July 18, 1996

Draft Summary

July 1 and 2, 1996 Base Programs Analyses and Policies Work Group Meeting at the EPA Environmental Research Center, Research Triangle Park, North Carolina

I.	OVERVIEW

The Base Programs work group held a meeting on July 1 and 2, 1996 to discuss the following issue papers: 1) Alignment of Boundaries, 2) Monitoring Incentives, 3) Population Weighting of Monitors to More Accurately Represent Personal Exposures and 4) Too Close to Call.

II.	PARTICIPANTS

Work group:

Jerry Golden-Chair, Joe Paisie-Chair, Vincent Brisini, Richard Chastain, John Crouch, Richard Dworek, Steve Gerritson, Rich Halvey, Robert Kappelmann, Arthur Lee, Brock Nicholson, Bob Palzer, Steve Pezda, Jim Ralston, Greg Schaefer, Jean Vernet, Herb Williams, and Mel Zeldin.

Work group members not in attendance:

David Baron, Glen Cass, Gregory Dana, Jeff Gabriel, Dennis Lawler, Richard Phelps, Don Pickrell, Jim Salvaggio, Conrad Schneider, and Eric Skelton.

Other attendees:

David Chock, Tom Helms, Donna Lamb, Bob Lopez, Rebecca Battye and Beth Friedman (EC/R--Environmental Protection Agency (EPA) contractor support).

III.	ACTION ITEMS

1.	Mr. Lopez is to distribute copies of the slides developed from National and Regional Strategies (NRS) Work Group presented at the May 30, 1996 Federal Advisory Committee Ace (FACA) meeting.

July 1, 1996

IV.	MEETING SUMMARY

Mr. Golden introduced Bob Lopez and Donna Lamb from the NRS work group. Dr. David Chock, a member of the Science & Technical Support (STS) work group, also attended the meeting.

Mr. Palzer asked how the coordination with NRS and STS work groups will happen. Responses were that the NRS meeting on July 22 and 23 is open to members of the Base Programs work group who want to attend. The integration of the control strategies approach will be discussed at this meeting. The work groups have assigned members to follow each issue paper in the other groups.

Designations: Identifying Sources of Influence

Mr. Mel Zeldin and Mr. Dennis Lawler authored the issue paper. Mr. Lawler was on vacation and, therefore, could not attend the meeting. He had not reviewed the changes made by Mr. Zeldin based on the previous conference call.

Mr. Zeldin reviewed changes to the paper since the previous draft. Issue #1 is no longer discussed as a discrete issue because the Designations issue paper addresses this issue. Instead the discussion is moved to the background section of this paper.

Control Requirements

Mr. Zeldin had received a letter with comments from David Baron. In summary, Mr. Baron supports national controls because there are no lengthy delays during modeling demonstrations. He also likes the idea of national controls on upwind areas. Mr. Zeldin stated that consideration of national strategies is beyond the scope of this work group, and he suggested that it be forwarded to the NRS work group.

Mr. Lopez noted that one of the NRS issue areas is control regions and that he sees this as a joint issue. He stated that the basic principles that will guide NRS work is summarized on the slides that were prepared for the May 30, 1996 FACA meeting. He offered to distribute copies of the slides to Base Programs members. Mr. Palzer concurred that emissions that are upwind one day are downwind the next. He supports both groups working together.

Mr. Paisie clarified that the overlap issues that would be addressed with joint issue papers are:

1.	Designations,

2.	Alignment of Boundaries,

3.	Integration, and

4.	NSR.

On the integration with the NRS issues, Mr. Lopez stated that there is not a neat line-up from issue to issue between the two work groups, but they line up better on a sub-issue by sub-issue basis. He told the group that it would help NRS representatives to talk about the issues on a sub-issue level.

Mr. Lee noted that issue #4 is a national strategy.

Mr. Brisini stated that the presumption in the paper is that designations will establish where controls will be implemented and that regional controls will be required. He said the paper needs to explain why this is such a significant issue in the beginning of the paper. Mr. Paisie and Mr. Gerritson noted that the rationale for the approach was laid that out in the previous paper and consists of the following options:

1.	Control where we see violations, i.e., status quo,

2.	Broad regions, or

3.	National controls.

Mr. Gerritson agrees that the general approach should be clarified in the front of the issue paper and that general agreement was reached that the old approach doesn't work. Two areas are defined, the area of violation (AOV), where the population is being exposed, and the area of influence (AOI), which contains the sources. Mr. Brisini said the missing link is that the group has never identified how the designation will drive controls. In other words, the significance of the designation needs to be discussed. He added that each paper, Designations and Alignment of Boundaries, should stand alone, and, if necessary, key assumptions should be repeated.

Mr. Ralston concurred that national controls like the federal motor vehicle emission control program (FMVECP) make sense because of factors such as growth in vehicle miles traveled, passenger miles flown, and safety concerns. The final recommendations should be a mix of local and national controls.	Mr. Ralston stressed that there is still a need for local controls because national controls require time to implement. National controls also depend on maintenance. For example, in the FMVECP there still must be a requirement for maintenance of diesel engines and local operators.

Mr. Kappelmann stressed that it is important to clarify that AOVs are related to health impacts and that the public should know where there is a problem with the air. At the same time, the states need the authority to get emission reductions outside the AOV. He also sees a need to take steps at the local level too.

One participant compared AOIs and AOVs to a donut. Sources inside the donut (the AOV) may not have the same control requirements as sources comprising the donut (AOIs). This type of approach has not been allowed in the transport debate.

Mr. Palzer stressed the importance of transport, which drives the need for national standards for woodstoves and cars. The section 112 Maximum Achievable Control Technology (MACT) program for air toxics should also be considered relevant. Mr. Palzer said if an area is going to meet all three standards, larger areas will be required. He also said that the competitive pressures between areas drives the need for national strategies.

Mr. Zeldin asked if one can reference the air pollution level back to the source. Mr. Paisie stated that the group is also assuming that we can identify areas such that everyone does not have to do all of the controls. The group has bought into the idea that control areas are feasible. Mr. Brisini also asked what mechanism will be used to enforce the control requirements.

Mr. Pezda asked to include a discussion of flexibility and cost. Mr. Zeldin stated that Issue #5 addresses this somewhat. Mr. Chastain said the group should keep focused on addressing areas when and where there are problems. He asked the group to avoid mission creep. Mr. Zeldin stated that later discussions for Phase II will tackle some of these details.

Mr. Golden clarified that the Base Programs mission is to start locally and move out. The NRS work group is starting with a big area and moving in. Mr. Golden reiterated Mr. Chastain's request to remember our mission.

Mr. Kappelmann said, unless there is a way to determine the level of significance of the AOI on the AOV, that the entire country could be considered an AOI. He stated that there are some areas where the national program makes sense, and that this program is based on the lowest common denominator controls. The AOIs would be areas where regulatory agencies would be given authority to consider additional controls. He agreed there is a need to determine how to define the different areas. Mr. Zeldin concurred that there will be a need for some combination of both national and local controls.

Mr. Dworek asked if there is an advantage to make the AOV as small as possible from a cost-effectiveness standpoint. The small amount of emissions that pushes an area over the standard could be from a local source. Mr. Zeldin brought up the point of cost versus equity. If the group supports equity, i.e., a "level playing field," the costs will be higher. Supporting cost leads to some areas or sources facing competitive disadvantages, although the overall cost of the program will be less. Mr. Dworek asked if the monitoring and scientific data for an area should be analyzed by all of the stakeholders. This analysis may result in different solutions. Mr. Zeldin reiterated that conceptually this group just needs to define a blend of controls. The details of the program would be a Phase II issue.

