Draft Summary of the Federal Advisory Committee Act (FACA)

Science and Technical Support Work Group Face-to-Face Meeting

Fairview Park - Marriott Hotel

April 7, 1997

Falls Church, Virginia

The Science and Technical Support Work Group (STSWG) of the FACA Subcommittee met on Monday, April 7, 1997 in Falls Church, Virginia. A list of 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

Diana Andrews	Kentucky

John Cabaniss	AIAM

David Chock	Ford Motor Company

Kirit Chaudhari	Virginia

Cyril Durrenberger	TNRCC

Bruce Hill	Appalachian Mountain Club

Jay Hudson	Santee-Cooper

David Kelly	Navajo EPA

George Lauer	ARCO

Tom Moore	Arizona

Dave McNeill	Utah

S.T. Rao	New York

Dan Weiss	Cinergy Corporation

Jeffrey West	GPU Services Corporation

Steve Ziman	Chevron

Work Group Members Not Participating

Glenn Cass	Cal Tech

John Core	WESTAR

Ellis Cowling	NCSU/SOS

Rich Poirot	Vermont

Mark Scruggs	DOI

Manop Vanichchagorn	Louisiana

Jay Rosenthal	USN

Jay Turner	Washington University

Non-Work Group Participants

Bob Wayland, SAIC; Bob Palzer, Sierra Club; Ted Russell, GIT; Bob Judge, U.S. EPA/Region I; John Chamberlain, U.S. EPA/OPPE; Ned Meyer, U.S. EPA/AQMG; David Sanders and John Silvasi, U.S. EPA/OPSG.

Summary of the Meeting

Tom Helms opened the meeting by thanking everyone for attending, and announcing the following changes in the day's agenda:

Agenda

9:15 am - Model Workshop Discussion

9:45 am - Tom Moore RAMP Discussion

10:15 - 12: 00 noon - Joint Meeting with NRSWG and BPAP

Lunch

1:00 - Modeling Requirements - Ned Meyer

2:00 - RFP Discussions

Tom Helms reminded the Work Group members that we needed to go to this joint meeting today, to make sure that science is not lost in the preparation of their respective issue papers.

Model Workshop Discussion - Harvey Jeffries

Source Apportionment Workshop

Mr. Jeffries began by stating that there were a number of people who had introduced techniques, and/or demonstrated different techniques for doing source apportionment (e.g., Rich Poirot's trajectory analyses, etc.). He said that originally this workshop was scheduled for early February; however, STSWG determined that the time line was too accelerated, and the workshop would be better served if held in July/August. He noted that various members of this Work Group were asked to submit information on the formulation of the workshop. Mr. Jeffries further stated that Ned Meyer went through this information, and had put together some initial materials. He said that OAQPS will be funding the workshop, and hence will be the targeted "client". He announced that SAIC will most likely be the contractor for this workshop.

George Lauer asked if everyone would be provided with the opportunity to present their material?

Harvey Jeffries responded that the schedule was one day for ozone, one day for PM and another half day for the peer reviewers to do their stuff. Therefore, one of the questions to be answered is, do we have enough time to extract the necessary information in such a short time? He said that some of these tools are immature at this stage. Accordingly, it is not possible to ask the presenters to take a specific case study and do a specific suite of analyses. So, Mr. Jeffries

continued, in order to present anything at the workshop, the presenters will be required to submit information to the chairman for peer review, 2-4 weeks in advance of the meeting.

Mr. Jeffries indicated that the presentations will be about 45 minutes in length, with suitable time for questions. There will be a limit of five (5) ozone and five (5) PM papers. However, he said that anyone who was interested could submit written material for consideration by the workshop; however, we simply need to limit the number of oral presentations. Mr. Jeffries stated that the management and operation of this workshop was under the guidance of OAQPS and the selected contractor. The workshop would be open to the public, and would most likely be in RTP.

Tom Helms interjected that the exact timing of the workshop was still being worked out.

Cyril Durrenberger inserted that he thought we needed to have a specific data set and prescribe some specific analyses to be performed. Further, he would also like to see that this workshop address Models-3 and how it fits into all of this.

Harvey Jeffries responded that Mr. Durrenberger was welcome to send any information to Ned Meyer (or the contractor).

Cyril Durrenberger asked if OAQPS was going to pick the chair of the workshop?

Harvey Jeffries replied that the peer review panel should have two ozone experts, two PM experts, a chair and a meteorologist. He stated that a total of 6 members should be on the peer review panel.

Cyril Durrenberger added that he just wanted to ensure that whatever came out of this workshop to be worthwhile and that it could be used by the regulatory community.

Diana Andrews agreed with Mr. Durrenberger. Ms. Andrews stated that the regulators need to be able to utilize whatever tools are selected.

Steve Ziman suggested that STSWG needed to discuss the details of the data requirements as well.

Harvey Jeffries responded that the workshop was focused, and was supported by both ORD and OAQPS.

