Draft Summary

September 4, 1996 Base Programs Analyses and Policies Work Group Conference Call

I.	OVERVIEW

The Base Programs Analyses and Policies (BPAP) work group held a conference call on September 4, 1996 to discuss "Defining Areas of Influence (AOI's)".

II.	PARTICIPANTS

Work group:

Jerry Golden-Chair, Joe Paisie-Chair, Vince Brisini, Steve Gerritson, Robert Kappelmann, Arthur Lee, Bob Palzer, Steve Pezda, Richard Phelps, Greg Schaefer, Eric Skelton, Jean Vernet, and Herb Williams.

Work group members not in attendance:

David Baron, Richard Chastain, John Crouch, Gregory Dana, Richard Dworek, Jeff Gabriel, Rich Halvey, Dennis Lawler, Brock Nicholson, Jim Ralston, Jim Salvaggio, Conrad Schneider, and Mel Zeldin.

Other attendees:

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

III.	ACTION ITEMS

1.	Upcoming Calls and Meetings. The BPAP work group will hold a face-to-face meeting on September 16 and 17 in Durham, North Carolina to finalize the current issue papers and prepare for the presentations to the Federal Advisory Committee Act (FACA) Subcommittee at the end of the month. There will also be a BPAP conference call on September 18 to discuss the "Areas at Risk" paper.

2.	Donna Lamb of the National and Regional Strategies (NRS) work group requested that a BPAP representative participate in the NRS meeting when the integrated programs issue paper is discussed. Mr. Paisie will try to attend, and Mr. Kappelmann will try to call in.

IV.	MEETING SUMMARY

Defining AOI's

Mr. Paisie said the NRS work group is working on defining AOI's. He requested that the BPAP work group use this conference call to review the NRS prepared summary material with the intention of providing BPAP to NRS. This is not a joint issue paper, but BPAP should have some relevant comments on the topic. Mr. Gerritson said he would be participating in the NRS discussion on this issue via telephone, and Mr. Lawler will be attending the meeting in person.

Concept A1, AOI defined as AOI = area of violation (AOV), was discussed. Members felt the disadvantage that the scenario is too close to business as usual was stated too strongly. Mr. Schaefer said that in the West, this could be an advantage. Mr. Kappelmann noted that not everything in the past is bad or inappropriate. Mr. Chastain suggested a disadvantage is that the scenario may have limited applicability. Mr. Gerritson suggested adding that a lack of flexibility is a disadvantage too.

Mr. Brisini objected to the entire scenario, because it means there is no real AOI. Mr. Gerritson noted that the scenario is silent on the requirements that would result under the scenario.

Scenario A2, AOI defined as source of activity exterior to the AOV, may not be easily defined geographically according to Mr. Schaefer and Mr. Palzer. Mr. Brisini said a disadvantage of the scenario is the difficulty inherent in demonstrating the influence of a single source on an area. Mr. Gerritson said the scenario seems to be limited to a couple of areas (e.g., Class I areas and the coast of Maine), and the only advantage is that the scenario addresses transport.

Mr. Schaefer said it is premature to assume that scenario B1, AOI defined by X miles out from AOV, would be illegal under regional haze, because that program has not been developed. Mr. Brisini said an additional disadvantage would be that the scenario does not account for varying atmospheric conditions. Mr. Skelton said the issue of equity of controls on sources is an issue. The scenario could provide an incentive for sources to locate just outside of the AOI. Mr. Gerritson said there could be an existing contributing source outside of the AOI because of the arbitrary nature of the boundary definition. He suggested that instead of a disadvantage based on terrain, one should be framed to address meteorological effects. Mr. Brisini added that multiple conditions can influence transport. Mr. Kappelmann and Mr. Paisie questioned the scientific basis of the scenario. A disadvantage would be that B1 may not be science-driven.

Mr. Golden added that the B1 scenario could also lead to less economically efficient controls. Mr. Kappelmann rephrased to say that a disadvantage is the difficulty in optimizing benefits and limits to flexibility. He explained that benefits are measured in the eye of the beholder. What may be uneconomical to the industry may be beneficial to the airshed. Mr. Chastain noted that the AOI is just a study area, and one should not presuppose identical treatment within the AOI and the AOV. Mr. Gerritson said if the boundary is drawn arbitrarily, there may be a need to overcontrol in the AOI to compensate for contributing sources that are not within the AOI, as defined. Mr. Pezda agreed that a disadvantage is a lack of flexibility to implement cost-effective controls.

Members agreed that scenario B2, AOI defined by some statistical routine on the source (impact) histogram, is not presented clearly. The graphical presentation is in error because it presents a continuous distribution rather than a histogram. Mr. Gerritson added that another disadvantage is that this scenario would be very difficult to explain to legislators and others. Mr. Schaefer said the last disadvantage, "may not account for smaller sources outside AOI that affect the AOV albeit in a small way," could apply to any of the scenarios. Mr. Kappelmann and Mr. Lee stressed that the option should not be abandoned, just revised.

Mr. Brisini said that scenario C, AOI defined by emission density maps, is based on emissions at one point in time. He said an issue is what happens with changes in emissions and sources over time. Mr. Palzer and Mr. Gerritson said this issue applies to many of the scenarios. Mr. Gerritson said that the issue of linking changes to the AOI boundaries could be addressed in the "attainment dates" issue paper. He suggested a reconsideration of boundaries may be appropriate every 5 years or so. Alternatively, Mr. Brisini suggested the reconsideration of boundaries is a maintenance issue.

