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:	June 14, 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	ORGANIZATION	TELEPHONE #	FAX #

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

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

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

Mr. John Christiano	National Park Svc.	(303) 969-2070	(303) 969-2822

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

Dr. Thomas Godar	American Lung Assoc.	(860) 714-4055	(860) 714-8035

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

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

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

Mr. Richard Hayslip	Salt River Project	(602) 236-6699	(602) 236-3407

Mr. Shawn Kendall	Phelps Dodge Corp.	(602) 234-8308	(602) 234-4814

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

Mr. Jerry Pardilla	Natl Tribel Envt Council	(505) 242-2175	(505) 242-2654

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

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

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

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

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

WG Co-Chairs

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

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

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

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

____________________________________________________________________________________________

MESSAGE The next Coordination Group conference call is on Wednesday, June 19, 1:00 - 2:00 EDT, call-in number 202-260-7280, 4065#. Attached are the following materials for the call: 1) agenda for the call; 2) summaries of May 22 conference call and May 29 meeting. See you Wednesday.

SUBCOMMITTEE ON OZONE, PARTICULATE MATTER, AND REGIONAL HAZE

IMPLEMENTATION PROGRAMS

COORDINATION GROUP

Meeting #10

Wednesday, June 19, 1:00 - 2:00 EDT

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

AGENDA

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

2.	Update on ad hoc group addressing Interim Transition Policy Principles

3.	Discussion of CG responsibilities and process issues

A. Ensuring timely delivery of WG products according to phase I schedule

B. Development of phase I Subcommittee report

4.	Scope of Communications & Outreach WG

- Re: outreach to general public

5.	CG ideas for July 30 Subcommittee meeting agenda

6.	Upcoming Meetings

- Discussion: We anticipate many CG members being unavailable for a conference call on July 3 due to the holiday. We can have the next conference call on WEDNESDAY, JUNE 26, 12:30 - 2:00 EDT instead. Does this date/time work for CG members?

Attachments

1.	Summary of CG conference call on May 22 and meeting on May 29

SUMMARY

FACA Coordination Group Conference Call

May 22, 1996

I.	PURPOSE

A conference call took place on May 22, 1996 to enable Coordination Group members to discuss the revised agenda for the May 30, 1996 Subcommittee meeting, the Interim Implementation Policy (IIP) Principles, the Designations Issue Paper, and to review the National/Regional Strategies Work Group principles for four major issues.

II.	PARTICIPANTS

Workgroup Attendees:

Sally Shaver, EPA/AQSSD (Co-chair)

Rich Damberg, EPA Staff Team Leader

Tom Godar, American Lung Association

Brian Baldwin for Charles Goodman, Southern Company Services

Beverly Hartsock, Texas NRCC

Richard Hayslip, Salt River Project

Shawn Kendall, Phelps Dodge Corp.

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

Greg Allen for Karl Schultz, E.I. Dupont de Nemours & Co.

John Ellston for Robert Shinn, New Jersey

Doug Neeley for Winston Smith, EPA Region IV

John Taunton, Exxon Co., USA

Workgroup Members Not in Attendance:

William Becker, STAPPA/ALAPCO

Georgia Callahan, Texaco

John Christiano, National Park Service

Mary Gade, Illinois

David Hawkins, NRDC

Jerry Pardilla, NTEC

Patrick Raher, Hogan & Hartson (Co-chair)

Bradford Smith, Environmental Elements Corp.

James Souby, Western Governor's Association

Other EPA Attendees: Bill Hamilton, Joe Paisie, David Mobley, Tom Helms, Sharon Reinders, Denise Gerth, Robin Dunkins, David Sanders, Mark Wolcott for Gay McGregor, Jan Kleeman, and Rosalina Rodriguez.

