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 6, 1996

Summary May 29, 1996 Base Programs Analyses and Policies Work Group Meeting at the Durham Omni, Durham, North Carolina

I.	OVERVIEW

The Base Programs work group held a meeting on May 29, 1996 to discuss 1) feedback from the Coordination Group on the Interim Implementation Policy (IIP) principles and the Designations Issue Paper, 2) draft issue papers on Population Weighting of Monitors to More Accurately Represent Personal Exposures and Introduction and Implementation of a 'Too Close to Call' Category to Reduce the Impact of Meteorological Fluctuations on Attainment Designations, and 3) draft issue paper on Designations: Identifying Sources of Influence.

II.	PARTICIPANTS

Work group:

Jerry Golden-Chair, Joe Paisie-Chair, David Baron, Vincent Brisini, John Crouch, Jeff Gabriel, Steve Gerritson, Robert Kappelmann, Dennis Lawler, Arthur Lee, Brock Nicholson, Bob Palzer, Steve Pezda, Richard Phelps, Charla Rudisell for Jim Ralston, Jim Salvaggio, Greg Schaefer, Conrad Schneider, Jean Vernet, Herb Williams (via phone), and Mel Zeldin

Work group members not in attendance:

Glen Cass, Gregory Dana, Richard Dworek, Rich Halvey, Don Pickrell, and Eric Skelton.

III.	ACTION ITEMS

1. Formation of a sub-work group, to further discuss the IIP principles, will be considered if the Subcommittee sends the principles back to this work group.

2. New target date for submitting the Population Weighting of Monitors issue paper to the Coordination Group is June 19, 1996. Authors are to rework the paper to remove "I's" and "We's," capture the merits of the current approach, add the Work group discussion about setting up monitoring networks using population weighting, and, possibly, set up requirements to address "gaming." Vince Brisini will draft an option of population weighting, with a listing of pros and cons. Finally, the paper may need to include the position "if it ain't broken don't fix it."

3. Greg Schaefer will help the authors expand the discussion of the level of background in the Identifying Sources of Influence issue paper. Further discussion of this paper will occur on the next call.

4. The next teleconference call is scheduled for June 12, 1996 between 11:00 and 12:30 pm EDT. The call in number is 919/541-1593.

IV.	MEETING SUMMARY

Feedback from the Coordination Group on the Interim Implementation Policy (IIP) principles and Designations Issue Paper

Joe Paisie briefed the Coordination Group on the Base Programs groups' progress on the IIP. He reported his sense that consensus was largely reached between the industry and State sectors, but that the environmental sector still had unresolved concerns in some areas (e.g., substitution). The American Lung Association representative to the Coordination Group agreed to take the lead in coordinating the environmental sector's issues. As for those principles and comments raised by STAPPA/ALAPCO, the Coordination Group agreed that these and other issues could and should be raised at the Coordination Group and at the full Subcommittee levels.

Joe Paisie also presented the designations issue paper to the Coordination Group. This is the first paper to be brought before the full Subcommittee. This presentation is scheduled for May 30, 1996.

Following Mr. Paisie's report to the work group, there was a general discussion of whether consensus on the IIP principles had been, in fact, reached. Members were concerned that the Base Programs work group's efforts be reflected accurately to the Subcommittee. Some members felt that consensus had been reached with the exception of the substitution issue, on which the environmental sector disagreed. However, Conrad Schneider noted the environmental sector also disagreed with the idea of bump-ups and had concerns in other areas as well. He was also concerned that the environmental position would be misrepresented by casting it as an outlier in the process. The State representatives generally felt that closure had not been reached, particularly since the STAPPA/ALAPCO comments had not been fully resolved. Finally, the industry representatives expressed concern that the overall agreement on the IIP principles represented a "package deal" and that undercutting of some issues would lead to the entire package falling apart. Several members felt more discussion at the work group level was needed, although the level of effort that should be devoted to further discussion was debated because of other, pressing demands on the work group's time. Herb Williams suggested the possibility of forming a sub-work group to continue discussions on these issues.

