UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

Office of Air Quality Planning and Standards

Air Quality Strategies and Standards Division

Research Triangle Park, NC 27711

FAX TRANSMITTAL

DATE:	May 20, 1996	NUMBER OF PAGES =

TO:	COORDINATION GROUP, FACA SUBCOMMITTEE on

Ozone/PM/Regional Haze Implementation Programs

FR:	SALLY SHAVER, CO-CHAIR	(919) 541-5505, Fax (919) 541-0804

RICH DAMBERG, TEAM LEADER	(919) 541-5592, Fax (919) 541-7690

NAME	TELEPHONE #	FAX #

Mr. Patrick Raher (Co-Chair)	(202) 637-5682	(202) 637-5910

Mr. S. William Becker	(202) 624-7864	(202) 624-7863

Ms. Georgia Callahan	(914) 838-7645	(914) 838-7115

Mr. John Christiano	(303) 969-2070	(303) 969-2822

Ms. Mary Gade	(217) 782-3397	(217) 782-9039

Dr. Thomas Godar	(860) 714-4055	(860) 714-8035

Mr. Charles Goodman	(205) 870-6325	(205) 877-7938

Ms. Beverly Hartsock	(512) 239-5818	(512) 239-4808

Mr. David Hawkins	(202) 783-7800	(202) 783-5917

Mr. Richard Hayslip	(602) 236-6699	(602) 236-3407

Mr. Shawn Kendall	(602) 234-8308	(602) 234-4814

Mr. Tim O'Brien	(313) 323-2895	(313) 248-5030

Mr. Jerry Pardilla	(505) 242-2175	(505) 242-2654

Mr. Karl Schultz	(302) 773-4394	(302) 773-4494

Mr. Robert Shinn	(609) 292-2885	(609) 292-7695

Mr. F. Bradford Smith	(410) 368-7090	(410) 368-6721

Mr. James Souby	(303) 623-9378	(303) 534-7309

Mr. John Taunton	(713) 656-2401	(713) 656-6594

WG Co-Chairs

Mr. Jerry Golden	(423) 751-6779	(423) 751-7545

Mr. Harvey Jeffries (room 120)	(919) 966-7312	(919) 966-7911

Mr. Don Theiler/Bob Lopez	(608) 266-0603	(608) 267-0560

Mr. Ron White	(202) 785-3355	(202) 452-1805

____________________________________________________________________________________________

MESSAGE The next Coordination Group conference call is on Wednesday, May 22, 1:00 - 2:30 EST, call-in number 202-260-7280, 4065#. Attached are the following materials for the call: 1) agenda for the 5/22 meeting; 2) summary of May 8 conference call; 3) revised agenda for May 30 Subcommittee meeting; 4) Base Program WG summary on Interim Policy principles; 5) National/Regional Strategies WG revised principles for addressing its 4 major issues; 6) Base Programs WG designations issue paper summary; 7) info on Durham Bulls baseball game, May 29. See you Wednesday.

SUBCOMMITTEE ON OZONE, PARTICULATE MATTER, AND REGIONAL HAZE

IMPLEMENTATION PROGRAMS

COORDINATION GROUP

Meeting #8

Wednesday, May 22, 1:00 - 2:30 EST

Call-in Number: 202-260-7280, 4065#

AGENDA

1.	Roll Call / Review of Last Meeting and Today's Agenda

2.	Revised agenda for May 30 Subcommittee meeting

3.	Discussion - Interim Transition Policy Principles

4.	Discussion - Designations Issue Paper

5.	Review of National/Regional Strategies WG principles for 4 major issues

6.	Upcoming Meetings

- May 29, Coordination Group meeting, (NEW TIME) 3:00-6:00, Durham, NC

- May 30, Subcommittee meeting, 8:00-5:00, Durham Omni Hotel

- June 5 conference call cancelled

- Next conference call on June 19 (same time and number)

Attachments

1.	Summary of May 8 conference call.

2.	Revised agenda for May 30 Subcommittee meeting.

3.	Base Program WG summary re: May 7-8 meeting on Interim Policy principles and designations issue paper.

4.	Base Programs WG designations issue paper summary.

5.	National/Regional Strategies WG revised principles for addressing its 4 major issues.

SUMMARY

FACA Coordination Group Conference Call

May 8, 1996

I. PURPOSE

A conference call took place on May 8, 1996 to enable Coordination Group members to discuss the FACA calendars for June and July, a draft agenda for the May 30, 1996 Subcommittee meeting, the overview of the FACA management plan, potential agenda items for the May 29 Coordination Group meeting in Durham, NC, and to receive an update from the Base Programs Work Group.

