that I/M has been a success. In the West, if I/M had been on the list of items from which States could choose, States would have seen that it was the only approach. A choice may have been more palatable to States throats. He suggested adding "subsequent to the implementation of national strategies" after "greatest extent practical." Mr. Paisie said that is part of the timing issue.

Mr. Paisie commented that the control strategy development process is described as being very sequential. How could it be done in a more parallel fashion? Ms. Vernet said question 3 addresses this.

Mr. Marin said it makes more sense to talk about prescribed reductions instead of prescribed measures. What is the distinction between prescribed and discretionary measures? We're talking about what is left over after national measures have been implemented. A prescribed reduction should be established first. Then States would have discretion to meet the target.

Mr. Luneburg commented that all of the work group's concerns are addressed later in the paper. Focusing on the wording is wasting time. "To the greatest extent practical" can mean anything to anyone. He suggested moving on to the options and to pros and cons. Ms. Vernet responded that she was just alerting the work group to Dan Johnson's reliance on this hypothesis for questions 1 and 2.

Mr. Skelton said "to the greatest extent practical" is a big nothing. It does not make any difference to the hypothesis. Discretion is great as long as it is not abused. He interprets the hypothesis as: if an area abuses discretion, it loses it and prescribed measures fall into place.

Ms. Vernet said the comments she has been hearing are contained in the options. She suggested that during this two-day meeting, work group members make sure all the options have been identified.

Mr. Dworek endorsed the concept of flexibility and supported the language in the hypothesis. He gave an example of seven sulfur dioxide (SO2) monitors that have showed noncompliance in the past but now show compliance. The locality has asked EPA for permission to spend money on 2.5 particulate matter (PM2.5) monitoring instead of on maintaining their SO2 monitors. Planners and sources should have the maximum flexibility. He favored option 8, which suggests that planners and source owners would choose the measures.

Mr. Palzer said a list of national and prescribed measures has been developed. He hopes the work groups are not considering abandoning the measures that have already been enacted or scheduled to be enacted.

Mr. Schaefer said the working assumption "Class I areas should be treated as AOVs" is showing up in more and more issue papers. This assumption has many implications that work group members should think about.

Mr. Paisie commented that if option 7 (prescribed measures coupled with classification bump-ups) is recommended by the work groups, it would require a classification scheme. The question of how the classification system should be designed is another story.

Mr. Palzer said option 6 (reasonably available control technology/reasonably available control measures (RACT/RACM) type prescription applied to some or all sources) will need some criteria to determine "some." He wanted it noted that there will be some basis for determining which sources would be affected.

Mr. Luneburg was concerned that several subissues are evident in the options. The list of options is not logically arranged. Some options focus on whether prescribed measures should be established, others address how much prescription, and still others focus on the basis for prescription.

Question 2.2. What factors should be considered when selecting specific prescribed measures?

Mr. Halvey noted that some source categories are prohibited from being regulated. States cannot develop their own mobile source standards, for instance. Shouldn't this be a factor? Ms. Vernet replied that legal constraints would be a con for some of the options.

Mr. Paisie asked how EPA would use the criteria. Ms. Vernet said the Control Strategies subgroup and the work groups may evaluate the measures listed in the Opportunity Matrix using the criteria. This qualitative assessment would categorize the measures as being good or not-so-good national/prescribed measures.

Mr. Gerritson commented that factors 2 (amount of emission reduction feasibly achievable) and 7 (predictability of emission reduction) seem to be the same thing. Ms. Vernet said they are distinct concepts, but perhaps they are not worded correctly.

Mr. Pezda suggested adding "achievability of the standard" as a factor. Mr. Gerritson agreed. Areas should be sure that the measures they implement have a positive effect on the pollutant they are trying to control.

Mr. Palzer said cost-effectiveness by itself does not mean a lot. It does not adequately capture spatial extent, pollutant mixture, and other air quality parameters. For instance, a problem that surrounds one site is very different from a problem that is evident throughout an entire area of influence (AOI). He requested that "cost/benefit-effectiveness" be added. Ms. Vernet replied that factor 5 (extent to which more than one pollutant reduced or ambient problem addressed) addresses multiple pollutants. Mr. Halvey thought cost-effectiveness would be part of the disbenefits in factor 6 (amount of disbenefit "costs"). Mr. Pezda said "cost-effectiveness" is different from "cost/benefit."

Mr. Brisini observed that if cost-effectiveness is based on dollars per ton, factor 6 is needed. However, if cost-effectiveness is based on air quality benefits, factor 6 is not needed. Mr. Luneburg said he may have been responsible for factor 6. Factor 6 is intended to mean air quality disbenefits caused by a particular control strategy, not economic costs. That is why "cost" is in quotes.

Mr. Marin suggested four additional factors: 1) legal authority; 2) timing of reductions (e.g., phase-in, turnover); 3) compatibility with existing controls; and 4) harmonization. One member responded that legal authority may not fit. The legal authority issue would be decided before the list of factors is utilized. Ms. Vernet said the legal authority issue pertains to EPA's authority to prescribe measures in the AOI or other multi-jurisdictional domains.

A member suggested considering economic incentives. This should be a separate issue not a factor.

Mr. Paisie noted that coming up with all possible factors is a daunting task.

Control Strategies -- Joint Session with NRS Work Group (9:45 - 11:00)

Question 2. Should there be minimum requirements imposed as additional prescribed measures common to some or all areas for control (e.g., final AOI, preliminary AOI, area of violation (AOV), other domains)? If so, which measures should be adopted, where should they be applied, and on what basis will the measures be determined?

Dan Johnson said national measures could be viewed as a special case of prescribed measures or vice versa. Since questions 1 and 2 are two spins on the same question, perhaps only one of them needs to be discussed at length. He proposed the following approach to question 2: 1) start with the notion that complete discretion is preferred; 2) determine which national measures overcome the shortcomings of discretionary measures; and 3) determine which controls make sense to apply based on an area's air quality. He asked if this same thought process should be used to address question 1.

