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

May 24, 1996

Summary

May 7 and 8, 1996 Base Programs Analyses and Policies Work Group Meeting in Research Triangle Park, NC

I.	OVERVIEW

The Base Programs work group met on May 7 and 8, 1996 to discuss the revised draft issue paper on "Designation Issues for New NAAQS (Issues 1a and 1b), and "comments on the Interim Implementation Plan (IIP). In addition, Joe Paisie provided an update on the development of revised ozone and particulate matter (PM) National Ambient Air Quality Standards (NAAQS).

II.	PARTICIPANTS

Work group:

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

Others:

Rebecca Battye and Beth Friedman, ED/R, Incorporated (EPA contractor support).

Work group members not in attendance:

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

III.	ACTION ITEMS

1)	Some members said they could not easily retrieve issue papers from the bulletin board, and requested hard copies. The group agreed that authors would transmit issue papers via e-mail and fax to those without e-mail. See discussion under Schedule Matrix for more information on issue paper distribution and other protocols.

2)	Base Programs conference calls are scheduled for May 15, June 12 and 26, and July 10. The group will have a face-to-face meeting on May 29, in advance of the May 30 FACA meeting. Future conference call agendas will place the substantive items first, and the administrative items will be reserved for the end of the call.

IV.	MEETING SUMMARY

NAAQS REVIEW

(Overhead slides used in this discussion are not included in this summary.)

Joe Paisie updated the group on the latest developments in the ozone and PM NAAQS standards setting process. He said the ozone form of the standard options have been expanded to include an option that involves a two-tier test for compliance. One test would be set such that an area would clearly not comply when the fifth highest 8-hour average concentration (averaged over three years) exceeded 0.08 ppm (for example). The 2nd test would be set such that an area would clearly comply when the second highest 8-hour average concentration (averaged over three years) was less than 0.08 ppm (for example). Those areas with monitoring data in the "gray zone" between these two boundaries would be considered "in the range" of compliance.

The 8-hour average would be developed on a rolling average basis. The highest 8-hour value from each monitor for each day would go into the 3-year calculation. For example, to determine if an area were clearly in attainment, for a given monitor, the second highest reading in each year for three years would be averaged. This average value would be compared to the standard.

One member noted that shifting to an 8-hour standard from a 1-hour standard will move the location of the peak air quality readings.

Joe Paisie summarized current staff recommendations for the PM standard.

1.	Current PM NAAQS should be revised.

2.	Ambient particles, including both fine and coarse fractions should be the focus.

3.	Fine and coarse particles should be considered separately.

4.	PM-2.5 should represent the fine particles.

5.	PM-2.5 should have two averaging times--short term (one expected exceedance averaged over 3 years) and long term (expected arithmetic average).

6.	The short term levels should be 18-65 micrograms/m3 and the long term levels should be 12.5-20 micrograms/m3.

7.	PM-10 should represent coarse materials.

8.	There are two PM-10 options:

a.	Retain current annual standard alone or in combination with the 24-hour standard.

b.	If the 24-hour standard is retained, consider a more robust form to better address the episodic nature of coarse particles.

9.	The short term level should be 150 micrograms/m3 and the long term level should be 40-50 micrograms/m3.

This approach would add ozone nonattainment areas relative to the current standard, based on 1990-1993 monitoring data. It was noted that data from 1994 and 1995 will make a difference in the calculations for Texas, adding additional nonattainment areas. Increased numbers of PM nonattainment areas are also predicted. In response to a question, EPA stated that the 1994-1995 monitoring data will be available in the next month or two. Nationally, 1991-1993 looks worse than 1994-1995.

SCHEDULE MATRIX

(The schedule used in this discussion is not included in this summary.)

