Draft Summary of the Federal Advisory Committee Act (FACA)

Science and Technical Support Work Group Meeting

Hyatt Regency Hotel

February 19, 1997

Washington, DC

The Science and Technical Support Work Group (STSWG) of the FACA Subcommittee met on Wednesday, February 19, 1997 in Washington, DC. A list of the participants and a summary of the meeting follows.

Work Group Participants

Name	Affiliation

Tom Helms, Co-Chair	U.S. EPA

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

Kirit Chaudhari	VA DEQ

Cyril Durrenberger	TNRCC

Bruce Hill	Appalachian Mountain Club

Tom Moore	Arizona

Dave McNeill	Utah

S.T. Rao	N.Y. DEC

Jay Rosenthal	U.S. Navy

Mark Scruggs	DOI

Jay Turner	Washington University

Work Group Members Not Participating

Diana Andrews	Kentucky

John Cabaniss	AIAM

Glenn Cass	Cal Tech

John Core	WESTAR

Ellis Cowling	NCSU

David Kelly	Navajo EPA

Rich Poirot	Vermont

Manop Vanichchagorn	Louisiana DEQ

Dan Weiss	Cinergy Corporation

Jeffrey West	GPU Services Corporation

Steve Ziman	Chevron Corporation

Non-Work Group Participants

Bob Wayland, SAIC; Ted Russell, Georgia Tech; Dennis Issacs, Dupont; Bob Judge, U.S. EPA/Region 1; Josh Flam, U.S. EPA/CUS; Mark Wolcott, U.S. EPA/OMS; Ned Meyer, U.S. EPA/AQMG; Charlene Spells, U.S. EPA/IPSG; David Sanders and John Silvasi, U.S. EPA/OPSG.

Summary of the Meeting

Tom Helms opened the meeting by defining success for today's session. He stated the meeting had been shortened to only a morning session, because in the afternoon STSWG members were encouraged to interact with the other Work Groups in a fact-finding mission. Mr. Helms identified four items that needed discussion during the morning session:

-	Set Schedule - Morning topics and the afternoon agenda

-	Workshop Discussion

-	AOI/RAMP Discussion

-	Overview Papers - for STSWG positions at the general meeting

Mr. Helms indicated that at 1:30 pm half of the group will visit with BPAP and the remainder of the STSWG will meet with the NRSWG. Following an interactive exercise, the groups will come back together after visiting "all 9 cells" and put together a summary of the pertinent issues. Tom Helms indicated that we participate in this endeavor, because it will give the STSWG members the opportunity to participate in the actual policy making process.

Control Technology Paper

Tom Helms reiterated that with all the things STSWG currently has going on, that he was very reluctant to sign-up our Work Group for Issue Paper. Thus, he indicated that he had "subcontracted" with David Mobley to allow Charlene Spells to work-up this document. Ms. Spells will involve the STSWG in modifications and revisions of this document. Mr. Helms said that unless anyone violently objects, this is the way this paper will be completed.

Source Attribution Workshop - Harvey Jeffries

Harvey Jeffries began this discussion by saying that Ken Schere is working this very issue for the NARSTO-NE Program and that Ned Meyer is working this for the policy programs. Thus, there is sufficient interest from both the science and policy sides of EPA to better understand source apportionment. Harvey Jeffries indicated that Ned Meyer is interested in conducting a workshop that will be peer reviewed by paid contractors. The reviewers will receive the information prior to the workshop and review it, and declare it suitable for presentation, then attend the presentation, and following the meeting, summarize the findings and issue a summary document.

Mr. Jeffries indicated that he had begun to compile a reasonable list of topics for the ozone side of the program; however, he asked Tom Moore, Mark Scruggs and others provide him some information for the particulate matter (PM) side of the issues.

Tom Helms reminded the group that Charlene Spells has also been dragged into the PM side of this issue.

Harvey Jeffries now began a detailed discussion of the Source Attribution Workshop.

Purpose

Assess the applicability of source attribution techniques for

-	Estimating AOIs

-	Complementing use of nested regional grid models

Why Should I be Interested?

-	AOIs to form the basis for future planning to attain proposed NAAQS for ozone and pm

-	STSWG expressed concern about technical defensibility of AOIs

-	STSWG asked to provide guidance on the definition of AOIs

Kirit Chaudhari asked for details on the types of models that are being discussed for the workshop.