Cyril Durrenberger noted that he would really like to have more feedback and input on this issue.

Tom Helms told Mr. Durrenberger that Ned (Meyer) would be in contact with him, so that EPA could discuss these issues and then get back Mr. Durrenberger.

George Lauer noted that he had just completed something similar to this for global climate models. He encouraged STSWG to formulate their questions early.

Cyril Durrenberger asked if the material had to be peer reviewed prior to the workshop?

Harvey Jeffries responded that since some of the techniques are so new, and have received so little review, he thought we needed to be very careful about excluding any technique, simply because it has not appeared in the reviewed literature.

Kirit Chaudhari asked if these models had to go through the same EPA review process that all the other models go through?

Ned Meyer replied that this issue had not been addressed yet.

Steve Ziman inserted that he thought this was a real problem.

Harvey Jeffries offered that he envisioned the first and second day of the workshop would be considerably different, because ozone efforts are much more advanced compared to PM efforts. He stated that all of this could potentially be wrapped into the Models-3 framework.

Cyril Durrenberger clarified that essentially, you are doing peer review "in process" as opposed to doing it in advance. He noted that he thought if this was done properly, then it could be a very effective process.

George Lauer stated that only the framework needs to be peer reviewed in advance.

Harvey Jeffries offered that we want this workshop to be based on science. The applicability of the identified tools can be handled in a later workshop. He said that essentially, we want to identify the available tools and discuss their pros and cons.

Steve Ziman noted that the NARSTO workshop in late November would also tie in nicely with this, and could provide some valuable insights.

Jeffrey West reiterated that we must maintain impartiality in this workshop. He suggested that this objectivity should be in place from the selection of the contractor all the way to the selection of the chairman and the peer reviewers.

Harvey Jeffries replied to Jeff West that the time line is only so long and added that we cannot afford to wait to have the National Academy of Sciences review this information.

Tom Helms inserted that EPA would consult with each of you in the development process to ensure that your concerns are heard and discussed. He said that EPA did not intend to "stack the deck"; the Agency really wants to do a good job here.

Harvey Jeffries added that a NAS review panel was discussed; however, we simply could not go this route and meet the time schedule presented to us.

George Lauer asked if the papers would be available on the website?

Harvey Jeffries answered that they would be placed their following the initial peer review and acceptance.

Jeffrey West asked if there were selection criteria for the chair and the review panel, or was this simply going to be done internally at EPA?

Harvey Jeffries responded to Mr. West to send any information that he had and everything would be considered. He clarified that the information should be sent to Ned (Meyer), not to Tom Helms.

Jeffrey West inquired if he should ask the NARSTO community to contribute names and/or information?

Tom Helms replied, absolutely.

RAMP Discussion

Harvey Jeffries announced that even in Tom Moore's absence, STSWG still needed to move on with this discussion.

George Lauer asked who was actually funding the activities of the RAMPs?

Tom Helms responded that right now, EPA did not actually know this answer.

George Lauer again asked, do we assume that the RAMPs are going to be funded by EPA grant money, or some other pot of money (e.g., similar to OTAG)?

Diana Andrews replied that the states did not use any Title V money in OTAG.

Harvey Jeffries asked if EPA was considering public/private partnerships to fund the implementation process?

Tom Helms responded that EPA was not advocating this at this time; but, the Agency was not really ruling anything out at this time.

George Lauer stated that everyone must realize that there would be some new entities in this process that are not that well plugged into the system.

Discussion of RAMPs - Harvey Jeffries

-	Basically 5-9 RAMPs

-	Each RAMP would have a technical/modeling center to handle the technical issues (e.g.,	inventory development, modeling, analysis, etc.). Every state does not necessarily have to have a technical/modeling center.

John Silvasi noted that individual states would be contributing information to the RAMP. The individual states would still be doing their own specialized work, but would be funneling information to the RAMP level.

George Lauer again asked who would be funding these activities; was it going to be funded by OAQPS?

Harvey Jeffries responded that you must realize that there is a hierarchal approach to implementing these policies.

Steve Ziman interjected that as you do these types of analyses, states are going to find out that they do not have the data to run the models that are required by the RAMP.

Harvey Jeffries responded to Steve that he was not going to stop or prolong this decision. He stated that STSWG had to figure out how to do the best possible with the information that was currently available.

Steve Ziman replied that STSWG had the responsibility here to put the "buyer beware" caveat on this approach. STSWG is severely data limited, and we cannot sufficiently model these scenarios. He further stated that we could not stand behind these model results until we have better data.

*** Break ***

Joint Work Group Meeting

Joe Paisie began by announcing that Control Regions and Control Strategies will be the two basic categories that we were interested in discussing today. Everything that was discussed today would be relatable to one of these two issues. He noted that the matrix was an attempt to show the inter-relationships between each of the issue papers, relative to these two broad categories.

