Draft Summary of the Federal Advisory Committee Act (FACA)

Joint Meeting of the National and Regional Strategies Work Group,

Base Programs Analyses and Policies Work Group and the

Science and Technical Support Work Group

Omni Hotel

January 30, 1997

Durham, North Carolina

The National and Regional Strategies Work Group, the Base Programs Analyses and Policies Work Group and the Science and Technical Work Group (STSWG) of the FACA Subcommittee met in a joint meeting on Thursday, January 30, 1997 in Durham, North Carolina. A list of the participants and a summary of the meeting follows.

STSWG Work Group Participants

Name	Affiliation

Tom Helms, Co-Chair	U.S. EPA

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

Diana Andrews	Kentucky DEP

John Cabaniss	AIAM

Glenn Cass	Cal Tech

Kirit Chaudhari	Virginia DEQ

David Chock	Ford Motor Company

Cyril Durrenberger	Texas Natural Resource Conservation Commission

Tom Moore,	Arizona

S.T. Rao	New York DEQ

Mark Scruggs	DOI

Dan Weiss	Cinergy Corporation

Steve Ziman	Chevron Corporation

STSWG Work Group Members Not Participating

John Core	WESTAR

Ellis Cowling	SOS

Bruce Hill	Appalachian Mountain Club

Jay Hudson	Santee Cooper

David Kelly	Navajo EPA

Dave McNeil	Utah DEQ

Rich Poirot	Vermont

Jay Rosenthal	Navy

Jay Turner	DOT

Manop Vanichchagorn	Louisiana DEQ

Jeffrey West	GPU Services Corp.

NRSWG Work Group Participants

David Mobley, Co-Chair	U.S. EPA

Don Theiler, Co-Chair	Wisconsin

Joe Belanger	Connecticut

Nina Dougherty	Sierra Club

John Heuss	General Motors Corporation

Dewayne Huckabay	City of Houston

Dan Johnson	Washington

Donna Lamb	USDA/Forest Service

John Leary	Western Governor's Association

Marvin Lowry	Georgia

Ted Russell	Georgia Institute of Technology

Terry Rowles	Missouri

Sarah Peirce-Sandner	Kodak

Chris Shaver	Environmental Defense Fund

NRSWG Work Group Members Not Participating

Andrew Aitken	New England Power Service Company

Mark Brownstein	Public Service Electric and Gas Company

Timothy Byrd	Gallo Winery

Bruce Craig	NGSA

Cliff Doumas	Mobil Corporation

Larry Feldcamp	Baker and Botts

Joe Francis	Nebraska

Mike Frost	S. Ute Tribe

Stan Hathcock	Webster South

David Hyder	North Carolina DOT

Amy Lilly	AIAM

Timothy Method	Indiana

John McManus	American Electric Power Company

William Miller	Philadelphia

Rusty Russell	Conservation Law Foundation

Lydia Salmon	Kenecott Copper Company

Ted Wernick	Gillette Company

Tom Wright	AAMVA

Bob Wyman	Latham and Watkins

BPAP Work Group Participants

Joe Paisie, Co-Chair	U.S. EPA

Jerry Golden, Co-Chair	TVA

Bob Palzer	Sierra Club

Vincent Brisini	Pennsylvania Electric

John Crouch	Hearth Products Association

Richard Chastain	Southern Company Services

Richard Dworek	U.S. Steel

Steve Gerritson	LADCO

Rich Halvey	Western Governor's Association

Dennis Lawler	Illinois EPA

Brock Nicholson	North Carolina DEM

Steve Pezda	Ford Motor Company

Richard Phelps	Eastman Chemical Company

Jim Salvaggio	Pennsylvania

Dick Shoeneberg	Department of Transportation

Eric Skelton	Spokane County

Jean Vernet	Department of Energy

Herb Williams	Texas Natural Resource Conservation Commission

Mel Zeldin	South Coast AQMD, California

BPAP Work Group Members Not Participating

Gregory Dana	AIAM

Jeff Gabriel	National Pork Producers

Robert Kappleman	Jacksonville Electric Authority

Arthur Lee	Texaco Corporation

Jim Ralston	New York

Conrad Schneider	Natural Resource Council of Maine

Non-Work Group Participants

David Baron; Bob Wayland, SAIC; David Sanders, U.S. EPA/OPSG; Bruce Polkowsky, U.S. EPA/VEPG; Bill Hamilton, U.S. EPA/PRG; Robin Dunkins, U.S. EPA/IPSG.

Summary of the Meeting

Introduction

Bill Hamilton welcomed the participants and reminded everyone to prepare for the February Subcommittee Meeting. He emphasized the need to stay on schedule and that the time slots would be strictly adhered to. He then went on to say that this is the most important thing that EPA has done in the past 25 years. We will not see another project of this magnitude in our tenures at EPA. This is a major revision of two NAAQS and the Regional Haze Rule. These regulations will have long- term, long-lasting impacts on the air quality for the American people. We have made tremendous progress in recent months, and have a good deal of work to do in Phase II. Thus, each of you should be proud of what you have done and what you will be asked to do.

Discussion of the Phase II Implementation Plan

Bill Hamilton stated that we are trying to outline the things that need to be completed in Phase II. There are approximately 44 individual tasks that need to be addressed. Thus, since we have five meetings remaining, this means that, on average, nine issue papers must be discussed and finished at each FACA meeting.

John Heuss noted that there is a list (on page 3) with a deliverable date of April 1997 for a Regulatory Impact Analysis (RIA). Bill Hamilton responded that when EPA proposes major regulations or strategies, the Agency is required to prepare an RIA. He said that they are part of the Phase I and Phase II effort that he has been tracking, and that he was responsible for them. They do not have to be reviewed by the Subcommittee. John Heuss stated that it would be very informative for EPA to walk through what they have done on the previous RIAs. Bill Hamilton responded that this will be done at the February meeting in the evening. The National Ambient Air Quality Standards (NAAQS) RIA will be discussed, and will be linked to the particulate matter (PM) and ozone RIAs.

Now, Mr. Hamilton asked if the group could focus on the Phase II Management Plan once again:

Section 5: Outlines the system or liaison for EPA and the Work Groups. There are a lot of blanks; but, EPA is working on it. We hope to have it completed by the February FACA meeting.

Section 6: Is a summary for the Subcommittee of the critical implementation issues. EPA intends to identify all of the major issues and list the issue resolution and action items. EPA needs to try and direct the Subcommittee to answer the questions that need to be answered in order to develop a Phase II implementation plan.

Page 14: Schedule for the FY97 FACA Meetings. Eight issue papers are listed for the February meeting (the agenda has not been finalized; this is a tentative list).

Section 8: Current schedule of face-to-face Work Group Meetings (i.e. essentially monthly meetings).

Page 16: NAAQS Implementation Meetings Schedule (meetings to inform the public).

Attachment A1: FACA time line.

