Draft Summary of the Federal Advisory Committee Act FACA)

Science and Technical Support Work Group Meeting

Mutual Building, Tom Helms' Office

January 28, 1997

Durham, North Carolina

The Science and Technical Support Work Group (STSWG) of the FACA Subcommittee met on Tuesday, January 28, 1997 in Durham, North Carolina. A list of the participants and a summary of the meeting follows.

Work Group Participants

Name	Affiliation

Harvey Jeffries, Co-Chair	University of North Carolina-Chapel Hill

Diana Andrews	Kentucky DEP

Kirit Chaudhari	Virginia DEQ

David Chock	Ford Motor Company

Jay Hudson	Santee Cooper

Tom Moore	Arizona

Jay Turner	DOT

Dan Weiss	Cinergy Corporation

Steve Ziman	Chevron Corporation

Work Group Members Not Participating

Tom Helms, Co-Chair	U.S. EPA

John Cabaniss	AIAM

Glenn Cass	Cal Tech

John Core	WESTAR

Ellis Cowling	SOS

Bruce Hill	Appalachian Mountain Club

David Kelly	Navajo EPA

Dave McNeil	Utah DEQ

Rich Poirot	Vermont

S.T.Rao	New York ARB

Jay Rosenthal	Navy

Mark Scruggs	DOI

Manop Vanichchagorn	Louisiana DEQ

Jeffrey West	GPU Services Corp.

Non-Work Group Participants

Bob Wayland, SAIC; Cyril Durrenberger, TNRCC; Ken Schere, U.S. EPA/NERL; Ellen Baldridge, U.S. EPA/AQMG; Robin Dunkins and Charlene Spells, U.S. EPA/IPSG; Bill Johnson, David Sanders, and John Silvasi, U.S. EPA/OPSG.

Summary of Meeting

Harvey Jeffries opened the meeting by stating that he had an opportunity to attend MARAMA last Thursday. He indicated that he had gotten good feedback from the various State agencies, and had been involved with some good discussions. These discussions have adjusted our agendas for both Thursday's meeting and the February meeting. There have been two revisions to the AOI/AOV paper. There is a 1/22/97 version, which is called RAMP. As a result, Mr. Jeffries indicated that he had to generate more technical information lately than he had intended.

Tom Moore said that he was dizzied by the pace that is currently being set by the FACA process. I would like to divide today's presentation into three different pieces. It is clear that EPA staff and FACA understand the AOI/AOV concept to a certain extent. Now we need to flush out the concepts, and provide a menu of details and examples that the others can begin to embrace. As we develop the details, it is likely that we will create even more unknowns, which we will not be able to solve. Mr. Moore concluded that Harvey's summary of the NRWSG effort was in fact correct. There are a number of new papers that deal with these issues (e.g. institutional mechanisms, AOI/AOV, etc.). I think we need to respond to these new papers from a science standpoint. Additionally, a paper from BPAP, "AOV Boundaries", just appeared on the BBS today. It attempts to define a procedure for defining AOV boundaries and how you would use these in the planning process. The development of this issue is summarized in the following time line:

July 1996:	Designations Issues for the New NAAQS

September 1996:	How should AOI/AOVs be Defined?

December 1996:	An Update on AOV/AOI

January 1997:	Regional Air Management Partnerships (RAMP)

There will be Interstate transport and local issues. We need to:

(1)	Offer a menu of technical definitions about "what is an AOV" - how measured;

(2)	Construct a menu of technical options for defining an AOI - more regulatory than scientific;

(3)	Construct a menu of institutional mechanisms, that will define what needs to be done first. This will address the time lines that are currently being overlaid on top of this entire FACA process.

Mr. Moore stated that he would like to present essentially these three view graphs at Thursday's meeting, and then solicit comments from the group that is present.

Harvey Jeffries asked what is the situation with AOI, because Mr. Moore tended to address only AOV until the very end.

Tom Moore responded that he sees them both as being equally important; however, AOV is currently simpler to get our hands around, and thus we tend to talk more about it.

Harvey Jeffries stated that based on the MARAMA meeting, there is a group of people on NRSWG and/or BPAP who have side-stepped the AOV issue entirely. They do not envision a sequential process based on determining the AOV and then proceeding to define the subsequent AOI.

Tom Moore responded that this is a correct assessment. I have maintained this supposition throughout this entire process. If you can define AOI without really having a scientific process for doing so, then you are really changing the way EPA has been doing business for the past 25 years. If we are not establishing site-based compliance, then we are simply developing regional emission control strategies.

Steve Ziman noted that we do not have the data to support the level of guidance that EPA is requesting.