Mr. Salvaggio objected. National measures should have a benefit for most areas. On the other hand, prescribed measures are those that are especially effective in a particular area, such as I/M and trip reduction.

Joe Belanger said that the ozone transport assessment group (OTAG) adopted a list of recommended national measures yesterday. He will distribute copies of the list.

Question 2.1. What is the appropriate mix of prescribed and discretionary measures to achieve a required air quality objective?

Mr. Johnson explained that the hypothesis for question 2.1 was developed because he felt the mission statement contains too many degrees of freedom. The hypothesis was formulated based on the content-related principles, which, taken as a whole, suggest that flexibility is good. Once the work groups approve the hypothesis, he will transform it into a working assumption.

He said beginning with the hypothesis, work group members should use the following approach to this question: 1) determine what is wrong with complete discretion; 2) evaluate prescriptive options that address those weaknesses; and 3) rank the options by increasing prescriptiveness.

Mr. Palzer commented that the hypothesis is bogging down the work group discussions. He suggested bypassing the hypothesis and getting into the criteria and other issues. Work groups could then re-visit the hypothesis if needed. In addition, the hypothesis conflicts with the original definitions. Based on the BPAP's earlier discussion, Mr. Paisie recommended leaving the hypothesis on the table and modifying it later as needed. He cautioned that the work groups can spend all their time word smithing the hypothesis without getting into the substantive issues.

Mr. Gerritson offered an argument against complete discretion. Prescriptive measures level the playing field and bypass the political process.

Sarah Peirce-Sandner supported the hypothesis. First, complete prescription would eliminate a customized reasonable further progress (RFP) process. In addition, the hypothesis is balanced in that discretion would be allowed as long as attainment is achieved in a timely fashion. Finally, all problems cannot be characterized in three or four different airsheds, particularly PM-fine problems. Complete prescription may not work. Problems should be solved in a cost-effective manner.

Mr. Johnson said the hypothesis would be tabled for now.

Question 4. How should the situation be handled where national measures are not implemented, or are not timely? What is the consequence to the regulatory agency (e.g., sanctions)?

Jon Heuss has proposed an additional sub-question: what happens if original estimates of prescribed and discretionary measures are not correct? Mr. Gerritson gave the architectural regulation/negotiation as a clarifying example. The EPA initially provided States with a certain emissions reduction target. The ultimate emission reductions were not as great as projected, and States had to make up the reductions. Ms. Vernet said the case exemplified a failure of the EPA. The federal estimated target was not met.

Question 5. For areas of control that involve multiple jurisdictions (e.g., interstate/intertribal/state-tribal), what process and criteria should be used by the responsible planning body in assessing the mix of controls (national, regional, State and local) to be included in the regionally integrated plan?

Chris Shaver said question 5 should be restated to indicate that the mix of controls could be in the regional implementation plan (RIP) or in the State implementation plan (SIP).

Mr. Dworek suggested adding equity as a criterion for assessing the mix of controls. For instance, sources in Pennsylvania may have more stringent requirements than those in neighboring States. The sources should meet the same level of control. Ms. Shaver replied that equity is a factor which could be defined at the local level. Mr. Chastain said concepts of equity and leveling the playing field are over-arching. This question may not be the place to incorporate them. He views equity as treating sources commensurate with their contribution to a problem.

In response to Mark Brownstein's comment, Ms. Shaver said this question was difficult because her group did not know whether the decision process should be top-down or bottom-up. She said Mr. Brownstein's suggestion of a bottom-up process was fine.

Mr. Brisini commented that the work groups have different views of what the roles of the various planning bodies should be. Question 5 should be linked with the Institutional Mechanisms paper. The options attempt to delineate the role of the planning body, and this goes beyond their intent. He objected to the implication in the last sentence of option 1 that States would develop control strategies for the RIP. Ms. Shaver acknowledged that "RIP" should be stricken from the sentence because the RIP/SIP issue should not be dealt with here. She will insert "states/tribes within the area for control." Mr. Brisini was fine with the change.

Mr. Paisie said this paper should stick to the definitions that have already been agreed upon in the 2/13/97 Regional Air Management Partnerships and Areas of Influence paper. Mr. Johnson said the subgroup decided up front not to re-visit the final AOI discussion. They purposely chose a neutral term -- "areas for control."

Mr. Heuss asserted that the Control Strategies paper should be tied to the Modeling and Inventory Requirements paper to lead to more specific answers. The Control Strategies paper will need to get into technical issues, such as emission budgets, transport, and the roles of different pollutants.

NAAQS Implementation Process -- Joint Session with NRS Work Group (11:00 - 12:00)

Mr. Golden said the diagram was an attempt to bring together concepts from all issue papers. He emphasized that some ideas do not represent work group consensus. The RFP diagram and prevention of significant deterioration (PSD) concepts have not been incorporated yet.

The diagram builds on a two-tiered classification system proposed in the Classifications issue paper. The classification scheme would differentiate between areas where transport is critical and areas where the problem is predominantly a local one. Mr. Golden believes most areas will fall into the transport-dominated classification.

He presented the version of the diagram that had been discussed on the May 7, 1997 BPAP conference call. The diagram had been color-coded to highlight areas of controversy (orange) and to indicate changes suggested on the BPAP call that he had not made yet (blue).

Mr. Belanger commented that an area at risk would be akin to an AOV in the transport path. An arrow or a decision block from the at-risk loop should feed into the transport-dominant pathway. Areas that are at risk and downwind should have a right to participate in the upwind regional air management partnership (RAMP) process just as the AOV does. Mr. Doumas clarified that national measures would help keep an area at risk from becoming nonattainment. Mr. Golden added that voluntary measures could be used as well. Areas at risk are areas that are not significant enough players to have mandatory controls but are close enough to a violation to be at risk.

