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 AND REGIONAL STRATEGIES WORK GROUP

INTEGRATED IMPLEMENTATION ISSUE PAPER

TABLE OF CONTENTS

I. INTRODUCTION	2

A. General Issue Statement	2

B. What is Meant by Integrated Implementation?	2

C. Why Does Integration Make Sense?	4

II. DATA AND TOOLS NEEDED TO PERFORM AN INTEGRATED ANALYSIS	6

A. Issues	7

1. Expanded Monitoring Network for PMfine, Ozone, and Regional Haze, Including Speciation	7

2. Expanded Capability to Do Integrated Modeling	7

3. Expanded Emissions Inventories	8

4. Regional and Seasonal Variability/Meteorology	8

B. Options	8

C. Details of Information Needs	9

1. Expanded Monitoring Network for PMfine, Ozone, and Regional Haze, Including Speciation	9

2. Expanded Capability to Do Integrated Modeling	11

3. Expanded Emissions Inventories	11

4. Regional and Seasonal Variability/Meteorology	11

III. ASSESSMENT OF POTENTIAL INTEGRATED CONTROLS	12

A. Environmental Benefits and Disbenefits for PMfine, Ozone, and Regional Haze	12

B. Related National Programs and Initiatives	12

C. Scheme for Weighing Multiple Benefits	12

D. Should Costs of Controls be Evaluated?	12

E. Timing	12

F. Pollution Prevention	12

G. Incentives for Early Implementation	12

NATIONAL AND REGIONAL STRATEGIES WORK GROUP

INTEGRATED IMPLEMENTATION ISSUE PAPER

DATE: November 12, 1996

CONTACT PERSONS:	Bob Kappelmann, phone (904)632-6249, fax (904)632-7376

Donna Lamb, phone (202)205-0800, fax (202)205-1096

Mark Scruggs, phone (303)969-2007, fax (303)969-2822

I. INTRODUCTION

The objective of this paper is to discuss integrated implementation, the importance of the analysis phase in identifying when and where integration is appropriate, and issues associated with the analysis that need to be addressed in Phase II.

A. General Issue Statement

The Environmental Protection Agency (EPA) has issued advanced notice of proposed rulemaking for revised ozone and particulate matter National Ambient Air Quality Standards (NAAQS) and a new regional haze program. There is a growing body of evidence linking ozone, fine particulate matter (PMfine), and regional haze through common precursors, common photochemical reactions, and common transport mechanisms. This suggests that the assessment of ozone, PMfine, and regional haze, along with the related compliance and control strategies, can be optimized through consideration of all three pollutants in an integrated fashion, rather than considering them independently. To the degree that integration of timelines and milestone dates does not delay the achievement of a NAAQS, integration may provide significant benefits.

B. What is Meant by Integrated Implementation?

The terms "integration" and "integrated implementation" are used interchangeably throughout this paper. These terms may have different meanings to various stakeholders. At least three areas of integration have been identified: integration of timelines, integration of intergovernmental activities (e.g., monitoring and modeling), and integration of analyses and control strategies. More specifically for the latter, a clarification of these terms are provided here as a guide to readers.

"Integration" and "integrated implementation" refer to the process of considering ozone, PMfine, and regional haze when developing a plan to attain the NAAQS and regional haze progress. This process involves the following four steps:

Integrate collection of data pertaining to ozone, PMfine, and regional haze (e.g., integrated ambient monitoring plans and collection of inventory data), where appropriate.

Analyze these data to identify geographical regions where:

Integrated control strategies would enhance the attainment of NAAQS and regional haze progress compared with non-integrated control strategies;

Integrated control strategies would have little or no incremental impact on attainment of NAAQS and regional haze progress compared with non-integrated control strategies; or

Integrated control strategies would impair the attainment of NAAQS and regional haze progress.

Develop a plan with integrated control strategies for the geographical areas described in 2a and, with caveats noted below, 2b and make decisions regarding the implementation of this plan. The implementation decisions would take into account optimal public interest, cost-effectiveness, non-quantifiable benefits, the rate at which standards or progress can be affected, and other factors.

Implement the plan.

For different geographical regions, it should be noted that integrated control strategies would not necessarily mandate a simultaneous emission reduction program aimed at ozone, PMfine, and regional haze from sources subject to the requirements. Integrated control strategies means a process whereby the likely future emission reduction obligations of a source for ozone, PMfine, and regional haze are defined as a result of the integrated analysis in step 2. A source would then, within the timelines of the NAAQS and regional haze program, identify the best method of achieving these reductions, either through a single element program addressing all precursors simultaneously or a multi-stage program addressing some precursors singly. For areas where the integrated analysis shows little or no benefit of integrated control strategies to NAAQS and regional haze objectives, integrated controls strategies may still be preferred if this results in more cost-effective emission reduction programs for sources subject to the program.

