August 20, 1996

Draft Summary

August 7, 1996 Base Programs Analyses and Policies Work Group Conference Call

I.	OVERVIEW

The Base Programs work group held a conference call on August 7, 1996 to discuss the issue paper on Attainment Dates.

II.	PARTICIPANTS

Work group:

Jerry Golden-Chair, Richard Dworek, Rich Halvey, Dennis Lawler (substitute), Arthur Lee, Brock Nicholson, Bob Palzer, Richard Phelps, Jim Ralston, Greg Schaefer, Eric Skelton, Herb Williams, and Mel Zeldin.

Work group members not in attendance:

Joe Paisie-Chair, David Baron, Vince Brisini, Glen Cass, John Crouch, Gregory Dana, Jeff Gabriel, Steve Gerritson, Robert Kappelmann, Dick Long, Steve Pezda, Don Pickrell, Jim Salvaggio, Conrad Schneider, and Jean Vernet.

Other attendees:

Beth Friedman (EC/R--Environmental Protection Agency (EPA) contractor support).

III.	ACTION ITEMS

Upcoming Calls and Meetings. The Base Programs work group will try to schedule one or more face-to-face meetings to prepare for the September 26 and 27 Federal Advisory Committee Ace (FACA) Subcommittee meeting in Norfolk, Virginia. The next Base Programs conference call is scheduled for August 21 from 11:00 am to 12:30 pm EDT.

IV.	MEETING SUMMARY

Attainment Dates

Mr. Williams gave a brief overview of his summary of the issue paper, "Attainment Dates." The issue paper is organized into the following sections:

1.	Planning Cycle,

2.	Statutory Requirements,

3.	New Ozone National Ambient Air Quality Standards (NAAQS) Options,

4.	New Particulate Matter (PM) NAAQS Options, and

5.	Integrated NAAQS Options.

Planning Cycle

Mr. Williams confirmed that the starting point of the ozone timeline is designation. Mr. Golden suggested that under the area of violation (AOV) and area of influence (AOI) construct, the first two steps of the process (emissions inventory and photochemical grid modeling) would have had to occur to some extent in order to make the initial designation. In the case of ozone, it may be possible to immediately designate some AOVs. However, in the case of PM, more time will be required to establish the monitoring network. Also, establishing AOIs may take more time. Ms. Reinders said the first three years would be needed for planning. Mr. Williams said that the timeline assumes the planning necessary for designation has occurred prior to the start of the timeline at designation.

One member asked whether significant growth in the ozone monitoring network was also needed. Mr. Williams said that Texas would certainly need more monitors, and that the monitoring State implementation plan (SIP) might be the mechanism to implement expanded monitoring. Mr. Golden agreed previous issue papers have also recognized the need for additional monitoring to fill data gaps and validate models. Ms. Reinders noted that once the NAAQS are proposed in the fall, it will be easier to address monitoring needs. Mr. Palzer stressed that the group should not wait until Phase II (of this process) to address monitoring issues.

Mr. Nicholson said the timeline should show 12 to 24 months for States to adopt control strategies and submit their SIPs to accommodate States that have legislative review requirements.

Attainment Date Options

Mr. Dworek said he prefers an option that allows the local determination of attainment dates compared to options that set a specified time limit. He said that in the face of new, more stringent standards, it is not possible to predict the time required to reach attainment. Mr. Lee agreed that a one-size fits all scheme may not be achievable. Mr. Williams had some of the same concerns, and he said he prefers Option 5 (reasonable progress - no date). Mr. Lee agreed that Option 5 is reasonable and said mid-course corrections are the key.

Mr. Palzer said the fact Oregon had nonattainment deadlines was a major incentive that resulted in some of the worst PM areas in the country reaching attainment. Mr. Lee said in areas with local problems, a definite attainment deadline may be achievable. However, in areas where background emissions are a problem, the question of achievability becomes significant. Mr. Palzer said in Oregon the problem was not entirely local. However, other factors in the timber industry resulted in a decreased timber harvest and helped override the more regional emissions from this industry that contributed to the area's PM problem. He noted that Oregon has developed successful cooperative ozone strategies.