Ms. Peirce-Sandner likes that the papers have been pulled together. However, she is concerned about areas that initially determine their problems to be locally generated but down the road get pulled into an AOI with additional requirements. In addition, the diagram indicates that prescribed measures would be implemented before AOIs and RAMPs have been set up. Monitoring and speciation will be occurring around the same time as the AOIs and RAMPs are being established. She is concerned about the implication that controls would be implemented before adequate speciation and monitoring. Mr. Golden agreed. He explained that the intent is to suggest that to the extent measures that make sense in nearly all circumstances (e.g., nitrogen oxide (NOx) RACT or vapor recovery) but have not been implemented in all areas can be identified, they should be pursued.

John Silvasi thought the Too Close to Call paper had been tabled. Mr. Golden said it had been, but several BPAP members still support the concept.

Mr. Silvasi asked why the progress requirement only applies when attainment is infeasible. This is inconsistent with the RFP paper. A sub-subgroup of the RFP group is addressing attainment feasibility, and there is substantial resistance to the concept. Mr. Golden said the intent was not to set a firm attainment date but to require continuous progress.

Mr. Brownstein observed that national measures kick in at the beginning of the process. The diagram should loop back in midcourse so that additional national measures are on the table as policy options. Mr. Golden did not think the RAMPs would develop control measures. Mr. Johnson said if several RAMPs indicate that they need a particular measure, it may make sense to implement the measure nationwide.

Mr. Brownstein said the diagram shows that national measures will be considered in developing local plans. The measures are developed from a top-down approach with EPA deciding. Why preclude measures from being developed from the bottom-up? Many local measures may create jurisdictional commerce issues that cold be addressed by a national measure. For example, the automobile industry concluded that developing the 49-state car would make more sense than creating separate vehicle emissions standards for individual States. Mr. Belanger clarified that Mr. Brownstein's idea would be an additional set of national measures apart from those established up front. Mr. Golden asked how long it would take to develop national measures through a grass-roots effort. He does not see this working from a timing perspective.

Ms. Bartlett said "barely violating" would be a more accurate term than "too close to call." The area is still a nonattainment area. Areas that are barely over the nonattainment mark could potentially petition to get out of nonattainment status when they see what national measures are coming. Mr. Golden responded that the approach in the diagram differs from the rigorous statistical test proposed in the paper.

Norm Fichthorn asked if the "Prescribed Measures Menu 2" box feeding into "Develop SIPs" means that prescribed measures are already in place or that the local/state authorities have a choice. Mr. Golden replied that if a prescribed measure is in place, it is in place. If not, the local/state authority would implement the measure or substitute a measure yielding equivalent air quality benefits. Where effective and cost-effective measures can be identified, areas should implement them. The Progress During SIP Development paper is addressing whether these measures should be in place before the new SIPs.

BPAP Work Group Session

NAAQS Implementation Process (1:30 - 2:30)

Mr. Paisie proposed that the NAAQS Implementation Process diagram be presented at the June FACA Subcommittee meeting as a recommendation for the Classifications paper. Going forward with the flow diagram could help the work groups reach closure on some of the issue papers.

Mr. Crouch noted that the diagram assumes that the AOV is equivalent to the Control Region. Mr. Golden replied that the diagram assumes the AOV with local contribution is in the Control Region.

Mr. Chastain suggested three types of areas: 1) AOV; 2) primary control area; and 3) secondary control area. The primary control area would be similar to the existing nonattainment area, and the secondary control area would be like the AOI. Ms. Vernet said the Control Strategies issue paper captures the concept in the term "Areas for Control." Mr. Marin cautioned against using generic approaches such as the two rings option. The decision should be left up to the RAMP.

Mr. Golden said the issue of how to define the geographic boundaries of the AOV is still on the table. Mr. Schaefer recommends defining the AOV as small as possible in order to emphasize the AOI and to allow maximum flexibility. Mr. Palzer said areas that are not violating the standard should not assume they will not be subject to mandatory measures.

Mr. Skelton asked about the "all feasible measures tried?" test. Mr. Golden replied that the area would still be in the planning phase so a better phrase would be "what reasonably can be included?" The progress requirement in such cases would be emissions- or ambient- based, and the planning process would resume. Mr. Marin commented that "feasibility" is very subjective and open to abuse. Mr. Golden said EPA would be the arbiter of feasibility.

Mr. Luneburg was concerned about the lack of attainment dates. Mr. Paisie said the diagram does not take a position on attainment dates.

Mr. Chastain asked who would decide if a problem is predominately caused by transport. Mr. Skelton responded that the Classifications does not get into that level of detail.

Mr. Skelton commented that contingency measures should be added to the diagram. Contingency measures should be initiated after "Progress Meets Plan" and before sanctions.

In response to Mr. Lawler's question, Mr. Golden explained that the dashed line on the first page indicates that emission inventories may need to be adjusted after national measures are promulgated. Mr. Mueller was concerned that the dashed line would preclude States from taking credit for national measures. Ms. Vernet said the flow chart should acknowledge that national measures may be identified and implemented throughout the process, as opposed to national measures being a one-time decision. Mr. Lawler added that national measures might be implemented in two phases. RAMPs could recommend national measures. Mr. Paisie said the CAA Amendments obligate EPA to issue some national measures. Mr. Marin provided examples of Title II national measures that were not mandated.

Mr. Golden drew a line on the diagram which linked areas at risk with the RAMP process. This was in response to Joe Belanger's comment in the earlier joint session. Mr. Chastain said the Areas at Risk paper includes other options. Mr. Brisini said the RAMPs will be very large and will include all areas. The question is should a potential AOI be defined for the area at risk. Mr. Pezda said the Areas at Risk paper is being stretched beyond its original scope. The paper just talks about voluntary measures, but the work groups are discussing mandatory measures for areas at risk. Mr. Palzer suggested changing "voluntary" to "proactive" on the flow diagram.