John Heuss inserted that he thought that integrated implementation would involve both control regions and control strategies.

Joe Paisie asked Mr. Heuss how he saw that working?

John Heuss responded that you would have regions that are local problems, you would have regions that are both PM and ozone problems, etc. You are going to have a whole suite of issues to deal with here.

Opportunity Matrix for Ozone, PM-Fine, and Regional Haze Integration - David Mobley

Purpose of the Matrix

-	To support development of Integrated Implementation and Control Strategies Issue Papers

-	To consolidate ozone and PM information into one table

-	To identify control opportunities and to show cross-cutting benefits of different control measures.

How the Matrix is Organized

-	Source Categories (used SCC approach)

-	Source Category emissions from the 1990 National Inventory

-	Control Opportunities under each source category

-	Relative control efficiencies for primary PM-fine, SOx, NH3, NOx and VOC

What the Control Efficiency Symbols Mean

Benefits	+++	-	> 80%

++	-	> 50%

+	-	0 to 50%

X	-	Reductions possible, but not quantified

Disbenefits	-

Multiple-Pollutant Benefits

-	Shading indicates reductions in both PM- and ozone-forming emissions,

-	At least a "+" in either:

-	NOx/VOC columns, or

-	Primary PM/SOx/NH3 columns, and

-	At least an "X" in corresponding other set of columns.

Sources of Data

-	OTAG

-	GCVTC

-	STAPPA/ALAPCO

-	Background documents for RIAs

-	Others, including OMS, states (Texas), and European studies on ammonia emissions

Further Work

-	Identify PM 2.5 versus PM-10 efficiencies

-	Identify Title II requirements

Comments

Submit comments or suggestions in writing with supporting documentation to:

Bob Lopez

Bureau of Air Management, Air Pollution Control

State of Wisconsin

101 S. Webster

Madison, WI 53703

phone: (608) 267-5284

fax:	(608) 267-0569

e-mail: lopezr@dnr.state.wi.us

David Mobley announced that there was a companion piece behind this document, which would come from the RIA document.

Rosalina Rodriguez reiterated that there were matrices that list the control strategies, their effectiveness and costs. You are correct in this information does exist in a single document - the RIA.

Harvey Jeffries asked what the purpose was of this paper. He said he had seen the matrix and was still confused. Was it simply to show that there were control techniques?

David Mobley responded yes, as well as to find out whether there were control techniques that work for multiple pollutants.

Pre-Sip RFP - Nina Dougherty

Introduction

-	Pre-SIP is reasonable further progress prior to SIP approval under the new/revised NAAQS

Links to Other Papers

-	RFP (3/13/97)

-	Rewards and Sanctions (2/13/97)

-	Transportation Conformity (begin drafted)

-	RFP Requirements in AOIs/AOVs (10/8/96)

-	RFP Metrics (10/16/96)

Working Assumptions

-	Paper is neutral on whether current nonattainment system is retained or the AOI/AOV concept is adopted.

-	Covers all areas that potentially violate or potentially contribute to a violation of the new/revised standards.

-	Does not address any changes to RFP requirements for current nonattainment areas as described in the Interim Implementation Policy (IIP).

Issues to be Discussed by Subgroup

(1)	When should pre-SIP RFP begin?

(2)	Where should pre-SIP RFP apply?

(3)	What should constitute pre-SIP RFP?

(4)	What is the authority for pre-SIP RFP?

(5)	Should PM, regional haze and ozone be treated the same or differently?

Issue 1. When should pre-SIP RFP begin?

-	The new/revised NAAQS promulgation

-	The date AOVs or nonattainment areas are proposed

-	The date AOVs or nonattainment areas are finalized

-	The date the RAMPS are set up

-	The date of preliminary AOI designation

-	The date of final AOI designation

Issue 2. Where should pre-SIP RFP apply?

-	Nationwide

-	Within XX miles of monitored NAAQS violation

-	AOVs, nonattainment areas and areas likely to violate or contribute to a violation of the new/revised standard

-	Preliminary AOIs

-	Final AOIs

Issue 3. What should constitute pre-SIP RFP?

-	Nothing additional (IIP, MACT, Acid Rain Program, etc.)

-	National measure (EPA adopted measures)

-	State planning efforts

-	Encourage early reductions through economic incentive program

-	Extend IIP requirements to more areas

-	Require a substantial reduction from an early baseline date for initial state RFP requirements (e.g., 15% rate of progress plans)

-	Require states tot adopt and implement rules as expeditiously as possible that will result in early emission reductions.

-	Time table requirements

Issue 4. What is the authority for pre-SIP RFP?

-	PSD regulations

-	Section 110(a) of the CAA (e.g., (2)(H))

-	Section 126 of the CAA

-	Section 172 of the CAA

Issue 5. Should PM, regional haze and ozone be treated the same of differently?

-	Yes, to have consistency

-	No, because ozone has more information than PM/Regional haze.