Jerry Golden presented a schedule matrix of issue papers and other key milestones. He noted lessons learned from development of the first issue paper. One was that too many authors make it hard to meet schedules. He suggested that no more than two individuals co-author any of the future papers. He also noted it is difficult to finalize papers. He asked members to electronically transmit comments to the author(s) in advance of the meeting devoted to discussion of the issue paper. Joe Paisie encouraged authors to begin their issue papers early, so that more time for review could be provided.

There was a discussion of the value added by having the co-chairs perform an initial screen of the issue papers before transmittal to the rest of the work group. The group agreed to delete this step in order to provide more review time.

The group discussed the need for the authors to receive written comments. This will provide documentation of comments and help ensure they do not get "lost." Written comments are also important because not all work group members are on every call.

Some members said they could not easily retrieve documents from the bulletin board, and requested hard copies. The group agreed that authors would transmit issue papers via e-mail and fax to those without e-mail.

Dick Dworek said he was looking for a co-author for issue paper 1e, incentives for monitoring.

ISSUE NUMBER 1a AND 1b PAPER

(Overhead slides used in this discussion are not included in this summary.)

Steve Gerritson stated that the purpose of the issue paper was to acknowledge that the current system was unable to deal with transport into nonattainment areas. He presented five slides that were prepared by Joe Paisie and Jerry Golden. These slides included a summary of the options for presentation and a proposed consensus position. Mr. Gerritson stated that, although this paper addresses the basis of the designation, the real issue is the size of the nonattainment area.

The first slide summarized the state of data and modeling capability for ozone, PM-fine, and visibility. The second slide summarized the options comprising the designation basis for ozone, PM-fine, and visibility. The third slide summarized four options for designation criteria. In this slide, "enhanced monitoring" means PM-fine monitoring. The fourth slide summarized designation options. The fifth slide presented the proposed consensus position.

Much of the discussion related to this issue paper is grouped under three general headings: modeling, monitoring and designations.

Modeling

It was stated that additional models, besides MODELS3, are available for PM modeling. Who performs the modeling is an issue. Especially when there are areas with overlapping jurisdiction, if each area models using different data sets, the modeling results will be inconsistent. Another problem is that State agencies will not necessarily have the resources to do their own modeling. Joe Paisie said this group can recommend modeling as a tool for designation determinations and then make a recommendation that there is a resource need as well.

One member recommended that care be used in the use of the term "modeling," which can take on very strict, limited connotations. Instead, the paper should emphasize a broad definition of modeling as an interpretation or analysis of data. "Statistical evaluation" was proposed for the term modeling.

Monitoring

One member noted there is no Federal Reference method for PM-fine monitoring, which could limit implementation of options requiring these data.

There was a discussion on the use and need for constituent or speciated data. One member stated that the process should parallel the health effects research (which is often constituent or species specific). In contrast, another member responded that the form of the standard, which is mass-based, means that designation options should also be mass-based. However, the CASAC meeting is the proper forum to address the form of the standard. It was also noted that data from filters can be archived and subsequently analyzed. A recommendation to add a footnote regarding the ultimate need/desirability for speciated data was made.

Concern was expressed that the plan to monitor every six days could result in a single monitored event being counted as six exceedances. This problem is due to a flaw in the Federal Reference method. Joe Paisie suggested adding another footnote requesting daily monitoring.

One member recommended a monitoring board to ensure that all the monitors are not in one county. Another member said an area cannot be designated as a zone of influence based on monitoring. Joe Paisie responded that what is being discussed is establishing a source receptor relationship. He suggested using whatever information is available. He noted that particles do have a signature or carry a tag to facilitate identification of their source.

One member noted that if the monitoring method changes, the values will change. One needs to consider if changing the monitoring method (or using data collected under different monitoring methods) will make the standard more stringent.

There was a suggestion to establish an exposure monitoring network, but this title was found to be limiting. An understanding of both exposure and transport is needed. The emphasis of the network should balance population exposure and problem definition to address transport. How can incentives for monitoring be created?