Population Weighting of Monitors to More Accurately Represent Personal Exposures

Steve Pezda and David Chock led the discussion of the May 22 revised issue paper regarding the siting of monitors using population weighting. The paper was revised to address the following expanded options.

1.	Population-based monitoring, with the current network,

2.	Population-based monitoring, with an expanded network, and

3.	Maintain status quo monitoring.

Conrad Schneider asked why, if the form of the standard takes risk into account, does the monitoring network also need to reflect risk concerns. Steve Pezda replied that population weighting is independent of the health risk assessment. The goal is to achieve health-based improvements to the bulk of the population exposed to a given risk. He agreed there is still a concern to be addressed about people exposed to peak levels, and suggested the answer probably lies in some sort of local action, such as ozone alert days.

Conrad Schneider also expressed concern that the proposed population weighted monitoring would not address populations in "shadow" areas. Bob Palzer said that it is prudent to have monitors where the highest levels of pollution exist, because this ensures better ambient air for the entire region. He also noted that what is presently a rural area, can become urban in a short time. Steve Pezda said the Clean Air Act is interpreted as allowing some risk, and the focus is protecting the majority of the population. Steve Gerritson countered that the Clean Air Act "population at risk" is established as the population that is more susceptible than the general population. The goal of protecting the majority of the population is served by setting the standard to protect the population at risk. In addition, ozone is a regional problem, which means that there is pollution where no one is looking. David Hawkins added that use of population weighting would invite "gaming" of the system by creating apparently "clean" States compared to the results achieved by using modeled/monitored air quality.

Greg Schaefer gave an example of the inequity of the current system illustrated by a case where a person works in Denver, Colorado, which is a PM-10 nonattainment area, but lives 40 miles north in an area that has no violations, but is still part of the nonattainment area. David Hawkins said this is an area boundary problem, and not a population risk exposure problem in the context of monitoring.

Some members discussed whether the issues raised by the approach should really be considered in the context of the standard and whether this issue is an appropriate implementation issue. Joe Paisie said the issue is an implementation issue, assuming the eventual form of the standard supports it. Jim Salvaggio said if the standard is concentration-based, concentration per capita could be valid. In contrast, a health effect standard would be supported by measures of exposure.

Brock Nicholson noted the difficulty in using counties of different sizes to reflect population density.

David Chock gave an example of a tradeoff in risk. He said a strategy to lower downwind ozone by decreasing NOx would result in people closer to the source having a higher exposure. Vince Brisini added that it would not be necessary to move the monitor with the higher value, assuming one checks to see how large an area the monitor data actually covers.

Jean Vernet asked if there is a distinction between monitor placement for attainment versus placement for control strategy. She also asked if there are differences between ozone and PM. One member replied that the current recommendations in the EPA PM staff paper are to initially place the monitors where the people are located.

Vince Brisini said the issue should be framed in terms of how you demonstrate attainment or nonattainment with a small number of monitors. Just because a single monitor shows a problem, this does not mean the rest of the area is not at risk. The ability to average monitored data would create incentives for monitoring. He asked, in general, is the issue population weighting or data averaging or incentives? Mr. Brisini suggested adding an option of averaging monitors based on geographic location to recognize that in some areas more monitors are present. Richard Phelps agreed this option would encourage the placement of additional monitors and result in better data. In response to Conrad Schneider's comment that this option would not reflect the high monitor, Greg Schaefer suggested that "hot spot" mitigation would be an appropriate strategy.

David Hawkins said that the premise of averaging is that the network is statistically robust enough to support valid averaging. He questioned the overall benefit of putting substantial resources in developing a sufficiently robust network to accommodate averaging. On the other hand, adoption of this approach without sufficient investment will result in invalid averaging. Vince Brisini said this is why more monitoring incentives are needed. Mr. Hawkins replied that monitoring disincentives arise from the current consequences of identifying "dirty air." However, a system that moves to regional responsibility of where sources are would move the creation of incentives in the right direction. Joe Paisie noted that the idea of incentives is a different issue.