Attachment A2: Presents the relationships between the various air quality Management Issues, which was first presented by Joe Paisie in November.

Attachment A3: Describes the Issue Paper Principle Development Process. It is a two-step process (once for discussion; once for closure).

Mel Zeldin noted that the Phase I proposal is due in June 1997 and that the final is due in June 1998. He then asked if EPA involves FACA in the review process, or is it entirely in EPA's hands at that time?

Bill Hamilton responded that it would be totally in EPA's hands at that point.

Joe Paisie commented that this is something we want to play be ear. Mr. Paisie indicated that he had heard Sally Shaver musing about this question; however, at this time, no direction has been made at the management level.

Steve Pezda noted that the Base Program Analysis and Policies (BPAP) Work Group Issue Paper on "Too Close to Call" was recommended by EPA in one of the Staff Papers and by CASAC; however, it did not show up in either the Ozone or the PM proposals.

Bill Hamilton asked if either Joe Paisie or David Mobley had a response.

Joe Paisie responded that he had asked the Coordination Committee to act on this, but they have not to date. It most likely will get rolled into one of the other papers. Mr. Paisie indicated that he just did not see it being treated as a separate issue.

Donna Lamb noted that on page 2, regarding the nature of regulator efforts, there is no date for the Regional Haze Rule.

Bill Hamilton acknowledged that absence and made a note of it.

John Heuss inquired regarding a secondary ozone standard . Is there any FACA involvement on this?

Bill Hamilton said "no" and that the NAAQS setting is separate from the implementation.

Joe Paisie added that the general approach that is taken, is that we don't have to distinguish between the primary and secondary standards for implementation.

John Heuss inquired as to whether or not we can ask the individual Issue Papers to address the concept of the secondary standard.

David Mobley interjected that the National and Regional Strategies Work Group (NRSWG) has asked their authors to address the secondary standard issues as the Issue Papers are being prepared. However, the focus is clearly on the primary standard. Also, Mr. Mobley indicated that it was his understanding that the Haze Rule was in the Phase I proposal, and thus, it would not be necessary to have a separate date/schedule.

Bruce Polkowsky responded that "yes," the basic structure is included in the Phase I plan.

Bill Hamilton responded that it would be made explicit, and better defined in the next version of the Management Plan.

Dennis Lawler stated that the PM Monitoring Rule is also missing.

Vince Brisini said that since we will assist in developing the Issue Papers, it would be a lot easier if we could take the Issue Papers on the Web Site and separate them into three groups: (1) Final versions; (2) Current versions under construction; and, (3) Old drafts. Mr. Brisini indicated that this would make it easier to work with. Under Area of Influence (AOI) control regions, you need a separate Science and Technical Support Work Group (STSWG) paper. Simply making a decision on some NRSWG measure is not appropriate. This is a technical, scientific issue. Thus, you either need to incorporate the science into this paper, or have a separate science paper on this issue.

Bill Hamilton responded that we have a inter-group liaison system to accommodate this process. Mr. Hamilton questioned if this was sufficient, or do we really need a separate science paper on these issues?

Vince Brisini answered that if you have additional planning areas that you are not calling an AOI, then yes, you do need a separate paper.

Harvey Jeffries interjected that Tom Moore is the liaison with this group. We have, as a Work Group, produced a separate document on the STSWG TTN site. We are still in the process of revising this paper. Also, STSWG is still not entirely satisfied with our involvement on this issue, and we will raise these points in the course of discussions today.

Vince Brisini stated that, as he saw it, these are the tools that will be used to identify control regions. Thus, he would advocate that these papers be labeled as NRSWG/STSWG.

Bill Hamilton noted that they are not listed as liaisons in Section 4, but that they are listed in Section 5 of the Phase II Management Plan.

David Mobley said that there is a pointer in the current NRSWG paper to the STSWG piece mentioned by Harvey Jeffries. Mr. Mobley then presented a preview of the AOI Issue Paper. In this discussion, Mr. Mobley stated that in order to clarify the AOI Issue NRSWG decided to get a straw man draft of their paper out for everyone to review and comment on. He said that the group thinks that they have been successful in accomplishing these goals. However, he went on to say that the Work Group knows that the paper is not perfect; but, concluded by stating the group has done a reasonably good job of getting the basic information before the other Work Groups. Mr. Mobley also indicated that it was important to have this joint meeting of the three Work Groups. He charged the group to consider that If we cannot make consensus today, let us at least have the opportunity to air our differences, and agree on a strategy to reach consensus going into the February FACA meeting in Washington, DC. Mr. Mobley stated that February 13th is the target date for having all revisions posted on the TTN for the February 20th Subcommittee meeting. So,	he would like to propose that Don Theiler present the issues on the AOI paper, followed by	Chris Shaver's presentation of the Institutional Mechanisms. Thus, once all of this	information is on the table, the joint group can then begin the discussions. Following the presentation of the material and the open group discussions, Jerry Golden and Harvey Jeffries will have the opportunity to present the BPAP and STSWG side of the story.

Area of Influence (AOI) Issue Paper - Don Theiler

Don Theiler began by stating that EPA staff had prepared a good deal of the material he was about to present. He stated that a potential straw man includes the following three components: (1) Planning Domains; (2) AOIs; and, (3) Control Regions. Mr. Theiler asked how do we identify the planning domain? There will be large groups of states who must come together to form planning regions. He reminded that group that a planning region does not imply a control region and that the planning process is simply to ascertain culpability.

A planning domain is a state, or group of states, which would convene to identify the boundaries of the AOIs and the States and Tribes who would be involved in developing the Regional Implementation Plan (RIP). There are numerous options for the number and size of the domains (from 2 - 9). However, everyone involved in the FACA process has taken their own personal definition of the planning domain. Thus, these subdomains are taking on a much larger role than that which was originally envisioned. One possibility of a subdomain would be to divide the nation into two halves, somewhere around the 100th meridian. However, no one could determine where to draw this line. Texas was particularly vocal with regard to the feasibility of this "line drawing" technique.

Secondly, we did a regional approach, where there were no lines drawn. When you draw lines, people get very offensive. Thus, we have two options: one is provided by EPA staff, and one is provided by the State of Texas. EPA staff has devised a nine-component regional approach (NW, Northern CA, Southern CA, SW, Rocky Mt. North Plains, Mid West, SE, NE, and Gulf Southern Plains). Northern and Southern California, Kentucky and West Virginia are considered players in multiple regional domains.

The Texas approach has eight subdomains with no states participating in more than one regional domain. However, I personally have problems with this approach because of the relationship of the Twin Cities to Wisconsin, and the placement of Iowa. On this latter issue, I have been very vocal in the OTAG process.