Bob Palzer suggested that the title be changed to "Interim Implementation Policy RFP".

David Mobley responded that the IIP was already underway, and thus this change was not viable.

Joe Paisie offered that if we change the title to reflect IIP, then we were begging the question of whether IIP is still open for discussion. The answer is no, the IIP is closed.

Robin Dunkins suggested changing the title to "Transitional Period RFP".

Joe Paisie said he liked that idea.

Reasonable Further Progress (RFP) - SIP Phase: Status Update - Sarah Peirce-Sandner

RFP:	2 Phases

pre-SIP Phase	SIP Phase

(This is the RFP-SIP Phase Issue Paper)

|------------------------------------|-------------------

Promulgation of	SIP Approved

New NAAQS

Objective of Update

-	Review progress to date on key issue #1:

-	Should RFP process be standardized nationwide? Customized at the AOI/AOV level? Or hybrid?

-	This is a work in progress - the work group has not completed discussion on this issue.

-	No work group consensus stated or implied.

Process for Addressing Issue #1

-	Standardized RFP process in place (e.g., adopted ozone RFP as model).

-	In order to evaluate the pros/cons of standardized vs. customized process, a "model" customized process must be assembled.

-	The work group has developed a "preliminary" customized model.

Key Characteristics of "Standardized" and "Customized"

-	Standardized

-	single, standard RFP metric (emissions)

-	a standard quantity/rate (3%/year) and type (VOC with later NOx substitution)

-	Customized

-	2 metrics: air quality and emissions reductions

-	Not yet reviewed by work group:

-	Actual metrics for air quality and emissions reductions

-	Degree that these metrics can be customized at the airshed basis

Assumption/Principles for the "Customized RFP" Process

-	The goal of the customized RFP process is to ensure measurable, periodic progress towards attaining the NAAQS by the applicable attainment date:

-	a subgroup may develop an alternate RFP process for instances where attainment by the attainment date appears likely.

-	The example process assumes that most SIPs will have multiple emission reduction programs, some of which are implemented in a sequential (step-wise) fashion.

Ms. Peirce-Sandner discussed the following two graphics:

-	Graph #1 - Initial RFP Development Process

-	Graph #2 - Iterative RFP Process (e.g., are you getting the reductions you thought you should get, based on the control strategy implemented?)

RFP-SIP Phase: Next Steps

-	Discussion of appropriate air quality and emission metrics, including any bounds to be placed on these metrics in the "customized process"

-	Rate, base year, frequency of demonstration, relationship to RH and secondary NAAQS

-	Issues identified at 2/97 FACA meeting

Control Strategies - Dan Johnson

Overview

-	Introduction

-	Mission Statement

-	Definitions

-	Principles

-	Working Assumptions

-	Key Issues

Mission Statement

-	This paper will recommend a process to be used by the responsible air quality planning authority for allocation of control responsibilities among national, prescribed, and discretionary required measures.

-	This issue paper will also attempt to produce lists of:

-	suggested national measures, and

-	suggested prescribed measures. Which the FACA Subcommittee should consider and potentially recommend to EPA.

Definitions

For the purpose of this Issue Paper the Control Strategies Subgroup will use the following standard terms to classify control requirements:

-	National measures

-	Prescribed measures

-	Mandatory reductions

-	Discretionary measures

-	Area(s) for control

It should be noted that, where appropriate, incentive-based programs may be used.

National Measures (e.g., federal motor vehicle plan)

-	Air quality improvement measures

-	Federally required nationwide

-	Applied without regard to air quality status

Prescribed Measures (e.g. RVP plan)

-	Air quality improvement measures

-	Federally required in a substantial area

-	Applied with regard to air quality status

Discretionary Measures

-	Federally enforceable air quality improvement measures

-	Selected by the air quality regulatory authority

-	Added to applicable national and prescribed measures in a plan to achieve air quality objectives

Mandatory Reductions

-	Total Federally enforceable control program necessary in an area to achieve the air quality objectives

Area(s) for Control

-	Area(s) within which emission source(s) will share, appropriately, in the responsibility to achieve an air quality objective (e.g., NAAQS, reasonable progress objective)

Principles

-	The Issue Paper will be prepared in accord with the content-related principles (February 20, 1997) adopted by the FACA Subcommittee.

Working Assumptions

-	Areas violating the revised ozone standard and/or particulate matter standard will be considered Areas of Violation (AOVs) in advance of or perhaps in lieu of nonattainment areas.

-	Class I areas with impairment will be treated as AOVs.

-	In response to an AOV, states, tribes, or multi-jurisdictional organizations (whichever is appropriate) will identify and Area(s) for Control.

-	When the Area(s) for Control is multi-jurisdictional, there will be an institutional mechanism that will, at a minimum, recommend to the EPA the appropriate allocation of emission reduction responsibility between states and tribes in a document called the Regional Implementation Plan (RIP).

-	New Source Review requirements will be addressed in a separate issue paper.