Jerry Golden said that the Work group is not yet in a position to submit this issue paper by June 5, so it will target the 19th. The Work group will need to inform the Coordination Group about not meeting the schedule. He thought the Work group should look at the issue paper again, as it still reads as if it is an advocacy paper, and needs to be returned to the author's to remove "I's" and "We's." The Background is thorough on the problems with the current approach but needs to capture the merits. The current approach is conservative, if the high spots are captured. He asked, what is the purpose of the standard? And answered, to extend protection to all. The authors should try to capture the discussion in the Work group about setting up monitoring networks using population weighting. He also said that the discussion of the issue of the potential for "gaming" suggested a need to set up requirements to address "gaming." Jerry Golden asked Vince Brisini to draft an option of population weighting, with a listing of pros and cons. Jerry Golden said that he thought he heard a majority (he was not sure it was a consensus) leaning toward a position of "if it ain't broke, don't fix it." He asked whether other's agreed, stating that if so, that position should be taken into consideration for the next draft of the issue paper.

The co-chairs summarized that population weighting could be used to set priorities, and to evaluate control strategies, but that the current approach should still be used for designation decisions.

David Baron suggested that the Work group eliminate the issue paper, altogether. He thought that the monitoring issues in it could be rolled into the monitoring issue paper. Greg Schaefer disagreed, and argued in favor of rolling the existing paper and recent discussion together. There was a discussion on whether further discussion or work on this issue paper was warranted. Steve Pezda reminded the Work group that the process was supposed to encourage thinking "outside of the box," on the Act and EPA policy, and suggested that the group treat the issue in the same manner as the other issue papers by revising it and sending it up to the Coordination Group. Jerry Golden said that if Steve Pezda is ready to draft it, then the discussion in the Work group should be captured on paper, reviewed, and then passed on. Jim Salvaggio was concerned that passing it on would imply acceptance, and therefore he feels an obligation to look at the issue more thoroughly, yet he does not want to spend more time on it. Herb Williams believes it is worthwhile to have an issue paper on averaging of monitors. Vince Brisini asked whether the issue paper should be about population weighting, or averaging of monitors. The Work group agreed that Steve Pezda would redraft the issue paper, and the Work group would review it again before deciding whether it would advance to the Coordination Group. The Work group acknowledged the contributions of Steve Pezda, Dennis Lawler, Mel Zeldin, and David Chock to the work on the issue papers.

Introduction and Implementation of a "Too Close to Call" Category to Reduce the Impact of Meteorological Fluctuations on Attainment Designations

David Chock distributed a handout describing the issue of reducing the impact of meteorological fluctuations on attainment designations. Ozone tends to fluctuate, making it difficult to determine if an area is in attainment. The handout quoted the EPA Staff Paper that recommended consideration of alternative attainment test criteria. To accommodate the fuzziness in the status of an area, the concept of "too close to call," has been developed as an approach that would look at the range of highest observations. Despite improvements in air quality in the 1980's, the heat wave in 1988 caused many violations of the standard, and several areas "flip-flopped" in their attainment status. He believes the standard is more stringent than people assume. If air quality observations are represented as a bell-shaped curve, an area needs to move the bell down substantially to keep the tail below the standard. He presented a Monte Carlo simulation on data from California, and showed scatter plots of the annual mean and annual second highest levels. If an area needs to meet the standard all of the time, it may not be able to meet the standard at all. He said that he was only proposing his approach to analyzing the measurement data for areas that are "too close to call", and that it would be inappropriate to apply the approach in an area such as Los Angeles. He related the concept that he had presented to building a dam for the 100-year flood versus the 50-year flood.

Conrad Schneider asked what are the implications of "too close to call"? Would this apply to areas already in attainment that have a bad year? Would the number of nonattainment be reduced by a factor of 10? David Chock responded that this approach would involve about 10% of the counties in a year of big fluctuations, and about 1% in years of small fluctuation. If an attainment area experienced a year of high fluctuations, 3 years of data would be checked, and if the pattern continued, the area would be nonattainment. This approach is not being proposed to address redesignation.

Mel Zeldin asked if the approach would be concentration based? If the exceedance base is the last three years, and the data show that the area falls into the "too close to call" range, would that not be an exceedance? David Chock responded that it would be concentration based. The exceedance approach uses a binary scale, for which the mean determines the standard deviation. David Chock says this does not make sense for this problem. A concentration approach is needed.

