7.0	Developing a Working and Responsive Science-Policy Continuum

In recent years national and regional air quality entities have met to consider the transport of ozone and particulate matter (PM), and the creation of regional haze conditions among different States and tribal areas. Groups meeting to examine the problems and coordinate goals have included the FACA Subcommittee for Ozone, PM and Regional Haze Implementation Programs, Grand Canyon Visibility Transport Commission ( GCVTC ), Southern Appalachian Mountains Initiative (SAMI), the Southern Oxidant Study (SOS), the Ozone Transport Commission (OTC), the Ozone Transport Assessment Group ( OTAG ), and the North American Research Strategy for Tropospheric Ozone ( NARSTO ). A common topic of discussion at these meetings was the need for increased communication and shared resources between the policy planning and the science communities.

This chapter presents some examples where scientists and policy planners can find common ground and suggests ways that scientists and policy makers can work cooperatively to address air quality programs for ozone, PM, and regional haze. The individual sections consider the benefits of continued use of regional air quality entities, methods by which the science community and policy makers can both be served by the same resources, and some ways that policy makers can utilize scientific contributions. The chapter contents are not intended to be comprehensive but represent the possibilities available through the cooperation of the scientific and policy planning communities. Many of the recommendations reflect discussions at Science and Technical Support Work Group ( STSWG ) meetings, the Source Attribution Workshop (SAW) sponsored by STSWG and EPA in July 1997, NARSTO critical reviews, and GCVTC recommendations.

7.A	Benefits of Regional Air Quality Entities

The FACA Subcommittee, GCVTC , SAMI, SOS, OTC, OTAG , and NARSTO represent seven national and regional air quality entities that have gathered in recent years to collectively examine ambient air quality and develop strategies to meet compliance with EPA standards. Representatives from States and tribal lands, industries, environmental groups, technical experts, and other stakeholders served as members and discussed ways to evaluate air quality, modeling efforts, implementation strategies, and cost-effective programs.

The GCVTC represented an experiment in regional policy development through cooperative partnership among State, tribal, and federal government entities with participation from stakeholders and technical experts. The GCVTC process promoted cooperation to define the needs of the scientific and policy communities and also functioned as a mechanism that allowed intergovernmental discussion of the policy recommendations. In addition, the GCVTC recommended guidelines for future administrative structures. Some of the recommended guidelines for future structures that would be mutually beneficial to the scientific community and policy makers included:

Coordinating research and development efforts on visibility and airborne particulate assessment methodologies to ensure that the efforts will be focussed on the concerns associated with policy formulation;

Developing ongoing funding mechanisms to support the administrative functions, specific research, and monitoring activities; and

Coordinating implementation of inter-jurisdictional mechanisms for addressing regional haze, including monitoring activities ( GCVTC , 1996).

A goal of the regional air quality entities is to bring all stakeholders into consensus concerning the approaches to be used. Through this structure, scientists and policy makers are able to express their concerns and needs in the same forums. The definitions and roles of regional air quality entities and regional modeling centers should be stated explicitly in such a way that politically-created regional entities support rather than hinder developments in the scientific community. FACA 's proposed regional air management partnerships ( RAMPs ) are viewed primarily as political entities that identify technical people, establish the funding sources for regional modeling centers, and approve the scientific findings. However, the decisions about RAMP boundaries and participants should not interfere with the scientific efforts ( STSWG , 1997).

The RAMP process could be successful if two levels of RAMPs are recognized. The first RAMP would be large and political in nature with the goal of directing initial analyses . A second RAMP would be defined by this initial process, and the second RAMP would proceed with the technical development efforts and the assessment of planning tools and control strategies ( STSWG , 1997). In this manner both policy planners and the scientific community tend to benefit from the use of RAMPs and/or other regional air quality entities. The scientists and policy makers would then be able to codefine their needs in a forum where both groups work together to define their goals and the methods whereby they attain them.

7.B	Codefining Needs Between Scientists and Policy Planners

Scientists and policy makers do not always consider how the other group will use data. Both the scientific data gathered for air quality studies and the data used for compliance determinations can be measured with similar instrumentation and resources. However, inappropriate placement of monitors, measurements taken with inappropriate sampling frequencies, or gaps in the necessary meteorological data are likely to occur. By working together, scientists and policy makers can develop methods to codefine their needs, benefit from each other's data sets and experiences, and establish more complete data sets and better air quality management strategies. A few examples of the potential benefits of such planning efforts are presented below.

Emission Estimates

Significant data gaps still exist in emission inventories. One notable example is the lack of confidence in ammonia emissions factors and inventories. In order to remedy this situation, more resources should be allocated toward filling the data gaps as the science and policy planning communities, together, identify and prioritize their data needs. Policy makers would identify locations and emission sources where better estimates are geographically necessary, while scientists would establish the tolerances of inventory uncertainty that both communities could accept. This prioritization and tolerance definition would help the groups responsible for emissions estimates to allocate their resources in an appropriate, responsive manner.

Monitoring Networks

Extensive national monitoring networks currently exist for tracking ozone (more than 500 sties) but not for measuring PM-2.5 or regional haze. For example, the Interagency Monitoring of Protected Visual Environments (IMPROVE) monitoring network measures PM-2.5 and PM -
10 in Class I areas and only operated 42 monitors in 1996. The precursors for ozone, PM, and regional haze have been measured only for scientific purposes to date, with the exception of the limited sampling of the national Photochemical Assessment Monitoring Stations ( PAMS ) network. As more resources become available, scientists would choose to place monitoring networks in areas that best improve the understanding of pollutant concentrations and their formation processes. These areas may be where the models require boundary conditions, "hot spots" where concentrations are expected to be high, and areas where the concentrations can be well-tracked by the modeling efforts. In contrast, policy planners addressing ozone, PM, and regional haze standards are tasked to locate monitors where they will best protect human health, delineate nonattainment areas, identify contributors to pollutant formation, verify "hot spots", assess environmental equity, protect visibility in Class I areas, and measure progress toward attainment ( Demerjian , 1998).