Diana Andrews asked what does it mean "that everyone wants something that is very prescriptive"?

Steve Ziman responded that the people in the regulatory community want a cookbook approach to compliance.

Harvey Jeffries commented that he had felt this frustration as well. In response to Tom Moore's persistence at these NRSWG and BPAP calls, we were starting to see a move back from what was appearing to be a very rigid, top-down structure. He concluded that there appeared to be a lot of flexibility in it after all.

John Silvasi mentioned that there will be a new set of Issue Papers going on the TTN tonight. He suggested that they be downloaded prior to coming to the meeting on Thursday.

Steve Ziman asked David if he could have copies of these papers waiting at the hotel for everyone tomorrow night.

David Sanders indicated that he would try to do this, but made no promises.

Harvey Jeffries stated that there is some reticence among the policy people regarding the AOI/AOV issue. We cannot allow ourselves to get caught in "past" thinking. We must concentrate on futuristic thinking.

Steve Ziman responded that we do not want a prescriptive lock in.

Harvey Jeffries stated that he did hear Sally Shaver and others at very high levels, state that they are willing to listen to any viable options. Thus, there have been discussions at high levels to allow for as much flexibility as possible.

Tom Moore said that he really wanted to stress that ultimately the policy decision must take a conservative approach. He stated that the more technical issues that we can brightly illuminate for this group, the more flexibility we will ultimately have. This is where the menu approach comes in - a simple list of pros and cons. The pros list could be quite small, with the cons list being extensive. We can only suggest; we cannot prescribe.

Cyril Durrenberger responded that it would be helpful to have at least some prescriptive elements; however, flexibility is also an useful tool. Looking at things from the past (e.g. use of photochemical models), gives us good guidance.

Diana Andrews said that we need to get away from things like the 15% Plan.

Steve Ziman noted that the policy people feel that without a hammer, they are helpless.

Harvey Jeffries interjected that we are getting off track here. How do we generate this menu of items that Tom has discussed today? Mr. Jeffries requested some help from the Work Group members to think about the AOI/AOV issue, and be ready to respond to these issues on Thursday. Mr. Jeffries indicated that he was not overly concerned with the planning process.

David Chock suggested that maybe someone from EPA could get us some maps to delineate these issues.

Harvey Jeffries asked David Chock and Steve Ziman to develop a list for what is needed to define the quantitative analyses necessary for determining AOI/AOV. Mr. Jeffries stated that our discussions not needed to turn more towards discussing Don Theiler's Institutional Mechanisms paper. He reminded STSWG members that these efforts should have been completed in November/December and thus, we were already a month late.

Tom Moore stated that the final rule needs to be written. The deadline is June 1997. So, the EPA must get going on this. This is all part of the Phase I implementation policy.

David Sanders noted that there also appears to be a bottom-line chicken-egg problem concerning AOI/AOV. Where do we start? It could be a push-me / pull-me problem as well. Which one do we start with, given that the AOV issue is a more linear process, and the AOI situation has a lot more problems?

Harvey Jeffries responded that his latest piece on the Conceptual Model refers somewhat to this problem. Mr. Jeffries stated that we need to move away from a site-based approach to AOI/AOV concept. However, Mr. Jeffries concluded that one of the institutional mechanisms that EPA has available to it is the State Implementation Plan (SIP). However, he responded that this does not mean that there are not other options. Rather, it simply means that whatever methodology is defined will be enforced by the SIP. He concluded by stating that obviously every State would like incoming air quality at such a level that would allow them to have some nominal level of emissions, without violating the standard.

Steve Ziman commented that this is covered in his paper about feasibility.

Harvey Jeffries responded that he knew that it was a feasibility issue. However, first we need to think through this issue in this manner, prior to determining whether it is/is not feasible.

Steve Ziman said that he would like for Harvey to stop for a moment, and think about inter-state transport as well as intra-state transport.

Tom Moore noted that the issue of state/tribal boundaries is a big issue, because there are a lot of large power plants located on tribal lands. Who is in charge of these? Legally it is the EPA. Thus, from a PM standpoint, jurisdiction over these is a big issue.

Harvey Jeffries responded that this is the type of information he needed. He confessed that he did not have his hands firmly around the PM issue. He said that he has focused for the most part on ozone. What is the sensitivity of local controls to degradation in remote regions? Mr. Jeffries reminded the Work Group that we had previously identified some people to look at the necessary analyses for AOI/AOV. Mr. Jeffries concluded by stating that he was most concerned about AOV; and, more comfortable with AOI.