II.	PARTICIPANTS

Workgroup Attendees:

Sally Shaver, EPA/AQSSD (Co-chair)

Rich Damberg, EPA Staff Team Leader

William Becker, STAPPA/ALAPCO

Georgia Callahan, Texaco

John Christiano, National Park Service

Charles Goodman, Southern Company Services

Beverly Hartsock, Texas TNRCC

Sherry Haller-Feaster for Richard Hayslip, Salt River Project

Shawn Kendall, Phelps Dodge Corp.

Cathy Waskiewicz for Tim O'Brien, Ford Motor Co.

Patrick Raher, Hogan & Hartson (Co-chair)

Karl Schultz, E.I. Dupont de Nemours & Co.

John Leary for James Souby, Western Governor's Association

Bradford Smith, Environmental Elements Corp.

John Taunton, Exxon Co., USA

Workgroup Members Not in Attendance:

Mary Gade, Illinois

Tom Godar, American Lung Association

David Hawkins, NRDC

Gay McGregor, EPA Office of Mobile Sources

Jerry Pardilla, NTEC

Robert Shinn, New Jersey

Winston Smith, EPA Region IV

Other EPA Attendees: Tom Curran, Joe Paisie, Bill Hamilton, David Mobley, Denise Gerth, Robin Dunkins, Linda Metcalf, David Sanders, and Rosalina Rodriguez

Other Attendees: Alan Krupnick, Don Theiler

Deborah Amaral, EC/R Incorporated (EPA Contractor Support)

III.	MEETING SUMMARY

Action Items from the meeting are as follows:

1)	Shawn Kendall will make the final report of the Grand Canyon Visibility Transport Commission (GCVTC) available to the Subcommittee as soon as possible upon its revision.

2)	Work Groups will prepare brief papers on the issues to distribute to the Subcommittee members in advance of the Subcommittee meeting in May, to lead Subcommittee members through the debates and/or the consensus that has been achieved.

3)	EPA said they will make the report from the Base Programs Work Group available to the full FACA Subcommittee no later than May 21, and to the Coordination Group as soon as possible for discussion at the May 22 meeting.

4)	FACA documents are being uploaded onto the Bulletin Board System (BBS). Members should provide Rich Damberg with the name they plan to use when on the Bulletin Board, to obtain access to the private development areas.

5)	The next Subcommittee meeting is scheduled for May 30, 1996, in Durham, North Carolina. The Coordination Group plans to meet late in the afternoon on May 29.

6)	The next conference call is Wednesday, 5/22/96, between 1:00 pm and 2:30 pm EDT, call-in number 202-260-7280, 4065#. At the May 22 meeting, members would like to discuss the agendas for the meetings on May 29 and 30. Members would also would like to have a general discussion on issues about which the Work Groups do not reach consensus, and how they will be presented to the Subcommittee. The June 5 conference call has been cancelled, the next call will be on June 19.

The meeting accomplished the following:

1)	The group agreed to try to schedule a Subcommittee meeting in conjunction with the next CAAAC meeting, which might take place in July.

2)	Changes to the draft agenda for the Subcommittee meeting in May were recommended.

3)	Members discussed the process for reviewing recommendations about the principles of the Interim Implementation Policy (IIP), and the schedule for submitting the principles and the policy to the OMB.

4)	Joe Paisie presented an update from the Base Programs Work Group meeting on the interim policy principles.

5)	Members discussed topics for the agenda for the May 22 conference call.

IV.	SUMMARY OF DISCUSSIONS

Overview of FACA Calendars for June and July

The group examined the FACA calendars for June and July, which were distributed with the materials for the conference call. The group agreed that if there will be a CAAAC meeting in July, it would be desirable to hold a Subcommittee meeting in conjunction with it. The date of the next CAAAC meeting has not been set yet, however.