Ms. Bartlett suggested substituting another phrase for "too close to call." Mr. Phelps proposed "indeterminate."

Areas at Risk (2:30 - 3:30)

Mr. Chastain summarized the key points in the issue paper Treatment of Areas in which Air Quality Trends Indicate the Risk of becoming an Area of Violation. The basic premise of the paper is that areas at risk should be encouraged to take steps to avoid possible violations in the NAAQS. Issues related to how the area at risk is identified are technical and are not addressed in the paper. Instead, Mr. Chastain said the May 9, 1997 version of the issue paper is structured to highlight the issues associated with voluntary versus mandatory requirements for areas at risk and the pros and cons of each approach.

Mr. Luneburg noted that there is existing legal authority under the CAA obligating States to maintain the standards. The paper should acknowledge this obligation, and at a minimum, require some advance planning. In addition, 1970's court decisions resulted in requirements for the States to do proactive planning. The PSD program is an example of proactive treatment as well. Mr. Paisie noted that part 51 has been largely purged of any planning requirements for attainment areas, because they have never been used. Instead, the SIP is the vehicle for this sort of planning. Several members questioned the authority of EPA to place requirements on areas that have not violated the standards.

Mr. Halvey said an additional disadvantage of a mandatory approach is the limitations that some States have in exceeding Federal requirements. Mr. Chastain noted that the limitation could take two forms. In the first, some States may be precluded from issuing State rules that are more stringent than existing Federal requirements. In the second, in the absence of a Federal requirement, the State cannot develop independent State requirements. Mr. Halvey suggested that the EPA's Office of General Counsel (OGC) needs to review this issue. Mr. Paisie said that the burden is on the States to satisfy the CAA, and that resolving conflicts between State law and EPA regulations is a State issue, to be resolved in State courts. Mr. Luneburg said that it is important to empower the States to take action. He felt that help needs to be given to those States with limitations. He also worried that short-term political considerations would override more common sense, proactive approaches. He felt that at least minimal planning should be required.

Mr. Luneburg said that there can be degrees of mandatory measures. Mr. Halvey suggested introducing an intermediate option of a mix of voluntary and mandatory measures. Mr. Schaefer was concerned that this sort of option would still result in an effective tightening of the standards. Mr. Gerritson said that any imposition of mandatory measures beyond planning and modeling effectively does away with the standard altogether.

There was considerable discussion about whether the work group should explore mandatory measures. Members agreed with the fundamental need to perform some sort of planning but did not agree on the actual measures that should be taken to implement proactive strategies. Mr. Salvaggio said if EPA were to monitor areas at risk and provide an "alert" to the Governor, this action would allow the State to take subsequent action. In contrast, without this level of EPA involvement, it is difficult for some States to say they "should" take on a new program. Mr. Salvaggio said that he is very uncomfortable with any sort of incentive package, and would favor an option between 1a (no new programs) and 1b (initiate programs to encourage and guide voluntary efforts) provided feedback to the State is provided. Mr. Lawler agreed and added that EPA's feedback might be better received at the level of the State environmental office compared to the Governor's office.

Mr. Brisini said that he favors option 1b (initiate programs to encourage and guide voluntary efforts). He added that changes in the averaging time and form of the standards could significantly remove the potential for areas to move in and out of attainment. Because trends in air quality should be easier to identify, voluntary programs should be sufficient and areas will have plenty of incentives to keep their attainment status. Mr. Schaefer also favored option 1b because it provides incentives for States to complete the process of addressing areas at risk.

Mr. Nicholson and Ms. Bartlett said that EPA should not go beyond providing tools for the States to use in addressing areas at risk. Mr. Nicholson, Mr. Mueller, and Mr. Salvaggio provided examples of where their States had supported development of voluntary programs. They felt the success of these programs depended on the relative nongovernmental, noncoercive nature of the programs. Ms. Bartlett suggested that an acceptable incentive could be for EPA to provide additional funding to support the voluntary programs.

Mr. Palzer said that preventing the creation of nonattainment areas is as important as fixing the problems in existing nonattainment areas. He would not want to preclude mandatory measures. Mr. Luneburg said that the paper should focus on the requirements to at least conduct planning. However, Mr. Schaefer noted that if the group cannot reach consensus on the basics of a voluntary program, all of the benefits of the areas at risk concept will be lost. He said that the environmental community would lose public notice of areas at risk, trends analyses, and other incentives to be at the table. Mr. Lawler added that this issue is not a major one for the FACA. He suggested it would be better to do what good is possible, and leave the rest on the table. Mr. Nicholson noted that he would not preclude a "mandatory" measure that came out of a voluntary program.

Mr. Palzer noted that he preferred the shorter title given to the paper in the presentation slide: Treatment of Areas at Risk of Violating NAAQS. Mr. Chastain that the longer title is more appropriate because it includes the concept of "trends," which is needed to differentiate between this paper and the "too close to call" concepts.

Mr. Gerritson asked how the areas at risk program would differ from the implementation of contingency measures. Ms. Videtich replied that areas of risk are not nonattainment areas, whereas contingency measures would be applied in current or recent nonattainment areas.

Mr. Long said that the inclusion of Attachment A, Summary of Kootenai County (Idaho) Memorandum of Understanding (MOU), is not appropriate because the county was in violation but had not been redesignated. In addition, the MOU was not implemented.

Mr. Luneburg discussed the differences in terminology between voluntary and mandatory versus prescribed and discretionary, and suggested a footnote to clarify their use.

Mr. Phelps said the paper should address the overall scope of the problem. How many areas at risk are possible? Mr. Chastain replied that this is a technical issue and should be directed to the Science and Technology work group. He added that if the options are limited to voluntary programs, the line defining an area at risk can be "fuzzier."