One member stated that his organization voluntarily placed a monitor in Phoenix. Using this data for a nonattainment designation would place a disadvantage on that area. Another member responded that the monitoring should be required. However, Steve Gerritson said this requirement would be an unfunded mandate.

One member stated that the first step is to develop an air quality data base and a reference method that can be relied upon.

One member stressed not to use existing PM-10 data as the basis for PM-fine designations. Different analytical techniques provide different results, and PM-10 data should not be used to determine the actual stringency of a program. PM-data could be used to identify problem areas.

Designations

It was suggested that Option 1 for PM-fine should include the use of PM-fine data, where available (the current option is to base the designation on available PM-10 data). A problem with this approach is that PM-fine air quality data can be based on several different monitoring methods.

One member stated the options, presented in the paper and on the slides, still address regional problems as if they were strictly local. State-specific options and schedules only address local problems. It was suggested that the group should take a broader look at designations.

It was suggested that the term "nonattainment areas" be avoided in the issue paper.

One member proposed the use of an unclassified designation for PM-fine until monitoring is complete because the use of modeling and a broad area to capture transported pollutants will be politically infeasible. A more defined attainment area with some recognition of transport should be selected. Joe Paisie asked if the PM methodology for designations would mirror the ozone methodology, assuming PM-fine data were available. Mr. Paisie stressed that the same logic (that is applied to ozone) could be applied to PM-fine, as opposed to waiting 2 years (to collect air quality data) to start to think about PM-fine designations.

One member proposed the idea of two classes of designations. One class would be health-based, which would be driven by monitoring. The other class would be considered a planning designation, and it would be driven by modeling. There was general agreement regarding the validity of this approach. However, one member stated that the advantage of a formal designation is that it requires something to happen.

One member cautioned against forgetting about natural events.

Joe Paisie clarified that the geographical aspects and institutional mechanisms are being addressed by the National and Regional Strategies (N&RS) group. Recommendations from the N&RS group were distributed during the meeting. One member asked, "What is the goal of the designation? To identify the area, or get controls from the upwind sources? What is the mechanism to achieve these controls outside of your areas jurisdiction? Is the goal to identify the emission sources or to achieve reductions?" Steve Gerritson said the goal is also to alert the public that there is an air quality problem. Joe Paisie said that using sections 110 and 126 actions (or nonattainment designations) has not worked regionally. If the designation process is not the mechanism to address regional transport, a strong signal must be sent to N&RS.

One member stated there are many problems associated with a broad nonattainment area unless it is all 38 eastern states. There was a suggestion that the nonattainment areas need an additional burden such as the development of a plan. In this way the nonattainment area can bring in the transport.

One member noted that one can designate without speciation data, but speciation data are needed to do the control plan.

One member stated that this issue has more complexity than "designation" and "nonattainment." What is needed is to define areas where there is:

1. local nonattainment,

2. regional nonattainment,

3. health impact area.

Another member asked if these areas will carry a burden in terms of control requirements? Steve Gerritson said zones of influence definitely carry a burden, and public health areas may carry a burden.

An addition to bullet 3 of the Designation Options slide: Areas for designation have a control strategy burden was suggested. Under this recommendation there is a "presumption." Then there is a need to determine if the presumption is true, which would result in additional monitoring. Jerry Golden reiterated this thought. Is the burden on a State to say "I've monitored, I have no exceedances, and I've analyzed, and I'm not hurting anybody?" One member stated that individual sources can generally state that they do not individually contribute to nonattainment, but in the aggregate they are the problem.

The question was raised about how to deal with overlapping areas. For example, Tennessee would be part of the southeast region and the midwest. The States would be grouped. Models for how the groups would operate include OTAG, Grand Canyon, and WESTAR.

One member reiterated that if there is existing PM-fine data showing a violation, the area should immediately be designated nonattainment without waiting an additional period of years. Otherwise the designation and resulting control strategies are put off for too long. In addition, PM-10 data may be of use for immediate designations.