Other Attendees: Alan Krupnick, Bob Lopez for Don Theiler

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

III.	MEETING SUMMARY

Action Items from the meeting are as follows:

1)	EPA will note corrections to the summary for the May 8, 1996 conference call;

2)	Beverly Hartsock will write up a sentence or two on the additional principles discussed during the call, pulling in material from the existing comments on the interim implementation policy, before May 29;

3)	Tom Godar will talk to Ron White and David Hawkins about preparation of an environmental group perspective for the May 29 meeting;

4)	EPA requested that any additional comments on the designations issue paper from the Base Programs Analyses and Policy Work group be submitted to Rich Damberg;

5)	Members were encouraged to submit additional items for the May 29 meeting, such as the additional proposed principles, to Rich Damberg quickly;

6)	EPA will send a letter to the Subcommittee on May 24, giving directions on where to find meeting materials on the Bulletin Board. The letter will note that time on the May 30 agenda will be made to discuss the themes of the IIP;

7)	All of the materials for the May 30 Subcommittee meeting will be placed in one location on the Technology Transfer Network (TTN);

8)	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. Members would like to discuss the IIP principles at the May 29 meeting;

9)	The next conference call is Wednesday, 6/19/96, between 1:00 pm and 2:30 pm EDT, call-in number 202-260-7280, 4065#. The June 5 conference call has been canceled.

The meeting accomplished the following:

1)	Participants reviewed the summary of the conference call held on May 8, 1996, and made suggestions for corrections and clarification;

2)	The group reviewed the agenda for the May 30 Subcommittee meeting;

3)	Joe Paisie presented the report from the Base Programs Work group on the IIP principles;

4)	The Coordination Group discussed the environmental groups' rejection of the principle on substitution, and agreed to invite members to present an environmental perspective at the May 29 meeting. The Group also added two more principles for further consideration;

5)	Alan Krupnick presented his outline of suggested themes for the discussion of the IIP during the May 30 meeting;

6)	Joe Paisie presented the designations issue paper from the Base Programs Analyses and Policy Work group in the form of a set of draft slides extracted from the larger paper;

7)	The group discussed the need to make information available before the meetings on May 29 and 30, and the plans to place the meeting materials on the Bulletin Board.

IV.	SUMMARY OF DISCUSSIONS

Review of May 8, 1996 Meeting Summary

Several members pointed out that a discussion about mechanisms for thinking "outside of the box" during the May 8, 1996 conference call was not reflected in the summary of the meeting. Members expressed the view that the outline of the IIP does not appear to include much "out of the box" thinking. One participant asked for clarification about the statement in the summary (5/20/96 fax, page 6) that the "Coordination Group will continue to move forward with work on the policy once it has the principles, and will not revisit them." EPA responded that it is looking for closure on the principles of the IIP on May 30th in order to keep with the current schedule. (Note: After the May 30 meeting, an ad hoc group was formed to further discuss the interim policy.)

Revised Agenda for May 30 Subcommittee Meeting

The group discussed the time available, in the afternoon on the revised agenda, for open discussion of the IIP principles. The group agreed that it would like to spend time discussing the principles today and at the May 29 meeting.

Interim Implementation Policy (IIP) Principles

EPA acknowledged the efforts of the work groups in crafting the principles of the IIP, and emphasized the objective of trying to reach consensus. Joe Paisie presented the expanded form of the report from the Base Programs Work group, which was sent to the members of the Coordination Group by FAX. Joe reported that the Base Programs Work group had an extended discussion of the SIP process, but made no recommendation. There was agreement about "No Backsliding" and the goal of progress towards attainment of the new NAAQS.

A substantial amount of the Base Programs Work group's time was spent discussing the possible substitution of alternative measures. The Work group members from industry and the States agreed that requirements could be satisfied by substitution of programs resulting in the same air quality improvement. The members representing environmental groups were in strong disagreement with the substitution principle, and expressed the sentiment that it is not appropriate to move away from the mandated measures in Subpart 2 of Title I of the Act.

If the air quality modeling is not sensitive enough to show improvement, then modeling should be conducted to investigate the direction of change in precursors (e.g., NOx or VOC) that leads to improvement. The substitution would be allowed only for pollutants for which reductions would be beneficial, and substitution would be allowed on a mass (ton-for-ton) basis, after modeling shows the correct direction. The Base Programs Work group expressed concerns about ecosystem impacts, and interactions with other pollutants. For example, trading SO2 emissions for NOx might be helpful for ozone, but it could exacerbate a problem with PM-fine. Substituting emissions might involve additional credit, or a greater than one-for-one exchange. The Base Programs Work group members from industry and the States also gave limited support to including population exposure concerns into the IIP.

