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 28, 1996

Summary June 26, 1996 Base Programs Analyses and Policies Work Group Conference Call

I.	OVERVIEW

The Base Programs work group held a conference call on June 26, 1996 to discuss the issue paper on "Identifying Sources of Influence." There was also a brief discussion of the results of the June 21 meeting between work group chairs and team leaders to discuss overall work group coordination issues.

II.	PARTICIPANTS

Work group:

Joe Paisie-Chair, Vincent Brisini, John Crouch, Richard Dworek, Steve Gerritson, Rich Halvey, Robert Kappelmann, Terry Switzer for Dennis Lawler, Bob Palzer, Steve Pezda, Richard Phelps, Jim Ralston, Jim Salvaggio, Eric Skelton, Jean Vernet, Herb Williams, and Mel Zeldin

Work group members not in attendance (note: some members had trouble calling in):

Jerry Golden-Chair, David Baron, Glen Cass, Gregory Dana, Jeff Gabriel, Arthur Lee, Dick Long, Brock Nicholson, Don Pickrell, Greg Schaefer, and Conrad Schneider

Bob Lopez represented Don Tyler of the National and Regional Strategies work group.

III.	ACTION ITEMS

1)	Upcoming Calls and Meetings. The next Base Programs face-to-face meeting is on July 1 and 2 in Research Triangle Park, North Carolina. A Base Programs work group conference call is scheduled for July 10 from 11:00 to 12:30 eastern. The Base Programs work group will meet on July 29 in advance of the July 30 FACA subcommittee meeting. The CAAAC will meet on July 31. The IIP subgroup will meet on June 27 in RTP. There will be a joint meeting between the National and Regional Strategies work group and the Science and Technology work group in Washington, D.C. on July 22 and 23.

IV.	MEETING SUMMARY

Identifying Sources of Influence

Mel Zeldin led the discussion of issues 1.c and 1.d, which are captured in the issue paper, "Identifying Sources of Influence." The latest version of this paper incorporates comments received in previous discussions and in writing. The order of presentation of issues was revised to enhance the flow of the paper. Also, "areas of violation" (AOVs) and "areas of influence" (AOIs) are defined to avoid confusion with the use of the term "nonattainment area."

Issue #1: Is the existing regulatory scheme adequate for determining nonattainment areas or are new approaches needed? Steve Pezda asked a clarifying question of new option 1.c., which refers to the establishment of national regulations across the country to selected source categories to reduce the need to establish AOIs. He asked how "selected sources" would be defined. Mel Zeldin responded that "selected sources" could refer to source categories, those sources contributing certain pollutants, or sources selected on the basis of the cost effectiveness of control. He said the selection of sources could be its own issue paper. Steve Gerritson agreed, and he suggested the selection of sources might be a topic for the National and Regional Strategies work group.

Bob Kappelmann stressed that a national approach in option 1.c does not remove the need for local or regional controls. Mel Zeldin agreed and noted that whatever is within the local domain will remain in the local domain. He said transport is a separate issue. One work group member commented that the option needs to look beyond national controls such as the Federal Motor Vehicle Control Program. The option should also include information on regional caps, emission trading, etc.

There was a general discussion about the overall presentation of the information in issue 1. Joe Paisie and others suggested that much of the discussion, which is currently presented as options, would be more clearly represented as background. The "Designations" issue paper already presents the need to define AOIs. Other members added that option 1.c recognizes that it may not be possible to define AOIs. Jim Ralston repeated that option 1.c does not preclude local controls, but it does acknowledge that some source categories universally contribute, i.e., automobiles. He said the adoption of national controls removes the debate about transport. Joe Paisie suggested that the future phase II control strategy may be the place to capture the idea of national regulations. Steve Gerritson suggested that this issue paper could merely note an interest in exploring national controls. The National and Regional Strategies group is planning a paper on regional administrative mechanisms that explores national controls. He suggested that the Base Programs work group collaborate with them on the topic.

Mel Zeldin summarized the outcome of the discussion on issue 1 as direction to move options 1.a and 1.b to the background section. Option 1.c will be the subject of a future joint issue paper with National and Regional Strategies work group.

Issue # 2: How are co-AOVs determined? Mel Zeldin clarified that the issue paper was developed to address areas that have both PM and ozone violations, although the scope could be expanded to address single pollutant areas too. In his mind, this grouping does not establish control priorities, but is only for the purposes of setting boundaries of AOVs and AOIs. Vince Brisini raised the issue of how new sources of precursors would be treated under this scheme and whether there could be nonattainment consequences. Mel Zeldin emphasized that the basis for the definition of AOVs is whether the public is exposed to concentrations of ozone and PM that exceed the health-based standards for these pollutants.