Thus, in order to smooth feathers, we have gone to the following options:

(1)	Eliminate Regional Air Management Partnerships (RAMPs) and go directly to identification of AOIs by a predefined process;

(2)	Divide the U.S. into two RAMP's (east-west) somewhere along the 100th meridian;

(3)	Divide the U.S. into three or more RAMPs (similar to the nine-option method previously presented); and/or,

(4)	Provide for the voluntary development of RAMPs. Under this process, these RAMPs should establish a process to reach consensus on the identification of AOIs for the AOVs and Class I Areas within their boundaries. No state would be forced to participate in a RAMP. However, a state may choose to participate in one or more RAMPs. The bottom line for this process is that the procedure for establishing AOIs must ensure that an adequate area is defined, and that the process is timely and efficient.

Anytime you draw lines, you must remember that these lines are not barriers. They are not physical barriers (i.e., walls) that prevent the pollution from moving into/out of an area. With respect to Texas, the maps were presented as an option only to the 100th meridian approach. It was also meant to take advantage of the existing EPA Regional Office structure.

Brief Discussion on AOI Issue Paper

David Mobley commented that he was the "EPA Staff" responsible for that map and that the majority of the EPA Staff would claim no knowledge of it. He stated that the maps was generated to simply stimulate discussion. Thus, do not interpret these lines as "written in stone".

Bill Hamilton interjected as to whether or not David Baron could be tied in at this time via phone.

Robin Dunkins responded that we can try.

Steve Gerritson asked Don Theiler if he was still looking for options.

Don Theiler responded "yes!"

Institutional Mechanisms Paper - Chris Shaver

Chris Shaver began by stating that everything we have prepared is based on the principles outlined on the TTN. We are dealing with two large regional domains (e.g. the 100th meridian approach). Thus, if we move away from this, the paper would obviously have to change. Again, we assumed that the States and Tribes would be responsible for determining how they would individually handle their respective pollution problems. The third assumption is that EPA will remain "the hammer" in this process in the event that individual states or groups of states fail to act accordingly.

"How do we do it" is the focus of the Institutional Mechanisms paper.

First, under what authority can we implement these groups if they choose not to do it voluntarily? Basically, we have two options: Use the vintage 1970 authority for Air Quality Control Region (AQCR), or the 1990 Transport Commission language. However, this latter approach is more restrictive and difficult to implement. Second, individual States and Tribes will have the implementation authority. The Regional Institutions (e.g., RAMPs) will not have the authority to impose regulations on member states and tribes, nor will they have enforcement authority. However, the Regional Institutions will perform functions necessary for the development of regulations (e.g., designing control strategies, ensuring a consistent adequate technical foundation for regional plans, and preparing "model" regulations). EPA will also be involved in this process to work with the States and Tribes. Third, EPA will be the fall-back hammer authority in this process. The planning regions will be charged with delineating AOIs, and in consultation with member States/Tribes and EPA, identifying AOVs. Thus, the planning regions should have a very significant role in this process. The role does not depend on the size of the planning region and thus, the role should not be affected. However, air pollution issues should be addressed on the smallest scale possible. Thus, a good deal of technical work will be done by these planning regions. The role of the Regional Institution in regional emission trading programs will also be important. There is a need for consistency among these regional groups in order to bring about an effective regional emissions trading program.

Our proposed recommendation would involve the Regional Institution in the emissions trading program, with some oversight from a more technical group or private entity. I would like to know if we have missed anything in developing this Issue Paper. I think that this will be the last run of this paper.

Brief Discussion of Institutional Mechanisms Paper

Jerry Golden stated that since the most recent revisions, BPAP has not had a meeting to discuss this paper. Mr. Golden indicated that BPAP still has difficulties with the nomenclature issue. In stated that BPAP has a basic problem with saying that the AOI is different from the control region; however, he concluded that he thought BPAP was still onboard with the overall concept.

Harvey Jeffries (showing a slide of the Air Quality Conceptual Model) commented that the group was over-simplifying the world here. Mr. Jeffries stated that we have data, and we have tools that can actually address these issues quantitatively. He concluded that he had not heard anything in Chris Shaver's paper that would cause STSWG to disagree. Mr. Jeffries asked the group to consider the following concept - the concept of the "Quality of Explanation" which he broke down into four components: (1) Compelling - admits no other explanation; (2) Preponderant - one explanation has more support than others (others also possible); (3) Permissive; and, (4) Missing.

Mr. Jeffries said that you must struggle to move-up this list, where compelling information drives the solution of your issue or problem. Exactly who should sit down at the table to plan can be determined by science and data analysis. What you do after you sit down is the political side of this problem. However, science can tell you precisely who needs to sit down at the table and start the discussion. Drawing arbitrary lines is causing us grief in STSWG, when we have the tools and the data to do these things quantitatively.

Area of Influence (AOI) / Area of Violation (AOV) Technical Issues - Tom Moore

Tom Moore outlined the AOI and AOV Technical Issues:

AOV/AOI Concept

-	Subcommittee open to ideas

-	What does it mean?

-	For controls

-	For public health/welfare

-	For NAAQS compliance and progress toward National Visibility Goal

-	A lot of good brainstorming has occurred to date; with some good suggestions arising

-	How would this apply (e.g., jurisdictions)?

AOV Concept

-	Increases flexibility for AIR QUALITY planning

-	"Area" of Unacceptable AIR QUALITY

-	What does this mean for technical analyses?

-	Public exposure notification/identification

-	Appropriate controls relative to local contributions

-	Site-based compliance

AOI Concept

-	Encourage/mandate/define the participants

-	Perform analyses to refine list/areas of contributing sources

-	Define region(s) with contributing sources to receive control analyses

-	What does this mean for technical analyses?

AOI Technical Analysis

-	New Levels of Effort in:

-	Monitoring data analysis

-	Gridded emission inventories

-	Modeling analyses/validation/reconciliation

- Analyses of:

-	Violation replication

-	Control options (iterative)

-	Documentation of attainment

-	Maintenance of NAAQS

STSWG Support of the AOI/AOV Process

-	Pros and Cons of:

-	AOV Technical Definition Criteria

-	AOI Technical Definition Criteria

-	Suggest necessary tools and time line for availability

Discussion of AOI/AOV Technical Issues

David Mobley interjected that NRSWG did discuss time lines in conjunction with respect to the five papers. One is the time line that assumes that each program (ozone, PM and Regional Haze) will progress at its own pace. The other is assuming that there is some degree of harmonization of programs.

*** The meeting was adjourned for a 15-minute coffee break ***

Don Theiler identified various options in the paper:

(1)	Eliminate subdomain - establish a process for AOI identification;

(2)	Divide into two planning regions;

(3)	Divide into > 2 but < 9 planning regions; and/or,

(4)	Voluntary participation

There was some discussion surrounding whether the RAMP was equivalent or not equivalent to the AOI. However, no consensus was reached on this issue.

Harvey Jeffries commented that it seemed to him that the group had the process backwards; let science determine who is in the AOI, not policy.

Don Theiler asked who operates the machine that determines the AOIs?

Harvey Jeffries suggested that EPA do this nationally.