Draft Agenda for May 30 Subcommittee Meeting

The group discussed the draft agenda for the Subcommittee meeting in May. Shawn Kendall offered to make the final report from the Grand Canyon Visibility Transport Commission (GCVTC) available to members of the Subcommittee, and to make a presentation on the report to the Subcommittee. The Operations Committee of the GCVTC will be meeting May 14, and the report can be sent out once any revisions are made.

Members considered the allocation of time, and the order of topics given in the draft agenda and recommended several changes. Participants approved of the placement of the discussion of Part 50 after lunch, and also approved of the amount of time allowed for discussion. The group agreed to reduce the amount of time for general status and opening remarks, to make more time available for presentation and discussion of the principles of the Interim Implementation Plan.

Several members expressed the desire for the Work Group presentations to explore certain substantive issues in depth rather than providing broad updates. In addition, Work Groups should discuss some of the most "difficult" issues they are currently addressing. Members recommended that brief issue papers be sent out in advance of the Subcommittee meeting in order to lead the Subcommittee through the issues and allow them time to organize their thoughts on the issues in advance.

The agenda includes a presentation following the Status of Part 50 on potential different ways to designate attainment/nonattainment areas should new standards be established. Some members anticipated that this topic might need even more time for discussion. The group agreed that by the May 22 conference call, more information about the details of the different viewpoints within the Work Groups and the preliminary designation topic will be available, and the Coordination Group will be in a better position to adjust the time allocation for the Subcommittee meeting agenda during the May 22 call.

Overview of Draft FACA Management Plan

The draft FACA Management Plan was included in the meeting materials, and reviewed during the conference call. The chart shows that the IIP principles will go to the OMB by mid-June, and the full IIP will be submitted to the OMB in the September/October time frame. Page 25 of the materials indicates where we currently are in the FACA process. (Step 45 corresponds to the full Base Programs Work Group face-to-face meeting on May 7-8, 1996. The May 30 Subcommittee meeting is indicated as step 47.)

Participants discussed the plans for the Base Programs Work Group to make recommendations to the Coordination Group. The Base Programs Work Group is reviewing the comments on the IIP, and will report on consensus, or differences, to the Coordination Group. The Coordination Group will continue to move forward with work on the policy once it has the principles, and will not revisit them. Members were eager to receive the draft quickly, to permit time for review before the meetings. EPA said they will make to report from the Base Programs Work Group available to the full FACA Subcommittee no later than May 21, and to the Coordination Group as soon as possible for discussion at the May 22 meeting. Members expressed the expectation that there will be extensive discussion at the Subcommittee meeting, and that whatever is agreed upon at the May 30 meeting will become the basis for the EPA's transition policy.

Potential Agenda Items for May 29 Coordination Group Meeting

The Coordination Group affirmed that it would like to hold a face-to-face meeting on May 29, before the full FACA Subcommittee meeting on May 30, in Durham, NC. At the May 22 meeting, members would like to discuss the agendas for the meetings on May 29 and 30. Members would also like to have a general discussion on issues about which the Work Groups do not reach consensus, and how they will be presented to the Subcommittee. The members agreed to meet at 4 pm, instead of 4:30 pm.

Update from Base Programs Work Group

Joe Paisie gave a live report from the face-to-face meeting of the Base Programs Work Group in Durham, NC. A summary of the discussion of the IIP principles will be included in the materials for the May 22 CG meeting.

Members of the Coordination Group asked about integration and interactions across pollutants. Joe Paisie said the Work Group did not discuss trade-offs among different pollutants, but considers the issue to be included under the definition of No Backsliding, and the principle of not exacerbating the other NAAQS. He summarized their position as "do no harm." He also discussed the relationship between transport and the substitution issue. The concept of substitutions may also involve expanded areas from which reductions may be obtained (e.g. possibly from attainment areas, possibly across state lines). It was asked that this point be emphasized in the presentation by the Work Group to the Subcommittee.

Coordination Group members also asked about the positions on reductions mandated in the Clean Air Act. Joe Paisie said the Base Programs Work Group had a very good discussion, and it has a fundamental disagreement about moving away from the mandated measures in the Act. Coordination Group members said it would be very beneficial to bring this issue forward to the full FACA Subcommittee for discussion. Members asked whether No Backsliding also meant continuation of planning milestones for current standards. Joe Paisie responded that states should roll all planning efforts into preparing for the revised NAAQS, or planning substitutions. The objective would be to merge paths into one planning scenario.