Mr. Zeldin suggested adopting a broader view of design values and classifications. He said a classification scheme could be developed that considers whether an area's nonattainment problem is due to local or regional emissions. More time would be required when regional emissions and regional controls are a factor. Mr. Golden suggested classifications could be based on the extent to which emissions reductions are under the control of a single entity, the degree of widespread problems, complexity, etc. Mr. Palzer agreed with this concept in general.

Mr. Williams said Option 4 (reasonable, incremental progress with classification based dates) could be expanded to include Mr. Zeldin's idea. Mr. Zeldin suggested defining "reasonable criteria." He noted that there could be cases where an area could have a severe exceedance, but that it would not require more time than other areas to reach attainment. Mr. Williams then suggested that the exact criteria could be area-specific. However, Mr. Palzer said he favored national criteria to avoid giving local areas an excuse to procrastinate. Mr. Lee favored establishing a set of criteria. However, the exact criteria that would apply in a given area would depend on local circumstances (meteorology, etc.) He disagreed that an attainment date is needed to force people to act.

Mr. Golden asked if the area has an adequate plan, why should there be a different schedule. Mr. Lee said factors such as basin effects in the South Coast can make it very difficult to achieve attainment. Mr. Palzer agreed meteorology can be a factor, but Oregon has the second worst winter meteorology in the country and is still meeting the PM standards. He said, "Where there's a will, there's a way."

Mr. Skelton agreed that having attainment dates is important because they drive the process of getting controls in place and create a sense of urgency. However, it is acceptable to allow extensions based on meeting criteria to qualify for them. Mr. Zeldin agreed that dates keep things moving forward. He would frame extensions in the context of incentives to meet earlier dates and a requirement to jump through more stringent hoops (e.g., reasonably available control measures (RACM) to best available control meausres (BACM). Mr. Ralston said that EPA needs to be involved to ensure national consistency.

Mr. Ralston said attainment dates should not necessarily be set upon initial designation. Instead, a minimum level of controls should be required during the initial period and the receipt of additional time increments (e.g., 5 years) would require the imposition of more stringent requirements. Mr. Lee stressed that achievability would still be an issue with this approach. Mr. Zeldin suggested that parameters could vary depending on the individual case.

Mr. Nicholson suggested that Options 3 (single date with extension based on reasonable planning schedule) and 4 (reasonable, incremental progress with classification based dates) could be merged. He said an upfront, simple extension is not acceptable, because some areas will know already that they need to take serious measures to reach attainment. He suggested that Option 4, modified to include extensions under different scenarios (miss deadlines, need different deadlines), is acceptable. Mr. Nicholson agreed that appropriate deadlines are needed.

Mr. Phelps said there is a need to add information and examples about achievability that addresses the coastal environment, meteorology, topography, etc. Mr. Skelton said EPA has developed a natural event policy for PM-10 that could serve as a model. This policy addresses instances where some natural events can overwhelm the ability of an area to stay in attainment. He suggested an ozone analog could include public health advisories. Mr. Williams said this issue is one of what you count as exceedances rather than an attainment date issue. Mr. Skelton responded that this approach provides an opportunity to discount exceedances of standards due to overwhelming natural events. Without this policy, some areas might never reach attainment. Mr. Williams said this approach is similar to the idea of accounting for overwhelming transport.

Mr. Golden said the designation scheme addresses transport and meteorology. Mr. Ralston reminded the group that it is not their charge to address the form and basis of the NAAQS. However, the group could inform the NAAQS setters that a system driven by extremes in meteorology is not productive. In conclusion, he opposes building options for flexibility due to meteorology. Mr. Phelps said he sees these factors as criteria establishing how States could obtain extensions and not NAAQS setting issues. Mr. Ralston responded that these factors can be recognized by adopting different controls such as RACM to BACM.

Mr. Palzer said he saw some agreement for an option that combines firm attainment dates with the flexibility to address more complex areas. Mr. Lee said he disagreed with a stringent set of dates because of achievability concerns. Instead of measures providing incentives for extensions, he saw these measures as providing penalties.

Mr. Golden asked why there would be a need to increase the severity of measures as a requirement to obtain an extension unless there are remaining effective local controls. He suggested staying away from prescribed measures and focussing on solutions that are cost effective. Mr. Nicholson said there could be increasing sets of performance goals. Mr. Zeldin said there needs to be increasing levels of controls to keep the process moving forward and to provide incentives to reach attainment.