Memo

TO:	David Sanders/STSWG members

FR:	Bruce Hill, Appalachian Mountain Club

DA:	Friday November 8, 1996

RE:	Thoughts on issue papers

CC:	Jayne Mardock, CAN

Members of STSWG. The following are some thoughts and responses following the Dallas meeting from your neighborhood environmentalist/scientist. I realize I am hardly preaching to a choir, but I hope a few of these ideas will resonate with members of the STSWG and of course, am listening to your arguments and consider myself open minded; policy based on bad science will not result in cleaner air. Any feedback would be appreciated and welcome as would conversations over the phone to clarify issues.

ON DEVELOPMENT OF TOOLS FOR AOI/AOV: At the meeting in Dallas there was discussion and disagreement as to the ability of some of the modeling and trajectory methods (HySplit, RADM, etc.) to identify AOIs for AOVs. I was very surprised at the time spent in assaulting ST's work. How much science is enough science to make policy seems to be the usual point of conflict. While some argue for more data to designate non attainment areas, others argue that the cost in lives lost will be unacceptable. The balance will be in the hands of the subcommittee and the EPA policymakers, however, the information we provide them on tools , their effectiveness and limitations, will help them most effectively balance the societal risks of moving too slowly , or too fast. I believe, based on my observations of the Dallas meeting that there may be too much focus and arguing on the details and not enough in developing the data and tools policymakers can actually use in the STSWG.

Our discussion in Dallas lead to the useful idea of a 'tools' chapter for the Conceptual Model. I believe that this will be the most important chapter in the paper if we can agree on, and catalogue, the current methods and their limitations such that policymakers can understand the usefulness and limitations/risks of using each method. Taking this one step further, instead of hours of arguing about the limitations of each method, it might be most constructive if STSWG could develop consensus around a specific recommendation as to the most useful combination of tools available today, to assign AOVs and determine AOIs.

ON ATTAINMENT DEADLINES: While promoting protective air quality standards, the environmental community is indeed sensitive to the need for cost-effective solutions, and has recognized the gains that have been made where we have promoted solutions that are realistic and effective. The environmental community also recognizes the need for sound science to avoid the risk of over-inflating the consequences of air pollution, such as occurred in the acid rain debate (Waldsturben--exaggerated forest mortality, for example). However in this debate, that the epidemiological data is clear and suggests that tens of thousands of humans die each year due to PM exposure in cities and even rural areas, all over the country. This wide distribution of effects to suggests a mechanical mechanism (ultrafines?), for health effects are seen in areas that have different PM speciation (ie some are nitrate dominated, others sulfate or organics). Immediate action to remedy obvious areas associated with health impacts by reducing fine mass is tantamount to saving lives. Attainment deadlines are an essential motivating component of this process in our view; RFP is not enough when the human stakes are so high, especially given the current definition which focuses on precursor emissions reductions -- a poor substitute for real progress. Immediate action, of course requires the best atmospheric science we can muster at the present to predict the ability of strategies to reach attainment. While papers like Steve Ziman's call this traditional approach into question, deadlines have proven one of the most effective motivators for progress, regardless of whether the deadlines have actually been met on time. Further, the Clean Air Act calls for such milestones. Thus it is my belief we should be focusing on the kinds of deadlines are appropriate rather than on effectively eliminating them.

ON MONITORING AND INCENTIVES: Prompt implementation and risk reduction will require that a well thought-out monitoring array be developed and systematically implemented ASAP to identify less obvious areas of violation once data is available. Everyone agrees that more monitoring is better. I think there is general consensus that a certain number of representative monitors that require speciation will be critical to targeting cost-effective emissions reductions. What we don't agree on is under what circumstances monitors should be used for science alone and others for compliance purposes. I believe that if a sound array of monitors is developed administered and supported by EPA for state implementation, then all other monitors for scientific purposes are fine. If however concentrations are measured at these monitors that indicate violations, this should trigger a requirement that a compliance monitor be installed. Otherwise we are cheating people of their right to know and the right to breath clean air. I cannot accept developing monitoring incentives to compensate for the ethic that some states will 'pull' a monitor rather than suffer a violation. Added flexibility to compensate for a bad ethic in monitoring is not a long-term solution that will protect public health, even if it does result in better atmospheric science. This is unacceptable to the environmental community and argues for EPA administration of a sound compliance monitoring system. Incentives to monitor are however important. I know this because of the benefit derived from the high elevation sites I operate--some as AIRS under EPA and NH protocols.