Don Theiler said "Okay!" Let me divide this into two pieces:

(1)	EPA takes the science and operates the machine to determine the AOI; and,

(2)	States take the science and operate the machine.

Sarah Peirce-Sandner responded that this is one of the most significant issues. Ms. Sandner stated that she was still confused about the options related to AOI and AOV. In each of the four options above, there are recurring themes: (1) Is there a planning region involved, and what is its function?; (2) What is the process that is going to be used for determining the AOI/AOV boundaries?; (3) What will we do for states that refuse to participate, when there is a preponderance of evidence that they belong to the problem but not compelling evidence for this situation? She stated that this is really an organizational issue, not a technical issue.

Joe Belanger said that states would have information based on what EPA had already "cranked-out". Then, the responsible states would be invited to participate.

Mel Zeldin commented that he liked what Harvey Jeffries initially suggested. Mr. Zeldin stated that he thought it was good to get EPA to do the initial "table call"; but, then allow the members at the table to do additional refinements and either increase or decrease the size of the planning region.

Texas commented that they prefer Option 3.

Dan Johnson asked what was the function of the RAMPs or subdomains?

Steve Gerritson stated that the LADCO/OTC/OTAG experience all strongly suggest that drawing lines immediately causes people to point outside the lines. Mr. Gerritson suggested that the group establish a process to determine AOI, without drawing lines and figuring out how to adjust them.

Vince Brisini interjected that a lot of the problem that comes from the drawing of arbitrary lines is the political versus scientific delineation of the subdomains. He stated that you have an iterative process of how you get to the desired results. First, you need to establish a rather large AQCR, and the purpose of that group is to determine how consistent the approach needs to be to improve air quality in this region.

Ted Russell stated that there is a lot of merit in not dividing the nation into regions. He concluded that there are models are available to analyze the feasibility of such an approach.

Don Theiler asked if this is the case for both ozone and PM?

Ted Russell responded that it definitely is the case for ozone, and is should be the case for PM in the near future.

Dick Dworek stated that West Virginia and Ohio should definitely be included in the Midwest or northeastern planning regions. He reiterated that you must have good up-front science for whatever you do.

Brock Nicholson commented that the concept of a RAMP of some dimension is necessary - the one size fits all criteria is not practical. Thus, Mr. Nicholson suggested that either Option 2 or 3 is preferred and may allow for even more refined development of AOIs. He said that voluntary participation is going to happen regardless, mentioning the OTAG process as a good example. He concluded that States want to participate in these adventures to protect themselves.

Don Theiler stated that the definition of the AOI is all sources within the region which are contributing to the monitored violation. Thus, the AOI must encompass all sources.

John Leary said that the Grand Canyon Visibility Transport Commission (GCVTC) used good science to come to their "AOI" definitions. Mr. Leary questioned why can we not follow similar patterns in the east to accomplish our goals?

John Cabaniss commented that he agreed with Harvey Jeffries and others that we should use data as opposed to arbitrary lines. However, there does need to be a limit to the number of AOIs. Also, we need to look at the distinction between AOIs for one pollutant versus AOIs for other pollutants. Thus, while science makes good sense, it in itself, is not perfect.

Steve Ziman asked how do we make this thing work? If you identify the AOI, you are building a mechanism that can work provided that all the stakeholders are at the table. It is very powerful if everyone is at the table from the beginning of the process. Mr. Ziman stated that you tend to have very few people leaving the table if they are included from the outset.

Dan Johnson said that he agreed that RAMPs are a good idea. Mr. Johnson also stated that he believed that there are some states that will and could work together, without EPA telling them how to do things. Thus, Mr. Johnson proposed a setup that would allow for 3-4 RAMPs in the east and one in the west (similar to what has been proposed for the west by the GCVTC). However, he cautioned the group not to worry about whether an individual state belongs in the west or the east. He stressed allowing the individual states to make these decisions for themselves, remembering that it is obvious that the east and west are different.

Joe Belanger responded that if science could provide the single prescription, and it was a cure all, then science would be great. However, this is not the case. The RAMP should be designed to allow the states to participate in the region where they can have the biggest impact on air quality improvement. If Ohio is most important to one area, then perhaps these controls would more than likely to clean-up their potential problems in any other areas.

David Mobley said that he took objection to the concept of arbitrary lines being drawn. Mr. Mobley indicated that EPA is not operating in the vacuum that some of the Work Group members are implying. He said that there is a good deal of information from NRSWG and STSWG to support the lines which were discussed earlier. For example, the emissions density maps will strongly support the 100th meridian concept. Finally, there is a lot of merit in developing a process. However, Mr.

Mobley cautioned the group to not develop a process simply to avoid the hard decision of designing AOIs.

Jerry Golden stated that he liked the idea of using a process to determine the AOVs, followed by the AOIs and the development of RAMPs. These regions should be process-defined, not any geo- political boundary. Secondly, what should be EPA's role in this whole process? Mr. Golden indicated a basic problem with the concept that AOI involvement means "the potential contribution to an AOV". He stated that we need EPA to help determine some prerequisites for participation in this whole process. Mr. golden concluded that once this is done, then the existing institutional mechanisms are in place to handle it.

Harvey Jeffries noted that if a state could solve its air pollution problems internally, then it should, by all means, do that. Secondly, regarding these arbitrary lines, the earth turns and causes certain forms of climatological patterns to develop. While we can say scientifically that any set of terms is a best fit, it is not written in stone. In any given year, something different could occur. Thus, Mr. Jeffries concluded stating, that if you do not take into account how the earth works, you are doomed to failure.

Donna Lamb stated that there is some value in the concept of a RAMP. Ms. Lamb continued saying that as we integrate ozone, PM, and RH that there is an element of looking at all three of these that is enhanced by the RAMP concept.

Don Theiler said that we should focus on the role of identifying AOIs.

Donna Lamb responded that there is an important function here: whether you use integration as the means of drawing the lines, or whether you draw the lines, and then use integration to evaluate the results.

Harvey Jeffries stated that you must have cooperation between states for monitor placement, model calibration, etc. Mr. Jeffries said that this process almost begs the perfect RAMP that defines the perfect AOI. He encouraged the group to focus on RAMPs that handle most of the situations. In conclusion, He stated that with regard to voluntary participation, you must have some mechanism to force states come to the table (i.e., to protect their own interests) and you need to have a mechanism to keep people at the table when things become uncomfortable.

Don Theiler stated that voluntary was meant to be truly that - you choose to participate. The alternative, a non-voluntary participant, means that you will be planned for regardless of whether or not you choose to participate.

Dennis Lawler said that we have talked a lot about drawing lines. The world is a continuum, but we do need to break it into parts from time to time. Mr. Lawler stated that we should start drawing lines today, using the best science; however, do not go into this blindly thinking that you can

accomplish the ultimate goal without first drawing some lines. If the states do this, they will have to be extremely broad. Thus, perhaps Option 1 is not as appealing as Option 2. States would also have problems with their governors identifying "guilty" parties in adjacent states.

