Draft Summary

Base Programs Analyses and Policies (BPAP) Work Group Conference Call

June 18, 1997

I.	PURPOSE

The Base Programs Analyses and Policies (BPAP) work group held a conference call on June 18, 1997 to discuss the June 16, 1997 draft of the Classifications of Designated Areas Under New NAAQS issue paper (draft #7).

II.	PARTICIPANTS

Attendees:

Jerry Golden (Co-chair), Joe Paisie (Co-chair), Vince Brisini, Richard Chastain, Rich Halvey, Dennis Lawler, Barbara Lee, Bill Luneburg, Steve Pezda, Jim Ralston, Jim Salvaggio, Greg Schaefer, Eric Skelton, Jean Vernet, Callie Videtich for Dick Long, and Mel Zeldin.

Work Group Members Not in Attendance:

David Baron, John Crouch, Gregory Dana, Richard Dworek, Jeff Gabriel, Steve Gerritson, Robert Kappelmann, Arthur Lee, Arthur Marin, James Mentesti, Joe Minott, Brock Nicholson, Bob Palzer, Richard Phelps, Richard Schoeneberg, and Herb Williams.

Other Attendees:

Rebecca Battye and Wendy Vit, EC/R Incorporated (Environmental Protection Agency (EPA) contractor support).

III.	ACTION ITEMS

Joe Minott of the Clean Air Council has been added as a new member of the BPAP work group.

The next BPAP work group conference call has been scheduled for July 2, 1997 from 11:00 a.m. - 12:30 p.m. (Eastern time). Phil Lorang of EPAs Office of Mobile Sources (OMS) will give a presentation on the Mobile Sources Technical Review Federal Advisory Committee Act (FACA) process. Background information will be distributed to work group members prior to the call.

A recommendation on classifications needs to be presented to the Subcommittee at the August meeting. In order to move forward on a recommendation, the following three questions will be distributed to the work group: 1) Does it make sense to have a classification system? 2) If so, should the classification system have a substantive purpose or a public education purpose? 3) If the classification system should have a substantive purpose, what types of requirements should classifications facilitate (e.g., attainment dates, control requirements, planning requirements, RFP requirements, etc.)? Work group members should formulate their responses to these questions in preparation for the July 2 BPAP conference call.

IV.	MEETING SUMMARY

Classifications Issue Paper

Mr. Skelton reviewed the changes that had been made to the Classifications paper based on the June 9 work group meeting in Durham, North Carolina. The former options were rephrased as issues, and, throughout the paper, "controls" was changed to "planning and control requirements." In addition, the concept of using "bump-downs" as a mechanism to reward air quality improvements was incorporated into issue 4 [Should areas be classified to emphasize differences between Areas of Influence (AOIs) and Areas of Violation (AOVs)?]. Finally, a discussion of the potentially lengthy period of time that would be needed to determine the influence of transport was added to issue 3 (Should areas be classified specifically to address regional transport?).

Mr. Skelton explained that options 4a (assign a classification to the AOV to reflect the severity of the nonattainment problem and to prescribe a public education and/or episode-advisory program) and 4b (assign a classification to the AOI which does not address severity, but instead addresses planning and/or control requirements) are not mutually exclusive.

Mr. Ralston asked if bump-downs would involve substantial review time in areas of transport. Mr. Skelton replied that the bump-down proposal is to assess air quality in an AOV. The AOV could be bumped down regardless of whether transport is an issue.

Mr. Luneburg asked if bump-downs would be related to the Reasonable Further Progress (RFP) curve. The bump-down concept might make sense in terms of public notification, but he was not sure about using bump-downs for easing control requirements. If controls are eliminated, continued progress won't be made. Mr. Skelton emphasized that the bump-down concept does not apply to AOIs. It only applies to AOVs as a way of informing the public about air quality improvements. What happens in the AOV would be separate from what happens in the corresponding AOI.

Mr. Paisie asked how the classification scheme proposed in option 4a differs from an air quality index, e.g., the Pollutant Standards Index (PSI). Mr. Skelton replied that the public education purpose of option 4a could be very similar or identical to an air quality index. However, he believed that an index simply reports day-to-day air quality. If an area wants to change the public's behavior on certain days, a program beyond an index is needed.

Mr. Paisie asked if bump-downs would be a mechanism for recognizing that an area is meeting its RFP curve. This concept ties into the RFP metric issue. He suggested that Mr. Skelton add some language indicating that this paper leaves the classification scheme open to absorb or complement whatever metric the RFP subgroup recommends.

Mr. Brisini asked how the issue of bump-downs relates to RFP. The classification discussion should focus on whether or not classifications should carry prescriptive requirements. Mr. Paisie agreed that is the bottom-line question.

Mr. Zeldin commented that if both options 4a and 4b are adopted, two separate nomenclatures should be established: one for AOIs and one for AOVs. The labels for AOV classifications should reflect levels of air quality, and those for AOI classifications should indicate levels of planning and/or control requirements.

