CLEAN AIR ACT ADVISORY COMMITTEE

SUBCOMMITTEE ON OZONE, PARTICULATE MATTER,

AND REGIONAL HAZE IMPLEMENTATION PROGRAMS

REPORT ON PROGRESS TO DATE

DECEMBER 5, 1996

LOS ANGELES, CALIFORNIA

OVERVIEW

•	This briefing on "Phase I" progress will be followed up by a written report at the Spring '97 CAAAC meeting

In this package

•	Charge to the Subcommittee

•	Time line for development of implementation strategies (Phases I and II)

•	Subcommittee membership and organizational chart

•	Accomplishments to date

•	Principles for interim implementation policy

•	Highlights from Subcommittee discussions to date

CHARGE TO SUBCOMMITTEE

•	Develop recommendations to EPA regarding integrated programs for attaining new/revised ozone and PM NAAQS and making reasonable progress toward national visibility goal of no manmade impairment

- Recommendations to be considered by EPA in developing phase I and phase II policies/rules

- Phase I addresses air quality management framework (designations, monitoring, planning approach, regional haze program)

- Phase II will focus on emission reduction strategies, attainment dates, sanctions, etc.

•	Continue present efforts to reduce emissions

•	Focus on relevant implementation issues, not issues related to standards or other titles of Act

•	Strive for innovative, cost-effective, and creative approaches

•	Recent letter from Administrator Browner points out areas for continued/expanded emphasis (see meeting materials)

TIME LINE

September 1995	First meeting of Subcommittee

November 1996	EPA proposal of new/revised primary & secondary NAAQS for ozone and PM, interim implementation policy.

November 1996	FACA Subcommittee concludes Phase I discussions.

December 1996	Presentation to CAAAC on progress to date.

June 1997	EPA promulgation of new/revised primary & secondary NAAQS for ozone, PM, interim implementation policy.

June 1997	EPA phase I proposal of integrated implementation strategy for ozone, PM, and regional haze.

November 1997	FACA Subcommittee concludes Phase II discussions.

December 1997	Presentation of draft Phase II report to the CAAAC.

June 1998	EPA final action on Phase I of the integrated implementation strategy.

June 1998	EPA proposal of Phase II of the integrated implementation strategy.

June 1999	EPA final action on Phase II of the integrated implementation strategy.

SUBCOMMITTEE MEMBERSHIP (non-EPA)

•	Significant EPA and stakeholder effort devoted to this project

Subcommittee	Work Groups*

13	State/Local/Regional Orgs.

23	Industry representatives

8	Environmental Organizations

4	Academia

6	Federal Agencies

4	Attorneys/Consultants

58	TOTAL (Includes 16 CAAAC members)

27 Base Programs

30 National/Regional Strategies

14 Communications

20 Science and Technology

18 Coordination Group

109 TOTAL * Work groups include some Subcommittee members.

ACCOMPLISHMENTS TO DATE

•	7 meetings of full Subcommittee since September 1995. Planning meetings every 2 months in 1997.

•	Work group conference calls at least every 2 weeks. Several work group meetings in-person.

•	Principles for interim implementation policy for ozone and PM NAAQS implementation (see meeting materials)

•	Scientific and technical discussion on integration of ozone, fine particles, and regional haze management (see meeting materials)

•	Communications strategy

- Recognized as critical to success of implementation program

- FACA Subcommittee home page on World Wide Web: http://www.epa.gov/airlinks

- 2500 file downloads/month

•	Guiding principles for developing issue papers

PRINCIPLES FOR INTERIM IMPLEMENTATION POLICY

•	Interim implementation policy covers time frame from date new/revised NAAQS are promulgated until new SIPs are approved by EPA

•	Principles address the following key issues:

- No backsliding allowed - current controls retained.

- Maintain progress for areas not attaining current standard

- Substitutions allowed under limited circumstances (recognizing potential benefits of regional reductions)

- Current designations retained and some redesignations allowed

- Attainment demonstration requirements

- Cannot remove PM-10 controls if benefit PM-2.5 reductions

ACCOMPLISHMENTS TO DATE (cont.)

•	Development of 14 issue papers

-	Designations Issues for New NAAQS

-	How Should Areas of Influence Be Determined?

