1.0 INTRODUCTION

In September 1995, the EPA established the Subcommittee as a part of the CAAAC. The Subcommittee was formed under the authority of FACA.

At that time, the The EPA was conducting a scientific review of the NAAQS for ozone and PM, and the GCVTC was developing recommendations on approaches for addressing regional haze. Given the potential for significant changes in national air quality standards and related implementation programs in 1997, as well as the existing information about common sources and atmospheric processes leading to formation of ozone, PM, and regional haze, the EPA believed it was important to begin exploring possible new integrated approaches to attain potential new or revised NAAQS for ozone and PM, and reduce levels of regional haze in mandatory Federal Class I areas.

The Subcommittee discussed a range of policy and technical issues and sought to provide consensus recommendations where possible. Input from the Subcommittee will be taken into consideration by The EPA in the development of future implementation strategies. This report provides a summary of the Subcommittee's second phase of discussions from December 1996 through December 1997.

At the time of publication of this report, the Subcommittee is composed of 82 members representing a broad range of interests in air quality management, including State, local, and Tribal governments, environmental and public interest organizations, industry, and academia. Five work groups were formed to assist the Subcommittee: the Base Program Analysis and Policies Work Group (BPAPWG), the National and Regional Strategies Work Group (NRSWG), the Science and Technical Support Work Group (STSWG), the Communications and Outreach Work Group (COWG), and the Coordination Group. Together the work groups involve 138 additional individuals and interested organizations contributing to the overall advisory committee process. The current organization of the Subcommittee is illustrated in Figure 1.

The Subcommittee has discussed a total of 28 issue papers during the final phase of its activities. Papers have been drafted and presented principally by representatives of the BPAPWG and NRSWG. Representatives of the STSWG have played a significant role in the development of the issue papers by responding to specific technical questions from other work groups, serving on joint issue paper teams, authoring sections of some papers, and providing formal comments on issue paper drafts. Although few specific consensus recommendations have been made, the Subcommittee and associated work groups have made significant progress in identifying options, discussing pros and cons for many critical air quality management issues, and agreeing on principles by which options in particular areas should be evaluated. Table 1 lists the meetings held between September 1995 and December 1997.

FACA SUBCOMMITTEE MEETINGS
DATE	LOCATION
September 26, 1995	Research Triangle Park, North Carolina
March 21, 1996	Alexandria, Virginia
May 30, 1996	Durham, North Carolina
July 30, 1996	Crystal City, Virginia
September 26 - 27, 1996	Norfolk, Virginia
October 29 - 30, 1996	Dallas, Texas
November 19 - 20, 1996	Denver, Colorado
February 20 - 21, 1997	Washington, DC
April 8 - 9, 1997	Falls Church, Virginia
June 10 - 11, 1997	Durham, North Carolina
August 13 - 14, 1997	Portland, Oregon
October 9 - 10, 1997	Chicago, Illinois
December 17-18, 1997	New Orleans, Louisiana

It is hoped that the input provided to The EPA from the Subcommittee through this process will be of great value as the EPA develops its initial implementation strategy (scheduled for proposal in December 1997). The Subcommittee was asked to continue its substantial progress throughout 1997, in order to provide the EPA with input and recommendations on remaining issues critical to the development of the EPA's final implementation strategy (scheduled promulgation for December 1998), which is intended to address policies for control strategy development.

1.1 Subcommittee Organization

The following is an overview of the Subcommittee and the groups formed to support its work, including the Coordination Group and four work groups. A list of group members, as of October 1997, appears in Appendix A.

Roles and Responsibilities of Work Groups

The Subcommittee has established five work groups to research various issues and report their suggestions on integrated approaches for implementing revised NAAQS for ozone and PM, as well as new regional haze reduction program recommendations. The following is a list of these groups and a brief summary of their roles and responsibilities.

The Coordination Group was formed to provide direction to work group chairs in determining priority issues and timeframes to be considered by the full Subcommittee without managing details of the work group process. It assures that the output of the various work groups is coordinated and supports the overall goals of the Subcommittee. To achieve this, the Coordination Group has established working principles for the work groups to follow in developing issue papers. In addition, the Coordination Group provides the work groups with an early review of work products before they are presented to the full Subcommittee. An ad hoc team from the Coordination Group drafted key principles for use in developing the proposed interim implementation policy covering the period from finalization of new standards to approval of State plans to implement the new standards. Ad hoc groups covering specific issues also report directly to the Coordination Group.