Note: Because an integrated analysis may take some time, an optional program could be developed to encourage early directionally correct controls for one or more of the pollutants. If there is a difference in the timing for one of the pollutants or a decision against integration, sources would be allowed to voluntarily participate in banking or other innovative programs in the interim. Any early emission reductions could be credited or banked toward meeting future requirements. Such incentives would provide some certainty for sources that know requirements will be imposed but do not know exactly what they will be or when they will be enacted. By choosing to act early, sources would also create more flexibility in possible future options. Incentives for early action will be discussed in greater detail in Phase II, along with the other issues addressed in section III.

C. Why Does Integration Make Sense?

Several connections exist among the three pollutant categories. The linkages are based on the existence of common emission precursors, source categories, as well as atmospheric chemistry and meteorological processes which affect more than one pollutant. For example, emissions of oxides of nitrogen (NOx) and volatile organic compounds (VOCs) can lead to ozone, PMfine, and regional haze formation. A combustion source often emits both sulfur dioxide (a PMfine precursor) and NOx (an ozone precursor). The sequence of atmospheric chemistry reactions underlying ozone formation is in part responsible for PMfine formation. Similar meteorological processes affect the movement, mixing, and removal of ozone, PMfine, and precursors.

Historically, implementation programs designed to meet a NAAQS, as well as the related Federal guidance provided to the States, focused only on the achievement of that NAAQS without formal recognition of the impact of that program on other NAAQS or related environmental criteria. This was due in large part to the lack of adequate understanding of pollutant transport and secondary pollutant formation chemistry, as well as the administrative complexities involved in dealing with integrated NAAQS implementation programs. In some cases this has lead to increased costs to States in developing and administering overlapping or redundant programs. In addition, industries often face multiple and sometimes conflicting requirements in complying with different NAAQS implementation programs.

The establishment of a new PMfine and ozone NAAQS and a regional haze rule, along with improvements in the state of the science coupled with demands for more cost-effective implementation programs, create the opportunity to consider integration of NAAQS implementation programs. Given the regionality, spatial patterns of air quality indices, precursors, sources, atmospheric chemistry and meteorological processes which affect more than one pollutant, and control options, integrating the ozone, PMfine, and regional haze programs may make sense.

The basics of an integrated strategy, for example, would use any or all of the following: considering environmental benefits and disbenefits for PMfine, ozone, and regional haze; giving credit for existing related local, State, and national pollution control programs; prioritizing schemes for analyzing benefits and disbenefits; and considering economies achieved by an integrated strategy, common timing of milestones and pollution control requirements, and pollution prevention opportunities. The possibility of integrating all parts of the program would be determined in the planning stage. (The better the analysis, the better the integration of the implementation strategies. It may not be possible to completely integrate all of the analysis tools, but it may be possible to use several tools together to approximate an integrated assessment. Also, there may be different attainment dates for different precursors initially -- the coordination of these dates may improve as the integration process proceeds.)

Developing integrated criteria and policies for the ozone, PMfine, and regional haze implementation process may be sensible in several different program elements. First, benefits could be gained in developing integrated monitoring plans for common precursors. To achieve optimum results, a multi-State integrated approach may be necessary. Second, integration of compliance programs would help eliminate overlapping control programs and help provide certainty to industry as to what requirements they must meet. It makes sense to deal with sources having impacts on several NAAQS with an integrated approach. Administrative cost would be saved by both regulators and industry. In addition, integration of NAAQS programs may facilitate emission trading programs. Integration of compliance programs on an inter-State basis will also help mitigate perceived competitive advantages which may occur with piecemeal control strategies. Third, to the degree that integration of timelines and milestone dates does not significantly delay the achievement of a NAAQS, integration may provide significant benefits. Improvements in the planning process for both the private and public sectors would be enhanced. Finally, integrated approaches would provide an opportunity to consider related mandates associated with other national programs which share common precursors and primary pollutants.

Integration has such a large potential to save costs and to benefit public health and the environment that there are cases where the implementation of ozone (or PM or regional haze) programs should be adjusted in order to allow for integration (by adjusting timelines, etc.). In cases where a PM timeline is not coincident with ozone, for example, designing a strategy for solely PM should be avoided if analyses allowing the consideration of ozone consequences are available. Similarly, States, which are prepared to implement an ozone strategy followed by a PM program two months later, should analyze ozone simultaneously with PM. Partially integrated strategies may make sense in cases where analyses performed with integrated monitoring and modeling show the wrong coincidence of seasonal violations for ozone and PM. Even without integrated monitoring or modeling, many control measures influence multiple pollutants. If the kinds of controls in these different categories were known, then better recommendations on how to evaluate control strategies could be made. A final example is when integrated monitoring is available but integrated modeling is not. In this case, two models should be utilized to determine whether integrated strategies are feasible.