Mr. Brisini said that scenario D, AOI defined by sources X days out, would result in a constantly pulsating AOI. Mr. Gerritson said the scenario fails to address changes in meteorology. Mr. Kappelmann said this scenario is beyond workability.

Mr. Gerritson noted that several of the scenarios mention trading impacts, but only some address the directionality of trades. Several of the trading impacts are misstated.

With respect to scenario E, AOI defined by "Cap of X %" of modeled impact, Mr. Gerritson said the problem is in the details. There are different effects for different episodes. Mr. Kappelmann liked the scenario on a theoretical basis, but said there are practical problems with respect to meteorological variability. Mr. Schaefer questioned the stated disadvantage that the scenario discourages participation of sources outside of the area. Mr. Paisie explained that once "X" is less than 100 %, there will be sources that are not part of the AOI, as defined. This disadvantage holds for some of the other scenarios as well.

Mr. Brisini said an advantage of scenario F, AOI defined by "greater than X %" of modeled impact, is that it provides a mechanism for a rebuttable presumption for sources claiming they do not influence the AOV. A disadvantage, however, is that the siting of new sources becomes very difficult. Mr. Schaefer suggested another difficulty would be in obtaining political acceptance.

Mr. Gerritson said both scenarios E and F may be beyond the capability of existing models. Mr. Pezda suggested asking the science group for input. He felt that these options show promise and are workable.

Mr. Kappelmann said scenario G, AOI defined to include "X %" source contributions to any exceedance above the level of the standard, would be constantly changing shape. Mr. Gerritson said scenario G also carries the modeling feasibility concern.

Mr. Brisini questioned how scenario H, AOI defined as State boundary in multi-State amoeba situation, differs from option G. Mr. Gerritson said scenario H establishes a political process, but he does not see the advantage in covering the entire State. Mr. Palzer said the concept might work better if applied to other existing jurisdictions.

Mr. Gerritson viewed scenario I, AOI defined as Eastern Region or Western Region, or National, as overkill. Mr. Palzer noted that the results of modeling may lead to this scenario. Mr. Brisini said Western AOI controls could differ from Eastern AOI controls.

Members said that scenario J, Combination of option I and subregions, is overkill and confusing as presented. Mr. Pezda said that scenarios H, I, and J all move away from the reasoned application of controls through the establishment of arbitrary boundaries.

Mr. Gerritson said he preferred the development of a scenario to combine scenario C, AOI defined by emission density maps, with a common sense, weight-of-evidence test based on modeling. Mr. Brisini saw merit in scenario I, AOI defined as Eastern Region or Western Region, or National, because it would allow an effective cap and trade program.

Integrated Issue Paper

Mr. Kappelmann reported that the bulk of Base Programs comments on the integrated paper have been incorporated by NRS. Key comments are that speciated data are needed to implement each of the revised national ambient air quality standards (NAAQSs) as well as in an integrated fashion. The section on when it makes sense to integrate approaches has been revised to reflect more of the advantages of integration. In summary, the overall paper is improved, and it meets the "big picture" as outlined by BPAP. Mr. Paisie noted that this issue paper is on the agenda for the next Coordination Group call. Donna Lamb of the NRS work group requested that a BPAP representative participate in the NRS meeting when the paper is discussed. Mr. Paisie will try to attend, and Mr. Kappelmann will try to call in.

Attainment Dates

Mr. William's goal is to have the revised attainment dates issue paper on the EPA Technology Transfer Network (TTN) by September 9. He asked for clarification of one comment from Steve Pezda regarding what measure is applied to document progress: emission reductions or reductions in measured pollutants. Mr. Gerritson can not imagine how the standard could be attained without a minimum level of emissions reductions. Mr. Pezda agreed, but said the focus of the effort should be how to achieve the standard. Mr. Gerritson responded that there is a political need for a progress requirement. Mr. Paisie said there is a general need for a credible emission reduction program. Mr. Skelton said a percentage reduction in emissions is a good, predictable tool for use in measuring rate of progress. He said it is too difficult to measure progress against the standard itself. Mr. Paisie suggested that the details of this issue might be better left to Phase II (of the FACA activities). Mr. Williams concluded from the discussion that some level of minimum emission reduction is required.

Mr. Phelps commented that the paper needs better definition of terms.

New Source Review (NSR) Considerations

Mr. Schaefer is still waiting for comments from Bob Palzer and Donna Lamb.

Mr. Brisini said the NSR paper should address the idea of a rebuttable presumption. The intent would be to give owners or operators the opportunity to make a case for an exemption from the new source program if they can demonstrate they do not contribute to the problem.

Mr. Schaefer said his sense was that NRS considers new source programs to be a Phase II issue. Mr. Brisini and others disagreed, saying that there are clear Phase I concepts in this issue. Mr. Gerritson said controlling growth is critical to the new designation concept. The details of the program, however, are implementation issues.

Areas at Risk

Mr. Chastain said he is working to incorporate comments on the areas at risk issue paper received during the last meeting. He plans to have the revised document on the TTN by the week of September 9. Mr. Paisie noted a number of members had left the meeting prior to the discussion of this issue paper, and he encouraged those members to give the paper a close review as soon as possible.