Coordination Group members asked Joe Paisie additional questions about the modeling that would be needed for making substitutions. He clarified that "directionality" refers to whether the change in emissions will make O3 better or worse, and that the purpose of the modeling would not be to determine attainment of either the new or the old standard, but to determine whether the proposed substitution of emission reductions would result in relative air quality improvements. He also responded to a concern that if modeling were required, it may limit substitutions, since States may have limited resources available for modeling. Joe Paisie reported that the Base Programs Work group discussion left open the possibility of using a ton-for-ton basis, which was supported mainly by members representing States. He said that the industrial sector and scientists would be more in favor of using models.

Joe Paisie also responded to questions about the use of relative risk, and weight-of-evidence. He said that relative risk had been discussed only in terms of population exposure, and that it had only limited support. The Base Programs Work group did not go into great detail in its discussion of models or modeling protocols, but kept its discussion at a conceptual level.

The Coordination Group discussed its perceptions about the concerns of the environmental groups about flexibility, backsliding, and the need to demonstrate a clear environmental benefit. Members expressed views on the need for some boundaries on the ways to show improvement, and how these might be achieved. One suggestion was to convene a panel of experts to look at the transition period and at methods for evaluating substitutions. The group described a sense of concern from the environmentalist viewpoint that the Subpart 2 measures are well-defined, and bring trackable, quantitative progress, but substitutions based on models may not produce tangible results and may be difficult to understand. Some in the group questioned whether certain required measures bring quantifiable benefits, and also whether the changes in the new standards will increase the requirements for emission reductions. EPA stated that it was not taking a position, but was trying to report that the States and industry were very comfortable with substitutions, and the environmental sector was skeptical.

Hartsock brought up two other points that were not listed in the report from Base Programs: 1) incentives for additional monitoring and early reductions, and 2) communications to the public about the new standards and educating the public about what is being accomplished in the programs. EPA asked whether communication should be addressed in the principles, or whether it was already addressed in the Communications and Outreach Work group action plan. The group agreed that prior to May 29, Beverly Hartsock will draft proposed language for these proposed additions to the interim policy principles.

Another member suggested that the Coordination Group seek further input from the environmental groups regarding their concerns on the draft interim policy. Several members thought it would be important to have time for the environmental groups to present their position, possibly to bring in a counter-proposal on substitutions. Tom Godar was invited to work with David Hawkins to bring in a presentation to the Coordination Group on May 29, for discussion on May 30. Tom Godar said that he may not be able to be there, but that Ron White should be, and that he will talk to Ron White and David Hawkins about preparing an environmental group perspective for presentation on May 29.

The Coordination Group discussed the structure of the time to be spent discussing principles during the May 30 Subcommittee meeting. Alan Krupnick discussed his proposed approach, which is to let each group speak on the themes, one theme at a time. Some participants thought this would take a lot of time, and were concerned that the Subcommittee might not end up with something tangible at the end of the discussion. Other participants observed that many members of the Subcommittee and Work groups who are not a part of the Base Programs Work group need time to discuss their views. Participants were also concerned about the CG making changes to the product of the effort of the Base Programs Work group on May 29, before presentation to the Subcommittee on May 30.

Designations Issue Paper

Joe Paisie presented a handout from the Base Programs WG on the designations issue. The handout was extracted from a more detailed issue paper written by Steve Gerritson (contact), Rick Phelps, Jim Ralston, and Eric Skelton. The proposed consensus position was that designation be based on monitoring plus some degree of modeling, and that different terms be used for 1) areas violating a NAAQS, and 2) areas having emissions that contribute to such violations.

Joe Paisie said it will be important to engage the Subcommittee, and to get feedback on framing the issues, since this will help with subsequent issues. He expects to be bringing many more issues to the Subcommittee at the next meeting (July).

One member suggested adding a fourth column to the second slide to discuss the pros and cons. Another member was concerned that the concept of "influence areas" overlaps significantly with the concept of "control regions" identified by the National and Regional Strategies Work group. He stated that consistency in language is needed, and asked the Coordination Group to give direction to both Work groups regarding which group is the lead on this issue.