David Hawkins said that he could see the need to integrate this approach with many other issues, including how the standard is defined, and without that, one can not develop a technique for defining the category. He asked about the regulatory implications of a third category, whether it would be better to err on the side of controls, without an indication that the air is clean or dirty, and also without an indication of how an area influences other areas. David Chock responded that this is the right time to raise the issue of air quality, location and transport. There is a need to decide what to do with an area that is "too close to call", and determine if it is a rural area with few emissions, and therefore not much to control, or if the air quality is due to transport, in which case the approach may not be applicable.

John Crouch asked whether the approach was intended for ozone or PM, and David Chock responded that it would be applicable to ozone, and also PM, which has fluctuations. Vince Brisini asked if the approach is to address a year that is not typical, and is targeted with statistical analysis, whether an area would be in attainment if it were meeting the standard for 2 years but not for the one year. David Chock replied that the approach considers 3 years at a time, to determine year to year fluctuation.

Joe Paisie asked whether EPA was redesignating areas that quickly from attainment to nonattainment with an "on/off switch?" and without some time awaiting further data. Jim Salvaggio commented that the this approach would allow a State to look at meteorological conditions. He referred to the analogy to floodplains and the frequency of exceptional meteorological events. One could base the strategy on the likelihood of a meteorological event, and if it were a one in a hundred year event, an area might blow an attainment strategy. He sees a problem in explaining this approach to the legislators, who will go ahead and make their own decision when they can not understand information that is presented to them.

The Work group discussed EPA's use of statistical fitting approaches and complex models such as UAM. The group asked for examples of how the approach would be useful for nonattainment areas seeking redesignation. David Chock has two examples in the handout. Shawn Kendall asked if the examples used the standard deviation. David Chock replied that the distribution used was lognormal, and for a very small sample size, the sensitivity of the test to the choice of distribution is not very critical. The censorship of data on the left side of the curve is not very critical, it is only 3 points in 3 years. Shawn responded that if one is looking for extreme values then it would be critically important, but if using the annual means and standard deviations of the means, then the choice of distribution would not matter so much. David Chock replied that the approach takes the average of the extremes.

Steve Gerritson thought that an approach like this was needed, and that the EPA had a flexible strategy which could accommodate the approach, but he agreed with others that the approach would be difficult to explain to legislators. David Chock said his approach brings down the scale and the size preventing an approach that is to stringent in some areas and too lenient in other areas. David Chock offered to develop a table to help explain the proposal to legislators and the public..

Vince Brisini asked for clarification on whether the approach would apply only in one direction, for an area above the standard to be declared "too close to call." The group discussed whether it would be necessary and desirable to use the approach both ways. Some felt that rigor justified a symmetric use of the approach. Brock Nicholson reminded the group that by default, areas are in attainment or unclassifiable, unless otherwise designated.

Joe Paisie asked what the group would want the areas that are "too close to call" to do? Herb Williams commented that Pittsburgh is an area heading toward attainment, and Texas has an area heading out of attainment. He added that statistical approaches need to be sold, and in Texas they have proposed taking the 3 middle years out of 5. An area would still go in the direction that its average moves, but this approach offers a much simpler way to explain the calculation. Joe observed that this approach would get rolled up in the form of the standard, much like the previous issue on averaging. David Chock said he had talked to the EPA about the approach going into the standard, and he was told that it was an implementation issue.

David Baron added that the legislators and public are already having trouble understanding the standards. He said the public will come to him and ask if they are meeting the standard, and he needs to be able to be very clear whether they are or are not. Already with ozone,the approach takes the 5th highest value, which removes the high readings. He is troubled with the idea that high readings are crazy. When the number of monitors is small, a high reading has a lot of significance, and the public is exposed to those levels. He thinks the public will have trouble with excluding data, will think it is questionable from a public health standpoint, and will become befuddled and lose respect for the program, that they will not buy it. He would stick with the current approach.