-	Integrated Implementation - placeholder.

Key Questions

-	Should there be additional measures or changes to the mix of those measures?

-	On what basis will they be determined?

-	Which measures should be adopted?

-	science

-	cost-effectiveness

-	achievability

-	public health

-	equity

-	input from the public

-	other

-	Should there be minimum requirements imposed as additional prescribed measures common to some or all Area(s) for Control (e.g., final AOI, preliminary AOI, AOV, other sub-national domains, or other domains)?

-	Which measures should be adopted?

-	Where should they be applied?

-	On what basis will they be determined?

-	science

-	cost-effectiveness

-	achievability

-	public health

-	equity

-	input from the public

-	other

-	How should the order of implementation be implemented?

-	How should the situation be handled where national measures are not implemented or are not timely?

-	What is the consequence to the regulatory agency (e.g., sanctions)?

-	For interstate, or State/Tribal Area(s) for Control, what (if any) guidelines should be used by the responsible air quality planning authority in assessing the mix of controls?

-	After answering each of the above questions, what implications are there for, or from, other issue papers?

*** LUNCH ***

Tom Moore - Roles and Responsibilities of RAMP Members

What should a RAMP do through its members?

-	Functions and duration RAMP-by-RAMP?

-	Functions and duration pollutant-by-pollutant?

-	Monitoring data collection/analysis coordination?

-	Emissions estimate preparation/refinement?

-	Modeling - level of effort? Precision of results?

-	Control Options - Clearinghouse or analyst?

Proposed Roles - Scientific Analysis

-	Fulfill technical needs of regional analyses

-	Define preliminary AOIs

-	Catalogue ambient and emissions data

-	Describe data gaps/limitations, the actions and time frame needed to improve

-	Develop work plan with time lines, technical work products and cost estimates.

Proposed Roles - Policy Development

-	Support political/policy - making decision processes.

-	Identify relevant time frames.

-	Quantify budget and technical staff resource needs.

-	Prepare draft "decision points" schedule for management?! As air quality analyses are performed.

-	Describe hierarchy and process of air quality control management.

RAMP Members' Responsibilities

-	To whom, what institutions.

-	Requirement for adequate level of effort.

-	Conflicts/synergies with related parochial programs.

George Lauer mentioned that there needed to be a provision for stakeholders to be involved in the technical aspects of RAMP development; it should not be limited to simply local, state and federal agencies.

Tom Moore stated that he did not disagree with this, but the initial intent was to have government agencies sitting as the voting bodies of the RAMP concept. There is no problem involving stakeholders, but they should not really be on the voting side of this.

Steve Ziman said there was some degree of credibility involved with being at the table from the very beginning.

Tom Moore acknowledged that he would rework this aspect of the statement. However, we have to separate the technical from the administrative aspects of the RAMP function. He clarified that he was not implying that any specific group supply the funding for the RAMP.

George Lauer added that there were a number of "models" from which you could draw information.

Cyril Durrenberger noted that each one of these models was different, however.

George Lauer agreed, and added that each one had its own successes and failures.

Tom Moore asked to have a list of these models sent to him, and he would try and incorporate them.

Specific Proposal - Aerometric Monitoring Coordination

-	Establish protocols, network design.

-	Develop specialized monitoring plans.

-	temporal and spatial coverage.

-	Propose network(s) and ambient reconciliation tools.

-	emissions

-	analytical "versions" or AOI "steps"

-	Control strategy testing

-	Maintenance demonstration

Specific Proposals - Follow Monitoring Example

-	Emissions Data

-	Modeling Analyses

-	Control Options Analyses

Straw-man on Modeling Tools - Ned Meyer

Bruce Hill asked if it was conceivable that EPA would become a central clearinghouse for these tools?

Harvey Jeffries responded that it was definitely possible with the Models-3 framework.

Bruce Hill mentioned that the OTAG Data Clearinghouse had been a real problem for his staff. We have not been able to get much useful information in a very timely manner.

Diana Andrews concurred that they had similar difficulties initially, but have seen improvement. Ms. Andrews continued that she also needed some input on the development of the emissions inventory and could use some guidance as well, on how to develop these numbers.

Ned Meyer noted that Chapter 5 summarizes the issues he thought were relevant for discussion by the FACA, and specifically STSWG. Essentially, this approach is a serial approach - where one looks at ozone, PM and regional haze in sequence, one after the other.

George Lauer added that he did not think that you could support this approach scientifically, because the episode times for PM and ozone do not often coincide..

Tom Moore asked, what if we did not like the tone of the questions at all? The way the RAMPs have worked has been through a partnership. Ned's (Meyer) document gives you a serial or parallel approach, and asks you to "buy in" or not "buy-in".

Ned Meyer reminded the STSWG that this was not EPA writing, that these were his own words.