Joe Paisie stated that in a complicated case, additional time is needed to look at transport. One member responded that in this type of case, the State should designate, do a SIP, and identify transport. Delaying designation delays the solutions.

One member stated there is no question Southern California will be in violation no matter what a future PM-fine standard looks like. The PM-fine problem will make ozone look easy by comparison because southern California already has an aggressive control program. California must have the maximum amount of time allowed by the CAAA to find technological solutions. The public will resist when they perceive that the control strategies cost them money or inconvenience. Examples of public backlash include resistance to reformulated gas and higher prices and the ride share program. Added time to comply with a revised standard will allow for development of better consensus with the regulated community.

Programs that are already on the books, but have not been fully implemented, should be identified to determine if more reduction strategies are needed or if the answer is better implementation of existing strategies. Steve Gerritson responded that the public should not be exposed to unhealthy air for the convenience of the agencies. The no backsliding principle will help.

EPA asked if there could be some intermediate requirements for areas that have a local problem (for example, wood smoke). Steve Gerritson said PM fine is likely to be the result of transport, and early reductions could lead to lawsuits and relocations. One member asked if, under the initially unclassified option, the time could be used to implement local controls to avoid a nonattainment designation. This could potentially solve the concern for a newly designated area. There is tremendous incentive for areas to implement early controls and avoid a nonattainment designation. It was stated that the whole second page of the Westar document, distributed at the meeting, deals with this issue. Another member stated that while in the unclassified state, areas should not be penalized for early reductions taken to avoid nonattainment designation.

One member stated that as the complexity of this issue increases, too much effort will be spent explaining the issue and addressing political concerns. Sometimes there is a need to go slow at the beginning to go fast at the end.

One member asked is the intent of the designations to address the quality of the air or the sources of the emissions? Unhealthy areas should be designated as soon as possible to inform the public of a problem. There should be fairly swift implementation of controls.

The time required to develop plans is not a designation issue. If the nature of the problem is transport, EPA can provide more time. One member stated that delaying designations puts us on the path of delays. Planning concerns do not relate to designation.

There was clarification that there are extensive areas with no ozone monitors. The delays, where there are data, are only for PM. For ozone, the designation and monitoring plans should be based on existing statutes. One member noted that PM designations without a federal reference method invites lawsuits.

Jerry Golden asked if the option "areas are immediately classified as nonattainment" should be included? Language about regional haze planning areas should be added.

INTERIM IMPLEMENTATION PLAN

The discussion of the IIP focused on a couple of general headings: timing, definition of backsliding, substitutions, and equity. The discussion resulted in a set of general principles for the IIP that are to be forwarded to the Coordinating Group.

At one point, the discussion shifted to the definition of "cost-effectiveness". John Chamberlain summarized the IIP proposed by Alan Krupnick. He encouraged members to read his proposal as a separate document (as opposed to comments on the IIP) as it proposed measuring benefits against costs. One member stated that Alan Krupnick's proposal does not consider the unknowns.

Timing

The first issue discussed was how long the IIP should remain in effect. Options include until SIP approval or until the State submits a SIP proposal. This produced a lot of discussion. One member noted that Texas enacts State measures before SIP approval, because the approval process can take so long. Joe Paisie noted that the current system results in sources required to meet two sets of rules (State and Federal). According to other members, related concerns include the Federal enforceability of title V control measures and the possibility of citizen suits. One member suggested that EPA be required to give a preliminary assessment of the SIP within a brief amount of time (e.g., 90 days). Another member noted that generally the State works with the Region in advance of SIP proposals in any case, and that the process includes an opportunity for public review and comment.

Mark Kataoka noted that the purpose of the IIP is to give guidance to the States and not to focus on the sources' obligations. Sharon Reinders noted the IIP is not the arena to resolve SIP processing issues.