Bob Kappelmann said that violations should be determined through the use of monitoring data. Modeling should be used to identify the geographic area of concern. He does not want to see a situation where modeling alone could cause a nonattainment area or AOV.

There was a discussion of the size of AOVs. Vince Brisini raised a concern that the issue paper implies that AOIs could equal AOVs, which would lead to a huge nonattainment area. If this is done, the significance of how one defines nonattainment is reduced. Bob Kappelmann suggested asking the Science and Technology group if there is a simple rule of thumb that could be used regarding the expected influence of an AOV. For example, the AOI would extend so many kilometers from the AOV. Jim Salvaggio objected and said this approach takes the AOI concept in the wrong direction. Instead, the paper should focus on the regional nature of the problem and take the broadest possible approach to decision making. Bob Palzer agreed. Vince Brisini said, however, that some areas need more extensive intervention than others. Jean Vernet added her concern that the public would be misled regarding the actual air quality in these combined areas. Mr. Kappelmann said the AOV could be larger than a county, but if the area becomes too big one encounters local control and States' rights issues. Mel Zeldin pointed out that it is very likely an AOV could cover a two-State boundary area.

Jim Ralston sees a motivation to identify areas where there are violations for both pollutants and then give those areas some sort of priority treatment. He prefers the simplicity offered by options 2.a and 2.b, but added that option 2.b would be improved by adding a demographic component to the boundary definition to incorporate entities such as consolidated metropolitan statistical areas (CMSAs). He said there should be a presumption that data from any monitor could be used rather than insisting on co-location of ozone and PM monitors. He concluded that the increased data needs associated with options 2.c and 2.d cannot be realized in the near future given likely available resources.

Issue #3: How are co-AOI's determined? Mel Zeldin introduced this issue and noted that the first set of options are heavily dependent on the availability of modeling tools.

Vince Brisini said the discussion of options should move away from the use of the terms "upwind" and "downwind" and focus simply on contributing sources. Several members agreed that the suggested terminology is more appropriate, especially when considering multi-day events. Members also noted that the designations of "upwind" and "downwind" can change in a single day as the meteorology changes.

Joe Paisie suggested that the discussion of options be changed to focus on broader issues. For example, should AOIs be defined as simply as possible or is more complexity needed to capture crucial nuances in establishing boundaries? Vince Brisini suggested a simple approach based on a determination of the half-life of precursor pollutants and a geographic boundary (e.g., 300 miles) to capture those pollutants. Mel Zeldin noted that none of the proposed options may be particularly "simple," even options 3.d and 3.f that do not rely on models.

Steve Pezda suggested eliminating option 3.c because it is too limiting. He also suggested adding an option that reflects the use of a combination of tools suggested in the other options.

Jim Ralston said that the boundary of the AOI should include the total area of the AOI for ozone and the AOI for PM-fine. Another caller agreed that a bias toward a larger area is appropriate for planning purposes. Similarly, she suggested that small sources should not be discounted. Bob Kappelmann said there should be a degree of latitude and flexibility in defining the AOI. He noted that inventories show that small sources can cumulatively make significant contributions.

Mel Zeldin summarized the outcome of the discussion on issue 3 as a consensus that AOIs should be defined broadly and that as many tools as possible should be used in making the definitions.

Discussion of this issue paper will continue at the July 1 and 2 meeting in RTP, North Carolina.

Consensus Position on Coordination Among Work Groups

Joe Paisie summarized the outcome of the June 21 meeting between the work group co-chairs and EPA team leaders. This summary was provided to Base Programs participants as Attachment 3 to the June 26 meeting announcement on the TTN. (The summary is not included with this summary.) Mr. Paisie said that the overall guidance reflects the FACA subcommittee's direction that more coordination between the work groups is needed and the Coordination Group's need to not be in the position of having to resolve differences between the other work groups. Mr. Paisie said that the co-chairs are in the process of assigning teams to resolve overlapping issues.

Agenda for July 1 and 2 Meeting

There was a brief discussion of the tentative agenda for the July 1 and 2 Base Programs work group meeting in RTP, North Carolina. Mr. Paisie said he hoped the group could come to closure on the remaining changes to the "Too Close to Call" and "Population Weighting" issue papers, complete the discussion on the "Identifying AOIs" issue paper, and start the discussion on the "Monitoring Incentives" issue paper.