Harvey Jeffries inserted that this paper had no life or role anywhere in the FACA process. Ted Russell is working on another paper, and we still have Chapter 5 of the Conceptual Model. Mr. Jeffries asked is we were going to write a separate paper, or one jointly with Mr. Russell?

Ted Russell replied that it was supposed to be a joint paper. Mr. Russell explained to Mr. Jeffries that STSWG was taking the lead from the science perspective, and that he was representing the NRSWG. Mr. Russell concluded that he envisioned STSWG's comments driving the effort that he was involved in.

Harvey Jeffries asked Tom Moore, who he was writing his paper for?

Tom Moore responded that he guessed he was standing on a soap box yelling.

Harvey Jeffries asked for clarification on what the work was that Mr. Moore was trying to accomplish? He stated that we had commissioned one paper (the one that Ted and I are writing). How do we incorporate all of the new, additional information?

Cyril Durrenberger also asked how was any of this information going to help us at the state level to implement the policy?

Harvey Jeffries replied that there were two parts of the implementation proposal. The first part comes in July 1997, and deals with the RAMPs. The second part deals with helping the states do SIPs, etc. (e.g., Phase II). He added that EPA needed to be able to take advantage of the information this group had to offer.

Cyril Durrenberger reiterated, that was what he was looking for; guidance and direction for the modeling/technical centers.

Harvey Jeffries asked if we were obligated as a Work Group to provide answers to the questions Ned (Meyer) has posed?

George Lauer responded that he viewed this as only a way to get our thought processes started.

Dan Weiss brought forward that he was still confused about how this effort is going to impact the July dates.

Harvey Jeffries clarified that this was for July 1998, not this coming July. We are discussing Phase II issues here.

John Silvasi noted that we obviously needed something prior to this date.

Harvey Jeffries responded that we could move forward with these issues given what we have right now. If Ned (Meyer) wanted to continue to move this forward on his own, then that is okay. Mr. Jeffries continued, the effort we make in STSWG must go toward our Work Group paper, and not STSWG cannot get bogged down on Ned's document. We would maintain an open door for Ned, and would help him wherever we could; but, we cannot finalize his document. We need to concentrate on our own paper.

Tom Moore indicated that he believed the original Tools Paper (Rao, Ziman, Moore, etc.) should be fitted into what we were currently trying to do.

S.T. Rao interjected that this group needed to deal with tools, and that this could be formulated under the Institutional Mechanisms paper.

Tom Moore responded that we can say whatever we want about models; however, if we did not address ambient monitoring and emissions, we would never have a better air quality management tool.

Harvey Jeffries replied that he had a hard time separating the models, data and institutional mechanisms.

Steve Ziman said to Harvey Jeffries that if you did not have the data to put into the models, then you really did not have a tool at all.

Tom Moore posed the question, what if we wrote a small, simple paper, which stated what needed to be done immediately in order to make a better decision up front? Then we could let EPA propose their Phase I guidance. From that point, hopefully the money will begin to flow and we could move on from there.

Harvey Jeffries asked Tom if he expected to see significant gains made within a year?

Tom Moore responded, no, but that he could see the framework coming into focus. For ozone, this issue is a slam dunk; but, for PM-2.5, ignorance is bliss.

Harvey Jeffries asked who generated the need for Ned's (Meyer) paper?

David Sanders answered that NRSWG was responsible for this effort. Mr. Sanders stated that with each Issue Paper a definition was needed, and this is one of the sticking points now with this paper - it really has no definition.

Harvey Jeffries questioned, was this a technical-only paper, or did it include some policy effort? Mr. Jeffries questioned if Mr. Sanders was saying that Ned's paper needs a "preamble" to explain why you wanted to do this in the first place?

Tom Moore replied, yes.

Harvey Jeffries added, okay, then let us create a definition for the paper, and then we could go back and forth with Robin Dunkins as we developed the concept.

John Silvasi - RFP Discussion

Underlying Principles/Assumptions of Customized Process

-	Goal - ensure measurable, periodic progress toward attaining NAAQS by applicable date.

-	AOI would tailor type, quantity and rate of emission reductions (compared to e.g., 3%/yr VOC reductions).

-	Alternate process to be developed for areas where attainment is difficult.

-	Start with plan to achieve attainment with step-wise emission reduction programs

-	Logic: ID emission reductions needed and track progress each step of the way.

-	Implement strategy and periodically assess progress through metrics (assume 2 kinds of metrics - emissions and air quality).

-	whether both metrics have been achieved, and

-	analysis of relative successes and failures of one or both metrics.

-	Several next steps could occur:

-	mid-course corrections

-	reevaluate

-	implement contingency measure

-	catch-up implementation

-	sanctions/penalties

3 Questions for STSWG:

(1)	Length of time needed for to determine air quality trends and interval for assessing changes in air quality?

(2)	Preference for RFP metrics based on scientific principles?

-	Technical considerations (uncertainty, data requirements, etc.).

-	Uses of metric (prospective/retrospective, trading, evaluating SIP relaxations,	etc.).