Mr. Kappelmann said that cost effectiveness is included as part of Issue #5. Mr. Palzer stated that if the group is going to talk about costs, benefits should also be discussed. Dr. Chock said that achievability should not be ignored. Mr. Pezda would like to add a couple of sentences about cost in the background. Mr. Ralston added that the picture must include the impact on biogenic and urban areas. There cannot be a focus on just the cost-effective controls. Mr. Brisini stated there is a need for a mechanism to determine where there are violations of the health-based standard and how do you get to the sources contributing.

Incorporation of Visibility/Regional Haze into AOI/AOV Concept

Ms. Lamb asked for clarification on where Class I areas fit into the AOV/AOI approach. Mr. Zeldin said that how areas are defined is a later issue. He recognizes there is overlap with respect to NRS issues. Mr. Golden asked if some areas contribute to violations in a Class I area, how would the AOI be defined? He thought the of co-AOIs might be relevant in this case.

Mr. Kappelmann wants criteria to make the areas of overlap manageable. Otherwise, he envisions a 37-state ozone transport assessment group (OTAG) type process. In addition, once Class I areas are added to the AOV's, the AOI's get bigger. Mr. Zeldin wants to focus on each pollutant and area individually.

Mr. Ralston stated that the ozone data are more advanced than regional haze data. He would like to add something that recognizes the differences in the data.

Mr. Damberg asked the group to broaden the definition of co-areas, which is presently limited to ozone and particulate matter (PM). In fact, regional haze should be included. While there are no regional haze nonattainment areas, there are Class I areas that are AOVs. Mr. Ralston said he assumed that ozone and PM-fines would be used to simulate regional haze, because of the lack of techniques to model haze. Mr. Damberg stated that there are post processors that can model light extinction off the PM-fine modeling results.

Mr. Golden said the group should not forget about visibility. From a sulfur dioxide (SO2) perspective, PM and visibility are more strongly related that PM and ozone.

AOI Boundaries

Mr. Zeldin stated that issues 3 and 4 on the definition of AOI's and AOV's have overlap with NRS. He added a recommendation at the end of issue 3 that two areas with overlap should be added together to form one bigger area.

Mr. Lopez raised a concern about the emphasis on co-AOIs. He said the issue of AOI has to be addressed, and he asked if it is the charge of the Base Programs group to look at the broad areas and the integration across pollutants. Mr. Golden pointed out that the Gerritson paper dealt with AOIs for single areas. A simple cross reference to the Gerritson paper might suffice.

Mr. Pezda asked if it is reasonable to limit the particulate matter controls to VOCs and nitrogen oxides (NOx) under option 3.c. Mr. Zeldin responded that when they listed the option, the criteria was what could be done. He noted the need to leave all of the options on the table and stated that 3.c does not have broad support. When strictly speaking of common precursors, there is only volatile organic compounds (VOC) and NOx. Mr. Pezda stated the need to address all of the precursors of particulate matter including NOx, sulfur oxides (SOx), VOC, etc.

Mr. Zeldin suggested that issues 3 and 4, which deal with the areas of influence, can be combined and addressed with NRS as one issue. The issue paper would address the definition of co-AOI's as a broad area. Mr. Brisini said that issue 3 is a coordinated issue with the STS work group. Mr. Paisie stated that the STS representative for this issue would be S.T. Rao.

Mr. Gerritson supported issue 3's recommendation to make the planning areas as large as possible. He added that the planning area and the area where controls occur may be different. On option 4, what approach can be used when the broad areas cannot be defined, he supports making the area as large as possible while allowing for maximum flexibility. Option 4.b, which is based on existing ozone modeling studies, should be used to define the AOI.

Ms. Lamb supported option 4.b to take advantage of work that has already been done. She suggested adding the Grand Canyon study to the list of existing studies. She said this approach underscores the importance of long term efforts, especially with respect to the Interim Implementation Policy (IIP) as we move toward the new standard. Mr. Golden clarified that what is been planned under the old standard will establish the glide path during the transition period toward the new standard. This approach is part of the IIP. Mr. Zeldin clarified his intent under option 4.b is to use the excising regional mechanisms (like OTAG, Grand Canyon Visibility Transport Commission (GCVTC), Ozone Transport Commission (OTC), etc.) if the AOI cannot be otherwise defined. Mr. Paisie clarified that option 4.b should refer to existing modeling structures. If modeling studies were available, the area would be defined according to issue 3.

Ms. Vernet asked about structures like OTAG, which include States that want out of the structure. For example, Nebraska wants out of OTAG. Mr. Paisie said this question is addressed in issue 5. Mr. Lopez clarified that OTAG is a study area and does not provide a control area. He said there is a need to keep Nebraska in OTAG because it needs to be part of the modeling study. Option 4.b should recognize the distinction between planning areas and control areas.

Mr. Lee has a problem with the last two sentences on option 4.b that recommend treating the ozone precursors and fine particulate precursors as the same. He also said the focus should be on monitoring rather than modeling. Mr. Zeldin responded that the intent is to keep the issue framed in the broadest sense. Therefore, he wants to stay focused on the structure as opposed to developing a technical justification.	Mr. Golden reminded the group that every time the term "modeling" is used it is meant in the broadest sense.

Mr. Pezda stated that there are significant differences between the precursors of ozone and fine particulate. On option 4.c he suggested changing the word "since" to "where." This suggestion was rejected. Mr. Kappelmann said that sulfates need to be added to the list of precursors.

Mr. Kappelmann suggested that the STS work group decide a distance for the AOI based on existing science. A simplified approach, such as 300 km from the AOV, would avoid political infighting. Mr. Zeldin said this concept is captured in option 4.e. Mr. Kappelmann questioned the issue paper's assertion that this was a less desirable option. Dr. Chock said that the determinations may need to be made case-by-case and that modeling should not be relied upon too heavily.

Mr. Nicholson asked what the intent is of an AOI. Mr. Brisini said if the underlying assumption is that nonattainment areas are areas for controls, what is the purpose of the "designation." Mr. Zeldin stated that this paper will refer back to the Designations paper.

Mr. Nicholson reiterated that there is a need to break away from the idea that nonattainment areas are where the controls are. He wants to make it clear that we can reach out beyond the violation area to get the needed controls. Mr. Paisie added that a planning framework has to be developed to start. The group has not talked about the controls yet.

Mr. Schaefer asked if the modeling period should be extended to look at the longest possible time frames. For example, should annual modeling be studied as opposed to the first 24 hours or modeling episodes. Mr. Gerritson said that the modeling timeframe depends on the form of the standard. Mr. Ralston said this input needs to come from the science group. Mr. Schaefer suggested there might be different AOIs based on the modeling time frame (i.e., one AOI for the 24-hour results and one for the annual results).

Mr. Golden asked how the planning area differs from the AOI. Mr. Nicholson responded that the planning area is where the State of North Carolina would do refined modeling. This planning area could go beyond the state boundary. Also, in terms of the timing, the AOI is the first analysis and this is a big OTAG-like area. After the first analysis, the State would do some refined modeling in a smaller area.