John Silvasi interjected that looking at the agenda, there is not a whole lot of time for free-ranging discussions. The schedule is very tight, and thus STSWG must have focused points, and be organized in their delivery. The concepts must be relayed in the form of the discussion.

Harvey Jeffries responded that if we do not have a chance to respond to Don Theiler's comments between 9:50 and 10:30 on Thursday, STSWG should literally rebel. Mr. Jeffries indicated that STSWG was going to take some time in the 11:00 - 12:15 slot to make our points.

John Silvasi said that he thought that this would be fair.

Steve Ziman agreed with Harvey, and noted that if they are not willing to give us the opportunity to speak, then why are we even here?

David Chock stated that he would be at the hotel around 5:00 p.m. on Wednesday afternoon if anyone is interested in discussing these issues.

Diana Andrews noted that there is a Monitoring Incentives meeting from 6:00 PM - 8:00 PM, so why not do it first thing in the morning on Thursday?

Harvey Jeffries responded that we should just try and get together on Thursday morning prior to the 9:00 AM meeting start.

Ellen Balldridge noted that there are two EPA people assigned to every issue paper. She suggested that STSWG members should send a courtesy copy of any Issue Papers to these two people. Ms. Baldridge indicated that this procedure should make the distribution of ideas complete.

Robin Dunkins responded that you need to send the comments to the lead of each Work Group, and then it will be their responsibility to disseminate the information.

Harvey Jeffries commented that he wanted to discuss the 12/20/96 Issue Paper - Ziman, et al. "Is the 8-hour Standard Attainable?" and asked if the document had been used for informational uses only.

David Sanders responded that it is on the TTN for people to look at; but other Work Groups may want their people to take a look at this issue. This is not on the agenda for this Thursday. The purpose of this discussion is to finalize the papers for the February FACA meeting.

Tom Moore stated to Harvey that he objected to the overall process. This should go directly to the Coordination Committee. It simply does not need to go through all of these other Work Groups, prior to getting to the Coordination Committee.

David Sanders said that he would talk with Tom Helms about this.

Tom Moore said that he thought the RFP paper dealt with the attainability issue.

Harvey Jeffries asked if David Chock and/or David Sanders could contact Sarah Peirce- Sandner prior to her presentation on Thursday, and allow her to read this issue paper?

John Silvasi said that he would call Sarah and let her know about the issue paper.

Tom Moore commented regarding the "AOV Boundaries" paper. It contains attachments from EPA Staff (e.g. Tom Pace, Ned Meyer, Joe Tikvart and David Mobley). I found this interesting because these tools have not been presented to us, at least not in the same method that they are presented here.

Ellen Balldridge responded that she was responsible for this. Ms. Baldridge indicated that she was simply trying to "refresh" the memories of the BPAP Work Group on what was available and what had been used in the past. She concluded that his material would eventually get to the STSWG for review.

Harvey Jeffries responded that Ms. Baldridge should have asked the STSWG to review this information prior to putting it on a "blessed" list without having our review.

Robin Dunkins said that she actually put this list together for Ms. Baldridge. Ms. Dunkins stated that the information was compiled in August 1996. She concluded that the information was only intended to summarize things on the OAQPS list over the next several years. It was not supposed to be an end all discussion.

Steve Ziman commented that tools are wonderful and that tools are great. However, he continued, if you do not have good data you get garbage in and garbage out. Mr. Ziman referenced the OTAG process as an example, and alluded to the mess this effort has generated. Mr. Ziman concluded that we cannot continue to mislead the American public with bogus science.

Harvey Jeffries asked if the list of information reflected both OAQPS and ORD efforts currently underway.

Robin Dunkins said "yes." Ms. Dunkins indicated that the list reflected ORD's thinking on August 20, 1996. She concluded by saying that the list is not currently accurate based on what we know today with respect to MODELS-3.

Conceptual Model

Harvey Jeffries indicated that we need a "cartoon" from someone in this group, which will adequately describe the range of meteorological processes. He also stated that we needed some graphics to accompany the text provided by Glenn Cass.

David Sanders noted that we would see everyone on Thursday and Friday at the meetings at the Durham Omni Hotel.

Harvey Jeffries responded that we will need a lot of time on Friday for the Conceptual Model. Mr. Jeffries also questioned the progress on the attendees list for the February meeting. Mr. Jeffries encouraged the attendance of Robin Dennis and/or Gale Thommason. Mr. Jeffries asked Ken Schere if he would be attending?

Ken Schere stated that he was not sure.

Dan Weiss said that he had source apportionment information from UAM-X for both ozone and PM and would be happy to share this information with the Group.

David Sanders adjourned the call.