Contingency Measures (3:45 - 5:00)

Mr. Skelton reviewed and summarized the Phase II Implementation Strategies for Contingency Measures issue paper. This is a joint issue paper with the NRS work group, and reflects comments by the issue paper subgroup members on the April 28 draft. Changes include dropping the discussion of maintenance plans because none of the currently identified issues relate to maintenance plans specifically. Issues 1-4 are largely the same. Issue 5 is proposed to be replaced with issue 15.

Mr. Luneburg said that issue 1 (Can contingency measures be episodic? Can episodic contingency measures be included in the core measures for the SIP?) should be rephrased as a "should" question rather than a "can" question to reflect the fact that this is a policy issue rather than a technical or legal issue. He also noted that episodic controls can take one of two forms. Episodic controls may be seasonal restrictions, which are probably legal under section 123. However, the second type of episodic controls, which are based on production cutbacks, are probably not permitted under the CAA because they are not considered enforceable. He added that the disadvantage of episodic controls is that there is considerable difficulty in determining when they are needed. Mr. Paisie said that EPA's stack height regulations make allowances for residential wood combustion, and are an example of episodic controls for PM. However, there are no exemptions for ozone episodic controls. He added that EPA has approved seasonal controls in implementation plans. Mr. Nicholson stressed the importance of providing a wide range of tools to high-growth areas, including episodic controls. While enforceability is an issue, he suggested that there could be simple triggers for episodic controls such as the temperature.

Mr. Luneburg suggested that issue 2 (Can contingency measures be voluntary?) should be rephrased as a "should" question too. He said that voluntary measures have not been creditable traditionally and there may be legal restrictions, which should be acknowledged in the issue.

Issue 6 was reduced to a single question: Could a contingency measure be used to expand the area of an AOI and broaden the applicability of the control measures? Mr. Skelton noted that any expansion would have to go through the RAMP, which would be a disadvantage of allowing this option. Mr. Marin added that this sort of expansion would present a timing issue because of the lengthy process that would be required to implement it. Mr. Nicholson said that some measures could be sub-AOI and that a logical extension would be to expand the controls to the entire AOI.

Mr. Skelton said that issue 7 had been rephrased as follows to eliminate the first question: Should contingency measures be required for PMfine as well as ozone and PM10? It is obvious that a general endorsement of the concept would mean that it would apply to PM-fine. Mr. Schaefer commented that the remaining issue (Will contingency measures be required for Class I areas for visibility purposes?) implies a visibility standard. In fact, the requirement is a goal to improve visibility. He questioned the need for contingency measures for something that cannot be violated. Mr. Skelton said the intent of the issue was to raise visibility as an issue. Mr. Paisie suggested that a placeholder might be appropriate in place of the specific issue.

Issues 8, 9, and 10 are proposed to be moved to other issue papers or were determined not to be needed. Mr. Skelton said that issue 11 (How much emission reduction is required for contingency measures?) was proposed to be eliminated because the answer is obviously "enough." Mr. Brisini said the issue is how much implementation is required, and how large does the menu of implementation measures need to be. This triggered a discussion that the issue should reflect how much of a shortfall should the contingency measures be expected to address. Mr. Nicholson said the General Preamble intended that contingency measures maintain progress while efforts are made to fix the SIP. Contingency measures were not intended to pre-prescribe how the area would reach attainment. Mr. Skelton said he would re-word issue 11.

Issue 12 is an economic incentives issue. Issue 13 (What can be used as a contingency measure other than emission reductions when an area determines they have controlled all that can be controlled and no additional measures are available?) was unchanged. Mr. Brisini commented that areas should be allowed to take credit for national measures that are not allowed in the SIP when they are invoked as contingency measures. Mr. Marin objected because areas that do not miss RFP or other targets would not be allowed to take credit for those measures. However, Mr. Nicholson said this would be acceptable if the emission reductions are subsequent to the triggering event of the contingency measure. Mr. Skelton and Mr. Lawler asked if there could be scenarios that allow an area not to implement a contingency measure or to replace a contingency measure. Mr. Luneburg and Mr. Nicholson said that the lack of viable contingency measures becomes an attainment date issue. Mr. Skelton said the intent of the issue was to address "nontraditional" contingency measures. Mr. Luneburg reiterated that the issue is one of attainment dates, and it should be dropped from this paper.

There was no further discussion of the remaining issues.

New Source Issues (8:00 - 9:30)

Mr. Schaefer led the discussion of the Considerations for the Implementation of New Air Quality Standards/Regulations (Phase II Issues) draft issue paper. He suggested deleting option 3 (Propose and promulgate PM2.5 increments.) under the PM10/PM2.5 issues. However, Mr. Gerritson said the option contains enough differences compared to the other options to make it worthwhile to maintain.

Mr. Paisie asked how the Integrated Implementation Plan (IIP) fits into the options. Mr. Schaefer said that option 2 (Do not propose or promulgate PM2.5 increments until such time as accurate models and emission factors are developed and validated.) would incorporate the IIP.

Mr. Brisini asked how new source requirements would fit into a PM2.5 increment program. What would a source do if it wanted to locate in an area that is an AOV for PM2.5 but in attainment for sulfur oxides and ozone? Since SO2, volatile organic compounds (VOCs), and NOx are precursors for PM2.5 as well as pollutants/precursors for sulfur oxides and ozone, would the source comply with lowest achievable emission rate (LAER) or best available control technology (BACT) for the precursors? Mr. Gerritson said the issue would be resolved by speciation. Mr. Paisie added that the issue is two-fold: 1) who contributes the precursors, and 2) how extensive should the treatment be? Both Mr. Golden and Mr. Schaefer agreed that option 4 (Do not develop PM2.5 increments for secondary particles.) is not viable because of the overlap between primary and secondary emissions in looking at AOVs for the various pollutants. However, Mr. Golden suggested that secondary pollutants could be addressed through technological requirements instead of through increments. Mr. Salvaggio said that the options were becoming too complex to implement, especially in the East. Mr. Brisini said the option should be limited to a technological floor, e.g., new source performance standards (NSPS). He suggested an across-the-board requirement for PM2.5 technological requirements with an increment component. Mr. Schaefer noted that the use of a market-based trading program in place of traditional new source programs would remove the concerns for increments. Mr. Nicholson opposed the assumption that trading programs could eliminate the need to demonstrate attainment, because you cannot assume that a cap over a broad geographic area protects the NAAQS.

