This is a preliminary document prepared by a subgroup of members of the National and Regional Strategies (NRS) Work Group as part of the Federal Advisory Committee Act (FACA) Subcommittee process. It is not an EPA document. This document has not been reviewed by the NRS Work Group and is subject to further work group discussion. Interested people should forward their comments to a member of the National and Regional Strategies Work Group.

INTEGRATED IMPLEMENTATION ISSUE PAPER - Phase II Update

DATE:	August 5, 1997

CONTACT PERSONS:

Bob Lopez	(608)267-5284, fax (608)267-0560 (Phase II Lead)

Bob Kappelmann	(904)632-6249, fax (904)632-7376, Base Programs WG

Donna Lamb	(202)205-0800, fax (202)205-1096, National & Regional Strategies WG

Mark Scruggs	(303)969-2077, fax (303)969-2822, Science & Technical Support WG

STATUS:	DRAFT #2

I. INTRODUCTION

The objective of this summary paper is to reflect the Phase I discussion and conclusions on integrated implementation and update the issue in light of the proposed Regional Haze regulation and administration guidance from the promulgated NAAQS for ozone and PM-2.5. It provides a summary discussion of the recommendations of the workgroups and subcommittee regarding Phase I integration issues and notes the scope of additional dialogue related to Phase II integration issues since November 1996.

A. Phase I Conclusions - Integrated Implementation

The subcommittee in Phase I concurred that the assessment of ozone, PMfine, and regional haze, along with the related compliance and control strategies, could be optimized through consideration of all three pollutants in an integrated fashion, rather than considering them independently. This was based on a substantial body of evidence linking the pollutants through common precursors, common photochemical reactions, and common transport mechanisms. The group generally felt that administrative incentives and regionally-sensitive guidelines for NAAQS and haze program integration could provide significant benefits and acknowledged that integration of timelines and milestone dates should not delay the achievement of a NAAQS or reasonable progress toward air quality improvement.

The group further felt that any new administrative guidelines for integration consideration within the individual SIPs should address regional as well as national considerations in regard to monitoring, modeling, comprehensive technical assessment including inventories and control strategy development. Most participants felt that though initial SIP timelines and milestones couldn't be synchronized, that ample opportunity and need existed to pursue midcourse SIPs synchronization. Some participants felt that such synchronization should only be a planning goal and not a mandatory SIP component. Most felt that the guidance should be built upon a premise of administrative incentives for coordination and early action based on a multi-pollutant improvement objective. Nearly all participants felt a strong need for early and broad-based speciated monitoring data to support better integrated analyses and control strategy development.

B. Summary of Integrated Implementation Dialogue, Issues and Constraints

The Phase I Integration paper (11/12/96) provided an in-depth definition (picture) of an optimum integrated implementation approach, stepped through possible scenarios for achieving integration and noted technical tools needed to pursue integrated air quality assessments and to produce reasonably integrated plans.

Data and tools highlighted in the Phase I dialogue are important for assessing the problems from an integrated perspective, but are not absolute prerequisites for an integrated approach to plan development. If speciation, for example, is not available early in the process, a fully or partially integrated ozone and PMfine and/or regional haze strategy may still be possible. The Phase I dialogue strongly encouraged an accelerated implementation of expanded monitoring, modeling, and emissions inventories, including speciation and transport considerations. Additional and extended integration tools issues are being addressed in the Inventories and Modeling issue papers.

To address some of the strategy development issues, the Phase I dialogue identified a need for a better understanding of the real opportunities for a long term control strategy optimized on a multi-pollutant basis. An "Opportunities Matrix," for reviewing both key emission sectors and key control measures was drafted and received a limited workgroup and subcommittee review. The matrix is crafted on a major emissions sector basis. Most participants acknowledge the inherent value of such a tool, particularly for SIP options development, but most did not wish to pursue an extended development and review effort. The most current, reviewed matrix will be an attachment to any final Phase II integration paper.

Other issue papers have addressed or are addressing integration issues related to dates and designations, progress issues before and after SIP development, and regional control strategy approaches and criteria that relate to cross-pollutant integration.

II. Phase II - EVOLVING INTEGRATED IMPLEMENTATION ISSUES

The Phase II issues dialogue on integration efforts focuses on situations where the administrative requirements, evaluation tools, plan development criteria and level of air quality understanding are not immediately conducive to a fully integrated planning construct.

Issues/questions have been identified for situations that have more obviously complementary

problem & solution sets for multi-pollutant air quality management versus those that do not obviously point toward integrated solutions or which are reflective of very different or very uncertain emissions or transported pollutant problems.

In Phase II, the group had specifically anticipated exploring three general areas:

1	Identification of strategies and control measures with multiple pollutant benefits or problems

2	Solving multiple pollutant problems when the assessment tools or planning timelines are different, where the benefit of plan and controls integration is not obvious, or where an integrated controls response is negative

3	Incentives for early implementation of integrated controls where indicated as positive

The Opportunity Matrix and early issue dialogue primarily focused on situations where integrated response appears clearly beneficial. This led to a limited set of options but no recommendation to date, given the need for a better indication of the SIP timelines and milestones affecting the three pollutants. The Control Strategies and National Measures papers are focusing on the crafting of national and prescribed or discretionary regional/local measures under different circumstances where integration efficiencies are but one of several criteria for measure selection.