Setting aside regional haze for a moment and examining PM, cases exist where, at least on the surface, little linkage between PM and ozone is evident. Differences include the contribution of primary particles to total PMfine (and especially PM10) and wintertime (actually non-summertime) PMfine events. Some primary particles are generated by strong wind conditions (e.g., soil/geologic material) and other mechanical processes (e.g., roadway fugitives). The fraction of primary PM peaks in the summer in most of the western third of the country where there is little precipitation for 6 to 8 months per year, leading to dry, windy conditions for the generation and movement of geologic materials. Ammonium nitrate, a significant PMfine component in the West, is not stable at the high temperatures associated with elevated ozone. Meteorological effects which influence the creation, maintenance, or removal of high levels of ozone and PMfine may be significantly different between pollutants, regions of the country, and times of the year.

Putting ozone and PM aside and looking solely at visibility, visibility protection requires its own distinct set of considerations. First, PMfine concentrations that are far below any possible NAAQS can adversely affect visibility in a significant manner, particularly in more pristine environments, such as Class I areas in the rural West. Second, relative humidity plays a significant role in increasing visibility impairment, particularly in the East. Third, unlike the NAAQS approach of setting a national standard, under section 169A of the Act States are required to make "reasonable progress" toward the goal of preventing future and remedying existing anthropological impairment of visibility in mandatory Class I Federal areas.

As the examples in the previous two paragraphs suggest, assessing ozone, PM, and regional haze individually might support a decision to not integrate. However, the problems caused by the three pollutants should be evaluated from an integrated perspective to the greatest possible extent. Since the examples where there is less linkage may vary across the country, it makes sense that an integrated assessment of ozone, PMfine, and regional haze may result in different degrees of integration in different locations.

II. DATA AND TOOLS NEEDED TO PERFORM AN INTEGRATED ANALYSIS

In order to develop a solid basis for the integration of PMfine, ozone, and regional haze strategies and to build upon existing knowledge, several new/improved tools will be needed, including: 1) a representative monitoring network for PMfine, ozone, and regional haze with data useable for developing strategies; 2) selected speciation of PMfine from this network (the sites to be affected by regulatory strategies are the most important); 3) accurate point, mobile, and area source inventories of sources contributing to PMfine, ozone, and regional haze ambient air quality problems (e.g., NOx, VOCs, SO2, CO, primary PM2.5, NH3, and toxics); and 4) ozone and PMfine integrated modeling capabilities under various meteorological, emissions distribution, and topographical scenarios.

Analysis of the regional and seasonal variability in the pollutants, the meteorology, the sources, and the impacts should provide a more holistic process for determining which sources need to be included. This analysis would also refine the specific zones within an area of influence which are the most important and would better identify where integrated strategies are needed and where they are not necessary.

The data and tools highlighted in this section are important for assessing ozone, PM, and regional haze problems from an integrated perspective, but are not prerequisites for an integrated approach. If speciation, for example, is not available, a fully or partially integrated ozone and PMfine and/or regional haze strategy may still be possible. This section strongly encourages an accelerated implementation of expanded monitoring, modeling, and emissions inventories, including speciation and transport considerations.

This section first conceptually examines how monitoring, modeling, and emissions inventories should be enhanced to address all three pollutants together (parts A and B). Then, to provide greater detail on data and tool needs, this section presents an excerpt from the Tools and Resources Timelines (part C).

A. Issues

1. Expanded Monitoring Network for PMfine, Ozone, and Regional Haze, Including Speciation

Much of the general atmospheric chemistry involved in ozone formation can affect PMfine formation and, thus, regional haze, in certain instances. For example, ozone is the major initiator of hydroxyl radicals, a chemical intermediate which converts sulfur dioxide and nitrogen dioxide to more oxidized sulfate and nitrate forms. Both sulfates and nitrates can contribute to PMfine formation. Clearly, a linkage between ozone and PMfine exists through the role of ozone in generating hydroxyl radicals. A correct characterization of the basic ozone chemistry and the associated linkages among the precursors is needed to predict the affect of changing emissions on air quality indices. Speciation may include the chemical breakdown of particulate matter, ozone, and precursors.