Harvey Jeffries responded that he did not want to get into the debate about RAMPs, AOIs, etc. Mr. Jeffries indicated that we need to stay focused on the Source Apportionment Workshop, and what role this workshop might have in our overall discussions. Some preliminary candidates were identified:

-	Environ/UAM-X; Ralph Morris has been discussing this in several places

-	Ted Russell - based on direct decoupled sensitivity techniques

-	Harvey Jeffries - Process Analysis

-	SAI's Technique (developed by a former student of Harvey's)

-	Trajectory Analyses (Poirot and Univ. Of Washington)

-	Robin Dennis' Techniques

-	Eric Edgerton's work at ESE

Harvey Jeffries suggested that the group should allocated one day for the discussion of ozone-related issues and one day for PM-related topics.

Ted Russell questioned if techniques that utilized both or multiple pollutants would be discussed?

Harvey Jeffries clarified his statement, saying that he meant to say that many techniques only apply to ozone or PM; however, there are techniques that do apply to both pollutants and these would obviously be considered..

Mark Scruggs suggested that the recent SAMI effort could potentially be useful to this topic.

Ned Meyer stated that Models-3 was a viable player; however, there is considerable speculation on the time frame under which it will be available and usable. He cautioned the group from locking-in on one set of tools to do all of these control analyses.

Ted Russell said that the Models-3 issue brought up a very important issue here with respect with tools. He indicated that the group needed to attach a realistic time frame to each of these tools, their availability and their technical qualifications.

John Silvasi reminded the group that the current point for RAMP designation is set for June 1998.

Harvey Jeffries stated that he did not believe that there was sufficient time to get a sophisticated modeling analysis in place in time to impact this process. However, Mr. Jeffries concluded that anything that is proposed for presentation at the workshop, should be available for use in late 1998 or 1999. For the purpose of the workshop, we need to have tools that are currently producing results that can be openly discussed and debated.

Ted Russell suggested that whatever method that is chosen initially, should not be "burned" into law, because this will serve to inhibit further scientific productivity. He encouraged the group to look for a short-term solution up-front and allow the end result to be a work in progress.

Cyril Durrenberger responded that there are core things that can be used for fundamental decision making, and then there are ancillary things that can be used for refinement purposes. We simply cannot afford to invest a great deal of money into some tool that will not be useful down the road. There needs to be a hierarchy of tools that the individual states can pick and choose from.

Harvey Jeffries cautioned the group not to confuse the application of the tools with the identification of the tools that are available for the ultimate applications.

Ted Russell inquired what other information do these tools provide that is complementary to the overall process? The suggested that this is a basic, fundamental question that needs to be answered.

John Silvasi stated that it appeared to him that we needed to have preliminary workshop, prior to the Source Attribution Workshop to identify some of these issues.

Dave McNeill stated that you do not want to have source attribution done in a way that is incompatible with your models.

Tom Helms recognized that there were a lot of "bright ideas" floating around the room, and questioned how we get these ideas focused. His suggestion was that this focus could be provided at the workshop.

Tom Moore said that in his opinion, we were talking about source attribution too much in terms of modeling. He reminded the group that we did not want too much rigor and no flexibility. He encouraged the group to not make a value judgement about how good a given source attribution methodology is; rather, let us look at what is out there and what each individual tool does.

Dave McNeill cautioned that you needed a level playing field when discussing source attribution tools and methodologies. However, he did support the concept of linking source attribution results to numerical models.

Mark Scruggs questioned if we were going to tell workshop participants what model to use and where to go and get it? He also questioned the motivation for such a process.

Harvey volunteered to take cut at this question. He indicated that right now there are people making "fuzzy" claims about what their particular models/techniques can and can not do. The purpose of this workshop is not to define a given technique for this process. It is simply a hierarchy of available tools, which could be used in the definition of AOIs.

Ted Russell suggested that the format included both peer reviewers/panel members, as well as allowing the individual presenters to inter-compare their respective techniques.