Don Theiler stated that the corollary to this is that if the governor does not identify the "guilty" parties, then he may get blamed for it totally.

Glenn Cass added that the issue is somewhat asymmetric and we should not lose focus of this thought. If you mis-draw your lines, then you could be eliminating cross-boundary transport. Thus, especially in the east, I would support Harvey Jeffries' and Ted Russell's concept of using some sort of continental-scale modeling analyses to determine the divisions in the eastern U.S.

*** The meting was adjourned for 1-hour for Lunch ***

David Mobley gave a summary of the Morning Session with the following points:

(1)	There should be a strong science underpinning for whatever approach we take.

(2)	Science has to be involved in developing the process to define the RAMP and the AOI.

(3)	EPA must take a role in stimulating the development of this process.

(4)	There is merit to having, as a minimum, an eastern and western region.

(5)	Starting large and going small is better than the reverse procedure.

(6)	Time constraints are important in getting from A to Z.

(7)	There is not a strong distinction between RAMPs and AOIs. Thus, perhaps we should begin to think of these as one institution.

(8)	Ozone, PM and RH each have their peculiarities. Thus, a one size fits all approach is not feasible.

Don Theiler commented that it appears that the 12 western states believe that they have a functional RAMP for at least handling visibility issues (i.e. the GCVTC). Thus, we will need to attempt to work this out for the eastern United States.

Reasonable Further Progress Paper - Sarah Peirce-Sandner

Sarah Peirce-Sandner presented this paper and noted that it was still in its infancy. The paper did not begin until January 9th. Thus, she defined success for today as having a lively discussion and receiving input from anybody and everybody.

Objective:

-	Update Work Groups on status of paper

-	Review of skeleton issues

Solicit Input

-	Are all the key issues identified?

-	For the issues that have options listed, has the full spectrum of options been	identified?

Next Step: More fully develop pros/cons of each option

RFP Overview

-	RFP History

-	Pre-1990 CAAA

-	Post-1990 CAAA

-	RFP Future

-	The goal

-	Two interim issues to be dealt with

-	Implementation

Pre-1990 CAAA

-	Section 171

-	Section 172©

Post-1990 CAAA (did not really change a great deal)

-	Ozone moderate and higher class

-	90-96: 15% VOC reductions

-	1996 attainment date: 3% per year VOC reduction averaged over a 3-year period

-	PM-10

-	Quantitative emission reduction milestones to be achieved every 3 years

Issue #1: What should the goal be for RFP?

Option 1:	Annual incremental reductions in emissions of the relevant air pollutant(s) as are required by regulations or may reasonably be required by the Administrator for the purpose of ensuring attainment of the applicable NAAQS by the applicable date (CAAA definition).

Option 2:	Ensure measurable, periodic progress towards attaining the NAAQS by the applicable attainment date.

Issue #2: What should RFP be in the interim implementation period?

Interim Issue #1:	For areas that go from attainment of old NAAQS to nonattainment of the new NAAQS, what should RFP requirements be until the new SIP is approved?

-	Same as Interim Implementation Program (IIP) proposal

-	IIP proposal plus "additional measures"

(a)	Emissions inventory

(b)	(a) plus action to prevent emissions growth

©	(b) plus promote "voluntary" reductions measures

(d)	(a) plus mandated mandatory emission reductions

Interim Issue #2:	What should "alleged" or potential AOIs have to do in the interim period?

-	Maintain the current measures until AOI is officially
designated as an AOI

-	Impose RFP requirements in the inventory program, as outlined in (a) - (d) above.

Chris Shaver asked what is the legal authority to implement this issue, if an area is not designated as an AOI?

Sarah Peirce-Sandner responded that she would get to this in the pros/cons discussion. She then continued with the presentation.

How should RFP be defined (post interim period)?

-	(a) Reduction in precursor (ozone) or precursor/direct emissions (PM-fine)

-	(b) Same as (a) but with different weights assigned to an emission reduction based on its efficacy (e.g. VOC reactivity, location of reduction relative to impact, etc.)

-	Combination of (a) and (b)

-	Reduction in NAAQS pollutant concentration

-	Reduction in NAAQS pollutant concentration weighted for population exposure

-	Reduction in NAAQS pollutant concentration relative to emissions reductions

How should RFP be measured? (It depends on the definition.)

-	Inventory alone (e.g., simple emissions reductions)

-	Monitoring (e.g., NAAQS concentration reductions)

-	Modeling (e.g., human exposure)

-	Etc.

How frequently should RFP be demonstrated and by whom?

-	Frequency: dependent in part of "measure"

-	Annually

-	Every 2-3 years

-	Dependent on control program implementation

-	Who is responsible for this demonstration?

And, Yet To Come ...

-	Does RFP include mandatory measures?

-	Can RFP go outside Title I for reductions (e.g. Title IV, Title III)?

-	For end-loaded control strategies, can the emission reduction be applied earlier in the RFP process? If so, how?

-	How do voluntary control measures fit into RFP?

-	Should RFP for ozone and PM-fine be integrated? If so, how?

-	Should RFP for ozone and PM-fine be integrated with regional haze? If so, how?

-	Attainment feasibility - when does RFP stop?

Discussion of Reasonable Further Progress Paper

Harvey Jeffries commented that STSWG has a paper that deals with attainability; but, I think it approaches RFP as the measure of attainability. From the STSWG perspective, RFP supplants the attainment date issue.

Joe Paisie noted that we are going to have specified attainment dates. This was decided in Denver.

Joe Belanger commented that he thought of RFP as progress on the standard and not the emissions. However, there has been no discussion on the progress as related to the investment.

Dan Weiss inquired that you mean that just because you were in an AOI you should not be required to do any emissions reductions?

Sarah Peirce-Sandner responded that is correct. That was a little bit misleading. If you point to an AOI before it is officially established, you are extremely vulnerable.

Jim Salvaggio commented that framing the options that the IIP is basically a "do nothing" option is not valid and he did not agree with this concept. Mr. Salvaggio stated that there is a great deal of good that will come during this IIP period. Thus, there will be some progress under this option. He stated that perhaps some re-wording needs to be done to that particular option. Secondly, in terms of looking at RFP, he indicated that we have to be careful how we structure this. He cautioned that we have to link these discussions to discussions regarding the AOV. Mr. Salvaggio urged the group to consider RFP measures which are non-emissions reductions, such as planning milestones, etc.

Sarah Peirce-Sandner responded that is correct. We will include planning milestones in RFP.

Steve Pezda stated that costs are not considered in the NAAQS process, only in the implementation process. However, Mr. Pezda thought that costs could be considered in the RFP discussion. He stated that if emissions reductions are a measure of RFP, then cost definitely needs to be considered in this paper.