Benefits could be gained in developing integrated monitoring plans for common precursors. This is especially true in locating monitors to help validate air quality models. Due to the regional nature of ozone, PMfine, and regional haze, monitoring systems needed to adequately define the problem, as well as measure progress, often spanned numerous State and local jurisdictions. To achieve optimum results, a multi-State integrated approach may be necessary. Rather than solely focusing on urban receptors, the monitoring objective should include the science of transport. Limited resources will often require multi-parameter monitoring at many sites. An integrated approach will help determine when a site can meet the modeling and compliance needs for several parameters or prove beneficial for only one.

2. Expanded Capability to Do Integrated Modeling

The multiple nonlinearities and positive and negative feedbacks among the ozone, PMfine, and regional haze linkages demand spatially and temporally representative modeling capabilities to predict pollutant concentrations. Several issues are associated with the complementary and integrated use of models, ranging from the need to evaluate models with sound data bases to conducting fully integrated analysis optimized through the separate, strong attributes of data and models. In addition, common methodologies for modeling inputs, such as emissions inventories and monitoring data, should be ensured in order to conduct inter-State modeling analyses.

3. Expanded Emissions Inventories

There is a need to develop a modeling-quality emissions inventory for ozone and PMfine. They may need to cover NOx, VOCs, SO2, CO, primary PM2.5, NH3, and PM10. The inventories should be available for at least the lower 48 States and should include annual and daily emissions, so that different seasons can be modeled.

4. Regional and Seasonal Variability/Meteorology

Significant regional and seasonal variations exist in air pollutant emission sources, monitored data on air composition and types of pollutants, geographical conditions, meteorological conditions, atmospheric chemistry interactions among and within each type of air pollutant (ozone, coarse particulate, fine particulate, haze, etc.), which result in significant regional variations in the composition of the air and air quality concerns. Uniform health- based national ambient air quality standards and goals are to be achieved. Significant air pollution interactions (which may or may not be congruent) occur both within and among air quality regions, as illustrated by transport issues.

B. Options

Option 1: Pollutant by pollutant. Continue the present individual pollutant uniform nationwide monitoring, modeling, and emissions inventory approach.

Option 2: Uniform nationwide guidelines. Use an enhanced uniform nationwide monitoring, modeling, and emissions inventory approach, including speciation. Specifically focus on multi-pollutant approaches to address issues of inter-pollutant interactions, transport and boundary conditions.

Option 3: Uniform nationwide guidelines supplemented with regional needs. Develop a multi-pollutant focused, uniform monitoring, modeling, and emissions inventory system, including speciation and transport, which uses the regional air quality data variations. Uniform nationwide guidelines could lead to "lowest common denominator" guidelines or could request unnecessary information from some regions.

Option 4: Regional guidelines with some minimum formatting guidelines to facilitate sharing of information. Recognize the regional nature of the array of monitors and speciation needed to integrate in the future. Develop different regional performance-based, multi-pollutant monitoring, modeling, and emissions inventory approaches, including speciation and transport, with an effective periodic measurement and evaluation system. Common methodologies for modeling inputs, such as emissions inventories and monitoring data, should be ensured in order to conduct inter-State or national modeling analyses. This approach would allow a region to do a more tailored job of defining information needs without getting formal approval from the EPA.

Recommendation

Ideally, option 4 is recommended. This makes sense based on the work of the Grand Canyon Visibility Transport Commission (GCVTC), the Ozone Transport Assessment Group (OTAG), and others in identifying and addressing regional needs. Examining details in Phase II may show options 2 or 3 to be necessary in the short term. Option 1 was rejected because in an integrated approach enhanced PM, ozone, and regional haze monitoring, modeling capabilities, and emissions inventories, including speciation and transport considerations, are needed. Speciation is needed irrespective of whether and to what degree integrated implementation takes place. An adequate amount of speciation to sufficiently characterize the problem should be required initially and, then, only speciation as needed to determine if the controls are effective. This may cost more in the short term but will save both time and money in making implementation decisions in the long term. These initial costs could be mitigated by proper monitoring network design.

Note: There is also a need to balance costs among monitoring, modeling, and emission inventories, so that the information available for assessing the different control options is balanced.

C. Details of Information Needs [This will become part of the Tools and Resources Timelines paper to be considered in Phase II]

This section is a preliminary draft of the specific tools and data needed for ozone, PMfine, and regional haze programs. Information needs are listed in order of priority. Additional meteorological data will also be needed.

1. Expanded Monitoring Network for PMfine, Ozone, and Regional Haze, Including Speciation

PMfine

Initial monitoring network for new NAAQS compliance, including all large urban areas and existing PM10 nonattainment areas.