Participants asked about the sense of the Base Programs Work Group on Subpart 2. Joe Paisie responded that the measures in Subpart 2 would stay in place, but that areas could substitute other measures which could be more effective. The requirements would not be abandoned, but would be turned into a requirement to achieve environmental improvement, and opportunities to include broader geographic areas. Joe Paisie also reported that the Base Programs Work Group has completed its first issue paper, and will continue work on another batch of them next week. A summary of the issue paper on information to be used for designations of nonattainment areas and establishing regional haze planning areas will be distributed to the CG for discussion at the May 22 conference call.

Upcoming Meetings, Possible Agenda Items and Other Business

The FACA Subcommittee will meet May 30, 1996, from 8:00 am to 5:00 pm, at the Omni Durham Hotel, Durham, NC. Jerry Perdilla, who is from the National Tribal Environmental Council (NTEC) and on the FACA Subcommittee, is now a member of the Coordination Group. In other business, Tim O'Brien is now the Subcommittee and Coordination Group member from Ford, and Cathy Waskiewicz will sometimes serve as his alternate at CG meetings. The FAX cover sheet will be corrected to say EDT, instead of EST, for the meeting times.

Rich Damberg said that some FACA documents are lengthy, such as the summary of the IIP comments (40 pages), and are being put up on the Bulletin Board System (BBS). He said that the National and Regional Strategies Work Group also has posted issue papers on the BBS. He recommended to Coordination Group members that they explore the BBS, or have a staff member do it for them, on a regular basis. Members should let Rich Damberg know who will be using the BBS, so he can make arrangements for them to have access to private development areas.

Tom Curran explained that the brochure in the meeting materials gives the approach to reaching the BBS through telnet. He reported that when the file transfer protocol (FTP) became available, over 1000 documents were downloaded in 24 hours from the BBS using the Internet access. He also reported that over 400 people were on the BBS last week.

The next conference call will take place on May 22, 1996, from 1 to 2:30 pm, EDT. The call-in number is (202)260-7280, 4065#. A face-to-face meeting is scheduled for 3 pm in the afternoon on May 29, 1996, in Durham, North Carolina. The June 5 teleconference call is cancelled, and the following conference call is scheduled for June 19.

Draft Agenda (5/15/96)