Monitor placement is not an exact science for either the scientists or the policy makers. Although proposed monitor sites may not be optimal for either group, there will often be placement opportunities that can provide valuable information to both the science and policy planning communities. The process of monitor placement must include the broad community of data users and the ability to find appropriate corrections for the identified network limitations ( Demerjian , 1998).

Either formal or informal dialogues between the scientific and policy communities can then assess the utility of monitor placement after data becomes available. The discussions should be ongoing and provide an iterative analysis of a monitor's utility. Through this interaction (which may occur at meetings of the regional air quality entities), continued optimization of the monitoring network can occur through the re-evaluation process. This re-evaluation process will become more important with the integration of the standards and the implementation of ozone, PM, and regional haze programs.

Modeling Needs

As scientists and policy makers begin to work together on modeling needs, policy makers will benefit by having input into the choice of scientific models and episodes as they are scrutinized by the science community. The science community will likewise benefit because policy makers will be able to direct resources toward current data gaps. For example, the large counties in the western States are not always well characterized in terms of local emissions estimates, especially on tribal lands. By using available resources to develop better economic models that consider tribal communities, the policy planning community will be able to provide more accurate inputs for the gridded models. The models can then consider the distinctive characteristics of tribal lands, their economic structure, and the demographics that are often missed in broader regional analyses ( GCVTC , 1996).

7.C	Use of Science in Policy Decisions

Scientists and policy makers have differing short-term goals when making decisions about the allocation of resources. When developing regulations to mitigate or correct a problem, policy planners are affected by statutory deadlines, public perception, and other influences that the scientific community does not necessarily consider. These additional influences often, sometimes conversely, distinguish the differences between the optimal control strategies predicted by scientists and the control strategies which are deemed achievable and ultimately implemented by policy makers.

A major distinction between scientists and policy planners is in their interpretations of model results. The scientific community recognizes that a model's strength is in evaluating past episodes and not in making future predictions of meteorological events. Even if models are perfect predictors for historic cases, the stochastic nature of the atmospheric meteorology dictates that predictions for future years are based on forecasts. This reality will always introduce uncertainty into the planning process, and this uncertainty should be considered when making policy decisions ( STSWG , 1997).

Determining the Maximum Expected Benefits from Policy Decisions

Assessing the Impacts of Regulatory Models

Regulatory models have been approved by EPA for use in preparing implementation plans for nonattainment areas, developing maintenance plans for attainment areas, estimating boundary conditions, and evaluating the consequences of opting out of control requirements. Sample regulatory models include the Industrial Source Complex Model ( ISC3 ), the Urban Airshed Model ( UAM ), the Offshore and Coastal Dispersion Model (OCD), and the MODELS-3 Third Generation Air Quality Model.

Regulatory models will always reflect the types of information gaps that exist in models used by scientists. However, the scientific community can assess the uncertainties associated with the models under given sets of conditions. Air quality models, databases, and data analyses need to be improved prior to planning decisions. If sufficient analyses are not undertaken, then the use of modeling tools to develop realistic approaches for improving air quality will be questionable. The mechanisms of ozone formation are not yet fully understood, and assessments by STSWG and NARSTO concluded that the models and databases are currently insufficient to plan for PM standards or integrated plans for PM, ozone, and regional haze ( STSWG , 1997).

By including the scientific community in the planning process, policy planners will be able to develop realistic expectations from the models and choose achievable time frames for data gathering activities. Scientific characterization and quantification of uncertainties (in models, inventories, etc.) and recognition of these uncertainties by policy makers will allow policy planning to proceed while data gaps still exist.

Model predictions should be compared to ambient air quality measurements collected in the future, and midcourse corrections to the models and control strategies should be made when necessary. Because of the uncertainties in the planning process, an iterative step should be introduced into the planning process. Model predictions should be compared with ambient air quality measurements at some point in the future (e.g., five or six years after the adoption of the plan), and the effectiveness of the model and the control measures should be re-evaluated. A midcourse correction should be made when necessary. As part of this mechanism, scientists would be able to compare the data from the past and present years to determine if improvements in ambient air quality were achieved based on favorable meteorology or on effective emission reduction schemes. This evaluation would enable policy planners to better understand the costs associated with the air quality improvements up to that time ( STSWG , 1997).

Identifying the Shortcomings in Policy Decisions

References

Chock, D.P., S.L. Winkler, and S. Pezda , Attainment Flip-Flops and the Achievability of the Ozone Air Quality Standard, Journal of the Air & Waste Management Association, 47: 620-622, 1997.

Demerjian , K.L. , A Review of National Monitoring Networks in North America, prepared for the NARSTO Assessment and submitted to Atmospheric Environment, July 1998.

Grand Canyon Visibility Transport Commission ( GCVTC ), Recommendations for Improving Western Vistas: Report of the Grand Canyon Visibilility Transport Commission to the United States Environmental Protection Agency, June 10, 1996.

Science and Technical Support Work Group ( STSWG ), Science and Technical Support Work Group's Position on AOI / AOV Papers, FACA Subcommittee on Ozone, Particulate Matter and Regional Haze Implementation Programs, November 1997.