A primary consideration is how to most appropriately weigh the multi-pollutant control benefit (or disbenefit) of various measures in crafting an optimum strategy. Beyond basic efficiency considerations, criteria can include relative control cost, optimum controls timing, regulatory/control measure flexibility, a balance of air quality and investment certainty, and aggregate socio-economic impact.

The group is currently discussing an integration approach or considerations that might be pursued in situations where there remains a strong uncertainty regarding real opportunities for any integration of controls or the administrative or analytic support structure for control plan development. In the worst case, such a situation might reflect opposing approaches to optimum control of two or more pollutants. The group is exploring the likely scope of such a problem and any options to address it.

Finally, the group is trying to identify the minimum needs in terms of information, regulatory certainty and targeted incentives that might provide state and emission source stakeholders the capability to address and build integrated control responses without increasing either regulatory burdens or investment uncertainty or risk while producing sufficient future air quality improvement certainty to facilitate health and environmental stakeholder support.

The continuing integration dialogue has followed the issue development guidance related to content and process. Issues, options and recommendations will have to be refined to reflect components of the recent NAAQS and haze rules and administration directive related to revised/extended timelines and milestones that affect or address integrated implementation.

III. RECOMMENDATIONS for INTEGRATED IMPLEMENTATION (Aug 4 Revised)

1. The assessment of ozone, PMfine, and regional haze, along with the related compliance and control strategies, should be optimized through consideration of all three pollutants in an integrated fashion, rather than considering them independently.

Rationale for the general Implementation Integration Recommendation - 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 a single specific NAAQS without formal recognition of the impact of that program on other criteria pollutants or related environmental measures. 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 the new NAAQS and the regional haze rule, along with demands for more cost-effective implementation programs, creates the opportunity to seriously consider some level of integration between the programs. Given the potentially broad regional scope and spatial patterns of these pollutants, their precursor emissions and sources, and the improving understanding of the atmospheric chemistry and meteorological processes which affect them; integrating the three programs seems to make common sense.

2.	EPA should not force implementation timelines to coincide

Rationale - The time needed to pursue up front technical and data efforts varies significantly between the pollutants. In addition, in order to encourage improved ultimate environmental outcomes, flexible milestones have been proposed as part of the final rule for PMfine and for regional haze. Integrated evaluation is not necessarily predicated on integrated timelines.

The group has consistently highlighted a desire to pursue integration in administrative and analytic components while acknowledging the timelines can't be made to coincide. Long term plan integration objectives should be addressed in guidance regarding inventories, air quality modeling and monitoring network development.

Note: Proposed Recommendations 3 through 7 are the result of extended dialogue based on the acknowledgment during Phase I that the structure of the refined implementation programs need to address an objective of heightened multiple pollutant integration but that technical information timelines and administrative milestones are not likely to mesh soon.

3.	EPA needs to address the issue of regional haze improvement where early local NAAQS SIPs aren't or won't drive program development and automatic progress. This may involve incentives to pursue regional approaches to address transport where the science warrants a broadened or more distant area response.

Rationale - Administration guidance supporting the final NAAQS rules and haze proposal reflect an assumption that visibility progress will automatically result from acid rain, regionally generated ozone and PMfine control plans and other national measures. Where these efforts are likely to fall short of significant regional improvement due to a localized control response, or for areas where there will be no new or continued NAAQS violation, a more refined regional effort may be needed to ensure progress.

4.	EPA should provide states incentives and encouragement for "periodic" SIP-driven integrated plan evaluations rather than mandate mid-plan corrections for the building of integrated strategies and for refined integrated milestones.

Rationale - State and stakeholder participants have expressed support for integrated assessment and plan development in a fashion that reduces administrative burdens and provides incentives for early multi-pollutant control. There does not appear to be a legal basis for mandating an integrated approach.

5.	Through implementation guidance EPA needs to encourage greater or more flexible SIP attainment or progress credit for sources or source sectors investing in longer term, optimized multipollutant controls.

Rationale - Stakeholders have identified a need for the encouragement of longer-term, higher-risk controls investments that address multiple pollutants. These may be the result of pollution prevention initiatives or technologies that address several precursors. With some level of regulatory certainty and a time certain "safe harbor" for participating industry, such as the MACT program for air toxics, opportunities to obtain both multiple pollutant and early reductions may be enhanced.

6.	EPA and the states should emphasize the use of control measures with multiple pollutant benefits in crafting SIP strategies addressing both NAAQS and haze.

Rationale - Improving air quality data and assessment tools should provide the basis for an enhanced evaluation of the potential cross-pollutant impacts of control options and for identification of the most critical and most efficient sectors for control of multiple pollutant problems.

7.	EPA should consider a broadened criteria for the possible waiver or adjustment in timing or location of controls based on multiple pollutant and transport affects on public health and visibility.

Rationale - Early waivers granted for certain NOx controls following the 1990 amendments did not always address regional transport and cross-pollutant impacts. A more refined balancing assessment is indicated for the waiver or allowance for delayed or staged implementation of controls affecting the ambient concentrations of more than one criteria pollutant.