Harvey Jeffries indicated that this had been discussed earlier, but the logistics were just too complicated. The individual presenters would have to provide their presentation materials at least 3 weeks in advance of the workshop to allow adequate time for peer review. Each presenter would receive 45 minutes to present, followed by a detailed question and answer session.

S.T. Rao insisted that we need clear objectives on what it is we want to accomplish in this effort. Mr. Rao questioned whether EPA was requesting the workshop or if the individual vendors (e.g. presenters) pushing for this effort?

Tom Helms stated that the Agency was calling the workshop, and that EPA was going to pay the individual peer reviewers.

Harvey Jeffries reminded the Work Group members that this not just OAQPS; but, that there are key people from ORD participating as well.

S.T. Rao again asked if anyone had developed the key questions that we were trying to resolve by holding this workshop?

Harvey Jeffries responded that it is difficult to pose those questions at this point, because we really do not have enough information on the available tools. Mr. Jeffries indicated that he could generate questions, that Mr. Rao could generate questions, etc.; but, that it will be up to EPA and the workshop to address these issues.

S.T. Rao indicated that one of the basic questions is simply how do you do it; but, the other side of this issue is the technical detail. Is this feasible? What is driving this process - is it the questions we need answered or are the people who have tools simply saying, "I have a tool, please take a look at it?"

Dave McNeill questioned what the end-product of the workshop would be. Will it be a Federally mandated approach?

John Silvasi indicated that EPA is looking to the FACA process to advise it on what to do along these lines. Mr. Silvasi stated that EPA is looking for input from this body (e.g. STSWG) on how to go about doing this process.

Ned Meyer replied that this would be more along the lines of defining initial tools that could be used in the designation of RAMPs.

Tom Moore asked if the EPA would structure the workshop differently if they were selecting a process for RAMP determination as opposed to simply reviewing material?

Tom Helms replied that the Agency was not looking to endorse any individual tool; rather, EPA wants to identify tools that could be applicable.

Ted Russell stated that he was not opposed to Mr. Helms approach; however, he stated that it would be good if the peer reviewers did have some charter to rank the tools, and to assess the pros and cons of each tool.

Harvey Jeffries reminded the group that the individuals being discussed for peer reviewers are experts in the field, and they have been doing this for quite some time.

Ted Russell acknowledged Harvey Jeffries statement, but replied that when you start talking about different RAMPs using different tools, you will have a problem. Mr. Russell indicated that RAMPs having this degree of flexibility would inevitably lead to problems. He suggested that the workshop should provide some base-level of guidance.

David Sanders stated the viability of methods will come from how you formulate the questions at the beginning of the workshop. He reminded the Work Group that the formulation of the questions is the crucial element for today's discussions.

Mark Scruggs interjected that he agreed with S.T. Rao. Mr. Scruggs said that before you can have such a workshop, we need to identify what issues we want them to resolve. He suggested that we instruct them to resolve this process, at this resolution, at this location.

Tom Helms responded that it was quite possible that EPA did not know exactly what it wanted at this time; however, the would recognize the system when they saw it.

Mark Scruggs reiterated that this all comes back to the definition of the AOI and how it will be used in this entire process.

Harvey Jeffries commented that if we researched what has been general practice and what is available, that this type of information would frame the questions we need to address.

Mark Scruggs asked whether Harvey Jeffries was after specific sources, source regions, etc.?

Harvey Jeffries answered indicating that we need to ask the individuals with tools how their tools address these type of issues.

Tom Moore questioned if each presenter would have some applied example?

Harvey Jeffries responded, no, that each individual presenter will make their presentation, and then the group will be handed the presenter's results and asked for comments/opinions.

Cyril Durrenberger stated that he was all in favor of flexibility, but that some type of guidance would be useful here. Mr. Durrenberger said that the differences between PM and ozone will be problematic enough. You will need to know what model to use, what kind of data do you need; can it be done on an abacus or a CRAY, etc.

Harvey Jeffries summarized saying that he would ask each STSWG member to submit your favorite questions, and then we will discuss this over a call as a group.

Bruce Hill said that in his opinion, the toughest nut to crack in this whole FACA process is identifying the AOI. The environmental community is extremely concerned on whether this is viable. EPA needs to develop the core set of questions that needs to be addressed. Mr. Hill concluded saying that he feels that each RAMP should apply a common set of techniques from which they can draw conclusions.