-	Tiering of metrics (primary and secondary).

(3)	What tools are available for removing the effect of meteorology?

Starter List of Metrics:

-	Emission Reductions

-	precursors (ozone)

-	direct and precursors (PM-fines)

-	Weighting of emission reductions for effectiveness (e.g, reactivity, distance,	etc.).

-	Air quality - concentrations (several forms), including precursor concentrations

-	Population weighted exposure

-	Land weighted concentrations

-	persistence weighting

-	Different metrics for PM

-	End-loaded strategies (investment, adoption of rules) (for example, installing a light rail transit system - which could take 5-10 years for a region to see air quality benefits for the money invested).

-	Time integration of concentrations

Harvey Jeffries posed the questions: What is the length of time we need; what is our preferred metric; and how do we account for meteorology? These are the issues we need to accomplish today.

Tom Helms said that we needed a definition for success for these discussions; something that Sarah (Peirce-Sandner) could take back that represented concrete scientific suggestions to her group.

Harvey Jeffries interjected that there were certain questions that could not be addressed at this point until we did some analyses.

Cyril Durrenberger indicated that we could certainly give some examples for the group; but that he did not see how we could solve the customized RFP issue.

George Lauer asked if we were assuming the AOI/AOV case or the nonattainment/attainment case? It would greatly affect the answers that we provide to Sarah.

Sarah Peirce-Sandner said that she would assume that STSWG should deal with the AOI/AOV construct.

George Lauer acknowledged that we were then bound to the customized approach/process.

Sarah Peirce-Sandner responded that a customized approach implies a high degree of flexibility.

Cyril Durrenberger added that we would have to customize if we are going to measure RFP.

Harvey Jeffries asked if you could, in fact, detect a trend in the current 15 years of ozone data?

David Chock responded that he thought it was possible to "fix" the meteorology and then analyze the trend within the data set. He noted that you could do site-by-site regressions for a number of individual years. Perhaps three (3) years could be sufficient to diagnose a trend at a given site.

Steve Ziman interjected that you had to make sure you picked monitors that were not influenced by very localized effects. You are essentially looking at the noise detection limits for the time series.

George Lauer asked, what if we took 1988 as an example. Would we have a realistic trend here? Therefore, I question whether a 3-year analysis would be sufficient?

David Chock responded that you had to look at the error bars around your prediction. If your error was large, then you may have to discount your prediction. Regardless of the approach,

Mr. Chock believed the technology was available to determine the trend in time series data, and to successfully remove this trend.

S.T. Rao inserted that we needed to connect air quality to emissions. Mr. Rao questioned whether there was a consensus on this statement? He said this was a fundamental change in the way we had been doing business. Are we, in fact, reducing emissions to improve air quality? He asked was this what we were attempting to do?

George Lauer said he agreed except for in a region that was way out on the fringes of the sigma curve, where they might have to do a good deal of emissions reductions prior to seeing any improvement in air quality.

Steve Ziman disagreed with that statement. He stated that it depends on what metric you choose, and how you implement it.

S.T. Rao replied that he was not concerned with the metric here. He asked, did STSWG members think that air quality was linked to emissions? He questioned if the group could agree on this basic connection? He said that meteorology is variable, much more so than chemistry. However, all of this is beside the point. We must focus on the cause and effect.

George Lauer responded, perhaps the question should be restated to "over what time and space scales" should we be looking at?

S.T. Rao replied that would be the scale of weather, and we do understand this very well.

Harvey Jeffries asked if there was a general consensus that progress should be measured against air quality improvement and emissions reductions?

Bruce Hill replied that the environmental community was not very interested in this approach. He said that it generally took too long to show a trend and make the necessary corrections.

Tom Moore talked about the GCVTC results, and indicated that a large number of receptor sites, a number of years of data were required to reach those conclusions. He stated that you could turn off all of the SO2 sources in the region, and the signal was not detectable at most of the sites. Mr. Moore indicated that he was in favor of this in principle, as long as we were careful about determining the metric.

Harvey Jeffries inquired if RFP could be done entirely on emissions or did we need something different?

Cyril Durrenberger responded, something different.

Diana Andrews also replied, something different.

Cyril Durrenberger added that you needed a combination of metrics; you needed to look at air quality improvements and emission reductions. He continued saying that you could be getting tons of reductions and really be showing no improvement in air quality.

Bruce Hill asked how this differs from the current attainment demonstration?

Steve Ziman answered that current attainment demonstrations deal with only reducing the peak concentrations below the ambient standards. This new approach is trying to provide general regional improvements in ambient air quality.

John Silvasi interjected that we were all looking at air quality as a metric, as something that is new and radical. However, we have been doing this for years in terms of setting attainment. Therefore, this was not really a new, radical idea.

Sarah Peirce-Sandner noted that scientific support of any part of this process would be useful. She asked would it be possible to get a one-pager on each of the questions in 2-4 weeks? She then asked if the interim air quality metric was really necessary?