One participant asked Joe Paisie what the Base Programs Work group had discussed regarding visibility in Class I areas. Joe responded that the issue paper discusses the concept of regional haze planning areas, which would likely be multi-state regions responsible for measures to reduce haze at groups of Class I areas. This concept is similar to that of "influence areas" which contribute emissions to areas not attaining the NAAQS. It was acknowledged that some regional organizations, such as the Grand Canyon Visibility Transport Commission and Southern Appalachian Mountain Initiative, have already been looking at the regional haze issue. It was also acknowledged that the Base Programs Work group has less expertise on regional haze than ozone and PM. A participant asked whether non-Class I areas such as the South Coast basin would be addressed through the program. Joe Paisie responded that the short answer is "yes," that the PM staff paper notes that a regional haze program should help address the welfare effects of PM outside of class I areas as well. EPA requested that any additional comments on the slides be submitted to Rich Damberg, and noted that the slides would be revised.

National and Regional Strategies Work Group Principles for Four Major Issues

Handouts on the four issue papers from the National and Regional Strategies Work group were provided with the meeting materials, but had been updated since they were sent out. Rich Damberg stated that the most recent versions could be found on the Bulletin Board. David Mobley stated that they are still evolving, and that the Work group welcomes input from the Coordination Group on the issues they are addressing. Sally Shaver asked the members of the Coordination group to look over the four issue papers, and said that on May 29, there would be time to get back to David Mobley with comments.

Upcoming Meetings, Possible Agenda Items and Other Business

A face-to-face meeting of the Coordination Group is scheduled for 3:00 to 6:00 pm (NEW TIME) in the afternoon on May 29, 1996, in Durham, North Carolina. The FACA Subcommittee will meet May 30, 1996, from 8:00 am to 5:00 pm, at the Durham OMNI Hotel in Durham, NC.

EPA stated that the agenda for the May 29 face-to-face meeting will be similar to the agenda for the May 22 conference call, however, most of the time will be spent in discussion of the IIP principles, and on the designations issue. Members were encouraged to submit additional items, such as the additional proposed principles, to Rich Damberg quickly. EPA said that a letter would be going out to the Subcommittee on May 24, giving directions on where to find meeting materials on the Bulletin Board. All of the meeting materials will be placed in one location on the Technology Transfer Network (TTN). Alan Krupnick requested that the letter to the Subcommittee note that time will be available at the May 30 meeting for discussion of the interim policy so that members could prepare their comments.

The next conference call will take place on June 19, 1996, from 1 to 2:30 pm, EDT. The call-in number is (202)260-7280, 4065#. The June 5 teleconference call is cancelled.

SUMMARY

FACA Coordination Group Meeting, Durham, NC

May 29, 1996

I.	PURPOSE

A meeting took place on May 29, 1996 to enable Coordination Group members to discuss the agenda for the May 30, 1996 Subcommittee meeting, the Interim Implementation Policy (IIP) Principles, the Designations Issue Paper, to review the National/Regional Strategies Work Group principles for four major issues, and to receive reports from the Work groups.

II.	PARTICIPANTS

Workgroup Attendees:

Sally Shaver, EPA/AQSSD (Co-chair)

Rich Damberg, EPA Staff Team Leader

William Becker, STAPPA/ALAPCO

Georgia Callahan, Texaco

Brian Baldwin for Charles Goodman, Southern Company Services

Beverly Hartsock, Texas TNRCC

Richard Hayslip, Salt River Project

David Hawkins, NRDC

Shawn Kendall, Phelps Dodge Corp.

Cathy Waskiewicz for Helen Petrauskas, Ford Motor Co.

Patrick Raher, Hogan & Hartson (Co-chair)

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

John Elston for Robert Shinn, New Jersey

James Souby, Western Governor's Association

John Taunton, Exxon Co., USA

Workgroup Members Not in Attendance:

John Christiano, National Park Service

Mary Gade, Illinois

Tom Godar, American Lung Association

Jerry Pardilla, NTEC

Bradford Smith, Environmental Elements Corp.

Winston Smith, EPA Region IV

Other EPA Attendees: John Seitz, Bill Hamilton, Joe Paisie, David Mobley, Tom Helms, Tom Curran, Sharon Reinders, Denise Gerth, Linda Metcalf, Rosalina Rodriguez, Gay McGregor, Mark Kataoka, and Dick Long.