An acute problem I foresee with monitoring is relative to the frequency of the schedule. At the monitoring sites I work with in New Hampshire, there is an IMPROVE module A (PM2.5) operating on a Wednesday and Saturday schedule and Harvard Impactor (HI) PM2.5 monitors on a daily basis in the summer. In 1995 the daily HI monitors (10 hour) recorded concentrations up to 86 ug/m3 (second highest = 52 ug/m3, third highest = 42 ug/m3) whereas as the IMPROVE, operating on a 24 hour basis twice a week recorded a maxima of 20 ug/m3 (second highest = 20 ug/m3 , third highest = 19 ug/m3 ). This suggests two problems: 1) twice a week monitoring (even worse, 6th day) will not identify the true distribution of data and will likely miss many peaks and 2) monitoring may not make sense at night for the purposes of human health exposure assessment. I think this group ought to review proposed monitoring protocol if it is to provide useful exposure data.

Could Neil Frank come and brief us on the proposed FRM in Denver?

ON ECONOMIC INCENTIVES: A new idea, "Industry Average Performance Standards" (IAPS) is being developed by a NH State legislator Jeffrey MacGillivray and AMC member that should be heard and evaluated in this process. This is not a statement of support for the proposal ( I remain neutral at this point), simply as description of a new idea that may work better than Title-IV type trading. In essence, IAPS transfers money from dirtier than average producers in each industry to cleaner than average producers and gives all polluters an incentive to install cost-efficient controls as quickly as feasible. Money is collected from each polluter based on tons of a pollutant emitted and distributed based on the number of units of product produced. The result of the distribution is that 'dirtier than average' producers in each industry pay the 'cleaner than average' producers in the same industry. Government supervises fund transfers without keeping any. I am interested in response to this concept. Some of you may have heard it in OTAG.

ON INTEGRATED IMPLEMENTATION: It has been argued that a reductions strategy based on early non attainment designations for PM2.5 is not feasible given the limited data. While I believe, based on my survey of data in the epidemiology studies that plenty of data exists to begin to adopt control measures in various hot spots in the US with minimal additional monitoring data, I also think that there are plenty of evidence to begin to control regional haze which will, of course, have the benefit of reducing PM. In addition to nitrate dominated atmospheres in ozone exceedence areas where NOx reductions benefit PM, ozone and regional haze reductions, this is the most logical place of overlap and a reason to move forward in developing concepts for integrated control measures. Thus I think this is an interesting point of departure for discussion of integrated implementation. Obviously a one-size-fits-all approach will not be practical given the variety of sources of haze across the country and this is where STSWG might play a role in subdividing regions for regional haze implementation measures. I also wonder if we should be thinking more broadly about VOC reductions that benefit reductions in air toxics as well as organic aerosols?

ON RFP: In another area, I wonder if STSWG has spent enough time developing a concept for assessing progress, RFP, by means other than raw emissions reductions? This seems like another critical area we could spend time developing a position that would result in a meaningful product that would result in our ability to gauge progress in reducing heath impacts rather than reduced precursors in a complex atmosphere.

ON STEVE ZIMAN'S FEASIBILITY OF ATTAINMENT: An interesting but disturbing issue paper. If his hypothesis is true, an improved strategy to reduce emissions to eliminate 'flip flops' should be the focus of the discussion, rather than the alteration of the standard which is a protective standard based on health exposure data rather than practicability of attainment. Maybe we should be discussing strategies to reduce ozone baselines as well as peaks (such as suggested by S.T. Rao's recent publications). I would like to see more references/sources in section IIa, and some of the raw AIRS analysis work that went into the conclusions drawn this paper, as well as some discussion of the uncertainty in the models that feed into your conclusions. I am also interested in the number used for $/ton in the analysis. Is this something you could do in Denver, Steve?