Mr. Chastain asked if option 4b implies that controls would be uniform across an AOI. If so, this is inconsistent with previous work group recommendations. Mr. Skelton said the option is intended to be broad enough to allow for the possibility of subdividing the AOI. Mr. Zeldin said the distinctions among the levels of control/planning requirements in the AOI could be reflected in the classification labels. For instance, "selective" or "uniform" labels could be applied based on analysis.

The group discussed issue 5 (Should areas close to nonattainment be classified?). Mr. Paisie commented that since the Treatment of Areas in Which Air Quality Trends Indicate the Risk of Violating an Ambient Standard paper has been accepted by the Subcommittee, the Classifications paper should simply refer to that paper. The Classifications paper should not reopen the debate about what should be done in areas at risk. Mr. Skelton agreed.

The group discussed issue 7 (Should classifications be made to identify core requirements?). Mr. Skelton stated that the options are not mutually exclusive.

Mr. Brisini said one of the options should be to allow AOIs to put together their own set of core requirements. Mr. Schaefer said that approach implies that AOIs will have regulatory authority.

Mr. Lawler felt that issue 7 repeats issues addressed in the Control Strategies paper. He suggested that the paper simply refer readers to the Control Strategies paper. Mr. Salvaggio supported keeping issue 7 in the Classifications paper. It relates the states' obligations to the classifications. Ms. Vernet said the Control Strategies subgroup has begun developing a list of linkages with other issue papers.

Mr. Paisie said the key question is: Should classifications be used to facilitate choosing control strategies? The National Ambient Air Quality Standards (NAAQS) Implementation Process flow diagram presents one approach to integrating control strategies and classifications. He suggested adding the following information to the introductory section of issue 7:

The details of what control strategies will entail are contained in the Control Strategies issue paper. The following discussion takes a broad view of classifications and does not prejudge any decisions about control strategies.

Mr. Zeldin asked at what point the viable control strategies and classification options would be linked. Mr. Paisie said both papers are scheduled to be presented at the August Subcommittee meeting. He proposed that the questions presented to the Subcommittee highlight the linkages between the two papers. The group agreed on this approach. Ms. Vernet will make sure Mr. Skelton receives the latest version of the Control Strategies paper.

Mr. Paisie wanted the group to focus on whether a classification scheme makes sense. If so, the work group should decide what kind of scheme should be designed.

Mr. Luneburg asserted that if the classification scheme does not determine prescriptive requirements and attainment dates, it is not needed. It would be more confusing than helpful. Mr. Pezda agreed and added that establishing fixed attainment dates that vary from area to area acts as a type of classification. Mr. Zeldin countered that classifications are integral to the air quality management process. If the work groups don't address the issue, a de facto classification system will be imposed by the EPA. For instance, the determination of transport-induced versus locally generated air quality problems is a type of classification. Ultimately all requirements will be tied to some type of classification by the EPA. Mr. Pezda disagreed, arguing that, under the proposed AOI/AOV process, areas will make their own decisions.

Mr. Luneburg contended that decisions about classifications should follow the planning process -- Regional Air Management Partnerships (RAMPs), AOVs, AOIs, etc. After planning and analyses, areas would be able to make more informed decisions about classifications. Classifications are icing on the cake; the Subcommittee should focus first on the fundamental issues. Mr. Zeldin agreed but was concerned that EPA will develop some set of descriptors for imposing requirements. Mr. Paisie summarized Mr. Zeldin's concern: If the work groups don't say anything about classifications, the implication is that the work groups feel all areas are the same.

Ms. Videtich supports classifications. What other mechanism could be used for notifying the public of health risks?

Mr. Brisini said the key question is: Should classifications carry prescriptive measures? He is adamantly opposed to prescriptive controls. He supports using severity of air quality to determine the length of time to reach attainment, as well as using the AOI/AOV construct as a type of classification system.

Mr. Ralston proposed an additional classification option. Ozone is an "established" pollutant that areas have been dealing with for some time. On the other hand, fine particulate matter (PMfine) is "new." A simple classification could be set up for PMfine, and a more refined scheme could be established for ozone.

Mr. Paisie said the three fundamental questions are: 1) Does it make sense to have a classification system? 2) If so, should the classification system have a substantive purpose or a public education purpose? 3) If the classification system should have a substantive purpose, what types of requirements should classifications facilitate (e.g., attainment dates, control requirements, planning requirements, RFP requirements, etc.)? A recommendation on the Classifications paper needs to be presented at the August Subcommittee meeting. Mr. Paisie will distribute the three questions to work group members before the July 2 BPAP conference call in order to move toward a recommendation.

General Mobile Source Issue Paper

Mr. Lorang will make a presentation on the Mobile Sources Technical Review FACA process on the July 2, 1997 BPAP work group conference call. Mr. Wolcott said Mr. Lorang could provide a general overview of all the work groups and then explain the Inspection and Maintenance (I/M) and deterioration work groups in greater detail. A half hour would be left for questions. Ms. Vernet suggested distributing background information prior to the call in order to free up more time for questions and for discussion about the Control Strategies paper. Work group members agreed.

Mr. Ralston wanted Mr. Lorang to discuss State Implementation Plan (SIP) planning tools, including MOBILE6 and transport models.