Mr. Lopez asked that the paper include a discussion why there is a need to define two or three different types of areas. He said the key is that the AOI brings stakeholders to the table. Actual controls might be imposed on a subset.

Mr. Nicholson stated that one has to honor the particular pollutant's AOI. Trading outside of and in between the AOIs should not be allowed. Mr. Kappelmann added that he would like to keep the areas as small and as manageable as possible.

Mr. Nicholson said the use of political boundaries should not be prescribed, but States should have the flexibility to use them. He also said there is a strong argument for not assuming an AOI for one pollutant is the same as the AOI for a different pollutant. For example, diesels are a local area problem and should not necessarily be the strategy for the broader region. Mr. Dworek does not support the use of political boundaries. He wants the areas as small as possible.

Benefits of Co-AOVs/Timing Issues

Mr. Brisini asked what is the significance of the co-AOV designation. By satisfying the most stringent requirements (e.g., for NOx or VOC), the area should address the larger specific problems (i.e., ozone and PM). Mr. Zeldin stated that this is why he included issue 2 on the boundaries of the different planning areas.

Mr. Golden asked about the benefits of co-AOV's. Mr. Zeldin stated that it is very unwieldy when there is both an ozone and a PM-fine problem. There is a need to put them on a common time frame for State implementation plan (SIP) submittals, etc. Mr. Ralston agreed on the need for a common time frame. He said that the States' planning ability to solve ozone and PM are somewhat different. There is a need to start with strategies that will ameliorate both problems without making one problem worse and to avoid "fits and starts" from an industry perspective. Mr. Brisini worried that co-AOVs may not catch peoples' attention. Ms. Lamb agreed that the benefit of the same time lines is critical. She stated that this issue is very important to NRS. She said that the classes of strategies that have multiple pollutant benefits need to be analyzed.

Mr. Kappelmann asked if there are occasions that would result in non-intersecting AOV's, but in overlapping AOI's. Mr. Zeldin agreed this could occur, and that many of the same reasons to have co-AOVs would apply to co-AOIs.

Mr. Palzer agrees with option 2 and likes the idea of similar time lines for SIP submittals. Mr. Palzer objected to the terms upwind and downwind in terms of source contribution. Mr. Zeldin suggested that the recommendation could be for a source receptor relationship.

Mr. Brisini raised a concern that the co-area approach could result in selecting the most conservative control strategies. He presented a case where a 75 percent reduction is needed to meet the PM standard and a 50 percent reduction is needed to meet the ozone standard. Considered separately, different time lines are needed to meet these standards. Mr. Brisini is concerned that the States would select "extreme" ozone measures in order to address the PM problem. In contrast, Mr. Dworek concurred that there is real benefit in having integrated time lines.

Mr. Lopez said the complexity of the present ozone structure has almost destroyed the States' planning ability and that it is very difficult to explain to the public the different levels in the standard. Simplification with respect to schedules is also needed.

Mr. Palzer supported adopting the faster time lines when dealing with overlapping areas to maximize health benefits. However, he acknowledged that there may need to be some adjustments to account for whether the controls can be done.	Ms. Lamb suggested that a benefit for early reductions should be included.

Mr. Zeldin wants to stay away from the how and focus on whether the group wants to embrace the co-AOV concept. Ms. Lamb asked that a place holder be put in the paper to indicate that NRS is addressing the issue of co-AOV. She said that the NRS work group is in the process of developing sub-issues by addressing the general principles of the four big issues.

Mr. Lee added that the co-AOV approach lacks the concept of mid-course corrections.

Mr. Golden asked what was keeping the group from coming up with an integrated time scale, recognizing that the current time lines are in the legislation? Mr. Ralston responded that more is known about some areas, e.g., diesel particulate in Manhattan or regional haze in the Grand Canyon. This difference in knowledge could lead to different time scales. Mr. Damberg added that the Clean Air Act (CAA) provides an extra year for gathering regional haze data. Mr. Golden noted that the IIP did not let the ozone time line slide. Mr. Brisini and Mr. Zeldin agreed that the idea of integrated time lines is not that the time lines for all pollutants in the co-AOV are the same but that the planning for the area is integrated.

Mr. Paisie asked the group what are we trying to accomplish with a co-AOV. Mr. Zeldin responded that the elements of the planning cycle need to be the same. In his mind everyone benefits from an integrated SIP. Mr. Ralston supported the concept of co-AOV. There should be recognition from a health effects standpoint that the area is more than twice as bad because the pollutants have synergistic effects.

Mr. Lee expressed sympathy for the bureaucratic process, but he sees a co-AOV as creating more jargon and educational issues. If the purpose is to address the planning process, he asked if there is another way.

Mr. Gerritson stressed that the key is not the designation, but the ability to do the planning. If the problems are separate, for example the New York City ozone problem versus diesel bus particulate, he does not advocate a rigid approach.

Mr. Brisini asked if the "co" designation is needed in order to integrate strategies. For example, in the absence of speciated particulate data, the integrated strategy could be focused on the wrong precursors.

Mr. Palzer supported the identification of co-AOVs. For example, in southern Oregon there is a small carbon monoxide nonattainment area that is partly of a larger area that exceeds the particulate standards. The State has implemented an inspection and maintenance program for the entire area, as an integrated strategy.

Mr. Nicholson asked about the manner in which the co-AOV's would be defined. Mr. Nicholson finds option 2a.c inappropriate.

Mr. Ralston suggested that perhaps EPA could make some allowances for common planning areas and schedules and give flexibility to the State agencies to petition EPA. He would not require co-located monitors, but would use geopolitical or some other boundary in conjunction with quality assured monitoring data.

Mr. Golden said this comes back to the designations recommendations and the need for a monitoring plan. He identified two issues. First, is it ever important to say there are co-AOV's? Second, the group keeps trying to solve the implementation plan problems.

Mr. Zeldin said that if one considers the ozone and PM AOVs singularly, then the AOIs for each gets bigger. Mr. Gerritson said his ultimate concern is solving nonattainment. He added that whether an area is singular or a co-AOV is irrelevant. Mr. Zeldin responded that originally the group wanted to know where the AOV's overlap and how to deal with them in a common manner. Mr. Gerritson responded that once you grant flexibility on how to deal with the planning, then there is no other issue. Where is there an advantage or disadvantage?

Mr. Zeldin responded that he thought this group's original mission was to look at how the pollutants are linked. Mr. Paisie stated that where there are common problems, flexibility to co-align the strategies is needed. Mr. Golden asked if the AOV's are defined within a given geopolitical boundary. He wonders if there could contiguous area of ozone AOV, PM-fine AOV, and a co-AOV. Mr. Gerritson replied that AOVs, which are defined for health warnings, are not tied to political boundaries.

Mr. Brisini disagreed with the discussion. He stated that an AOV is not just about health and public notification, but includes the idea that the sources in the AOV are being notified that they will be participating in the control strategies. He asked if a new designation classification is necessary to achieve the integrated strategy. Mr. Dworek added that, in western Pennsylvania, ozone violations are in the north at 2 pm in the summer. In contrast, PM-10 violations are in the south at midnight during the fall/winter. Therefore the linkage in pollutants and strategies in Allegheny county Pennsylvania does not line up.

Issue 5

Mr. Zeldin said that options 5.b and 5.c are too focused on controls as written. He suggested the emphasis should be of use of the sources themselves to define the boundaries. He added that discussion of the need to consider the impacts of controls could be added to issues 3 and 4 and that issue 5 could be dropped.

