Draft Summary of the Federal Advisory Committee Act (FACA)

Science and Technical Support Work Group Meeting

Mutual Building, Tom Helms' Office

April 29, 1997

Durham, North Carolina

The Science and Technical Support Work Group (STSWG) of the FACA Subcommittee met on Tuesday, April 29, 1997 in Durham, North Carolina. A list of participants and a summary of the meeting follows.

Work Group Participants

Name	Affiliation

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

Diana Andrews	Kentucky DEP

Kirit Chaudhari	Virginia DEQ

David Chock	Ford Motor Company

Cyril Durrenberger	TNRCC

Tom Moore	Arizona

Jeffrey West	GPU Services Corporation

Work Group Members Not Participating

Tom Helms, Co-Chair	U.S. EPA

John Cabaniss	AIAM

Glen Cass	Cal Tech

John Core	WESTAR

Ellis Cowling	SOS

Bruce Hill	Appalachian Mountain Club

Jay Hudson	Santee Cooper

David Kelly	Navajo EPA

George Lauer	ARCO

Dave McNeill	Utah DEQ

Rich Poirot	Vermont

S.T. Rao	N.Y. Department of Environmental Conservation

Jay Rosenthal	Navy

Mark Scruggs	DOI

Jay Turner	DOT

Manop Vanichchagorn	Louisiana DEQ

Dan Weiss	Cinergy Corporation

Steve Ziman	Chevron Corporation

Non-Work Group Participants

Bob Wayland, SAIC; Jeff Butensky and Bob Judge, U.S. EPA/Region 1; Ned Meyer, U.S. EPA/AQMG; Bill Kuykendal, U.S. EPA/EFIG; Robin Dunkins and Charlene Spells, U.S. EPA/IPSG; David Sanders, U.S. EPA/OPSG.

Summary of the Meeting

Introduction

David Sanders began by noting that Tom Helms and John Silvasi were off at STAPPA/ALAPCO. He also stated that subgroup calls were started last week for RFP (John Silvasi), Meteorological Variability, and the joint paper with NRSWG.

RFP Issues

David noted that three issues had been put forward: Frequency Interval, Metrics and Meteorological Variability. He stated that the first two issues were lumped together and that Meteorological Variability was done separately. He asked Cyril Durrenberger if he would begin the discussion.

Cyril Durrenberger began by stating (with respect to Metrics for the air quality part of RFP) that we had not looked at the emissions part of this. He stated that (1) we should have a minimum of three years, or perhaps longer, depending on what we come up with regarding meteorological variability, and that perhaps five or six years would be best; (2) we should have a meteorological normalization procedure (i.e., t-test, or something like David Chock's effort; (3) we should look at the design value as the Metric; (4) exposure-based Metrics would be presented in a paper written by himself and Jim Smith, which should acknowledge time, space, and interannual variability; (5) we should look at population exposure where appropriate. He noted that some ideas had been discarded but nothing had been finalized. The approach could be used with both planning and tracking (e.g., modeling and monitoring, respectively), and that we need to minimize exposure. This could be done by using these last two Metrics. We need to establish some iterative type of approach (e.g., 6-10 year cycles), which can be evaluated over time. The Metrics can be used to track progress, and also can be used for planning. He suggested that individuals look at the notes as they come out and remember that they are a straw man to take pot shots at.

Harvey Jeffries asked where the paper was that he (Cyril) and Jim Smith had written?

Cyril Durrenberger responded that he had passed it along to John Silvasi, but could not send it to anyone else. It is scheduled to be presented at the AWMA conference in June, and basically discusses eight different metrics. Perhaps population is a pretty good metric; however, John Silvasi would like to run it by some of his health effects people.

Harvey Jeffries asked Cyril if he could delineate between the exposure and population methods?

Cyril Durrenberger responded that exposure looks at concentration, hours and space, whereas population looks at these relative to population exposure. Take the LMOS case for an example. For a large part the LMOS area, there are not very many people living along the shores of Lake Michigan. However, from the spatial extent, the whole region is in nonattainment. This also affects the design value as well.

Ned Meyer asked Cyril if he would you use air quality data to make these determinations?

Cyril Durrenberger responded that they would use models; both prospectively and retrospectively.

Tom Moore inquired as to whether or not this meant that it was expected that the boundaries of the AOIs and AOVs would be comparable to the current nonattainment areas?