-	Update on the Area of Violation/Area of Influence Concepts

-	Institutional Mechanisms

-	Integrated Implementation

-	Attainment Dates

-	New Source Review

-	Economic Incentives

-	Regional Haze

-	Monitoring Incentives

-	Options for Designating PM-Fine Areas

-	Areas at Risk of Becoming Areas of Violation

-	Utilization of an Exposure-Based Monitoring System

-	"Too Close to Call"

•	New issue papers under development: Classifications, Reasonable Further Progress, Sanctions, Mobile Sources/Conformity/Fuels, Fire Policy

HIGHLIGHTS FROM SUBCOMMITTEE DISCUSSIONS TO DATE

•	Scientific and technical discussion

- Common precursors and atmospheric processes affect ozone, PM, regional haze

- Pollutant transport can influence elevated levels of ozone, PM, and regional haze from sources hundreds or even thousands of kilometers away, depending on meteorological conditions

- Elevated ozone, PM, and haze levels can show similar spatial patterns, particularly in the summer

- Enhancements to tools and information bases are needed in several technical areas, and should be pursued expeditiously in order to support AOI designations, control strategy development, potential market systems

•	Area of violation (AOV) and area of influence (AOI) concepts

- AOV = Area in which standard is exceeded. Includes mandatory Federal Class I areas as AOV's for regional haze. Based primarily on monitoring data. Mandatory controls would not necessarily be required for all AOV's.

- AOI = Broader area containing the set of anthropogenic and nonanthropogenic sources potentially contributing to downwind AOV's, taking into account pollutant transport where appropriate.

- AOI designation would not necessarily mean all sources therein would be subject to controls.

HIGHLIGHTS FROM SUBCOMMITTEE DISCUSSIONS TO DATE (cont.)

•	AOV/AOI general concept serves as the foundation for many other issue papers

•	A 3-step process for identifying AOI's and control strategies has been proposed. Further discussion is needed to determine all parties that will participate in the following activities:

1) Designate planning regions; identify AOI's. (AOV's would be identified in parallel based on monitoring, data analysis.)

2) Prepare regional plans. (Refine AOI's if needed.)

3) Identify control strategies and areas in which they would be applied. (SIPs/TIPs would be developed to implement strategies.)

•	At November 1996 meeting, Subcommittee recognized need for further discussion on AOV/AOI issue papers, in conjunction with Institutional Mechanisms and New Source Review papers, to address related issues such as:

- Role of regional entities in defining AOI's and potential market-based systems, and incentives for State participation in developing regional plans in a timely fashion

- Consideration of mandatory measures (e.g., RACT, NSR) in AOV's and control regions

- Technology floor and potential role of trading in future NSR program

- Definition of Reasonable Further Progress during planning process

HIGHLIGHTS FROM SUBCOMMITTEE DISCUSSIONS TO DATE (cont.)

•	New source review paper to be further developed in phase II after market program elements are more clearly defined in Economic Incentives paper

- Concern expressed that this paper should be compatible with efforts of NSR Reform Subcommittee

•	Integrated Implementation paper recommends integrated technical assessments for ozone, PM, and regional haze, to the extent practicable

- Integrated assessments and planning should begin as soon as possible, although designations for PM-fine nonattainment areas/AOV's may take longer than those for ozone and haze

- National guidelines for technical assessment (modeling, emissions inventories, etc.) which accommodate regional differences are recommended

HIGHLIGHTS FROM SUBCOMMITTEE DISCUSSIONS TO DATE (cont.)

•	General agreement on a set of principles for issue paper on Options for designating PM-fine nonattainment areas/AOV's, including:

- The PM-fine monitoring program needs adequate financial and management support

- Speciated monitoring data should be required to assist in planning and control program design

- Areas with sufficient data shall be designated as soon as possible after NAAQS promulgation

- Early options for controls during the designation process should be explored and encouraged

•	Regional haze issue paper

- Recommended that regional entities define quantitative objectives for "reasonable progress," although need for deadlines and federal "backstop" was expressed

- General agreement on list of criteria for determining reasonable progress

- Further discussion needed on best available retrofit technology (BART)

SUMMARY

•	Subcommittee process is generating extensive interaction and dialogue among stakeholders

•	Potential is high for developing innovative approaches that can be acceptable to all parties

•	Next report on Subcommittee progress at Spring '97 CAAAC meeting