Bob Palzer stated that we are trying to measure progress towards meeting these standards. It is absolutely essential to include AOIs in the region where you are determining RFP. Actual measured reductions in emissions must be included in such RFP determinations.

John Heuss said that you need to start including costs and feasibility in RFP up front. Mr. Huess also encouraged the authors to be more prescriptive from the start.

Donna Lamb commented that when Sarah went through the changes to RFP in the 1990 amendment, they were tied quite closely to nonattainment areas. Thus, the costs were not so important. Ms. Lamb indicated that what we are looking at in the AOIs, which are in general much broader than costs, are important and should be addressed. She confessed that she was a little confused on percentage reductions and what is spelled out in the CAAA.

Sarah Peirce-Sandner responded that Section 182 percent VOC reductions are included in the IIP. With regard to your first issue, I am hearing that the definition of RFP is extremely dependent on whether it is in the AOI or in the AOV; we will take a look at this during the coming weeks.

Vince Brisini commented that he thought that we were somewhat mired-down into RFP being a baseline. Are we still going to have planning periods and goals for reductions? If indeed you have a desired reduction goal, by a specific date by virtue of a numerator and a denominator, then in fact you have a means of calculating a rate of progress.

Jerry Golden asked whether or not we should consider having different RFP requirements based on different classifications (e.g. AOI, AOV, etc.)? Can we actually measure RFP?

Don Theiler responded that we could have an interim period, prior to the final accepted AOI. In theory, this could be a long, long time. Mr. Theiler suggested that when an AOV is identified, it be subjected to the same RFP requirements as any existing nonattainment area. Secondly, there needs to be a point at which RFP either tapers off or is eliminated if a certain level of control is attained (e.g. if all sources are subjected to BACT, then you do not need to continue RFP).

Chris Shaver said that she agreed with Don Theiler on the length of the interim period, and the need for things to kick-in during this period. Secondly, she objected to considering costs in the definition of RFP. Ms. Shaver emphatically stated that where public health is concerned, there is no acceptable cost. Finally, she mentioned that the paper does address RFP for areas that are currently nonattainment, and which will remain in nonattainment under the new standard - e.g. prevent backsliding.

Sarah Peirce-Sandner noted that final condition is covered adequately under the IIP.

Don Theiler said that the existing requirements do stay in place until the new SIP is in place.

Tom Helms stated that there is no backsliding for areas currently in nonattainment under the IIP. The gray area is for areas that are attainment that are sliding into nonattainment under the new standard.

Joe Belanger stated that he did not agree with Chris Shaver on this issue. He stated that we really do need to consider costs in the RFP. He continued saying that if we are looking at a fairly steep increase in costs for reductions, we should invest in the concept of more reductions over the long haul, rather than a lot of cheap reductions up front. Mr. Belanger said it was his opinion that an easy ride up front is indicative of a bumpy, painful ride down the road.

Herb Williams said that he would caution against pre-SIP requirements that will inhibit a state's ability to do the necessary planning for a successful SIP.

Steve Ziman stated that you want a metric that makes sense. This will not be an emissions reduction-based metric. It should be based on some health-based or ambient-based metric. An emissions-based approach will eventually become asymptotic in nature.

Jim Salvaggio noted that it will be increasingly difficult in the future to continue measuring RFP as we have in the past. We are going to have to affect major changes in the American lifestyle to meet the reductions that are being discussed today.

Diana Andrews asked, that in the AOV arena, did you say that once the AOV was identified, you would require immediate action?

Don Theiler responded that IIP says that until there is a new SIP, the current policies stay in effect, and RFP demonstrations must continue. AOVs will not be available until 1999 when the designations are made (based on the 1997 data). Thus, it makes sense that we continue to use the current nonattainment designations until the new SIPs are in place.

Brock Nicholson said that he wanted to echo what Herb Williams said. Don't let the pre-plan process overwhelm the actual planning/adoption process. The energy should be put into getting the right plan implemented.

David Mobley stated that you need a comprehensive monitoring program to define the baseline for your individual region. Until you really establish a very good monitoring program, get that data, and determine where you need controls, RFP is not achievable.

Vince Brisini advised that care should be taken with RFP.

David Baron (via phone) stated that there are two issues. The paper seems to focus on the need to demonstrate actual progress. Also, when states submit their SIPs, they must show that the reductions are sufficient to meet RFP and attainment. Secondly, I did not see in the paper any discussion on the rate of progress which we will require (e.g. annual, straight-line reductions; higher reductions up front, followed by some straight-line reductions down the road; etc.)

Sarah Peirce-Sandner asked David Baron if he could go over his issue #1 again?

David Baron responded, what will the SIP have to show to get approved in terms of RFP. I am afraid that too often EPA has sort of skimmed-over this requirement. We need to require that the plan on its base requires certain RFP requirements, or it does not get approved. This deviates from a set of reductions by certain deadlines.

Economic Incentives - Joe Belanger

Joe Belanger presented some economic incentives information. He stated that Issues 3, 4 and 7 are the most important topics which currently remain. There is some interest still in Issues 2 and 5 (marketable Permits/Caps). The Issues (listed on page 5 of the paper) include:

-	What sources could be included in the program?

-	What are the problems associated with mixing and matching sources?

-	What is the right size and designation for the AOI and the trading program (i.e.
reduce/minimize the amount of leakage). Most of the trading program development has been done on a seasonal or annual basis, and mostly for ozone. This needs to be expanded.

-	Politics and equity are the major points here.

-	How do you manage growth?

-	To what extent can we really discuss inter-pollutant trading? This is the question we have for the science Work Group.

Group Discussion:

Steve Gerritson commented that you covered more bases than simply trading, and with respect to weighted emissions trading, he had a couple of questions. He said if we can assign a relative weight on emissions from source A and source B, then we should be able to do this for attainment. However, we cannot do this. Thus, Mr. Gerritson asked STSWG to review this idea. Secondly, with respect to fees, he cautioned the group to be attentive towards the open-ended nature

of these emissions. Finally, he warned the group that we did not know the public reaction to the changes in the price of these credits.

Vince Brisini said that relative to Option 1 in the 29 January paper, he thought you could claim, under emissions budgets, that over-control would be recognized. In addition to having a hard time setting the fees, you will have an equally difficult time resolving who sets the fees and how the proceeds are distributed. Mr. Brisini concluded that it would boil down to who sets the fees, how high they are, and how they are utilized.

Joe Belanger stated that the budget programs will never apply to every type of source.

Vince Brisini commented that with respect to Issue #7, inter-pollutant trading, he believes very strongly that the only way you can allow inter-pollutant trading is to achieve equitable ambient concentration effects, and not on a simple ton for ton basis.

Richard Chastain stated that he was sensitive to the tension that exists between something that is workable, and something that is technically justifiable. We need to have some scientific input to this issue, and the sooner the better. Weighted emissions trading is definitely a hot topic; but, we need to know from STSWG whether or not it is defensible. The budget approach is certainly a viable approach, as opposed to the fee approach.