Jay Turner commented that as he viewed the issue, what we want is to very specifically propose the issue, and give some detail. We want the individual presenters to come to us and tell us in one hour how your tool can address the questions provided to each presenter. Then the peer reviewers can identify the strengths and weaknesses of the approaches. Mr. Turner stated that you needed to clearly define the roles of the presenters and the peer reviewers.

S.T. Rao said that he was not trying to be difficult, but that we need to have clearly defined objectives. What do we want to accomplish? Mr. Rao indicated that he saw this as the fundamental issue causing confusion at this point. He concluded stating that if we could do this successfully, then the workshop would be very successful.

Harvey Jeffries suggested that following the Source Attribution Workshop, we should have another workshop to address the secondary issues, once we collect our technical information from the initial workshop.

Tom Helms warned the group of the policy deadlines, and stated that we first need to determine what technical methods are available, then we need to address the policy needs, based on this technical information. He reminded the group that the clock is ticking, so we need to layout a time line and get started.

As a means of a summary on this topic, Harvey Jeffries offered the following information:

-	We are all in consensus that we should have this workshop.

-	We would all like to contribute to the set of initial questions.

-	Thus, submit your information to us, and we can work with Ned to get them finalized.

-	We need a summary of the concepts, prior to the workshop.

-	Target Audience: EPA Staff; STSWG; thus, anyone who is interested.

S.T. Rao asked that the concepts be defined up-front and encouraged the organizers to make them as clear and succinct as possible.

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

AOI/RAMP Definitions:

-	2/13 - Theiler Paper, AOI213

-	2/13 - Shaver Paper, Institutional Mechanisms

Purposes of Each

-	Institutional Roles - ongoing?! (very basic science work that is currently underway)

vs.

-	Leading to Selection of Controls (a subset of the larger scientific process)

RAMP Definition - Theiler Paper

Proposed STSWG Statement:	Perform scientific analyses, develop technical tools and collect/analyze sufficient quantifiable data (to contribute knowledge) to support public policy decisions to control air pollution using the AOI 'process',

S.T. Rao commented that science does not contribute to a process; science contributes knowledge. (Thus, S.T. Rao proposed to add the language above which is in italics).

AOI Definition - Theiler Paper

Proposed STSWG Statement:	Science sufficient to replicate the characteristics of an AOV(s) (e.g. AOV observations).

Harvey Jeffries stated that he would quibble that there is not sufficient science to do this. There is engineering through models, which can accomplish this. Many models get the right answers for the totally wrong reasons. Basically, they have to explain why they have an area of violation. He indicated that he was unclear exactly why we need this type of a statement in the first place?

S.T. Rao suggested that we simply adopt Harvey Jeffries' words. You need a cause and effect linkage here. Thus, Mr. Rao suggested that we modify the statement to read as, "Sufficient scientific explanations of cause and effect."

Control Regions & Control Target Definitions - Theiler Paper

Proposed STSWG Statement:	Perform technical analyses to quantify/understand emissions pattern, their variation and the ambient effects at a AOV(s).

Dave McNeill suggested that instead of saying that the control region is going to perform, we should say the results need to be based on some technical basis, i.e., " Technical analyses based on (e.g. this control region needs to be based on a technical analysis) quantification of emissions patterns, their variation and the ambient effects at a AOV(s)."

GCVTC Recommendations regarding "Future" Scientific and Technical Needs (see 10 pages (21-25 and 61-65) from the GCVTC Report):

-	Inventory

-	Monitoring

-	Modeling Tools

-	Assessment Tools and Methodology

Request from Don Theiler's Group:

Step 1:	Prepare alternative RAMP configurations (e.g. draw the map). We cannot do this so, instead, outline the technical and science functions of RAMP members

Step 2:	STSWG to work with EPA to define guidance for preliminary AOI identification. Instead, outline menu of technical information needed for meaningful science analyses and policy decisions for the stages of the AOI through to a final control region and control target.

Cyril Durrenberger, playing the devil's advocated, asked who would draw the maps if STSWG did not?

Tom Helms replied that this group is essentially waving the right to draw the lines. Mr. Helms continued, that If you do not do it, EPA will step in and do it for you. So, the question before this group is do you want to play in this game, or not?