David Chock said that the approach was predicated on the outcome of the standard setting process, and that he can not go much further with it unless he can see what he is working with. The policy appeal for differential treatment is to avoid the binary disconnect of saying that once an area is in attainment, it does not have to do anything. If one were to couple this approach with a set of minimum measures that need to be applied close to the standard, one would get more political acceptance.

Beverly Hartsock said that she had just come from an effort to explain the program, and had heard a reaction in which the public could not understand how everything could change overnight. She said that "too close to call" seemed to hit home and sit well. The group she had addressed wanted to know what CASAC had said about the bright line, and it made them more comfortable and the concept of a flexible attainment region was comfortable, since it felt like local control, not federal control.

Conrad Schneider said that he had held a similar conversation with citizens trying to explain the 5th level, and that after a presentation on the health effects, he had never seen so much outrage. The outrage was over the fact that the public has to experience 5 of these high exposures before it can get protected. He and the Work group acknowledged that the Work group meeting was not the forum to discuss the standard, but that it was a forum to educate people and be scientifically correct. Conrad Schneider added that people still understand the health consequences of 1988, that at that time they had to up their asthma medications, and they still talk about it and are concerned about being protected the next time it comes. He made an analogy to the victims of a flood. He said that he had seen creative discussion of how to move the bell curve in other contexts, but was not seeing it in this meeting.

Steve Pezda said that they were not trying to water down the standard, but that due to meteorology, an area could have the wrong designation. The approach does not say what to do if an area is "too close to call." The group agreed that the approach was not practical, in the sense that it did not spell out what would be the consequence of being "too close to call." Jerry Golden added that the approach would be linked to the form of the standard. Richard Phelps said that a chemist running a process would see that this approach would tell you how to make controls, it adds definition, but still there would be fuzziness about the action line for control. As a tool that adds more clarity, he thinks it has a place in implementation, and whether it depends on the form of the standard could be tested with data. Conrad Schneider asked where we are on the flood scale, whether we are on the 5, 10, 50, or 100 year flood? David Chock responded that the probability of an error would be 30% misclassification of attainment as nonattainment, and thus the need for something in between.

Designations: Identifying Sources of Influence

Dennis Lawler and Mel Zeldin summarized the issues and options related to identifying multi-pollutant sources of influence. This issue paper drew from and expanded on the designations issue paper. The key concept they tried to incorporate was whether areas of influence could be defined in a way that reflects the influence of three pollutants.

Vince Brisini asked if option 1.d intended that strategies be established by source category or sector, but controls would be implemented concurrently (or not.) Mel Zeldin said the option could support either implementation approach.

Conrad Schneider noted that the Clean Air Act lacks the tools to address large source areas in terms of areas of influence. He stressed the threshold to form these areas should not be too high or too technical because evidence shows that large-scale regional strategies are needed. He suggested broadening the definition of areas of influence to address individual pollutants in addition to combinations of pollutants. He also asked if option 1.b, which sets a de minimis level of source emissions considered to be of concern, is a categorical de minimis or a source de minimis. Mel Zeldin said either form could be used.

Joe Paisie noted that, in terms of PM, monitoring data could augment modeling data. However, what would be done in the case of ozone should modeling prove insufficient. Mel Zeldin said the options assume that adequate modeling tools and inventories are available. Conrad Schneider urged that the challenge is to think of other ways to achieve these goals besides complex modeling demonstrations. Jim Salvaggio said, in terms of ozone, the ability to identify sources is an issue. The problem is each individual source is likely to be insignificant, on its own. Brock Nicholson added that implementing this strategy will require technically sound tools to attribute problems to sources, because the States will have to make a showing. Steve Pezda said models should not be ignored, just because they will take time to develop.

The group discussed the use of the term "RACT" as an example of the suggested level of control. The group agreed to delete this term because it carries unintended connotations. Jim Salvaggio also suggested use of a term other than "nonattainment area" to describe an area that does not meet the standard.

Greg Schaefer said the level of background is a key issue. He agreed to help the authors expand this issue.

Vince Brisini noted that options 1.b through 1.e. may require regulatory changes, and this qualifier should be added to the paper.

After a brief introduction of option 2, the meeting adjourned. The discussion of this issue paper will continue with the next conference call.