Mr. Chastain asked if option 5.c is based on $/ton of what is emitted or in terms of contribution. Mr. Zeldin responded this concept should be limited to identifying sources to define the AOI. The answer is $/ton in terms of what it would cost to control the source, but this information would only be used to define the AOI. Mr. Paisie added that another option is to look at emission or source density.

Mr. Golden noted that issue 5 is moot if the sources within the AOIs influencing the AOVs cannot be identified.

Mr. Brisini said that an option should be added to issue 5 to consider the total source category's contribution. For example, consider whether it is preferable to control fifty sources that emit 500 tons each or one 25,000 ton source. Mr. Brisini advocates looking at the contribution of the source and not just the $/ton. Cost effectiveness should not be measured in $/ton, but in terms of $/ozone control.

Mr. Palzer asked why all of the options in issue 5 contain thresholds. Mr. Zeldin said that the intent is to avoid a national AOI.

Mr. Gerritson added that discussion of issue 5 is hair splitting. The planning area is defined with modeling and empirical techniques. Once the data are in, he suggested letting the regulators establish which sources should be held responsible for the AOVs. He advocated dropping the issue. Ms. Lamb agreed. She added that Class I areas and the New Source Review (NSR) process have drawn boundaries and have done de minimis analyses. There is always a source on the boundary, and someone who will build on the boundary. She recommended that the group be as unspecific as possible until the planning phase is complete. Mr. Nicholson added that it should be clear that the States have the flexibility to choose the sources to control.

Mr. Schaefer said that if the regulator is challenged on including a source in an AOI, the source could put in a monitor to make the case. Mr. Paisie asked how air quality data will tie a source or AOI to an AOV. Mr. Golden responded that in the Southern Oxidant Study (SOS) some fairly sophisticated techniques were demonstrated. Mr. Ralston added that in the development of national standards by EPA, EPA becomes the ultimate arbitrator. Mr. Zeldin added that if the group accepts AOI, the group must recognize there will be some conflicts down the road. However, the group does not need to resolve this issue right now.

Ancillary Issues

Mr. Gerritson listed two additional options that he wants included in the Ancillary Issue portion of the paper. The first option is to work through an existing structure like Environmental Council of States (ECOS) and OTAG. The second option is to use EPA's authority under section 110 of the CAA.

July 2, 1996

Revised Alignment of Boundaries Issue Paper

On July 2, Mr. Zeldin recapped the previous day's discussion on the Alignment of Boundaries issue paper and provided a revised version of the paper.

Mr. Chastain asked that the first reference to contributing be changed to recognize a significant contribution. For example, in defining the AOI there should be a de minimis source contribution to the AOV. Mr. Zeldin suggested this level of detail might be more appropriate later in the document. Mr. Pezda said because the first reference is in the context of defining terms, the definition should be complete. Mr. Golden clarified that the significance issue applies to the contribution of the pollutant and not the precursor. Mr. Ralston agreed there is a need to identify source contributions. Mr. Gerritson said there is a need to look at sources, during the definition of the planning area that may make no significant contribution. Significance is more of an issue in defining control strategies.

Mr. Kappelmann stated that there is a need to get the science input on how far the AOI should extend, and the regulator should not be arbitrarily prevented from looking at a major source. However, this approach would lose value if the AOIs become too broad. Although it cannot be defined now, there needs to be recognition that the AOI will be bracketed.

Mr. Palzer expressed support for the current wording. This paper needs to be coordinated with two other work groups, and he believes the language should start very broad. Mr. Ralston also agreed that initially from a planning standpoint the AOI needs need to be broad because the models are not sufficiently deterministic. A threshold is appropriate for implementation. Mr. Dworek suggested that the AOI be considered a starting point.

Mr. Dworek added that AOV's could be much smaller than the classic nonattainment area. For example what was a 7-county nonattainment area could become a 2-municipality AOV. Mr. Zeldin stressed that the group's thinking on boundaries should not be constrained by political boundaries.

Mr. Golden pointed out that the Monitoring Incentive issue paper has an option for designations based on modeling, which provides an incentive to place a monitor to oppose a designation.

Mr. Schaefer asked if the group should deal with temporary AOIs caused by wild fires or prescribed burning. Mr. Paisie stated that EPA is developing a wild land fire policy that will address this concern. This issue will be added to the issue parking lot.

Mr. Lopez said the NRS group is also looking at using modeling to define areas. However, the dominant principle is that monitoring data are used. Mr. Ralston said the network citing criteria is a model of sorts, and he recommends that it be revisited. The Governors recommending designations will need confidence in the model. He added that the states have different modelling capabilities.

The consensus that the group has an overall comfort level with the paper.

Monitoring Incentives

Richard Dworek presented the major points from his draft issue paper. He emphasized that 85 percent of the counties in the U.S. have no monitors and other areas are over monitored. In one square mile of Pennsylvania there are more monitors than the rest of the state. He recommends a network that has as a minimum starting point one monitor in each county and expands as needed. The current monitors are not always where people live. He strongly supports placing the monitors where the people live. In addition, there are no monitors available to evaluate long-range transport.

Several on-going EPA programs and initiatives were used in trying to identify methods for setting up monitoring incentives. Project XL, the 33/50 program, and the common sense initiative were reviewed. He stressed public/private cooperatives and publicity for companies that are participating. Recently his firm was honored at a Governor's award banquet, and Mr. Dworek emphasized that this is an effective motivator. Also, he emphasized that the sources of the pollution and the associated control costs are not known until analyses using monitoring with speciation is conducted. Some of the necessary control strategies can be initiated on an earlier time frame and moved up in the company's business plan if the right incentives are used. Finally, industry can do a better job of planning their emission controls to avoid command and control strategies.

Mr. Dworek also spoke about the problems with the current monitoring network. He stated there was a 10 microgram/meter3 drop in monitored air quality data where they changed from a passive network. He also questioned whether the entire Pittsburgh area should be in non-attainment if only 2 monitors are registering violations and they are located in a river valley with a highway.

The following discussion is organized by issue/option.

General Comments

Mr. Halvey submitted written comments. He said the goal of monitoring is to characterize the extent of pollution. If the current monitoring network is not doing this, it is not bad science, but it is bad public policy. Mr. Halvey noted that when the population and sources are concentrated in a limited area, it can be difficult to develop public/private partnerships to monitor in more isolated areas. Mr. Halvey also noted that creative leadership awards are is catching on and need more development and emphasis.

Mr. Gerritson said that a voluntary program is nice, but there is still a need for a federal reference method and consistency across the network. The real disincentive to monitoring is that people do not want to know if there is a problem. Without safeguards and commitments, the participants can drop out of voluntary programs.

Mr. Williams said there is more to a voluntary monitoring program than just getting the private sector to pay for the monitors. A key component is getting the local government to agree to the need for the additional monitors. Mr. Golden asked if the local governments would support the monitoring if it were part of a State network. Mr. Williams replied there would still be concerns.

Mr. Crouch stated there needs to be a big benefit for a western State to do more monitoring. The powers that be (local governments?) are smarter now, and the Base Programs work group needs to craft a win-win situation for communities to place monitors. For example, the PM-10 monitoring network was successfully increased because additional monitoring was a condition of a source receiving permission to expand. If monitored data could be to a source's disadvantage, the source will not volunteer in the future.