SUBCOMMITTEE FOR OZONE, PARTICULATE MATTER AND

REGIONAL HAZE IMPLEMENTATION PROGRAMS

MAY 30, 1996

Omni Durham Hotel and Durham Civic Center

301 Foster Street

Durham, North Carolina

Thursday, May 30

8:30 - 8:40 a.m.	Opening Remarks - Bill Hamilton, Designated Federal Official

8:40 - 8:55 a.m.	Introductions and Role of Economics - Alan Krupnick

8:55 - 9:05 a.m.	Tribal participation on work groups - Jerry Pardilla

9:05 - 9:15 a.m.	GCVTC Update - Shawn Kendall

9:15 - 9:35 a.m.	Base Programs Work Group Update

--Interim Implementation Policy Principles - Sally Shaver/Joe Paisie

9:35 - 10:15 a.m.	Open Discussion of IIP Principles

10:15 - 10:30 a.m.	Break

10:30 - 11:30 a.m.	Open Discussion of IIP Principles

11:30 - 12:45 p.m.	Lunch

12:45 - 1:15 p..m.	Status of Part 50 Ozone Package - John Seitz/Sally Shaver

-- Discussion on form of the standard

1:15 - 2:00 p.m.	Preliminary Designation Discussion - Jerry Golden

2:00 - 2:15 p.m.	National/Regional Strategies Work Group Update - Don Theiler

2:15 - 3:00 p.m.	Open Discussion on National/Regional Strategies Work Group

3:00 - 3:15 p.m.	Break

3:15 - 3:30 p.m.	Science/Technical Support Work Group Update - Harvey Jeffries

3:30 - 4:00 p.m.	Open Discussion on Science/Technical Support Work Group

4:00 - 4:15 p.m.	Communications/Outreach Work Group Update - Ron White

4:15 - 4:30 p.m.	Open Discussion on Communications/Outreach Work Group

4:30 - 4:45 p.m.	General Discussion

4:45 - 5:00 p.m.	Next Steps

5:00 p.m.	Adjourn

INTERIM IMPLEMENTATION POLICY PRINCIPLES

REPORT TO THE COORDINATION GROUP

BASE PROGRAMS ANALYSES AND POLICIES WORK GROUP

MAY 22, 1996

INTERIM PRINCIPLES - OUTPUT FROM BASE PROGRAMS ANALYSES AND POLICIES WORK GROUP MEETING, MAY 7-8, 1996

1.	Interim implementation policy becomes effective at the time new national ambient air quality standards (NAAQS) are promulgated and remains effective until attainment state implementation plans (SIPs) for the new NAAQS are approved by the Environmental Protection Agency (EPA). Work group recognized problems with SIP processing but made no recommendation.

2.	No backsliding is allowed.

- All existing programs stay in place, e.g., the Ozone Transport Region.

- All requirements for new programs stay in place, e.g. 3% rate of progress or other actions to meet milestones including new programs that may be required as a result of the Ozone Transport Assessment Group or other transport related activities.

3.	Goal is progress toward attainment of new NAAQS in a flexible and cost-effective manner.

- Current or required new program provides rate of progress or "glide path" to govern actions in the interim.

- Ozone bump ups do not occur if the existing NAAQS is replaced.

- Particulate matter bump ups depend on the outcome of the NAAQS review.

4.	Satisfaction of program requirements is possible through substitution of alternative measures that achieve equivalent or greater rate of progress toward air quality improvement that would have been achieved with the former measures with focus on the new NAAQS.

- Substitutions are available to all States regardless of their status in adopting and implementing the Clean Air Act's (Act) mandated schedules.

- It is EPA's responsibility to deal with States that are behind schedule.

- Where modeling of the current or new program lacks sufficient capability or resolution to serve as a basis to show that the substitution achieves equivalent air quality improvement, substitution of measures could be on a ton for ton basis of the same pollutant basis or could be based on a demonstration of correct 'directionality'.

- Substitution has the potential to provide for implementation of strategies that are more cost-effective, are based on better science, provide greater public health and ecosystem protection, and provide opportunities to expand the area from which creditable reductions can be obtained acknowledging the possible impact of transport.

- Substitutions should not exacerbate the other NAAQS.

- Mechanism for trading may/will result in a greater than 1 for 1 exchange

5.	The burden of proof for equivalence of substitutions rests with the States and substitutions are to be documented and reviewed as a part of the SIP process.

6.	There is limited sentiment to include population exposure concerns into interim implementation.

▪	The environmental-interest members fundamentally disagree with movement away from the "Act's mandated measures".

- Reject the possibility of substitution.

This is a preliminary document prepared by a subgroup of members of the National and Regional Strategies Work Group as part of the Federal Advisory Committee Act (FACA) Subcommittee process. It is not an EPA document. It is subject to further work group discussion. Interested people should forward their comments to a member of the National and Regional Strategies Work Group.

Revised Draft May 13, 1996

NATIONAL / REGIONAL STRATEGIES WORK GROUP - ISSUE #1

ISSUE TITLE:	Institutional Mechanism for Development and Implementation of Regional Strategies

DESCRIPTION: Use of regional strategies implemented over a large geographic scale may not be entirely compatible with available institutions. In many areas where regional transport is significant, the current nonattainment area approach is not an adequate institutional mechanism to deal with the regional nature of the pollutants of concern. New institutional mechanisms may be needed to ensure development and implementation of strategies to reduce regional transport of ozone, particulate matter/regional haze, and their precursors. To develop an effective and equitable regional strategy, it will likely be necessary for a number of states, tribes, local governments, existing regional institutions, and EPA to work in concert to assure consistency, efficiency and broad public participation in the process. Some regional institutions already exist that may be appropriate fora for developing regional strategies.

ASSUMPTIONS: The options regarding the structure and function of a regional "institution" presented below are based on an assumption that regional-scale air quality planning will be driven by performance-based standards and make use of market forces (i.e., emissions caps and trading programs).

