This is a preliminary summary. It has been placed on the bulletin board for comments and corrections from 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.

June 5, 1996

Summary May 16, 1996 Base Programs Analyses and Policies Work Group Conference Call

I.	OVERVIEW

A Base Program Analyses & Policies Work Group teleconference call took place on May 16, 1996 to discuss four issues raised by Herb Williams at the May 15 meeting that STAPPA/ALAPCO wants addressed. Following is a summary of the discussion and proposed action items.

II.	PARTICIPANTS

Work group:

Jerry Golden-Co-chair, Joe Paisie-Co-chair, Vincent Brisini, Arthur Lee, Bob Palzer, Jim Ralston, Jean Vernet, and Herb Williams

Work group members not in attendance:

David Baron, Glen Cass, John Crouch, Gregory Dana, Richard Dworek, Jeff Gabriel, Steve Gerritson, Rich Halvey, Robert Kappelmann, Dennis Lawler, Brock Nicholson, Steve Pezda, Richard Phelps, Don Pickrell, Jim Salvaggio, Greg Schaefer, Conrad Schneider, Eric Skelton, and Mel Zeldin

Others:

Eric Schweitzer, EC/R Incorporated (EPA Contractor support)

III.	ACTION ITEMS

1)	Joe Paisie asked members to review the basic principles and comments on pages 1-9 of the IIP comment summary for the upcoming 6-hour meeting on May 29, 1996.

2)	Joe Paisie will send members the version of the IIP principles that will be distributed at the Coordination committee meeting. Members should review the IIP principles in advance, so they will know what editorial changes have been made.

IV.	MEETING SUMMARY

Information Update

Arthur Lee asked whether the issue papers had been discussed yet. Joe Paisie said the population weighting paper was discussed for about 45 minutes and the "too close to call" paper was discussed for 15 minutes. The author will revise the population weighting paper for the next meeting based on the discussion that took place.

STAPPA/ALAPCO's Questions

Herb Williams began by listing the following four issues Beverly Hartsock said STAPPA/ALAPCO wants addressed:

1)	An independent panel of experts should be appointed to identify options for the near term;

2)	Transport;

3)	Incentives for monitoring and early emissions reductions; and

4)	Public education and outreach during the transition.

Joe Paisie said the STAPPA/ALAPCO document is a culmination of discussion at the STAPPA/ALAPCO meeting. He recommended the work group focus on clarifying previously discussed issues and said it would not be advisable to add new issues with such skeletal attendance. Beverly Hartsock will bring these issues up at the Coordination meeting.

Vince Brisini said that as far as the questions go, "the devil is in the details." For instance, who will appoint the independent panel and will they be truly independent? What specific aspects of transport are they referring to? He said that these four issues are difficult to discuss without more details. He also wonders what is meant by public education in issue number 4 and whether this could be construed as a form of lobbying.

Transport

Jerry Golden said that transport may be the easiest issue of the four to address. He suggested that adding a few words to the previous bullets concerning transport issues may suffice. He noted that the work group has achieved agreement on some issues, for example that OTAG is in the baseline. Vince Brisini noted a firm position by a number of companies that OTAG should only provide principles, not specific reductions. Another member said that it appears any obligations existing as a result of transport will be included in the baseline. Substitutions outside the local area will be acceptable.

Several members suggested that some re-wording to clarify previous statements about transport may be adequate. A member said STAPPA/ALAPCO may have felt that transport was not adequately addressed because it was not explicitly mentioned. Vince Brisini said the ozone transport requirements are the only ones pertaining to transport.

Joe Paisie read several of STAPPA/ALAPCO's comments to the IIP aloud. He said that these issues have been addressed in the backsliding section and in number 4 -- areas where creditable reductions are possible. He also thinks STAPPA/ALAPCO's concerns can be easily addressed by re-wording.

Vince Brisini mentioned the need to address transport from areas without requirements prior to new SIPs. Arthur Lee concurred with the need to talk about requirements for these areas during the interim period. Joe Paisie said he thought this had previously been discussed. Nothing is required in those areas, but they can get creditable reductions. Vince Brisini said there is no need to "beat up" nonattainment areas if areas responsible for transported pollutants are going to be dealt with soon.

Herb Williams noted that the meeting was going beyond the agenda at this point and asked whether transport should be considered as one of the principles. Joe Paisie returned to the idea of altering the existing language to make it acceptable to STAPPA/ALAPCO. Vince Brisini asked for examples of specific wording. Arthur Lee suggested "the role of transportation may need to be recognized" as one example of possible wording. Joe Paisie suggested adding the language "acknowledging the possible role of transport" under IIP principle number 4.