Special Purpose Monitors

Mr. Dworek said Jim Salvaggio had previously suggested that voluntary public/private sectors monitors could be classified as special purpose research monitors. In this way, the data would not necessarily be focused on attainment/nonattainment decisions. Mr. Nicholson responded that North Carolina has special purpose monitors mostly to support urban airshed modeling, and that the data from these monitors reflect area wide values. However, if these monitors show exceedances, the State is obligated to report the violations to the public. The only case where this would not be required would be one in which the monitor is located such that its data do not represent area wide values, e.g., the monitor is on a mountain top. Mr. Ralston stated that they also had special purpose monitors until they recorded a violation. The monitors were subsequently removed.

Mr. Kappelmann said if monitors measure real exceedances, whatever the stated purpose of the monitoring was, this issue will be hard to duck. Mr. Ralston agreed and said the only exception might be where the entire exceedance could be attributed to transport.

Mr. Williams said in Texas they have three or four private monitoring networks. The oldest one is in Houston. These networks obtain background data for the prevention of significant deterioration (PSD) program. The data are not included in Aerometric Information Retrieval System (AIRS) and, therefore, are not used to determine nonattainment or attainment designations.

Ms. Lamb said the NRS work group is looking at transport, and she emphasized the need to look at different scales of monitoring. For example, the IMPROVE network does not characterize valley monitoring, but it is very good in terms of regional scale monitoring. She advocated considering incentives for companies that could not support local monitoring, because it would locally impact them. She suggested that they could be part of a bigger scheme, and transport monitoring may be a solution.

Disincentives to Monitoring

Mr. Brisini said the paper only presents options for incentives to monitor and suggested a discussion of disincentives not to monitor be added. Mr. Dworek responded that those companies that do not participate would have to face the consequences of command and control.

Mr. Kappelmann said it takes longer to do something (modify or build a source) in an unclassifiable area. This translates to an incentive to monitor to demonstrate attainment. He suggested if unclassifiable status carries more of a burden, the need to classify the area will translate into an incentive to monitor. Mr. Palzer suggested that unclassifiable areas should be assumed to be exceeding the standard unless proven otherwise. Another member said this would pose a problem in the west where areas with no people would have to monitor.

Mr. Nicholson said that prescriptive control requirements are the problem, and the ability to avoid the nonattainment designation is a very serious incentive.

One Monitor per County

Mr. Gerritson said that it is insufficient to have one monitor in each county. In the Lake Michigan Ozone Study, the State system was supplemented with 90 to 100 monitors, and it still was not enough. He noted that monitors in the same counties have very different readings.

Mr. Schaefer asked if the one monitor in each county would monitor ozone, PM-2.5, PM-10, or NOx? Mr. Dworek clarified that it is one monitor just to get started. Mr. Schaefer responded that he would like some flexibility for low population western counties.

Mr. Halvey also requested some flexibility for counties with no people and no extreme topography. In these cases, one monitor per county is too much.

Mr. Williams also supports the need for flexibility in citing monitors. He stated that in terms of where monitors are needed and the cost of the monitors, it is not practical to put a monitor in every county.

Monitoring as a Rebuttal for Designations

Mr. Gerritson stated that the issue paper is written in the context of the current monitoring system. Disincentives for monitoring are eliminated if monitoring data are decoupled from the nonattainment process. Mr. Lopez agreed.

One member suggested that an incentive for monitoring would be to provide data to appeal AOI boundary designations. There was a discussion of the feasibility of this option. AOI boundaries are likely to be established through modeling and based on projected precursor emissions and transport. Mr. Kappelmann clarified that when discussing the area of influence, you talk about a de minimis level and monitors could help establish this. However, just because no violation of the national ambient air quality standard (NAAQS) is measured in the AOI, it does not mean the source could not be contributing to a violation elsewhere. Mr. Golden said it might be possible to measure the reactivity of a plume to determine if the source is capable of influencing a violation. Others in the group said this type of monitoring would be extremely difficult to perform.

Mr. Gerritson also said he would be opposed to a system that created easy exemptions, nor should it result in the establishment of little fiefdoms for planning purposes.

Financial Incentives

One member suggested that there are things the State and federal agencies could do to support the voluntary monitoring program. For example, some amount, e.g., 5 percent, of the Title V emission fees could go to support monitoring. Alternatively, fees could be frozen for some period of time, with the additional funds devoted to monitoring. Finally, the State could lower the NSR offset requirements to 95 or 98 percent, with the assurance that the money the source would have spent to comply with the remainder of the offset is devoted to monitoring.

Mr. Williams said in Texas that some sources are allowed to divert enforcement fees to monitoring.

Mr. Lopez said if the designation provided more money to the community for health or other related programs, this would be an incentive. He noted that the NRS work group has been discussing moving the title V fees to help sources do more monitoring.

Mr. Palzer asked to include the possibility of getting some money from health-based organizations to fund additional monitoring.

Allow Additional Time in Exchange for Monitoring

Mr. Dworek said a key incentive to conduct additional monitoring is that it can provide more time to solve problems. Mr. Kappelmann stated that the utilities in Florida have established a monitoring network. The incentives are timing and the fact that the better you define the problem the more cost effective the solution.

Mr. Williams noted that under the 33/50 program, facilities had to participate early. He suggested developing a program similar to the Title III Early Reduction program for monitoring.

Mr. Williams also suggested developing flexible attainment regions for areas that identify problems as the result of additional monitoring. These programs do not carry an immediate nonattainment designation, but allow the area time to develop controls and other actions to mitigate the problem, before nonattainment must be declared. These areas are looking at substantive actions to avoid the nonattainment designation.

Mr. Dworek discussed his company's action plan that is used if they have an indication of a "meteorological" problem that could result in an exceedance. The whole plant is geared toward shutting down non-essential operations and checking everything to ensure there are no malfunctions. This is part of the action plan and is permitted under the CAA. The company's monitor has not measured a violation in the past 15 months. This is an example of how additional monitoring can allow a source to avoid exceedances through proactive controls. The result is additional time to implement less episodic controls.

Mr. Palzer commented on the episodic approach. Portland used the episodic approach, and the result is that they are in effect titrating just below the standard. He would prefer an approach that always keeps off the peaks.

Mr. Palzer stressed that monitoring should only provide more time if it is done early enough in the designation process. Late monitoring should not be rewarded.

Mr. Paisie noted early PM monitoring may not be possible until EPA selects a reference method. Mr. Zeldin said that in a nitrate-rich environment the monitors that capture the nitrate can be 40 percent higher than what will come out of the federal reference method monitoring protocol. Mr. Brisini stated that one cannot set the standard without a measurement technique because the measurement technique changes the level of the standard.

Mr. Crouch agreed that the only meaningful monitoring incentive is to allow more time. He suggested one possible way to structure a monitoring incentive program is to use a model based on a maintenance SIP as opposed to an attainment SIP.

Mr. Nicholson commented on the flexible approach taken for Tulsa. He stated that although more time is allowed, there must be a clear demonstration that there is movement.

Mr. Halvey is intrigued by the Region X approach. The Region does not designate an area nonattainment without providing the communities the opportunity to solve the problem. There is a need to do the monitoring, but the monitoring needs to be decoupled from the required control actions. He stated that there is a need to monitor attainment and get the controls early.

Ms. Vernet stated that the areas John Crouch and Rick Halvey are discussing have simple problems (i.e., local PM sources) and are not complicated cases like Philadelphia (regional transport/ozone). She was concerned about delays in designation. Mr. Halvey said that agreements have to be carefully crafted and may only apply to certain, small areas.