Glenn Cass commented that there are situations where it is best to turn the tables on weighted emissions trading. Mr. Cass indicated that when they explored this approach for Southern California a number of years ago, that they found very little sensitivity in the approach taken.

Harvey Jeffries commented that this issue of using science to do weighting, has been explored by the STSWG. There was general consensus that individual trades were not capable of being modeled. Modeling would only be effective on large, broad, across-the-board type of trades. A source by source approach to modeling trades is currently not feasible. It is also much easier to do the modeling if the pollutant of interest is emitted in that particular mode. For example, for ozone, a secondary pollutant, this would be extremely difficult. The realization has to be that this is not your attainment strategy. Command and control does not always have the answer and trading has the potential to bring this information to the forefront.

Brock Nicholson stated that he would be very concerned if we were to ignore the fact of source location in an attainment demonstration. For example, in Charlotte we have three power plants which are large sources of NOx. With the projected growth, there is no way we could allow these sources to go uncontrolled and meet our projected attainment demonstrations. It may be possible that we are dealing with local, regional and inter-regional transport here. We need to consider geographic location. You could have a localized trading program for an individual city, over top of a broader more sophisticated program.

Greg Schaeffer commented that we may want to look more at the definition of what exactly an economic incentive is. Mr. Schaeffer indicated that he was still confused and unable to put all of this into context at this time but, would working on it in the coming days.

Joe Belanger stated that yes, some have said that some of these issues are costs/disincentives as opposed to incentives.

Greg Schaeffer responded that is exactly what he meant . Perhaps, as we go through this, we can determine what works and what does not work.

Dan Weiss inquired as to how one makes this market-based system function properly?

Joe Belanger responded that for someone who is forced to come-up with a reduction beyond their ability, they simply have to go to the market and "buy" the reductions that they need.

Cyril Durrenberger commented that you cannot model individual trades. Nor can you trade among emissions categories. Perhaps we should provide a percentage reduction level for precursors. This approach could be done without command and control.

*** The meeting was adjourned for a 15-minute coffee break ***

Bill Hamilton reminded everyone that they only had an hour and a half left and that they would have to be brief in their presentations and discussions.

Classifications of Designated Areas Under New NAAQS (Draft #4) - Eric Skelton

Eric Skelton stated that the objective was to design options for how nonattainment area classifications could work under the new implementation process, including AOIs/AOVs. The paper is outlined below:

Problems with Current Classification Scheme

-	Lack of inherent flexibility to address local problems

-	Relatively distant compliance dates may create a sense of complacency, thus delaying	expeditious actions

-	Promotes a one size fits all strategy

Clean Air Act Basis for Classification

-	Subpart 1

-	Attainment dates

-	Feasibility of control measures

-	Transport region requirements

Classification Goals

-	National or regional consistency

-	Education about the seriousness of the air quality problem

-	Hierarchy of planning and control requirements and attainment dates, tailored to severity problem

-	Bump-up (means of addressing failure to attain within hierarchical classification)

-	Classification of air quality problems (e.g. within the area vs. heavily influenced by transport)

-	Integrated ozone, PM-fine and regional haze planning.

Issues to Consider in Evaluating Classification Options

-	EPA Administrator may decide not to classify areas based on degree of prescription or flexibility in developing plans and strategies

-	If there are no core requirements, most classification goals are moot

-	A highly prescribed system would be consistent with a classification system

-	Some combination of core requirements and regional discretion is desired

The Paper has eight options (to date):

Option 1:	Retain the current approach to classification (e.g. moderate, severe, etc.)

Pros:	Model is already familiar; allows for bum-up

Cons:	May not be enough differences between areas to justify; traditional classifications may carry negative connotations; and, may not adequately address regional transport.

Option 2:	Two-tiered approach to classification. Classify short (5 year) and long-term (10 year) non-attainment areas (or AOVs) and implement "easy" local controls or uniformly applied national controls in the short-term areas.

Pros:	Satisfies the requirements for expediency; initial classification could carry requirements for both AOV and AOI; allows for bump-ups

Option 3:	Classify areas specifically to address regional transport. Areas would be classified according to the following:

-	Simple transport area

-	Complex transport area (e.g. requires more analysis; more sophisticated planning)

-	Compound transport area (e.g. dealing with multiple pollutants)

Option 4:	Classify the AOV to inform the public

-	AOV classified to reflect the severity of the problem, informs and educates the public

-	Would incorporate the emergency episode plan, which could include prescriptive control measures

-	Could dictate planning and control requirements for the AOI

Option 5: Classify areas close to non-attainment. Core requirements could include:

-	Public education program

-	Program to track air quality trends

-	Contingency plan, or

-	Specific preventive measures (less stringent than traditional SIP requirements)

Option 6:	Classifications by control regions. Given very large geographic AOIs, identify sub-
regions within the AOI, with accompanying classifications that carry core requirements that become more stringent as the severity of the impact on the AOI is determined.

Option 7:	Classify to identify core requirements.

-	Each classification would carry specific planning and control requirements

-	Classification system proven means to impose core requirements, and would allow for bump-
ups

Option 8:	No Classification. If the control and planning issues are not significantly different between areas, then no classification system is needed at all.

Discussion of Classifications Paper

None.

Sanctions Paper - Steve Gerritson

Traditional Sanctions Process

Sanctions clock starts when:

-	EPA determines that a state has failed to submit a complete SIP or to implement an approved SIP

-	EPA disapproves a SIP

-	If the deficiency is not corrected within 18 months, EPA must impose an offset sanction

-	If the problem is not corrected 6 months after the offset sanction

-	FIP option

Proposed Positive Incentives for Not Meeting Deadlines

-	Reduced offset ratio

-	Additional Offset Credits

-	Flexible response

Proposed Negative Incentives for Not Meeting Deadlines

-	Accelerated future deadlines

-	Lower RACT thresholds

-	Denial of variances or alternative emission limits

-	Discounted credits

-	Additional Requirements

Additional Issues

-	Should sanctions for failing to attain by the applicable date be developed?

-	Given a possible multi-step planning process, where should sanctions be applied?

Discussion of Sanctions Paper

Don Theiler stated that the current sanctions program is not working properly. However, the threat of these sanctions is the only thing that makes the system work.

Steve Gerritson said that he agreed with Don.

Chris Shaver noted that the vehicle for putting some of these incentives into place is the promulgation of some form/type of rule by EPA immediately, up front. Secondly, in terms of disincentives, perhaps some type of interstate commerce control could be used to ensure that states cooperate. Ms. Shaver admitted that she was not a legal expert on this, but indicated that on the surface, it would appear to work.

Steve Gerritson said that he was not sure of the legality of this either.

Joe Belanger commented that no good deed should go unpunished! We have to be very careful not to make sanctions against people who have done what they have been told to do. For example, reducing bank credits implies that a region had at one time had a control program which allowed them to bank the credits. Why penalize them now? You would be better served to go after another region.