OPTIONS:

Administrative/Organizational

Regional institutions must include, at a minimum, states and tribes, local agencies, and existing regional organizations with jurisdiction over the relevant transport region. The regional institutions must cover all the sources and nonattainment areas that contribute to regional ozone, PM and visibility problems. These institutions should get input from a broad spectrum of the public.

Existing multistate institutional structures might provide useful models or mechanisms for regional planning and implementation efforts. The first step is to evaluate the roles, responsibilities, authorities, and effectiveness of existing institutions, including, NESCAUM, LADCO, OTC, SESARM, WESTAR, OTAG, MARAMA, GCVTC, ECOS AND STAPPA/ALAPCO. Through interviews with their respective executive directors or member states, we should identify institutional characteristics, assess whether the institution might be able to foster and oversee implementation of regional programs, and determine whether new institutions will be needed.

The role of stakeholder involvement in consensus-building and decisionmaking should also be explored. Regional institutions could help facilitate regular, and perhaps formal, involvement of major regional interest groups through, e.g., advisory committees.

The authority of the regional institution must be clearly defined. The efficacy (legal, political, administrative, etc.) of delegating regulatory authority to a regional institution should be explored, as should other approaches for ensuring implementation of regional strategies (e.g., including, interstate compacts, arbitration and negotiation mechanisms, incentives/disincentives, etc.).

Regional institutions must develop an operating protocol outlining the decisionmaking process that will be used to ensure that necessary and appropriate regional strategies are developed and implemented.

Operating procedures must discuss who gets to vote, the conditions under which a vote leads to action (majority or consensus), the extent to which decisions are binding on the member jurisdictions, how implementation of decisions will be ensured and by whom, and what steps will be taken if decisions are not implemented.

In developing the operating procedures, legal constraints under existing federal and state law -- that might affect the nature and amount of planning, implementation and enforcement authority that could be given to a regional institution -- will need to be examined. Non-regulatory mechanisms for ensuring implementation and compliance will also be explored, as will options for modifying current regulatory or statutory requirements to accommodate a greater role for regional institutions.

New institutional mechanism should compliment, supplement or replace functions served by existing institutions (EPA--headquarters and regional offices, states, local governments). Duplication of effort must be avoided, with responsibility assigned at the lowest level of government practicable. States should retain primacy (subject to EPA oversight and FIP authority) to the greatest extent consistent with air quality goals. Phased implementation of a new institutional mechanism may be prudent.

Factors to be considered in determining an appropriate and efficient allocation of responsibility among state, regional institutions, and EPA may include: efficiency, consistency, capacity, accountability, and enforceability.

New institutional mechanism should involve EPA in a collaborative decisionmaking process, including EPA's early and continuing participation, rather than the more iterative current model where EPA often does not weigh in formally until after plans have been developed. This should include developing protocols upfront between EPA and the regional institution outlining criteria, objectives, and technical approach to be used.

Technical

Institutional mechanisms should be structured to foster communication among States and the private sector involved with implementing measures. This goal envisions the mechanism as providing an information clearinghouse on what different States are doing as well as who the appropriate contacts are to learn further details. The institutional mechanism might also serve as the means for facilitating periodic meetings on various subjects related to implementing regional strategies in a coordinated fashion. The scope of the regional institutions role could also include identifying common local air pollution problems that affect multiple jurisdictions within the region (even though the problem is not regional in scope), and centralizing or coordinating technical support related to strategy development.

Institutional mechanism should promote use of improved analytical tools and databases, including, establishing guidelines that outline consistent and necessary information to be included in emissions inventories, as well as assumptions and modeling protocols to be used among the States implementing regional measures.

Institutional mechanisms should develop a means for summarizing and distributing information on cost-effectiveness of regional control measures, including,scientific basis for, technical viability of and capital/operating costs.

Regional institutions should ensure the orderly transfer of emission credits between jurisdictions, including, tracking, verifying, recording, and perhaps, enforcing conditions of, interstate emission reduction credit transactions.

Policy and Strategy Development and Implementation

Clear goals and objectives will need to be established for the institutional mechanism created which aim at developing and implementing regional control measures for air pollution issues that are regional in scope.