For those options relying on the future development of tools to implement increments, Ms. Lee said that there would have to be a time limit/backstop if it took too long to develop the resources to develop them.

Mr. Palzer said he prefers option 4, which would not develop PM2.5 increments for secondary particles because he worries about the use of a ratio based on PM10, particularly if there are no coarse particles in the actual emissions. Mr. Pezda suggested that this is a more generic concern relevant to all of the options that should be discussed in the introduction to the issue. Mr. Phelps also was concerned about the coarse versus fine particle debate.

Mr. Paisie said that the paper should have an expanded discussion of the complexities of primary versus secondary PM.

The group then discussed the permitting issues portion of the issue paper. Mr. Schaefer proposed that the paper should address the situation of sources immediately after EPA finalizes the ozone and PM NAAQS and proposes the regional haze rule. There was also discussion of whether sources only subject to primary increments would have to perform any modeling. Mr. Paisie thought this was an IIP issue. Mr. Lawler and Mr. Salvaggio suggested tabling the issue until EPA releases its rules. Mr. Paisie suggested that the discussion should be moved to the front of the paper and phrased in terms of the complexities that result from trying to address secondary PM increments.

Mr. Schaefer noted that the summary of a previous discussion on this topic mentioned the addition of air-quality-related-value modeling. The group agreed that this addition is not needed.

White Paper Update (9:30 - 10:15)

Mr. Paisie discussed EPA's thinking on the "white paper" presented by Lydia Wegman at the April 8 and 9, 1997 FACA Subcommittee meeting in Falls Church, Virginia. Based on the response to the paper at the FACA Subcommittee meeting, the EPA proposes to reduce the main ideas in the paper to a two-page summary, which will be designed to communicate EPA's general direction in implementing the standards. This summary is designed to address broad concerns from many sectors regarding EPA's plans to implement the new NAAQS. Mr. Gerritson noted that if EPA accepts the FACA subcommittee's recommendations, much of its need to explain its decisions would already be provided. Mr. Phelps said that the non-NSR portions of the paper should be salvaged because they were not controversial and contained a lot of useful information.

Mr. Schaefer asked if the Phase I report could address the implementation questions. Mr. Paisie replied that the Phase I report does not provide sufficient direction. Mr. Brazen noted that the Phase I report was never finalized, and Mr. Paisie said he would check into the status of that report.

Several members discussed their concern that EPA was recanting on the FACA charter to think "outside of the box," as evidenced by the white paper presented at the last FACA meeting. Mr. Gerritson stressed the need for EPA to keep the work groups informed of the results of any EPA legal analysis that relate to EPA's ability to move beyond the strict limits of the CAA. Mr. Schaefer said that advance notice of the white paper would have been helpful. He added that where EPA has made up its mind on a given issue, the work group should be informed so that the work group does not waste time on the issue. Mr. Paisie noted that with respect to NSR, the law is fairly clear and does not provide much room for EPA to move around within the box. However, there are other issues where there is more flexibility to expand the box. In addition, the FACA's input has been very useful to EPA in telling them where to push the boundaries of the CAA.

Mr. Phelps said that people are concerned about funding and timing issues related to implementation, which have not yet been addressed by the FACA Subcommittee. Rather than a fear of basic requirements, the concern relates to impossible deadlines, lack of technical tools, and unfunded mandates. Mr. Salvage pointed to a fundamental lack of trust between the States and the EPA. He asked if EPA will allow the States the necessary flexibility to address their problems.

Mr. Dworek asked how EPA/OGC viewed the monitoring paper premise that some violations could be decoupled from mandatory requirements, which is clearly out of the box. Mr. Paisie said that the upcoming Phase I notice and IIP should provide a sense of EPA's direction on these and other topics.

Control Strategies (10:30 - 2:00)

Ms. Vernet's goals for the discussion were to determine if the paper addressed the range of options and to identify missing options/ideas.

Question 2.1. What is the appropriate mix of prescribed and discretionary measures to achieve a required air quality objective?

Mr. Golden commented that criteria for how far down an area would go on its menu of measures would need to be developed for option 5 (menu of choices of prescribed measures from which the planning authority must choose).

Mr. Nicholson asked why prescribed measures were needed. Ms. Vernet said option 1 (no prescribed measures) covers that concern.

Mr. Golden asked how option 6 (RACT/RACM) would be a stand-alone option. Ms. Vernet replied that not all options are stand-alone.

Mr. Golden suggested adding "ambient impact equivalency" as an additional sub-option under option 3 (rebuttable presumption).

Question 2.2. What factors should be considered when selecting specific prescribed measures?

Mr. Luneburg said one problem with the paper is that it does not contain a question for where prescribed measures should apply.

Mr. Palzer was concerned about measures with significant benefits being precluded because they are costly. Mr. Paisie suggested adding a health risk reduction criterion to address this concern.

Mr. Nicholson wanted a factor about air quality benefits in the spirit of factor 2 (amount of emission reduction feasibly achievable). Ms. Vernet suggested: amount of reduction/air quality improvement feasibly achievable. Mr. Palzer commented that "feasibly achievable" may not be needed. Mr. Nicholson agreed, noting that the cost-effectiveness factor covers it. Ms. Langworthy added that public acceptability also addresses "feasibly achievable." Mr. Pezda said factor 2 initially referred to whether or not the measure is technically achievable. He suggested adding "technically achievable" as a factor since the meaning of factor 2 has been changed. Ms. Langworthy agreed.

Mr. Golden asked if public acceptability is good or bad. An argument for prescribed measures could be: measures that are difficult to push through the legislature should be prescribed by EPA. Mr. Nicholson would argue that those measures should not be prescribed.