Benefits of Reducing Air Pollution

Mr. Palzer stated that the incentives should be aesthetic and quality of life. He reviewed the Klamath Falls example which shows how air quality problems are solvable. Joe Paisie responded that the Klamath Falls example demonstrates that monitoring can provide a headstart on the process.

Summary of Discussion

The chairs summarized the discussion on flip charts that read as follows:

Options

1.	De-coupling controls from direct connection to non-attainment designations

2.	Special purpose research monitors local vs. regional (decouple from designation)

3.	Financial incentives (offsets, permit fees, title V monitoring recovery, health maintenance organization funding to prevent disease)

4.	Monitoring as a rebuttal for modeling expanded designations

a.	as a direct violation area

b.	as an AOI

5.	Monitoring based violations do not immediately lead to designations

a.	Tulsa Flexible Attainment Region

b.	Coeur d'Alene memorandum of agreement approach (i.e. only designate as nonattainment for failure to follow through)

6.	Gives an area "lead time" to design its own program--up-front early monitoring commitment gets you time to design your own program

7.	Areas with no data or reluctance to monitor do not get a pass.

On July 2, Mr. Dworek gave a recap of the previous days events. David Baron also provided written comments that will be included in the next rewrite. He identified 6 incentives. An additional incentive is to make the nonattainment area as small as possible.

Population Weighted Monitors

Mr. Pezda reviewed the changes to the latest version of the issue paper Utilization of an Exposure-Based Monitor System.

Mr. Pezda noted that the statement that people spend 90 percent of their time indoors is now referenced. The fact that EPA is considering an averaged approach is also referenced. Some of the material presented by Mr. Jim Salvaggio on the placement of monitors, was extracted and included on the bottom of page 1 and top of page 2. Mr. Brisini provided the text for option 4, and 4a was added. A suggestion from the general public on using monitors to prioritize was included as an option.

Mr. Zeldin stated that he still has substantial problems with the paper. Population and risk are addressed in the standard setting process. He asked how big an area would be chosen to average the monitors. If the area is large enough, there is no problem (e.g., no exposure). He does not like the averaging approach. People are still exposed to levels that have been established as unhealthful. Mr. Pezda responded that there is no ozone threshold, this approach looks at the air pollution problem overall, and asks whether some risks are acceptable.

Mr. Golden stated that one option is to use the existing network to establish areas of violation (AOVs) and use population weighting to prioritize actions. He added that this information could be used to set up controls for an area that has no violations.

Mr. Palzer agreed with Mr. Zeldin's concerns. He also added that there is no "threshold" for health effects for PM. However, the standard setting process determines acceptable risk. Mr. Pezda agreed to add particulate, but stated that the data are not strong. The data are all on PM-10 and total suspended particulates (TSPs), and there is nothing to explain how PM causes health effects. He said it is premature to make conclusions on the basis of the available data.

As a State official, Mr. Nicholson cannot explain to people that because they live in a less populated area they are less protected by the standards. This work group has had lengthy discussions on this point, and he did not see these discussions reflected in the paper. The State agencies and the environmental community are against this approach. Mr. Golden responded that this redraft tried to show that the existing network is conservative, and population weighting of monitors could be used as an additional tool to guide implementation efforts. Recommendations are not yet incorporated into the paper.

Mr. Brisini asked if the group is looking at the recommendations as a total package. Only by virtue of the standard does a reduction occur in an AOV. If reductions also occur in the area of influence (AOI), a large AOV is not needed. He suggested adding an option tied to the form of the standard. Mr. Brisini said that this option needs to be addressed because at the May 30, 1996 FACA Subcommittee meeting, Mary Nichols made the statement that EPA was considering "Population Weighting." The paper should acknowledge that the work group has addressed Ms. Nichols' comments.

Mr. Ralston said current monitoring is based on our ability to predict where maximum concentrations will occur and then modeling is used to fill in the gaps. He would prefer a monitoring network that increased the ability of modeling to define AOIs and exposure so that implementation plans can be developed considering the most cost-effective strategies resulting in the least adverse health impacts. He does not support an early decision to weight exposure. He supported Mr. Zeldin's comment that paragraph C of page 3 will change the form of the PM standard. He notes that nothing below neighborhood scale networks would be included, and because PM monitors are not on the ground, pedestrian exposures are largely unknown. Averages of roof top concentrations only provide information on what is blowing in the wind. Finally, he had a process question because this paper is not ready to be forwarded to the National and Regional Strategies work group. Mr. Pezda concurred that this statement was an error. Finally, Mr. Ralston has heard from EPA that micro and middle size networks would not be used for the 24-hour PM standard.

Mr. Halvey also commented that this is a discussion of the form of the standard. The main concern is one of public perception of a standard that is already difficult to explain and to demonstrate that the standard is protective of public health. Mr. Halvey noted that there is acceptance for the current temporal averaging of monitoring data and agreed a spatial average should not be inherently unacceptable. He said that one cannot separate this issue from the AOV, but the present process does not preclude an area from acting locally to bring down a high monitor. The real issue is the attainment designation that brings on all of the prescriptive requirements. One should be careful of "one size fits all" solutions, but also realize that the States have to show attainment everywhere. The difference is whether the AOI/AOV approach gives more flexibility.

Mr. Gerritson commented that the introductory language stating people spend 90 percent of their time indoors is irrelevant. He said the job of the States is to protect people when they are outside. He agrees that the current monitoring system is flawed, but that answers lie in a more regional focus that allows cost-effective regional solutions. He feels this paper goes against this trend.

Mr. Gerritson said the first disadvantage listed in paragraph B of page 2 is true, but irrelevant. The system is not designed to estimate overall health risks because this is the job of the standard. Also, the fourth disadvantage listed is not the fault of the monitoring network, but the narrow definition of nonattainment areas. This problem is mitigated with the AOI/AOV approach. Finally, he agreed with Mr. Zeldin that this is not bad science, but it is bad public policy. Mr. Gerritson said that it is immoral to exclude people because they live in rural areas.

Mr. Williams agreed that part of this issue applies to standard setting. He suggested that this issue may need to be rolled into one of the other papers to better address an overall air quality perspective. He stressed there is a need to have protection for folks living near high values. Implementation issues and control strategies may be addressed from the overall air quality perspective, however.

Mr. Paisie asked what local mitigation strategies can be implemented for ozone. Mr. Williams responded that an area approach requires a 75- to 80-percent reduction in VOC. However, local controls representing a 40- to 50-percent reduction in VOC can achieve the standard, but still not meet the area wide reduction.

Mr. Lopez stated that this issue reflects the politics of a local situation where there is a large entity versus a small entity. These politics are inevitable when transport is an issue. However, this approach will exacerbate the relative lack of power of rural downwind entities like Maine. Mr. Golden mentioned that in the OTAG forum there is discussion of cost effectiveness, and they are considering exposure-based units like $/parts per billion ozone/person. Mr. Lopez emphasized that this is one of several criteria under discussion.

Mr. Golden asked what is in the paper that leads everyone to assume the population weighting will be used for designations. Mr. Lopez said ambient air quality standards are not just about risk. He prefers the AOI approach. He noted that when preparing a SIP, population weighting is automatically included.