Other Attendees: Alan Krupnick, Don Theiler, Harvey Jeffries, Ron White, Dick Wilson, Andrea Bear Field, Herb Williams, Dennis Lawler, and Bob Palzer.

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

III.	MEETING SUMMARY

Action Items from the meeting are as follows:

1)	The Coordination Group will solicit volunteers for an ad hoc group to work quickly on the IIP principles, and report back in time for the principles to be ready for the July meeting of the Subcommittee.

2)	Members asked the Communications and Outreach Work group not to list their email addresses on the internet, and to consider how email messages from the public about the FACA process could be filtered and forwarded;

3)	Members asked John Seitz and Alan Krupnick to present ground rules to the Subcommittee on May 30 on the process for reviewing the products of the Work groups, including an explanation of the schedule for making recommendations to the EPA;

4)	If Mary Nichols does not arrive in time to speak at 9:30 am on May 30, the Science and Technical Support Work group presentation will be moved up;

5)	The next conference call is Wednesday, 6/19/96, between 1:00 pm and 2:30 pm EDT, call-in number 202-260-7280, 4065#. The June 5 conference call has been canceled.

The meeting accomplished the following:

1)	The group reviewed the agenda for the May 30 Subcommittee meeting;

2)	The Coordination Group discussed the structure of the recommendations it expects to make to the Subcommittee, and agreed to acknowledge the need to revisit the whole package in its entirety, and to put forth the pieces as "straw persons" for purposes of developing consensus. Members agreed that a package giving a range of options would be a balanced approach, and that striving for a consensus gives the process focus;

3)	Members agreed to form smaller task teams to address cross-group issues, as necessary, and also to continue work on the IIP principles;

4)	Tom Curran and Ron White presented a report on the progress of the Communications and Outreach Work group;

5)	Tom Helms presented a report on the progress of the Science and Technical Support Work group;

6)	The Coordination group reviewed the issue of overlap between the National and Regional Strategies and Base Programs Analyses and Policy Work groups on the issue of designations;

7)	Members discussed the plans for future meetings and conference calls.

IV.	SUMMARY OF DISCUSSIONS

Agenda for May 30 Subcommittee Meeting

EPA announced that Mary Nichols is scheduled to address the FACA Subcommittee at 9:30 am on May 30, therefore the agenda has been revised slightly. The discussion of the IIP principles will still go on after lunch. If Mary Nichols arrives late, members agreed that the presentation from the Science and Technical Support Work group could be moved up, since the other presentations were thought to flow together.

Members discussed whether there is a risk of reaching closure on certain issues before other related issues and recommendations could be pulled together into one package. Members were concerned that there might be a need for an opportunity to revisit issues once members could see all recommendations/options together.

The Coordination Group discussed whether its purpose was to come up with a single recommendation, or with a set of options on which people can comment. Members agreed that universal consensus would be highly desirable, but unlikely. Some feared that an extremely broad range of options might lead to a standstill, such as occurred when the total suspended particulate (TSP) standard was promulgated. Members agreed that a package giving a range of options would be a balanced approach, and that striving for a consensus gives the process focus.

Members discussed concerns about items that multiple Work groups have been developing independently, and which need to be coordinated. The Coordination Group recognized that its role includes spotting obvious overlaps and facilitating exchange about overlapping issues across the Work groups. Some members felt that the groups had not yet had a chance to conduct such a facilitated exchange on the issue of designation, and were concerned about how this would be presented to the Subcommittee. Others expressed comfort with presenting the material from different Work groups on designation to the Subcommittee as it stands, to begin dialogue on one of the basic issues, and to solicit direction from the Subcommittee.

The Coordination Group considered the process for Subcommittee review of the issues. The Subcommittee could accept an issue as presented, or it could send it back for more work. The group discussed forming smaller, ad hoc, groups to address issues that were returned. The group anticipated the need for smaller groups to discuss the IIP principles, the issue of designation, and possibly other issues. Members felt that it would be important to have representation from the Work groups and the Coordination Group on the ad hoc, "cross-group" groups. One member observed that the Coordination Group itself might be appropriate. The Coordination group decided that it would take on the IIP principles, if they were sent back by the Subcommittee on May 30. The Coordination Group would establish a smaller task group to work on the principles. The team would be instructed to work quickly using conference calls and FAXs, and report back to the Coordination Group in time to bring the principles back to the Subcommittee in July.