Criteria should be developed for (1) establishing the goals and objectives; (2) identifying and evaluating regional control measures; and (3) allocating implementation and enforcement responsibility among affected jurisdictions and governmental institutions.

Institutional mechanisms should be structured to support development and implementation of incentive- and market-based approaches to managing regional pollution problems, including, developing positive incentives for upwind areas to reduce precursor emissions. Possible things to consider include having downwind areas/sources defray some of the control costs at upwind locations in exchange for not having to implement the most costly controls in their area, use of performance goals rather than specific measures, providing a #bonus credit# for early implementation.

Revised 5/2 per WG Call and Comments	DRAFT

4-25-96r

NATIONAL / REGIONAL STRATEGIES WORK GROUP

ISSUE #2:	How should we identify areas/regions for control strategies? How do we evaluate the concept of nonattainment areas in dealing with ozone and fine PM transport?

Problem/Issue Statement:

Currently, nonattainment area designations try to do two jobs at once: delineate areas where the NAAQS is violated, and delineate areas where controls are needed. The presumption has often been that controls are needed everywhere in the designated nonattainment area and nowhere outside it. Traditionally, the boundaries have been political boundaries, such as county lines, that may not reflect either the area of violation or the area that contributes to the violation. Especially in cases involving long-range transport, these two types of areas may not necessarily coincide. Local groups may resist air quality monitoring for fear of being designated nonattainment because that designation triggers various regulatory requirements. This resistance to monitoring can keep us from understanding the true extent of the air quality problem we are dealing with.

Initial Principles:

1.	Determining areas where NAAQS are not being met ("monitored NAAQS violation areas") should be based on monitoring. The establishment of the boundaries for such areas should be based on a combination of monitoring and modeling.

2.	The current program of using monitoring data to designate areas where NAAQS are not being met needs to be revised to encourage rather than discourage the siting of additional monitors.

3.	Modeling as well as other relevant information should be used to determine if and where monitors should be located. If modeling predicts that NAAQS are not being met in certain areas, then monitors should be located in these areas within a reasonable period of time. The failure to site monitors in these areas within a reasonable period of time shall be a basis for requiring the development and implementation of a control strategy based on the modeling.

4.	A determination that an area is a "monitored NAAQS violation area" should not necessarily imply that controls are required in that area. Appropriate modeling and other sound technical information should be used to determine whether and, if so, to what extent controls should be required in that area (see also no. 7).

5.	Areas that, based on sound technical information and science, are shown to contribute significantly to the exceedance of NAAQS should be designated as "contributing areas." These "contributing areas" may or may not have monitored data showing violations of the NAAQS and thus may or may not be separate "monitored NAAQS violation areas."

6.	Spatially integrated control strategies should be required for all related "contributing areas" within "control regions" (see no. 5).

7.	In developing spatially integrated control strategies for "control regions," the following principles should apply:

•	Controls on all sources or source categories should be considered.

•	Controls for sources or source categories which contribute significantly to the violations of NAAQS should be prioritized and implemented on the basis of their contributions to reducing pollutant levels in the "monitored NAAQS violation areas" based on sound technical information and science, and the cost-effectiveness of controlling that source or source category.

•	In determining whether to require controls in "contributing areas," the impacts of such controls on air quality levels in the "contributing areas" and other areas must be considered (e.g. whether NOx controls will increase ozone levels in "contributing areas" to unacceptable levels.)

8.	Consideration should be given to developing an integrated control strategy for multiple pollutants if supported by sound technical information and science.

9.	Nationwide or multi-state regional controls should be promulgated by EPA for source categories where state-by-state controls are impractical, as has been done for consumer products and small engines.

10.	States should notify and educate the public in the "monitored NAAQS violation areas" about the health impacts of the violations, efforts underway to correct the violations and actions the public can take to minimize risk from the pollutants causing the violation.

(NRSWG.I2A)

This is a preliminary document prepared by a subgroup of members of the National and Regional Strategies Work Group as part of the Federal Advisory Committee Act (FACA) Subcommittee process. It is not an EPA document. It is subject to further work group discussion. Interested people should forward their comments to a member of the National and Regional Strategies Work Group.

NATIONAL / REGIONAL STRATEGIES WORK GROUP - ISSUE #3

May 9, 1996

Issue #3 Title: Develop and assess optimal national/regional/multipollutant control strategies that are effective from an interpollutant and transport perspective.