Jerry Golden suggested adding the following italicized language to principle number 2 after ...requirements for new programs stay in place "including new programs that may be required under OTAG or other transportation-related activities." They both think the issue of transport can be adequately covered by using this language in these locations. Joe Paisie said that this language can be put under the "all programs stay in place" paragraph and then suggested moving on to the other 3 points.

Independent Board of Experts

One member said this issue was not adequately discussed prior to this meeting. Bob Palzer said it is inappropriate to add substantive changes now with this skeletal group in attendance. Joe Paisie reminded members that they can raise any of these issues in one of the open forums. Vince Brisini stressed the need for members wanting to champion an issue to be present to follow the issue through and provide answers about important details.

A member asked whether anyone had attended yesterday's WESTAR meeting with STAPPA/ALAPCO. There was apparently discussion at the meeting about the fact that if EPA keeps the exiting PM-10 standard in the NAAQS revision process, the need for an interim policy is diminished.

Incentives for Monitoring and Early Reductions

A member noted that Steve Pezda's issue paper mentioned incentives in the designation discussion. Another member said the work group could probably reach agreement on wording such as "will try to find incentives for monitoring" to insert into existing language. Vince Brisini said the work group, at this time, can only say the issue needs thorough consideration, and an issue paper will be written on it in the future. Arthur Lee wants this issue to be addressed.

Herb Williams said he and Beverly Hartsock are concerned about what is happening to issues that are discussed without being commented on. Are they forgotten or rolled over for future discussion? He is looking for the best way to get the incentives issue considered. Vince Brisini said the report to the Coordination committee will reflect what has been discussed so far. He said that without someone there to champion a given issue, it may slip away. He also reiterated that the details related to an issue can make it a simple or complex one. Joe Paisie said the Coordination committee will listen to the report and then add their own ideas. The Subcommittee will also provide feedback. Additional or remaining issues will have a chance to be raised at that time. He reminded members that it is possible for issues to be brought up at higher levels if necessary.

Jim Ralston noted that New York missed the deadline to comment on the IIP and sent their comments later. He suggested that unaddressed comments be kept for future discussions. Jerry Golden suggested the idea of making a matrix including comments and the discussion that took place on them. Another member also suggested a matrix might help with comments that are mentioned and then seem to disappear. Arthur Lee concurred, adding that written comments like his and STAPPA/ALAPCO's should be recognized. Joe Paisie suggested that members look over their copies of the former comments and note any items that are left over or have not been adequately addressed. Before the work group takes the next step, he would like to see what input the Coordination committee and Subcommittee provide.

Jerry Golden suggested a contractor be asked to make a matrix containing a disposition of the comments. Joe Paisie expressed concern over having a contractor interpret whether items have been sufficiently addressed. He thinks the work group can do it. Jerry Golden suggested members send their comments to Joe Paisie, and he can focus them for coverage at a subsequent meeting. Joe Paisie suggested that, due to time constraints and the fact that the Subcommittee will also provide input, this issue be left as is for now to see where it goes.

Vince Brisini suggested all members review pages 1-9 of the IIP comments and decide whether they have been adequately addressed. Jim Ralston suggested members give their reactions to the IIP written comments to EPA for future discussion. Jean Vernet wants to get something to the Coordination committee that reflects what the work group did in the meetings on May 7 and 8. She noted that the work group did not systematically cover the comments on pages 1-9 of the IIP, but the substantive issues were covered. Joe Paisie remembers asking whether the issues were covered so he could close out pages 1-9. Another member said a systematic review is a good idea but the work group should wait to see what happens next week at the Coordination committee meeting.

A member suggested making a written "parking lot" of issues. If the Coordination committee and Subcommittee have more issues, they can be added to the list. Joe Paisie mentioned that if issues are not raised at the Coordination committee or Subcommittee levels, the work group does not need to push them. Instead, the work group can focus on higher-level questions. A member agreed that it is fine if there is no subsequent interest in the issues on the list. Joe Paisie stressed that members should review the basic policy in addition to the comments for the upcoming 6-hour meeting.

Because Joe Paisie has received feedback that some editing could make the comments more understandable, he and Jerry Golden said they will make editorial changes to the comments merely to make them clearer -- not to change them substantively. Joe Paisie will send members a version of the comments that will be distributed at the Coordination committee in advance so they will know what editorial changes have been made.

Public Education and Outreach

The meeting time elapsed before the issue of Public Education and Outreach was covered.

Conclusion

The additions suggested by Herb Williams will not be incorporated into the interim principles drafted by the work group at this time. The additions may be raised by STAPPA/ALAPCO at the next Subcommittee meeting and if agreed to by the Subcommittee will be included at that time.