Interim Implementation Policy (IIP) Principles

Beverly Hartsock presented two additional principles for consideration by the Coordination Group and Subcommittee:

"Any disincentives to the early implementation of control measures and additional, improved monitoring should be identified and eliminated, and incentives for such efforts should be established."

"A comprehensive and sophisticated public education and outreach strategy to enhance public awareness and understanding of issues related to the new NAAQS should be expeditiously developed and implemented"

Members also discussed a paper on the IIP principles prepared by the States, and a concern that the product of the Base Programs Work group effort headed in the right direction, but did not go far enough on the issue of transport. The paper from the States was reported to have a three page addendum of principles that STAPPA/ALAPCO would like to see adopted. Coordination Group members discussed making changes to the existing principle #2, inserting a new #4, renumbering, and adding new principles 8 and 9, which would be the two presented above. The proposed change for principle #2 (no backsliding) was:

- Since protection of public health and welfare must continue during and after the transition period, there should be no backsliding on emission reduction targets.

The new principle #4 would read:

4.	To more effectively address the issue of transport, new implementation policies must be structured.

One member asked about the procedures for making changes to the principles, and how likely they were to be approved by the Subcommittee during the May 30 meeting. The group discussed whether any of the principles were ready to be drafted by the EPA, yet, and how great the time pressure is to obtain approval and move on to drafting the policy. Members were concerned about redoing the effort of the Work groups, and discussed the process for reviewing and recommending changes to Work group products. One approach would be to forward proposals from the Work groups, but with comments and an alternative proposal by the Coordination Group. The Coordination Group considered the possibility that the principles might be approved in the May 30 meeting, and could be drafted by EPA in time for the Subcommittee to review in July, but asked the members to express their sense of the status of the principles.

David Hawkins reminded the group that the environmental-interest sector had concerns about the principle of substitution, the statement about no bump-ups, and the reference to population exposure. Specifically, their concern relates to policy trade-offs made in the 1990 Amendments. Environmental groups felt that what they got in exchange for allowing extensions in time to achieve the standards was a commitment for that time to be used productively to make tangible accomplishments. Environmental group members felt that there had been too much reliance on modeling, and that modeling had been abused. The structure of the 1990 Amendments specified certain control strategies and schedules. This had been thoroughly debated during the 1980's. The environmental groups feel that implementation is behind schedule, and that allowing renegotiations of specific Act requirements would undo many decisions and IOU's made 6 years ago, leading to a major battle with the environmental community.

Hawkins said that this was not a threat, only an expression of the feeling that this proposal says "what you thought you had, you don't have," and that any time things are opened up for renegotiation, all of the energy of the participants goes into strategizing about the negotiations instead of moving forward with reductions. When asked whether this position would affect the presentation of the principles to the full Subcommittee on May 30, David Hawkins replied that he would be very happy to have the discussion take place, but wants to give the Coordination Group a "heads-up" that consensus on some of the principles is not likely to be reached in a timely manner. He also observed that a number of the participants representing industry can only get comfortable with some of the principles if substitutions are included, so there are linkages among the principles for some participants.

The Coordination Group acknowledged that the discussion gave a good preview of what to expect at the Subcommittee meeting on May 30. Several members expressed the view that the positions of the different sectors were not far apart, and discussed the need to make sure that the extreme positions were represented on the ad hoc team, anticipated to be announced after the discussion of IIP principles on May 30. The Coordination Group expects to decide who will be on the ad hoc team, and would like to keep the team small, and charge it with the mission of coming up with a document that satisfies the concerns of the participants, to facilitate reaching consensus. Karl Schultz expressed the view that the positions are not that different, but that the members disagree about the details of how to get there. He wants everyone to have the same requirements for reductions, such as 15% across the board, everywhere, to avoid creating market distortions. John Seitz said that sounded like a "mega-FIP". David Hawkins said that was an issue before some of the Work groups working on designations, and is not identical to the IIP, which is about how to prevent promulgation of new NAAQS from turning into inaction. He repeated that he viewed substitutions as being equivalent to years of analysis, and therefore years of inaction.