ISSUE DESCRIPTION:

The photochemical reactions involving volatile organic chemicals, oxides of nitrogen and sunlight which produce ozone also produce other secondary pollutants. The photochemical reactions can result in oxidation of sulfur dioxide and oxides of nitrogen to produce visibility reducing species which may be regarded as fine particulate or as haze. This realization leads to the question of whether control of ozone, PM-fine and haze can be optimized through consideration of all of them together in an integrated fashion rather than considering each separately.

This issue considers first how we decide if integration is appropriate and second, if it is, then what integrated control strategies should be implemented to reduce the impact on public health and improve visibility caused by regional haze.

INTEGRATED CONTROL STRATEGIES SHOULD BE STRUCTURED ON THE FOLLOWING PRINCIPLES:

1.	Use Sound Science: Integrated control strategies for simultaneously reducing ambient concentrations of tropospheric ozone and fine particulate matter will be pursued if there is sufficient observation-based data to demonstrate both an environmental and economic benefit to integration.

2.	Performance based control strategies should be emphasized in lieu of prescriptive command and control strategies.

3.	Controls should establish emission reduction responsibility based on the contribution to the problems, while also considering cost-effectiveness.

4.	Prevent backsliding during the transition.

5.	Broad scale control strategies for contributing sources should be emphasized, where dictated by sound science.

6.	Focus on the interactions of the pollutants and the interactions between control strategies, identifying both positive and negative interactions.

7.	Integrate the implementation of the three rules (Ozone, Particulate Matter, and Regional Haze), to the greatest extent possible.

8.	Recognize that decisions need to be made based on scientific information that is improving and find institutional mechanisms to allow for mid-course corrections when significant new information is available.

NATIONAL / REGIONAL STRATEGIES WORK GROUP

Issue # 4:

REGIONAL INNOVATIVE STRATEGIES INCLUDING MARKET

BASED EMISSION TRADING

Full internalization of emissions costs through market based trading or other economic incentive programs holds the promise of achieving necessary pollutant reductions with improved efficiency thus reducing the overall cost to the economy.

The regional strategies should be designed around the concept of sources contributions to the various pollution problems (Ozone, Haze, PM )and their corresponding responsibility for emission reductions. The strategies should to the largest degree possible be structured to foster flexibility as to how each source meets its responsibilities. The extent of geographical, temporal and inter-pollutant flexibility within the program is necessarily a function of the physical, chemical and meteorological parameters of the non-attainment problem, but these constraints should be viewed in the context of effects of the overall program and not on the basis of individual trades or transactions. Protection of other(non regional) objectives must be maintained, but is best accomplished independently of the regional strategies. The present evolutionary direction of EPA's emission trading policy is consistent with the needs for flexibility and efficiency. Consideration should also be given to the use of other types of incentives such as fees or taxes and rebates where appropriate. The role, if any, of downwind sources /states in providing positive incentives for sources in upwind states to control emissions needs to be determined.

Regional Emission Trading Programs or other incentive programs should be structured on the following principles:

a.) Prevent the possibility of backsliding.

b.) Include the broadest possible spectrum of sources, contributing to the problem including mobile and area sources.

c.) Recognize and account for the differing, temporal and geographic impact of reducing the pollutants of concern.

d.) Establish an equitable baseline from which to develop emission credits.

e.) Provide a consistent program across emission source types in order to ensure a common or convertible currency for emission trading purposes.

f.) Provide for transition from other emission trading programs adopted by OTAG, OTC and states policy as necessary or appropriate.

g.) Provide for seamless trading across governmental	jurisdictions.

h.) Avoid the creation of bias or market distortions.

i.) Reward sources who take risks to accomplish innovative, early or voluntary reductions including those later required by law.

j.) Be designed to avoid delays in meeting or dilution of reduction responsibility i.e. no delayed compliance schedules or AELs.

k.) Use economic incentives or market based mechanisms rather than command and control strategies (e.g. LAER) to assure that appropriate levels of emissions are	achieved by new or modified sources.

l.) Provide a net environmental benefit as compared to command and control approaches reflecting a sharing of the cost savings with the environment.