Cyril Durrenberger responded, absolutely.

S.T. Rao inserted that you could not define a percentage improvement per year in air quality like you are currently doing for emissions.

Bruce Hill said that it seems we have put the cart before the horse. He stated that we should be asking whether we could do it, prior to asking whether we should do it.

Harvey Jeffries commented that they needed to discuss how to proceed with these issues, in order to get Sarah (Peirce-Sandner) some answers. He asked if John (Silvasi), Cyril (Durrenberger) and Steve (Ziman) could summarize what had been discussed here today, and then get back to the group? If so, once the group reviews it, we could send it over to Sarah.

John Silvasi acknowledged that they could do this.

*** BREAK ***

Meteorological Variability - David Chock

Extreme-value distribution approach

Mr. Chock stated that when designing the standard, we must take into account the meteorological variability. Otherwise, we would not have the ability to achieve the standard.

Diana Andrews commented that she did not see how this new standard was going to help.

David Chock answered that by using the proposed standard you reduce the magnitude of the fluctuation, but it does not remove the fluctuation. There is still variability, it was just shifted towards the extremes of the distribution using the proposed standard.

Steve Ziman said we have to accept the fact that there will be fluctuations from year to year. People will be exposed to dirty air; however, we must account for this variability.

Tom Moore noted that this metric was even more "synthetic" than the current approach being used for the existing 1-hour standard. Mr. Moore stated that you could not overshoot with this short-term standard.

George Lauer asked how far do you go? How far into the tails of the distribution does one go?

Harvey Jeffries inquired what the specifics were of this particular approach?

David Chock said it was a t-test of the third highest annual value. He explained that you take the three annual 3rd highest values and then you determine the mean.

Harvey Jeffries wondered if he had any examples of this because he said he was confused.

S.T. Rao inserted that he would like to see this issue from an air quality management perspective, so that we would be able to evaluate the cause and effect relationships for air quality.

Harvey Jeffries added that this needed to be done over again, and some examples and supporting data need to be added.

Jeffrey West stated that we were actually dealing with two separate tools here: S.T. is removing long-term trends, and David Chock is looking at episodic meteorological variability.

Prescribed Burning, Wildland Fire Issues - Bob Palzer

-	Address the need for increased prescribed burning to prevent an increase in wildland fires.

-	Ad Hoc Work Groups are currently working under the auspices of WESTAR; however, EPA has gotten involved and the involvement has widened.

David Kelly said that wildfires are naturally occurring events. They are required for good forest management. Without fires, the forest undergrowth gets out of control and leads to devastating consequences. Thus, we need to return to the more natural wildland fires, as opposed to "preventing" these. Mr. Kelly stated that one way to start this process was through prescribed

burning, until we can return the process to a more natural procedure. Currently, without prescribed burning, we would continue to experience deadly wildland fires.

Bob Palzer interjected that currently, wildfires were covered under the Natural Events Policy, and were exempt from NAAQS violations. He continued that some FLMs were interested in also excluding prescribed burning from NAAQS violations, however. Nonetheless, some of the prescribed burning was taking place at the worst meteorological conditions.

George Lauer asked if there was any indication of the particle sizes for wild fires?

Bob Palzer responded that generally it is in the PM-2.5 range and smaller.

Tom Moore added that we were setting a standard based on health effects, which was set in regions where wild fires do not occur. The Forest Service and the FLMs who chose to suppress fires should not get a free ride here regarding emissions.

George Lauer inserted that this smells like a policy issue, and not a science question.

Tom Moore remarked to George that it is a science issue.

Harvey Jeffries asked if it is possible to determine the PM from the burns from other sources?

George Lauer responded sure, we have done this in the Washington State area.

Bob Palzer replied that he respectfully disagreed. He stated that he had lived in the Oregon region, and was very familiar with Chemical Mass Balance techniques used to do this speciation, and you could not tell forest fire particles from other wood burning (e.g., wood stoves, fireplaces, wood-fired boilers, etc.).

George Lauer acknowledged that he would agree with that; you could not determine wood from wood. But you could determine wood smoke from other sources of PM-fines?

Tom Moore stated that some areas do have Smoke Management Plans; the Pacific Northwest does, but California has not done a very good job here.

George Lauer inserted that fire is a natural occurrence; the forest ecosystems need this.

Bob Palzer sighted an example from Medford, OR, which showed a reduction from 350 g/m3 to around a 100 g/m3 for a reduction in wood burning in wood stoves, boilers and agricultural practices.

Tom Moore added that burning needed to incorporate meteorology and the annual cycle of emissions, prior to establishing a policy.

In summary, Harvey Jeffries asked Tom Moore to write a "one-pager", which summarized the wildfire issue, and forward it to the Work Group for discussion.

Tom Helms thanked the participants for being at the meeting, and adjourned the meeting.