Mr. Kappelmann said the key issue is when is population weighting appropriate. This group says it is not a good use in detecting a violation. Is it useful for building a control strategy where there are limited resources? What if you do not have enough monitors? He found some things in the paper useful, especially when analyzing strategies and time lines.

Mr. Dworek said his concern is related to the balance in the system. He stated that the current system results in placing a monitor on the fenceline of a facility where there are no people. If this monitor shows a violation, and all of the monitors in the area show no violations, you could unduly alarm the local population. Monitors should be located at the highest predicted concentration, but also where the people are. Results from a single monitor should not drive an entire area. Mr. Kappelmann said it can be difficult to define where the people are. For example, there could be hikers in the area.

Mr. Crouch said the State and local air agencies are protesting the proposed approach, while still admitting that policy is developed using "triage". He suggested that siting PM-fine monitors should be separated from issues associated with existing ozone monitors. He said that when the standard went from TSP to PM-10, some of the monitors had to be moved. He suggested that for PM-fine, the monitors have to be where the people are.

Mr. Chastain found that the paper helps people look at better spending of limited resources. Using this type of approach for implementation avoids the question of whether we are addressing the standard setting process. To the extent data are available, it should be recognized that population weighting is already being done.

Mr. Golden asked if this should be a Phase II paper with an emphasis on implementation.

Mr. Nicholson responded to Mr. Kappelmann and Mr. Golden. The underlying message is that the reading of 100 in the rural area has different implications than the 100 reading in the urban area. He noted that the siting criteria already consider population. He added that it is appropriate to prioritize resources, and he favors the idea of refocusing towards implementation. Also, it is okay to talk about spatial averaging as long as the gaming aspect is recognized and not tolerated.

Mr. Zeldin stated that it would be helpful to state in the beginning that the purpose of the paper is not for attainment designation. He said the paper should present population weighting of monitors as another tool available to an air agency to prioritize controls and to set up a monitoring network. He recommends the paper become a Phase II issue and not remain a fast-track Phase I issue.

Mr. Lee sees the approach as an "out-of-the-box" approach. The current extreme statistics for attainment designation is very expensive to society. He would like to use exposure-based monitoring for attainment designation and thinks it will result in cleaner air, overall.

Mr. Gerritson sees a role for this paper in rethinking how we use monitors. Monitors can be used to help identify AOIs and the regional nature of the pollutants. From that perspective, the current monitoring system fails miserably. Also this approach could be used in Phase II implementations. He recommended rolling some of the paper into current papers and using the rest in Phase II.

Mr. Brisini stated that linkage is needed to AOIs and AOVs.

Mr. Kappelmann raised a concern about the equivalency of high population and rural areas being exposed to the same levels of pollutants. There may be no difference for ozone, but there are differences in composition and health impacts with respect to PM, e.g., the effects of diesel versus desert dust. Mr. Nicholson agreed, but said when all else is equal, rural areas should not be discounted.

Mr. Dworek recommends that the monitor siting guidelines be revised.

Mr. Ralston stated that a monitoring network designed to address risk should not forget about the secondary standard. The paper speaks about the NAAQS in a generic way. The secondary standard addresses sensitive plant species, which cannot tolerate lengthy exposures. Secondary impacts in rural areas should not be discounted.

Mr. Chamberlain is uncomfortable with rolling this paper into other papers or deferring the paper to Phase II. This paper highlights some key issues of the group and needs to go forward based on that.

Mr. Pezda commented that he has a sincere desire for a paradigm shift in thinking. He wants to look at overall health risk.

The co-chairs summarized the recommendations of the meeting as follows:

I.	1)	Recognize that Designation Paper contemplates monitoring system design and implementation prior to designation,

2)	Risk exposure policy to be set by standard writers, and

3)	Monitoring system design should be consistent with form of standard. (including secondary if applicable).

II.	Current siting criteria may need to be reviewed.

III.	Implementation aspects to be addressed in Phase II paper.

The co-chairs asked that any editorial comments be directed to Mr. Pezda.

Mr. Golden summarized, that if the form of the standard allows it, there may be a role for exposure-based monitoring in the attainment designations.

Mr. Paisie stated that there needs to be an summary document where the individual issue papers are woven together. There are no plans for the FACA subcommittee to draft a final report.

Too Close to Call

Dr. Chock reviewed the recent changes to the issue paper entitled Implementation of a "Too Close to Call" Category As a Mechanism to Reduce the Impact of Meteorological Fluctuations on Attainment Designation and State Implementation Plans.

Dr. Chock provided some background on the issue paper. He emphasized that the purpose of the proposed method is to eliminate fluctuations of the attainment status of an area due to meteorological episodes. Mr. Gerritson asked if Dr. Chock envisions that this will go both ways, i.e., from attainment to non-attainment and vice versa. Dr. Chock agreed the variations could occur in both directions, but said use of his proposed statistical technique will mitigate the variation.

Dr. Chock presented a data summary showing the 3-year means from monitors in counties over 11 years. He averaged the mean to see if the design value was greater or less than the various standards being considered. He concluded that, to ensure that no monitors exceed the design value, the standard would be effectively lowered from 80 ppm to 73 ppm, for example, using the current methodology. He then compared these data to the results that would be obtained if option 2 were implemented. The data show that the use of the statistical t-test flattens, but does not eliminate, "exceedances" of the design value. Similar results were obtained when he evaluated option 5.

General Comments

Mr. Zeldin stated the introduction is for ozone, and the approach will not work for an exceedance-based form. For example, the PM standard form may not be amenable to this approach. Dr. Chock said he favored use of a concentration-based form for the PM standard.

Option 2

Mr. Ralston stated that this approach assumes that the current methodology ignores meteorological influences. In contrast, Mr. Ralston thinks the current methodology does address meteorology, and, therefore, the paper attempts to change the form of the standard. Furthermore, he disagrees that the present system provides very few health benefits. This discussion, he feels, preempts the Clean Air Science and Advisory Committee (CASAC) process. Mr. Ralston does see a need to understand underlying trends, but disagrees that this analysis is appropriate for designations. He said fluctuations should be considered in making attainment and reasonable further progress determinations instead of in making designation decisions. Dr. Chock responded that he does not see this option as changing the form of the standard, because the standard does not address fluctuations.

Mr. Ralston also discussed the paper's emphasis on the need to limit the number of false positives. He said it is also important to limit the false negatives that could occur by virtue of a couple of cool summers. In New York, areas were allowed to move back into attainment based on commitments to implement future controls expeditiously as needed. In some cases, when faced with violations in 1995, these commitments have been proven soft.

Mr. Gerritson said when one looks at the previous recommendation of the group regarding AOVs and AOIs, the impact of fluctuations is lessened. He thinks the flip-flop in attainment status is hard on the regulated community, but noted that there will always be fluctuations in meteorology.

Mr. Palzer concurred that this discussion is input to the standard setting process. He noted that even if an area bumps up due solely to severe meteorology, the population is still exposed. He concluded that this approach has a net effect of weakening/revising the standard.

Mr. Brisini said that it is appropriate for the group to give consideration to the form of the standards, because the standards have not been proposed.

Mr. Schaefer asked if Dr. Chock's analysis considered the accuracy of the monitors. Dr. Chock responded that his paper assumes that all data are good. Mr. Brisini clarified that the paper assumes a random error as opposed to a bias error.

Mr. Lee sees this approach as the most technically sound. He also recommended that EPA needs to look at how achievable these standards are. He stated there is a need to avoid these flip-flops.