John Silvasi asked that if STSWG did not want to actually draw the lines, are there any things that you would want them to consider (or not consider) in drawing the lines? Mr. Silvasi reminded the group that Mr. Helms was correct - if STSWG does not draw the lines, EPA will draw the lines.

Dave McNeill questioned if we really did not accomplish our alternative to Step 1 in the first principle we just completed working on? Thus, the RAMP should be developed in such a way that would facilitate the statement that we currently have in the original first statement : "Perform scientific analyses, develop technical tools and collect/analyze sufficient quantifiable data (to contribute knowledge) to support public policy decisions to control air pollution using the AOI 'process'."

Harvey Jeffries asked the group to remember that every state will be included in a RAMP. Mr. Jeffries stated to the EPA personnel that STSWG is not reluctant to tackle the issue, rather it is reluctant to deliver the judgement, because STSWG does not have the resources to underpin any technical basis for drawing the lines. Mr. Jeffries continued that given enough money and time, someone could draw these lines, and do the necessary modeling, analysis and data reduction from which to draw sufficient scientific conclusions to support the drawing of any set of lines. Mr. Jeffries concluded that OTAG could probably do this for ozone at this time, but for PM and regional haze, who knows! Finally, he responded that given that this information is needed by June 1998, there is simply not enough time to do a quantitative analysis.

Cyril Durrenberger questioned if there would be different RAMPs for ozone, PM and regional haze?

Harvey Jeffries indicated that this has not been determined at this time.

S.T. Rao reminded the Work Group members that RAMPs are not technical by definition; they are purely political.

Harvey Jeffries continued that all a RAMP is about is cooperation among neighboring states. He concluded that it is similar to the old pre-1970 concept of an AQCR.

Tom Moore stated that the RAMP was not the issue that the group needed to be concerned about. Mr. Moore insisted that the AOI was the important entity here, because it does lead to targeted requirements.

Jay Turner interjected that target regions and control regions could easily cross RAMP boundaries. Thus, he continued that If you are within a RAMP, then you need information which can be shared with neighboring RAMPs. He suggested that STSWG needed to layout what elements individual RAMPs need to be doing in order to get the process started and moving.

Dave McNeill stated that if you are in two RAMPs, and they decide to do things differently, then you have a real mess on your hands. As a result, he argued that consistency should overweigh accuracy. It is much more important to have a consistent approach, with a less stringent technical definition.

Reasonable Further Progress

Tom Moore indicated that essentially, air quality-based metrics were being considered in this paper. He concluded that there are essentially two types of issues: (1) real RFP planning while the state is actually developing its plan; (2) pre-SIP issues, the time before EPA actually approves the plan. Finally, there are several other questions being considered:

-	Why are we even doing RFP?

-	Should we have standardized/customized RFP planning?

-	What is the range of metrics?

-	Do we need new/different metrics?

-	Is three years an adequate time period for the review process?

Dave McNeill asked if the authors had come up with the links between AOI, AOV and the old nonattainment areas?

John Silvasi replied that they had not been able to do this at this time.

Dave McNeill remarked that this is an interesting problem, given that RFP is only required in a nonattainment area.

Cyril Durrenberger added that Texas has RFP in some of the most serious ozone nonattainment areas at this time. Mr. Durrenberger asked what Texas was expected to do to keep these areas from getting worse? With regard to PM, he said that anything is possible, because the we simply just do not understand enough about the science situation at this time to make intelligent decisions.

Jay Turner asked what motivation do people have to implement control programs without RFP benchmarks?

Bruce Hill asked if there were air quality-based models which can adequately address the RFP issues and questioned if this was not the true issue before STSWG today?

S.T. Rao commented that the STSWG was not really debating the merits of an emissions- based and air quality-based tracking system; the two metrics go hand-in-hand. The real issue here is improving air quality, which gives incentives to data analysis, modeling, monitoring, etc. Thus, Mr. Rao concluded that EPA must have both RFP and air quality based procedures.

In conclusion, Harvey Jeffries suggested that these issues be expanded upon in the remaining chapters in the Conceptual Model. Mr. Jeffries agreed with Mr. Rao, stating that you do not need either or, you need both emissions-based and air quality-based metrics.