Mr. Paisie asked who will make the judgment. Ms. Vernet said the question 2.3 (Are there specific measures that can be recommended based on how they conform to these factors?) has not been fleshed out yet.

Mr. Paisie suggested focusing on all the factors except for equity and acceptability.

Mr. Golden said prescribed measures should be all measures that are likely to be in any compliance plan -- the "no-brainers." The prescribed measures should be used to jump-start progress. A lengthy analysis should be avoided. Mr. Nicholson said State agencies and legislatures tend to oppose anything that is pre-prescribed. Even if these measures ultimately end up in the SIP, rebutting a prescribed measure takes a lot of energy and resources. Mr. Golden agreed. However, he was thinking about the concern about no progress in the interim period.

Question 3. How should the order of implementation be determined?

Mr. Golden asked what the difference is between options 1 and 2. In option 2, is flexibility allowed for the prescribed measures? Mr. Gerritson replied that option 2 requires less in the way of prescribed measures. Mr. Marin said geographic applicability and RAMPS could be limiting.

Mr. Golden said option 2 fails to address timing.

A member asked if the target date is the same as the implementation date. Mr. Gerritson explained that the target date is the presumed implementation date. The distinction is between writing the SIP and implementing the SIP.

Mr. Golden said there are really just two options: 1) credit national measures on the target date and 2) credit national measures on the implementation date. Mr. Gerritson said option 1 would credit national measures on the target date; option 3 would credit national measures when they are implemented; and options 2, 4, and 5 are variations on these two basic options. The subgroup added variations on these two options to provide greater detail. Mr. Paisie said the paper covers the entire range of options. Mr. Martin recommended that the issue be simplified by narrowing the range of options to the two suggested by Mr. Golden.

Mr. Brisini said the real issue is when States should receive credit for national measures in their SIPs. Mr. Gerritson replied that he could revise the question, but NRS was happy with it. He explained that Dan Johnson does not want to restate the question because it would then have to go through the entire process to be approved. Mr. Gerritson will just enhance the background discussion to capture the idea.

Mr. Marin did not understand the issue about crediting measures upon implementation. States have always been allowed prospective credit. Mr. Gerritson replied that the options are just the range of possibilities.

Ms. Vernet said one approach would be to have both target and implementation date options for national, prescribed, and discretionary measures. Mr. Paisie said he understood the issue for national measures: EPA says it will implement a measure by a set date and fails to do it. Mr. Gerritson replied that questions 4 and 3 should not be confused. Question 4 addresses EPA's failures, while question 3 deals with allowing States to get prospective credit for national measures. The answer to question 3 has always been "yes," but perhaps a different approach could be taken in the future. The EPA has failed in the past, and States were expected to make up the reductions. One way to address this is to allow credit for national measures only when they have been implemented.

Ms. Lee said a practical difference between the options is that with no prospective credit, States must over-plan, whereas with prospective credit, States must identify contingency measures. Mr. Gerritson said contingency measures would be very different for SIPs that assume full credit for national measures up front versus SIPs that do not take credit for national measures until they have been implemented.

Mr. Gerritson said if States do not assume credit for the national measures, the SIP must contain rules for all of the sources that could have been covered by one national rule.

Mr. Nicholson was concerned about the options. He would hate to see a policy that would not put pressure on EPA or would hold EPA harmless. For some of the source categories, States have no tricks in their bags. Except for option 1, all of the options are non-starters. Mr. Lawler agreed and added that if the assumed reductions are not achieved, States simply make adjustments. States do not need 18 different contingency measures.

Mr. Paisie framed Mr. Nicholson's concern as a con: if States are not given credit for national measures on the target date, States may not be able to find extra "make-up" measures if EPA fails. Mr. Nicholson said a pro of presuming credit up front is that it keeps pressure on EPA. Mr. Gerritson said he purposely has not included any pros and cons at this point to help the work groups focus on whether the range of options is complete.

Ms. Lee said the paper should focus on what happens when a measure does not go through instead of on the timing question.

Mr. Luneburg suggested clarifying the discussion of question 3 by stating that the question applies to attainment and maintenance, as well as nonattainment areas.

Mr. Nicholson asked if States could take credit for national low emitting vehicles (NLEV) program and Tier 2 standards. Mr. Pezda said trying to forecast Tier 2 is risky. NLEV is more certain because it has been going on several years. Maybe States could assume a portion of the credit up front. States have to make a best guess just like industry.

Mr. Dworek wanted equity to be added to option 3. Equity is important to sources that have done a lot compared to other sources.

Question 4. How should the situation be handled where national measures are not implemented, or are not timely? What is the consequence to the regulatory agency (e.g., sanctions)?

Mr. Gerritson said the question was changed to "national and prescribed measures" to respond to yesterday's discussions.

For national measures which are delayed

A member asked if this question assumes that the planning body is not in control of implementation. Mr. Gerritson responded that the question would apply when States are required to issue control technique guideline (CTG) documents based on guidance from EPA, but EPA fails to deliver. This is just one example. Ms. Eves explained that Pennsylvania has been in several situations where its regulations have been delayed because EPA guidance was late or never appeared.

Mr. Golden is troubled by "credit" in the options. Is this implying that States do not have to do the measure and can simply move on? Mr. Gerritson replied that these measures will happen, they have only been delayed. Ms. Lee said the options refer to the timing of giving credit. They apply to question 3. Mr. Nicholson commented that option 1 seems to be a paper credit.

Mr. Marin observed that all of the options put the onus on States. He suggested adding an option to put the onus on EPA to adopt a substitute measure. Mr. Nicholson said this option would fit under "for national measures which are not implemented."

Ms. Lee asked where the line is drawn between a measure that is delayed and a measure that is not implemented. Mr. Gerritson said it was a good question and will need to be addressed.