Report from the Communications and Outreach Work Group

Tom Curran and Ron White described the progress of the Communications and Outreach Work group, and the group's plans for new activities. Tom Curran asked whether everyone was comfortable having their email address and their phone number listed on the internet, and whether there was a need for a standard response to be developed by the Communications and Outreach Work group. The Coordination Group discussed the need for openness and access to members as well as the problem of mountains of junk email. Some members felt that they were taking care of their own constituencies, and did not want their email address given out on the internet. One member felt that it was the role of the Designated Federal Official, not the members, to respond, and that it would be a disservice to the members to put this burden on them on top of the work they already have volunteered to do. The group discussed how it might ask the EPA or the Communications and Outreach Work group to appoint someone to act as a filter, or be the arbiter of comments sent to a designated mailbox.

The Communications and Outreach Work group is planning a satellite downlink very soon on ozone and PM, and is considering doing one in September on ozone and PM health effects, and plans to include some implementation issues to interpret what the new standards mean to the general public. They are also developing "info pacs," using OAQPS information, and are reviewing the work of the OTC, Maryland, and STAPPA/ALAPCO. They have contacted journalists about opportunities to get on their programs and to get mailing lists for the environmental media. The Work group has learned that the environmental journalists will hold an annual meeting in the fall, and the Communications and Outreach Work group will try to get on their program. Coordination Group members asked about basic questions and answers and the need to get information into a form that is readable and in plain English. Tom Curran said that they were working with OAQPS communications people, and are making a shell (mock-up) of FAQs (Frequently Asked Questions) for a home page (web site on the internet), which they hope will prompt participants to get the answers that are going to be needed.

The Coordination Group asked further questions about the Communication and Outreach Group's strategy for reaching the public and explaining air pollution. Some were concerned that the plans sounded too much like preaching to the converted. Ron White responded that the Communication and Outreach Work group has three audiences, those who do air pollution work for a living, those who may already know a lot about air pollution, but not about the FACA process, and members of the general public who do not know about air pollution, and who might want to know how it will personally affect them. The Work group feels that it must rely on the State agencies as the front line, and hopes to arm them with tools such as fact sheets, which the State and local agencies can use in their own programs.

Report from the Science and Technical Support Work Group

Tom Helms reported that the Science and Technical Support Work group has been having an interesting and lively debate. They have been having an identity crisis about the speed with which the process is moving, and the relevance of their work. They would like to be able to underpin decisions with good science, and are concerned about coordinating with other groups. The Work group is developing a big report, called a conceptual model, and is trying to document missing elements. They expect a draft by mid-June to early July, and are concerned about being too late. They have begun to address issues that have been fed to them by the other Work groups, especially transport. The Science and Technical Support Work group asked whether it would be relevant to present EPA model results on zones of influence, which suggest the potential need for national controls. The Coordination Group thought it would be helpful to have the model results presented, perhaps by Tom Helms or Robin Dennis. One member commented that the evidence would indicate the need for a national policy for regional controls.

National and Regional Strategies Work Group Principles for Four Major Issues

Don Theiler will present a summary of the principles for four major issues prepared by the National and Regional Strategies Work group at the May 30 Subcommittee meeting. The Work group would appreciate input on its ideas. The Coordination Group focussed on potential problems with overlap between Work groups, and asked whether the National and Regional Strategies Work group needed more interaction. Don Theiler said that interaction was a critical issue, and it had not been dealt with adequately. He thought it was important that issues not go forward without review by other work groups. Science and Technical Support needs the input from National and Regional Strategies about issues to frame their work, and National and Regional Strategies needs the input from Science and Technical Support to give them a reality check on their work, and show a way for the science to catch up with the concepts that National and Regional Strategies puts forward. He thought the co-chairs could visit and make presentations to get feedback at each other's meetings to get the needed interactions.

Don Theiler also thought that the designations issue clearly overlaps the Base Programs Analyses and Policy and the National and Regional Strategies Work groups, and needs to be coordinated before presentation of issues to the Subcommittee by the Work groups.