The STSWG is responsible for prthe EPAring and assessing the state-of-the-art with respect to emission inventories, air quality models, meteorological models, and analysis of air quality monitoring data. The efforts of this work group are to be coordinated with the ongoing work of such groups as the OTAG, GCVTC, Southern Appalachian Mountains Initiative (SAMI), and the North American Research Strategy for Tropospheric Ozone (NARSTO). The STSWG also supports the other work groups by providing comments and analyses on scientific and technical issues associated with specific issue papers.

The NRSWG is responsible for the development of broad regional and/or national strategies for addressing transport issues. This work group examines the AOV/AOI concept, institutional mechanisms, and broad-based market and trading approaches or other innovative strategies for achieving emission reductions. In doing this, the group considers the technical, policy and institutional issues associated with these types of approaches from the perspective of both generators and receptors of emissions.

The BPAPWG is responsible for conducting a re-examination of the existing base regulatory program to take into account the potential new NAAQS, as well as the Regional Haze program, and to better integrate broader-based regional and/or national control programs including the perspective of both a receptor and generator of emissions. The work group's activities include a re-examination of the designation and classification process to better reflect associated health risks and the definition of air quality problems. An important component of its work is the development of transition policies to facilitate moving from existing to new programs. The BPAPWG also has led development of issue papers on attainment dates, new source review, incentives for monitoring, and areas at risk of becoming nonattainment areas, as well as papers on implementation of a "too close to call" category and population weighting of monitors. The last two papers were discussed by the Subcommittee, and although they covered subjects of considerable interest, were deferred from further discussion in order to make time for more critical issues.

The COWG is responsible for developing recommendations for the EPA regarding the education of all interested parties, including the general public, through dissemination of information describing the nature and extent of air quality problems and the associated health and welfare impacts. The work group also considers how best to provide information to the public about specific options and recommendations developed by the Subcommittee as a result of its deliberations on issue papers. This includes an explanation of the measures being taken now and in the future to address these problems and the associated costs and benefits. The initial focus of the group is to explain the current state of our understanding of information on health and welfare effects. This will include the steps The EPA is taking to address air quality problems through possible new NAAQS and the Regional Haze program. The COWG will describe how The EPA, through the Subcommittee, is developing new integrated approaches to assure public health and environmental objectives are attained.

1.2 Coordination Group - Overall Charge to Work Groups

The Coordination Group developed the following charge to the work groups in March 1996:

The Administrator has charged the Subcommittee with providing advice and recommendations to The EPA for developing integrated approaches for implementing possible new ozone and PM NAAQS, as well as a regional haze reduction program. This effort will first focus on the most effective and cost-effective means of solving the problem of achieving attainment of the NAAQS and making reasonable progress under the Regional Haze program. It is critical to this process that the Subcommittee and its work groups strive to frame innovative and creative programs which identify new approaches to old problems without being restrained by the outcome of the standards review process and the law. This should result in the development of as full an options package as possible for presentation to the Subcommittee.

1.3 Development of Issue Papers

The issue papers were assigned to the work groups based on their responsibilities as outlined by the Subcommittee. For example, issue paper topics related to broad regional strategies for addressing pollutants (e.g., regional haze) were assigned to the NRSWG. In many cases, liaisons from other work groups collaborated with the lead work group to develop the issue papers and recommendations. In some instances, the issue papers were developed by two or more work groups. The work groups were given the guiding principles identified below and outlines to assist in formatting the issue papers and principles to guide the development of the issue papers. The work groups were not constrained by the requirements found in the current CAA, but were told they could "think outside the box" when developing the issue papers and recommendations. Figure 2 is a flow chart depicting issue paper topics as they relate to the air quality management process.

Smaller teams were formed within the work groups and members were assigned to develop the issue papers and recommendations. Work groups met on numerous occasions to discuss and make changes to draft issue papers. When final drafts were completed, a representative of the work group presented the issue paper and any recommendations/options to the Subcommittee. Many of the issue papers were revised and resubmitted based on comments from Subcommittee members. In certain instances where there was significant concern about the recommendations in an issue paper, an ad hoc committee was formed to review the matter carefully and try to resolve the concerns.