One member was concerned that without SIP approval, a State would be required to enforce the old SIP or face citizen actions. The IIP should include changes in SIP approval mechanisms or provide specific protection for the State/source in the interim. Another member provided an example where an upwind State decides to relax NOx controls, which would adversely affect the downwind State. States need the SIP process, with its notice and comment provisions, to address these concerns. EPA noted that as part of a SIP submittal, States have to certify that they are not causing downwind problems. The State still has to meet an attainment deadline.

One member suggested using the STAPPA proposal for a panel of experts to act during the interim period. The panel of experts could recommend suspending 15% VOC reduction when it's really a NOx issue. Another member objected to this proposal because there was no regulatory certainty for industry.

Another member cautioned that the IIP should not reward States that have delayed developing or implementing control strategies. If the new SIP is no good, the state is off the hook for the existing requirements. The deadlines and statutes in the 1990 CAAA should be adhered to. Emission offsets, and Enhanced I & M were fought for and they should not be given or traded away in the IIP.

One member suggested adding some language to the IIP to clarify that the intent is to help States understand EPA's thinking.

One member asked if an ozone SIP is approved before a PM SIP how does that effect the policy? EPA clarified that the new NAAQS for PM-fine and ozone are supposed to be promulgated at the same time. Therefore, the area would have integrated SIPs.

Definition of Backsliding

The group tried to define "no backsliding." Progress toward the new NAAQS means no backsliding. All programs in place will stay in place. Requirements for new programs (e.g. 3% ROP) will also stay in place.

One member proposed a method for quantitatively defining no backsliding. If you freeze the current requirements and you trust your model you can define what would be accomplished (in terms of air quality benefit) with the current requirements. Now you can work with that knowledge to find a program that is more cost-effective. Combine this knowledge of what current requirements will do with requirements on the National level (e.g. CTG's and emissions caps). A multiple pollutant approach can also be adopted. The proposal is to use the 3% rate of progress requirement to find the environmental target.

One member asked How do you model it? Who's the reference? Joe Paisie asked if the model needs to be defined. Another member suggested rephrasing the term from "no backsliding" to "progress toward attaining the new NAAQS."

In summary "no backsliding" means continue progress, use equivalency, alternatives can not work negatively towards other programs. No backsliding becomes a basis for reasonable further progress (rate of progress - ROP) and is the basis for the integration of the programs (i.e. the requirements under the existing NAAQS and the requirements under the revised NAAQS).

Substitutions

Jerry Golden raised the potential for ton for ton substitutions that are not part of a current trading program. He asked whether, for example, the substitution of VOC requirements (enhanced inspection and maintenance) for NOx requirements would require a SIP revision. Sharon Reinders said a revision would be required. One member noted that if nonattainment areas are defined more broadly, there will be incentives to replace current attainment area controls with current nonattainment area controls. Another member said the IIP should prohibit backsliding and that a savings provision should apply. The EPA needs to make a judgement about allowing the substitution of measures.

One member noted that the new NAAQS will need even more tightening and therefore substitutions will be needed to meet the milestone requirements. There was a suggestion to keep substitutions simple for the States. Allow substitutions of all VOC, or all VOC for all NOx.

This work group posed two questions to the other work groups to facilitate the development of recommendations regarding substitutions. The National and Regional Strategies (N&RS) workgroup was asked "Do we have any way to facilitate substitutions?" The Science and Technical Support workgroup was asked "What do you think about substitutions." The science group does not like ton for ton substitutions. A model is needed to consider chemistry, transport, etc.

One member proposed the following example for a substitution. Philadelphia has a 3% plan. In order to permit a substitution, Philadelphia would first have to show equivalence to the 3% reduction. Second they would need a stimulus, therefore, leave the 3% requirement to keep them looking for that air quality equivalence reduction.

One member asked "What are the boundary effects of these substitutions? How regional do you go?" Another member provided examples of the insensitivity of atmospheric chemistry models. He stated that their model shows that Whiteface mountain is not affected by transport. Also doubling emissions in a county increases ozone by 1 ppb. Joe Paisie acknowledged that there may be limitations in the tools but asked the group if there is a problem with this approach conceptually.