Pat Raher said he thinks it is important to identify the key issues that require attention from the Coordination Group. He offered that as a general concept, a number of issues will go forward as proposals to the Subcommittee, and to the extent that there is a problem, members should bring them up again. The Work groups should respect what each other are doing, and also expect that the products are not final until they are presented as a whole. David Hawkins said that it creates awkwardness to have one group ready to schedule discussion when the other is just getting started. Pat Raher responded that it is the Coordination Group's role to coordinate, and that there will be a couple of issues out of synchronization during the May 30 Subcommittee meeting. David Hawkins observed that this can be seen in the designations papers, which have different terminologies, and two time slots on the agenda.

Joe Paisie said that another perspective is the pressure of time, which goes back to the balance between going lock-step among the Work groups versus getting things moving. He said that Jerry Golden will present a preliminary schedule for reviewing issues on May 30. Don Theiler emphasized the need to work out a mechanism for coordination between the two groups, which could be done in a number of different ways. Pat Raher offered that the co-chairs could work out a mechanism and also address the time table, and assess when to stick with it, and when to get off of it. He felt that it was important to give the full Subcommittee members the picture of this overlap and process on May 30. John Seitz offered to describe ground rules at the start of the Subcommittee meeting.

Don Theiler referred to comments on transport in the IIP, and asked how they are to be considered. He felt that time was needed for one Work group to review and reach consensus on another Work group's product. David Hawkins suggested that one possibility would be for the Coordination Group to recommend to the Subcommittee a ground rule that when comments are received, they need to be addressed explicitly in their report. Joe Paisie said that he continues to have concerns with the time lines and the time necessary for all of the additional coordination. Pat Raher asked him if this was due to the fullness of the plate for the Base Programs Analyses and Policy Work group. Joe Paisie thought it was, and that his Work group had ended up with many of the pieces.

Sally Shaver said that when the groups were established, it was intended to divide the labor evenly, and to avoid overlap. Clearly, control strategies do have both regional and local dimensions. She said that the Work group structure may need to be reevaluated.

Don Theiler responded that there may be something to that point, as he can see that the Phase 1 issues predetermine a lot of things, and that is where some of the frustration in the groups is coming from. John Seitz asked if there was an assumption that no regional strategy could take place without designation of an area. Don Theiler responded that National and Regional Strategies is now proposing the concept of: a) an area not meeting the standards, and b) an area contributing to an area not meeting the standards. In some cases, the area in violation may not need controls to the extent required under the current regulatory scheme.

Joe Paisie said that he thought designations were clearly an issue for Base Programs Analyses and Policy. Don Theiler returned that when transport is taken into consideration, designations are also clearly an issue for National and Regional Strategies. Joe said that designations have two purposes: 1) to identify where standards are violated, and 2) areas for controls. Don Theiler observed that this illustrates the problem of overlap. Pat Raher commented that the need for coordination on the issue of designations is the job of the Coordination Group. Tom Helms added that the Science and Technology Support Work group says that neither one of the two Work groups should do anything without looking at maps.

David Hawkins asked, how does one tell what policy is good or bad without an idea of what the implications of designations are? David Hawkins said that if designations implied nothing about controls, there was less of an argument about assembling a robust database to tell which box to put an area in, but if getting a designation automatically signs an area up for something in the way of controls, the area will want better information.

Pat Raher felt that in opening up the Subcommittee meeting on May 30, it was important to give guidance on the overall time frame, and reassure the Subcommittee that it would not be asked to vote at 2:30 pm. John Seitz thought that was fair, but that we should not give the impression that the process is flawed when in fact the process for wrestling with these challenging issues is working. The Subcommittee needs to be told that it can send issues back to the Work groups.

Upcoming Meetings, Possible Agenda Items and Other Business

The FACA Subcommittee will meet May 30, 1996, from 8:30 am to 5:00 pm, at the Durham OMNI Hotel in Durham, NC.

The next full FACA Subcommittee meeting will be on July 30, in Washington, D.C. in conjunction with a CAAAC meeting on the 31st. Sally Shaver suggested that the Coordination Group meet again on July 29, and a large proportion of the members said that they have a schedule conflict with that date. Sally Shaver asked members to let her know of their conflicts, as the meeting may need to be rescheduled if only 10 or 15 members can come on that date.

The next conference call will take place on June 19, 1996, from 1 to 2:30 pm, EDT. The call-in number is (202)260-7280, 4065#. The June 5 teleconference call is canceled.