Monitoring of secondary aerosol precursors (e.g., NOx, SOx, VOCs, primary PM2.5, NH3) at a subset of these sites, mostly in urban centers. These could be thought of as a more flexible Photochemical Assessment Monitoring Station (PAMS) network for PMfine or "FPAMS."

Selected speciation of the monitoring data from A, above, to support and to be integrated with the FPAMS site data and Interagency Monitoring of Protected Visual Environments (IMPROVE) Class I data.

Tailor PMfine precursor data collection and related speciation analyses to the related area-specific air quality problems (e.g., ozone and/or regional haze) on a seasonal or episodic basis.

Design future epidemiological studies at sites which violate the NAAQS by the greatest margin on a regional basis. Measure all related gas and particle species at these locations and indoors to understand exposures to people and to support SIP analyses and future Criteria Documents. Provide resources to State and local air agencies to support the on-going operation of these "suites" of monitoring technologies.

Regional Haze

Link selection (and an increase in the number) of IMPROVE-protocol sites as PMfine "background" sites for urban areas, where meteorology and/or modeling analyses support that decision, and verify with periodic ambient data analyses, up to and including SIP-level modeling.

Continue the IMPROVE Steering Committee's intent to characterize the PM ambient air quality and visibility impacts for as many individual Class I areas, as resources allow. Use a menu of data analysis tools, including statistics, meteorology, and streamlined dispersion/receptor models to periodically review and adjust the network. Tie in other related ambient monitoring networks (i.e., the Clean Air Act Status and Trends Monitoring network (CASTNET), and others) where data goals are/can be mutually beneficial.

Increase analyses to support the relationship of (and the number of) optical impairment measurements to concurrent PMfine data for the Class I area(s).

Ozone

Monitor trends and episodes in NOx and VOC data at selected trend sites in new 8-hour ozone nonattainment areas or "Areas of Violation" (AOVs) to support future control strategies' analyses for the "Areas of Influence" (AOIs).

Reconfigure and increase the flexibility of PAMS to match and support the FPAMS concept.

Link increased rural ozone monitoring to seasonal data co-location at IMPROVE- protocol sites to support analyses of secondary ozone NAAQS compliance.

2. Expanded Capability to Do Integrated Modeling

Model(s) capability must focus on integration as a first step, with expanding spatial dimension (AOI boundary) only as feedback from the monitoring network(s) and emissions monitoring data analyses demonstrate need.

Successful integration of model routines must be based on a common quality of PMfine, ozone, and regional haze input data, and proceed in the proper iterative fashion (e.g., emission, meteorology, atmospheric chemistry) before moving to dispersion/receptor analyses.

Aggressive development of PMfine (primary and secondary aerosols) and regional haze modeling modules based on 2, above, is a higher priority than for ozone.

Modeling modules and supporting input data bases must accurately account for complex terrain, boundary conditions, and receptor site/time-specific impacts. These models are not presently available. When they are available, they need to be tested throughout the U.S.

3. Expanded Emissions Inventories

Spatial resolution of emission rates must be sufficient to draw an AOI(s) and defend the public policy decision. Increased emissions monitoring of point sources over some lower tonnage cutoff for NOx, SO2, VOCs, primary PM2.5, and NH3 is indicated from the GCVTC and the OTAG work. Better field work to estimate emission factors and areal/episodic dimension for area sources is needed on a AOV-specific basis. Mobile source emission factors should be comprehensively revisited for precursors. For ammonia, emissions inventories need to be developed for all sources.

Quality and quantity of emissions data estimates must be quantitatively measured on a periodic basis to facilitate high-performance market-based approaches.

Unless a national control strategy is indicated and given limited resources, it does not appear useful for any entity but the EPA to demand a compound-specific national emissions inventory. Could an incentive plan similar to the "monitoring incentives concept" be developed to allow regions to inventory compounds most closely related to their ambient regulatory needs?

4. Regional and Seasonal Variability/Meteorology

Regional variation will be more or less significant depending upon the level of the NAAQS and the form of the NAAQS and the regional haze program. Technical tools for integrated implementation of these NAAQS and regional haze rules should "roll- up" so that local problems (measured as health and welfare impacts) are addressed without delay from broad regional analyses, where appropriate.

III. ASSESSMENT OF POTENTIAL INTEGRATED CONTROLS

In Phase II, we anticipate exploring:

A. Environmental Benefits and Disbenefits for PMfine, Ozone, and Regional Haze

B. Related National Programs and Initiatives

C. Scheme for Weighing Multiple Benefits

D. Should Costs of Controls be Evaluated?

E. Timing

F. Pollution Prevention

G. Incentives for Early Implementation