One member asked if the environmental benefit test would have to be done for both pollutants? It was also pointed out that there are attainment dates which could require more than 3% emission reductions.

One member stated that the fallibility of the models is the reason a lot of specific measures are in the 1990 CAAA. Another member responded that the models don't have to be accurate they have to be relative. There would be consensus on the policy if mandated requirements like I & M were not discarded. Joe Paisie responded that I & M would not be abandoned (because the emission reductions are still needed). Another member stated the I & M fight will go from the Feds to the States.

One member requested that a health risk perspective be used to analyze substitutions. What is the health difference between a 2.5, 3, or 3.5 % reduction in emissions. Another member responded that lowering the concentration of ozone is the goal not a given percent reduction in emissions.

One member asked for some specific examples of substitution strategies. For PM, examples include trading power plant emission reductions for street sweeping. Or, diesel emissions in an urban area for street sweeping. For ozone, examples include, achieving a much larger ozone impact by reducing NOx emissions in the southeast than by reducing VOC emissions.

One member noted that trading urban NOx for urban VOC doesn't work very well. As an example, the lack of VOC controls in Pittsburgh is why they haven't attained.

One member stated that in southern California the new standards will result in a geographical shift in the population exposed. Will the substitutions reduce the risk to the new population? Will substitutions favor reductions closer to the source or optimize reductions to reduce exposures to new populations?

One member asked "How do you modify the requirements of Subpart 1 without changing the NAAQS?" Another member responded that under a new SIP you could still have these substitution measures. This policy would allow the substitutions earlier.

In summary, substitutions can not adversely affect the other NAAQS (i.e. ozone alternatives versus PM). There is a heavy reliance on current models for equivalence determinations - and a limited desire for ton for ton substitutions. Substitutions will allow for more cost-effective measures but must continue progress towards attaining the new NAAQS.

One member stated that substitution is a nice concept but no one will be able to do this and be sure of their air quality benefit. One member asked if the air quality benefit should be better than equivalent to address the uncertainty in the models? Another member responded that the models are only good at directionality determinations.

One participant asked if the group could agree on a fundamental set of required measures?

Joe Paisie summarized the options available to the group regarding substitutions. The first option is a free for all with the model as final decision maker (in terms of equity of the air quality benefit). The second option is also a free for all with the model as decision maker and an additional emission reduction required (a fudge factor) to account for the uncertainty in the process. The third option is a list of requirements that everyone is required to do and beyond the required actions, substitutions are allowed. This third option doesn't really add substitution or flexibility to the current system.

One member stated that the substitutions he has heard in the examples sound like great additional controls. Another member disagrees with the model as the decision maker. The decision maker must be the States. Another member commented on the offset requirement stating that if his area bumps up the offset will not get much because their problem is automobile emissions. Another member responded that indirectly, the offsets will force industry to support the automobile and area sources reductions.

Joe Paisie asked the group to think quantitatively about the substitutions. Ton for ton in 1e has not been addressed yet and it may need to be left in as an option. Perhaps % for % would work? One member stated that these substitution allowances are already allowed in the act. There is an equivalency statement for vapor recovery and I&M. In addition, section 182cC is about alternatives to 3%/year. Another member concurred that these substitutions are already allowed within a nonattainment area, however the bounds of where the substitutions are allowed can be expanded.

Equity

Joe Paisie asked the group to address the issue of equity. Some states have done what they can and others have not. The IIP does not deal with that situation. What should the group say about the delinquent states?

One member stated that at some point the states need to shift their resources to start planning to meet the new standard. Therefore a time must be chosen when you make the change. Continuing with the old requirements is not necessarily good.