1.4 Subcommittee Content-Related Principles

In order to provide guidance to the work groups, the Coordination Group identified a series of content-related principles to follow when developing issue papers and proposed recommendations. A set of nine principles was presented to the Subcommittee at the November 1996 meeting and discussed extensively.

The outcome of these discussions is the following final version (dated January 24, 1997) of the content-related principles.

1.	Progress toward attainment of revised NAAQS and achievement of regional haze program requirements should be achieved in an expeditious manner. Timetables for achieving progress should be formed by consideration of a number of factors, including health and environmental benefits, cost and technical impediments, available scientific information, requirements of the CAA, and administrative requirements.

2.	In the event of State or other responsible institution's failure to plan (or to participate in planning) and implement plans within the designated time frames, the Federal Government must take timely action to remedy the situation.

3.	All options/recommendations must be based upon specified deadlines for planning, implementing, and attaining the NAAQS and implementing Regional Haze program requirements.

4.	All options/recommendations which may require amendments to the CAA must be clearly identified with advantages and disadvantages for such changes analyzed.

5.	Assure timely environmental progress. Timely environmental progress means, at a minimum, continuing air quality improvements at a rate no less rapid than will be required to meet the current NAAQS. Early Federal, State and local actions to improve PM-fine air quality should be encouraged.

6.	Control strategies should be effective in achieving air quality objectives, should be designed to accommodate flexible response methods by emission sources, and should encourage continuing improvements in air quality. To this end, the advantages, disadvantages, and available information on cost effectiveness of a full range of control methods should be presented, including technology-based performance standards, market-based approaches, and other traditional and nontraditional approaches.

7.	All options/recommendations should provide for the use of best available, scientifically-based explanations in planning requirements and control strategy development. Such options/recommendations should include methods to identify the role of nonlocal transport processes and mechanisms designed to address such processes.

8.	Opportunities for integration of planning and implementation of solutions for ozone, PM, and regional haze problems that achieve better environmental results and lower costs should be fully pursued.

9.	Planning and implementation proposals should identify methods for early and continued involvement of potentially affected interests, to the maximum extent possible, to assist in the attainment of the revised NAAQS and achieving reasonable progress toward Regional Haze program goals.

1.5 Procedures for Developing Issue Papers and Presentations to the Subcommittee

To further ensure the continuity and quality of the work products developed by the work groups and presented to the Subcommittee, the Coordination Group developed the following principles and procedures to guide their efforts:

Active participation by all members in the work group is required.

Work groups are to strive for consensus recommendations. Consensus is defined as support for a position by a majority of members from all groups of affected interests (e.g., States, industry, public interest). Consensus does not require unanimous support of all members from affected groups.

If consensus cannot be reached on a recommendation within a work group, then the

positions with the most support are to be presented as options. Dissenting viewpoints will

be presented in writing providing a detailed rationale of the viewpoint. When a work group sector disagrees with a position, the matter may be referred to a smaller ad hoc group for resolution.

Issue papers and presentations to the Subcommittee will fully describe the positions of all

work group members and, to the greatest extent possible, set forth the work group's

recommendations. Presentations of the work group issue papers to the Subcommittee should emphasize recommendations/options and include the written reports of dissenting positions as described above.

Latest drafts of issue papers and other presentations to the Subcommittee must be on the

Technology Transfer Network (TTN) 7 days prior to the Subcommittee meeting. (One-page summaries of issue papers are acceptable substitutes for the full paper where no

recommendations/options are being presented.)

The Coordination Group will, in consultation with the EPA, develop appropriate principles

regarding content of issue papers for the guidance of the work groups.

Chapter 2 provides a brief summary of the issue papers presented to the Subcommittee at the meetings held. Also included is information regarding the level of consensus and the current status of each issue. Chapter 3 contains one-page summaries of the issue papers. Chapter 4 provides the scientific support for development of the implementation strategies. Chapter 5 outlines the updated strategy for the communication of findings and recommendations. Appendix A contains an updated membership list of the Subcommittee and the five work groups. Appendix B includes a more detailed summary of the issue papers, and Appendix C contains a table outlining the Subcommittee's primary audiences and their information needs as identified by COWG.