Option 4

Mr. Nicholson asked if option 4 could be used with monitoring results to determine if a strategy will work. He had previously thought the technique was limited to use as a tool to confirm modeling rather than being applicable to monitoring. Ellen Baldridge agreed this technique is more appropriately applied to analyzing adjustments in trends. A separate program would be needed to address areas near the standard. Mr. Nicholson suggested that Dr. Chock be more explicit in discussing the Cox/Chu approach. The Cox/Chu approach does a better job of matching the air quality modeling to the form of the standard.

Mr. Ralston sees option 4 as a tool for grading attainment SIPs. Therefore, it could be an implementation tool rather than a designation tool.

Option 5

Mr. Brisini supports option 5 because it is the only approach that goes after both the high and the low monitor readings as being atypical. The other approaches just focus on the high values. He also noted that this approach is simpler, can be more easily explained, and addresses Mr. Ralston's concerns about false negatives. Mr. Pezda responded that option 5 does not get to the Too Close to Call (TCTC) issue. This option only address the first half, the statistical method, of the TCTC.

Mr. Ralston said that option 5 decouples the attainment test from the statistics of the standard, which is not a good idea.

Mr. Nicholson suggested that option 5 should have a 5a and 5b. Option 5a would be the current option 5, and option 5b would add option 2 to option 5a.

Other Issues

Mr. Golden noted that the paper raises important issues and asked if they are more appropriately addressed as STS issues or implementation issues, particularly if one adopts the approach of an AOV. Mr. Paisie responded that it seems that this is only an issue if a single area will determine if a whole strategy moves forward. This may be more relevant in the west where the presence of isolated AOVs are more likely. In the east, transport may be the overriding factor. Mr. Gerritson responded that fluctuations are still an issue, although less of a problem, with an AOV approach. Mr. Nicholson stated that regional aspects are important, but an individual area's attainment status would still be very important to a particular state and city.

Mr. Golden suggested that if an area is in the range of a violation, some things should be done early to keep the area violating the standard. This idea was initially put forward by Beverly Hartsock. Mr. Williams said that the flexible attainment area approach keeps areas from going over the edge. Mr. Golden stated that the group will need to determine how to deal with this type of area in the Phase II implementation phase. Mr. Nicholson stated that Charlotte is implementing an ozone action day policy, and he sees a place for these types of actions.

Mr. Helms stated that EPA has struggled with the marginal/at-risk issue for years, and, previously, the lawyers would not allow EPA to address the issue. He used Charlotte as an example and suggested that the air quality data be run through a test that results in a classification of "Too Close To Call," "Interim Transition," "watch area," etc. Then the Texas approach of a flexible attainment strategy could be applied.

Mr. Pezda stated that transport was not recognized in the CAA, and fluctuations are a real problem. He stated that in an earlier discussion, Ms. Sally Shaver of the EPA said that population weighting and too close to call are being considered. Mr. Golden asked if the paper should be refocused to whether there is a need for TCTC and move the options to implementation. Alternatively, further analysis of the options could be forwarded to the STS work group.

Mr. Brisini stated that options 2 through 5 would eliminate TCTC by providing a more sure means for determining attainment or nonattainment.

Mr. Ralston supports S.T. Rao's approach.

Recommendations

The co-chairs summarized the preliminary recommendations from the discussion as follows:

1.	Need to do original designation in Phase I,

2.	Despite the form of the standard tough calls will need to be made, and

3.	TCTC methodologies or others may help to make these calls.

Following was an extended, interactive discussion of the meaning of fluctuations, gray zones, "in the range," etc. to the various meeting participants. We have tried to summarize the key points of this discussion.

The group generally agreed that TCTC might play a role in addressing meteorological uncertainty when analyzing air quality data near the "bright line" of the standard. The form of the standard recommended in the current EPA staff paper contains an "in the range" gray area that reflects the uncertainty in the health data; it does not directly address meteorological fluctuations. However, as a monitor reports data that triggers the upper or lower thresholds of the "in the range" gray area, TCTC techniques could play a role in determining whether the area has truly crossed a statistically significant line. The question at this point is: Should the additional uncertainty uncovered by the TCTC test result in designation actions, deferrals, delays, marginal status, etc.? Is the additional buffer zone needed? Alternatively, should the uncertainty be addressed in implementation rather than in designation.

Mr. Brisini and others argued that TCTC treatment smoothes the line, and that the certainty regarding the area's status with respect to the threshold is now increased. An additional "fuzzy area" is not needed once the data have been statistically treated. Alternatively, a "fuzzy area" could be built into the designation process that would use "untreated" data.

One member noted that an issue in considering "abnormal" meteorology is how long does it take before an abnormal event is considered normal because of changing trends. Another member pointed out that the underlying cause of the exceedance is the pollution, not the meteorology.

Mr. Zeldin stated that the group is still saying nonattainment and attainment. If the group thinks in terms of AOVs versus AOIs, designation as an AOV means only that a health-based standard is being exceeded. The controls required and the implementation consequences of exceedances are driven by the size and nature of the AOI. The fluctuations of an AOV should not matter in terms of risk if it is a bad year for meteorology. Other members disagreed and said any designation carries baggage. Fluctuations are still a problem even if a SIP with prescriptive controls is not required. Mr. Williams asked for some clarification of the AOI versus the area of in the range. These two areas may or may not be the same area.

Participants agreed there is a need to let the public know of any health concerns. However, some felt the public should be made aware of the costs of acting on information based on meteorological fluctuations. Others suggested that the public should also be made aware of the health effects costs that could be avoided with additional controls. Another point is that there will be some explaining to do when the monitor shows a violation and the statistical smoothing shows that the area is okay. Mr. Ralston said he could see this working for an attainment status but not for an attainment demonstration.

Some participants stated that the procedure needs to cut both ways, coming into and out of attainment.

Mr. Paisie and Mr. Helms both stated that if the consensus is to go with a rigorous statistical test, flexibility on the part of the regulators will be lost. Other participants argued that they would prefer a formal, open procedure rather than an ad hoc procedure that is dependent on individuals and their past history.

Mr. Nicholson would like to understand the role of meteorology versus a real trend in air quality caused by population growth. The public also needs to know when meteorology causes a violation. He would like to process the data and then compare it to a standard for a bright line determination. Mr. Palzer said he would like to ensure that the "line" is drawn to ensure that the "peaks" rather than the "valleys" are counted.

Mr. Golden clarified that the group is discussing two issues:

1.	Do we need this buffer range?

2.	How do you deal with the "bright line" between the zones?

The paper could be revised to present four options:

1.	Stay as it is

2.	Adopt within the range notion. No change in treating transition between ranges.

3.	Adopt within the range notion with better statistical treatment between ranges.

4.	No within range notion but add statistical treatment.

The group seemed to agree that the "within the range notion" is valuable. However, they did not reach closure on whether they wanted to add an enhanced statistical treatment around the boundary. At the close of the discussion, Mr. Golden recommended that the discussion be separated into two issues: the TCTC issue and the need for a buffer range issue. The TCTC issue will be sent to the STS work group for further analysis. A benefit of keeping the buffer range issue within the Base Programs work group is that it ensures that PM can get a similar "at risk" or warning category.

Mr. Kappelmann stated that education of the public is important for these issues and the area of influence. He asked if the Communication and Outreach work group should get involved. These issues present two good opportunities for public outreach.