One member asked if EPA will continue with bump ups after the new NAAQS? EPA responded that bump ups are not part of reasonable further progress (ROP), they are part of the old standard and the classification schemes. One State mentioned that they are scared they'll be bumped up in mid 1997 and have to work with that load of requirements at the same time they're trying to address the new standard.

One member stated that the process must be fair to areas that have done the prescribed measures. Joe Paisie reiterated that this member believes that an area should not be allowed to substitute for measures that were previously required for which the area is delinquent. However, areas with existing plans should be allowed flexibility to go toward the new plan without being held to the old standards.

One member asked if the basis for the substitution should be that the delinquent areas could catch-up.

One member stated that the integration of the two timelines (requirements under existing NAAQS and requirements under revised NAAQS) is in the loss of the line between ROP and no backsliding.

Joe Paisie asked the group if delinquent areas should be required to adopt measures at a faster pace than areas that have filed plans and enacted measures, in order to catch up. Is this issue really part of the IIP? The substitution issue is needed because it allows areas to get emission reductions outside of the nonattainment area.

One member clarified that outside of the transition policy these issues will be in the new policies developed under the new standards. Joe Paisie responded that this group has the ability to give the States flexibility to go after these measures or reductions.

One member proposed that the States be held harmless for past delinquencies and they be expected to develop plans and adopt measures at the same pace as areas that have developed plans and adopted measures. Another member responded that to "hold harmless" will result in people stopping all progress. This member suggested that States should be expected to make progress and have EPA deal with the delinquencies on a case-by-case basis.

One member clarified that the obligations are: did the area submit the 3% plan, adopt I&M, etc. The areas must still meet those obligations.

IIP PRINCIPLES

During the final lunch break, the notes on the flipchart were transcribed. The final two hours of the meeting were spent making minor editorial modifications to the wording of the IIP principles. The IIP principles from the meeting are:

Interim Implementation Policy Principles

Prevention of Backsliding

-	all programs stay in place

-	requirements for new programs stay in place (e.g. 3% ROP or other actions to meet milestones)

1.	Current program provides rate of progress or "glide path" to govern actions in the interim: Goal is progress towards attainment of new NAAQS

-	ozone bump ups do not occur

-	PM dependent upon standard

2.	Satisfaction of requirements is possible through substitution of alternative measures.

3.	Substitution can be either a ton for ton basis (of the same pollutant), or on an equivalent or greater air quality improvement basis. (If modeling of basic measure/strategy lacks the sufficient resolution to show AQ improvement, or go back to substitution based on directionality.)

4.	Substitution has the potential to provide for implementation of more cost-effective / public health / ecosystem / good science strategies and provide opportunities to expand the area from which creditable reductions can be obtained.

-	substitutions should not exacerbate the other NAAQS

-	mechanism for trading may/will result in a greater than 1 for 1 exchange

5.	Revisions occur as a part of the SIP process.

6.	Strong concerns expressed regarding the movement away from the "act mandated measures." Fundamentally disagree with substitutions.

7.	Sentiment to include risk concerns.

Joe Paisie asked the group for comments. One member commented that these statements do not address how EPA will deal with delinquent areas. Another member commented that the intent of IIP is to integrate the timelines (from the current standards to the timelines under the revised standards). Therefore this intent needs to be clearer somewhere in the document.

Joe Paisie clarified that these principles will accompany the NAAQS proposal. The remaining pages of the IIP or the details of the IIP will be completed in the October and November 1996 time frame.

As a final note one member commented that they want EPA back in the role of reviewer of SIPs because of the role of transport.

Next Steps

The next step is to give the Coordination Group an indication of what happened at the meeting. (This was accomplished by tying into their Wednesday afternoon call on 5/8/96). The IIP principles will also be reviewed by the FACA Subcommittee.

Joe Paisie asked if any members had additional outstanding comments. One member responded that the issue of bump ups runs contrary to the equity concerns. Another member reiterated that a comment they made through AAMA was to improve the models.