Mr. Lawler cautioned against allowing for delays and designing substitutions. Everything will tend to be delayed. Perhaps this issue should not be framed as a question. It could instead be included as paragraph in the background section. Mr. Gerritson said he could think of examples where it would not be an incentive to delay. If many States want State consumer solvents rules, manufacturers would then put pressure on EPA for a national rule. Mr. Nicholson said consumer solvents are a good example, but States do not have the option for engine standards.

Mr. Golden commented that the attainment date in the SIP could be changed. Failure of EPA could be grounds for changing the attainment date. Mr. Paisie asked why citizens should have to breathe bad air while States and EPA are pointing fingers at each other. Mr. Golden clarified that these options would be contained in an approved SIP up front.

Mr. Salvaggio suggested as an additional option: EPA promulgates regulations specifying the emission reductions it wants to achieve along with a schedule. Citizens would then be able to hold EPA accountable. Mr. Gerritson said it was a good suggestion but it may not be a quick fix. For example, automakers are not obligated to develop NLEV -- it is a voluntary effort.

For national measures which are not implemented

The group agreed to add Mr. Marin's option that EPA makes up the difference when a national measure is not implemented. Mr. Gerritson said he would also add Mr. Golden's flexible attainment date option. Mr. Paisie said the work group has already discussed attainment dates. Outside the twelve-year period, this option may not be feasible.

Mr. Mueller commented that it is difficult to understand what a reduction in RFP would mean without knowing what RFP will be.

Mr. Mueller asked if the options cover midcourse corrections. A midcourse evaluation may show that the next set of emission reductions is not needed. Mr. Golden said the NAAQS Implementation Process diagram contains this concept. Ms. Vernet said the grace period in the options would encompass a reevaluation.

Mr. Palzer noted that allowing a grace period when national measures are not timely does not solve the public health problem. Essentially, when there is a shortfall, the public loses. Mr. Gerritson said option 4 under delayed national measures and option 3 under national measures that are not implemented address those concerns.

Mr. Golden asked if the options are realistic. The attainment date has to change if three years into the SIP a State finds out that a major component is not being delivered.

Ms. Eves said unless the regulations are in place, States will be scrambling. The complete range of viable options should be covered. Mr. Nicholson said contingency measures should be in place to preclude the need for a grace period. Mr. Schaefer asked if the contingency measure would be identified up front. He was concerned about EPA pointing a finger at someone else with no warning when they fail.

Question 5. For areas of control that involve multiple jurisdictions (e.g., interstate/intertribal/state-tribal), what process and criteria should be used by the responsible planning body in assessing the mix of controls (national, regional, State and local) to be included in the regional integrated plan?

Ms. Vernet explained that question 5 is adding meat to the bones of the Institutional Mechanisms paper.

Cindy Langworthy asked if EPA would provide the targets or the guidelines to establish the targets in option 3. Ms. Vernet said EPA would provide the targets. Ms. Langworthy said this seems to blur the distinction between RAMPs and AOIs. She suggested adding a sub-option under option 3: EPA provides RAMPs with criteria and guidelines but does not set the emission reduction targets.

Mr. Luneburg said, at a minimum, EPA could issue regulations for voluntary measures in the interim. Ms. Eves said States cannot always take credit for voluntary measures.

Mr. Paisie asked who would make the classification judgment. Does the RAMP determine where the problems are and what kind of problems they are? Mr. Golden said the classification decision would occur before identification of the multiple jurisdictions. In the NAAQS Implementation Process diagram, the classifications determine the prescribed measures.

Mr. Schaefer said he has received comments from the Western Regional Air Partnership (WRAP) that RAMPs could not be formed without authority. Mr. Halvey responded that anyone can form an organization for planning without regulatory authority. If the organization makes recommendations that EPA would be responsible for reacting to, there may be legal issues. Mr. Schaefer wants to hear from EPA that RAMPs can be formed.

General Mobile Source Measures

Ms. Bartlett gave a few thoughts on where she is going to steer the paper. The background is substantially historical in nature; it does not contain any real issues. Since there doesn't seem to be any engine standards issues that are pertinent to the new NAAQS, she may move this section out as a separate paper or an attachment. The I/M and fuels sections do contain issues that are relevant to the new standards. Mr. Pezda said a lot of Subcommittee members did appreciate the background. Ms. Bartlett emphasized that the information would not be eliminated, it would simply be moved or put into an attachment.

Mr. Golden asked how this paper would be integrated with the Transportation FACA. Mr. Paisie said representatives from the other FACA process may make a presentation to the work group at the June 9 meeting.

The General Mobile Measures paper will be discussed in-depth at the June 9 BPAP work group meeting.

Next Steps

Mr. Paisie said Contingency Measures, Areas at Risk, and the NAAQS Implementation Process diagram are scheduled to be presented at the June 10 and 11, 1997 FACA Subcommittee meeting.

Mr. Skelton said he needs to revisit the Classifications paper in light of the NAAQS Implementation Process diagram and Control Strategies efforts. Mr. Golden said the paper does a good job of presenting the issues. The work groups may be ready to begin discussing a recommendation for the paper. Mr. Golden asked if the question of who decides the classifications should be addressed in the Control Strategies or in the Classifications paper. Mr. Paisie said the options were either EPA alone or EPA gets recommendations from the States.

Mr. Skelton reported that the next draft of the Contingency Measures paper will be ready before May 28.

Mr. Paisie said papers being presented at the June Subcommittee meeting need to be posted on the TTN before June 2.

Mr. Paisie proposed that BPAP meet by themselves unless members feel a real need to meet jointly with NRS on June 9. He does not want to spend a lot of time reviewing presentations at the meeting. General Mobile Source Measures and the Transportation FACA will be agenda items.

Mr. Paisie said a BPAP face-to-face meeting may be held in July. This is very tentative.

The next BPAP conference call will be held on May 28, 1997 from 11:00 - 12:30 Eastern Time.