Jim Salvaggio interjected that we are tending to focus the sanctions on the industrial sector, where the majority of our current programs have been implementing I/M programs, reformulated gasoline, etc. Thus, Mr. Salvaggio indicated that we were targeting the wrong group for the sanctions.

Dewayne Huckabay stated that he would like to re-title the paper. Incentives, and disincentives as well as sanctions need to be mentioned in the title, and discussed freely throughout the paper.

Steve Gerritson responded that the original title was more descriptive.

Dick Schoeneberg stated that the relationship between cause and effect needs to be spelled out here.

John Heuss suggested taking the approach of a parking ticket? If you pay immediately its $5. If you wait a month its $20, etc.

Boundaries of Areas of Violation (AOV) Paper - John Crouch

John Crouch presented the AOV paper and noted that BPAP had not yet started on this, but would be taking it up the next morning between 9:00 and 10:00 AM.

Paper Objective

-	To present options for the specifics of establishing AOV boundaries

Recommendations from the July 25, 1996 Designation Issues for New NAAQS Paper

-	AOV

Proposed Forms of the Standard

-	PM2.5 annual standard, based on a 3-year average of concentrations, spatially averaged across the area

-	Ozone - 8-hour standard

Issue 1:	What is the purpose behind defining an AOV boundary?

-	To count and track where violations occur?

-	To notify people exposed?

-	To set up boundaries to be used for regulatory requirements?

Issue 2:	Given a potential standard based on a spatial average, how should the boundaries be defined?

Issue 3:	Given a potential standard based on measurements at a single monitor, how should AOV boundaries be set around the monitor?

Issue 4:	How should PM-fine (e.g. spatially averaged) and ozone (e.g. single monitor) co-
AOV boundaries be defined?

Issue 5:	Should regional haze AOV boundaries be considered along with PM and ozone NAAQS or handled separately?

What other issues need to be in this list?

Discussion of AOV Paper

Donna Lamb asked what might change based on looking at the secondary standard proposals?

John Crouch responded that is a good point and that the authors needed to review this.

Brock Nicholson stated that John had "hit" on most of the issues. However, on the Issue #1, the third bullet, Mr. Nicholson indicated that it was his opinion that we had started at the outset to get away from the regulatory requirements and to simply look at the people affected by the violation.

John Crouch responded that he had heard a lack of consensus on this concept as early as this week's call for the BPAP group.

Brock Nicholson responded that he was offering "one side of the house", but he thought that we were trying to get away from this difficult issue; however, others might disagree.

Diana Andrews commented that she thought that one of the basic ideas was that the AOV concept of informing the public, and not triggering immediate regulatory requirements was going to be used as an incentive to increase monitoring. I would like us to settle on the fact that an AOV is what we have discussed in the past; that is, to simply notify the public, and organize the planning process to determine the AOI.

Steve Ziman said that he agreed with Diana. The boundary of the AOV is not that much of an issue. We need to concentrate our efforts on adequately dealing with the AOI. The need for an AOV is a health-based approach, while it is the AOI that really gets to the bottom line - cleaning-up the environment through emissions reductions.

Chris Shaver noted that she was impressed by the AOI tools document.

Don Theiler said that he agreed with Chris' comments and that there must be regulations in the AOVs. Mr. Theiler reminded the group that Chris Shaver had suggested a very plausible way to deal with this (e.g. a rebuttable presumption). This basically means there are regulations in place, unless you (e.g. the states) can show something different.

John Crouch noted that some people would say that you do not need to identify all of the AOVs within a given AOI.

Don Theiler stated that this is not that important. The most important thing here is to define your AOI, start the planning process, and get the ball rolling.

Tom Moore commented that if you are revising the standard, in the case of PM for example, there is a brand new time and space distribution of data. Thus, since the data are in fact incomplete, we need to remember this in our future discussions. One assumption about the technique of only using monitoring data to take a "snapshot" and then make public policy is that this is generally not a viable approach. Counties are often not the convention for selecting nonattainment boundaries in the western part of the U.S. We need to strike a balance in the AOV-setting boundary process. Finally, as a reality check, the AOV should be a subset of the AOI. This is not always going to be the case, but will be the case most of the time.

John Crouch said that he disagreed with Tom Moore's last statement.

Safe Harbors and Early Incentives Paper - Vince Brisini

Paper Objective

-	Design safe harbors and identify positive incentives to

-	Encourage States/Tribes to submit and implement plans early (RIPs/SIPs/SpIPs)

Model Safe Harbor Program

-	Early reduction program under the hazardous air pollutant (HAP) provisions of the CAA

-	Benefits of MACT Early Reduction Program

-	Provides sources with the flexibility to design cost effective reduction strategies

-	Provides sources more time to do MACT compliance

-	Reductions now as opposed to later

Issue 1: How can planning bodies (e.g. RAMP, etc.) be encouraged to plan early?

Issue 2: How can planning bodies be encouraged to submit those plans early?

Issue 3: How can you get sources to be encouraged to reduce emissions early?

-	What are the minimum reduction levels to qualify?

-	What if all sources qualify, but additional controls are needed to meet the NAAQS?

Discussion of Safe Harbors and Early Incentives Paper

Chris Shaver suggested that one might do a survey among the States, to see who has potential incentives to encourage early reductions.

Joe Belanger asked what an early reduction was worth? Is there a linear relationship between early reductions up front, and what would have been attained down the road? Can we put our hands around the issue of early reductions versus late reductions? I would invite STSWG to take a look at this. We must determine if there is a time-value associated with the benefits.

Dewayne Huckabay commented that he did not think that this paper warranted being a separate paper. It should be combined with one of the other papers.

Glenn Cass stated that the HAP example requires a 95% emission control scenario; thus, I think it is not a good example for this discussion.

John Heuss said that he thought that this whole discussion needs to be put into context under the existing CAA and the Trends Report. There have already been a lot of safe harbors, and a good deal of early reduction programs. Lets look at it on the basis of air quality that is improving significantly, and should continue to improve. The AOV has a time dimension as well and you should not lose sight of this dimension.

Meeting Summary was given by Bill Hamilton

Bill Hamilton indicated that he thought that the day had been very productive. Mr. Hamilton indicated that there were a limited number of BPAP Issue Papers on the front table. He concluded by stating that the RFP Sub-Group would meet in this room from 5-6 p.m. this evening.

Co-Chair Summary

Harvey Jeffries said that STSWG will split-up tomorrow and go to both the NRSWG and the BPAP Work Group Meetings. Mr. Jeffries reminded STSWG members to meet in the assigned rooms at 8:00 a.m. Friday morning.

David Mobley stated that the NRSWG would like your ideas on his earlier summary of the issues.

Don Theiler stated that the co-chairs would meet for breakfast at 7:00 a.m. on Friday morning.

Meeting Adjourned