Cyril Durrenberger responded that it depended on how one sets the standard. Some of this has been done in the OTAG work. The area covered may actually be bigger than the AOV, especially if one goes to something slightly lower than the standard. We would hope that the control programs would reduce the AOIs down to small, workable entities. We are really trying to control ozone and reduce its spatial extent.

Harvey Jeffries asked if these Metrics can be used for trading?

Cyril Durrenberger responded that he hadn't addressed this yet. You might want to use it to exclude regions for trading. We need to write this up, and have everyone take a look at it. We need to make sure that everyone clearly understands what we are proposing.

David Sanders stated that he was still confused with 'prospective' and 'retrospective'.

Cyril Durrenberger explained that 'prospective' is planning and that 'retrospective' is tracking (e.g., hindsight).

Harvey Jeffries noted that Cyril had only talked about one question.

Cyril Durrenberger responded that they had decided to talk about air quality first, and then move on to emissions.

David Sanders asked if Cyril and Steve Ziman were saying that the Emissions Metric, as a primary driver, was not all that important?

Cyril Durrenberger responded that he would not say that it was not important , but that they needed to look at the emissions records.

Harvey Jeffries inquired as to whether or not he had discussed emissions inventories yet?

Cyril Durrenberger responded that they needed to look at emissions inventories, and that they really had not done anything yet. Steve and I thought that we really needed to address the air quality metric first, and confirm that we are getting the actual reductions that we thought we were. We just don't have sufficient monitoring yet (especially for VOCs) to address an emissions metric, and for VOCs, we really only have the PAMS network, which is extremely limited.

Harvey Jeffries asked how much effort had gone into analyzing the PAMS data?

Cyril Durrenberger responded that they had done some of that, but that they really needed to delve into it further. We need to look for trends over time, and I don't know if anyone has already done this. One really needs to look at some of the ratios over time (e.g., NOx/NOy, CO/NOx, etc.). We have had PAMS data in Houston since 1993, and we are starting to look at trends over this period. We will have to be very careful with the analysis.

Harvey Jeffries commented regarding the normalization of meteorological procedures, stating that it was similar to what Bruce Hill and his group were doing. I think we basically have a call here for David Chock to present some more detailed examples for the group.

Cyril Durrenberger agreed.

David Chock responded that he would provide the information, but wondered when would be the best time?

Harvey Jeffries interjected that there wouldn't be a lot of STSWG people present for the May face-to-face, and that it would probably be June before they could get back together.

David Chock emphasized that he would definitely get this out before then, and volunteered to look at data for the respective regions if they would send it to him.

Harvey Jeffries asked for the date of the June meetings?

David Sanders said that he thought they were scheduled for 9-11 June in RTP. He then directed that they move on to the next agenda item: meteorological variability. He asked David Chock to give an update since neither Steve Ziman nor S.T. Rao were present.

David Chock stated that they had discussed different approaches; somehow freezing the meteorology, based on observations, to remove the trend in the time series. He noted that they had discussed the pros and cons of the different approaches and indicated that it was possible that the final version might be some type of hybrid.

Harvey Jeffries questioned regarding the term 'freezing,' as to whether or not they were really talking about standardizing the meteorology?

David Chock said absolutely!

Harvey Jeffries noted that he thought that one would develop some type of regression.

David Chock responded that it includes a regression, and that it would establish a regression between ozone and a set of meteorological variables.

David Sanders asked what were the differences between his approach and S.T. Rao's approach?

David Chock responded that Rao was looking at long-term variability, and removing these types of fluctuations (e.g., temperature).

Harvey Jeffries interjected that Rao was filtering in time, and separating bandwidths, and then analyzing the long-term component, which is simply a temporal filtering technique.

David Chock stated that he thought that Rao's approach contained some contamination.

Harvey Jeffries concurred and said that they were trying to get some funding for a Ph.D. student to work on this subject. It would involve simultaneous delineation of the spatial and temporal components. This area of analysis is evolving, and it will take some time to work it out.

David Chock noted that cross-contamination from year to year is a very real problem. S.T. Rao's approach does not take this year to year variation into account, because it simply lumps all of the years together.

Tom Moore stated that he would be careful about interchanging ozone and PM in these discussions. PM results from many direct emissions from mobile, area and point sources.

Harvey Jeffries said that he thought that this rested upon having some concrete evidence. Addressing David, he said that this revolves on your providing some examples, and a lot of explaining. I think you need to get together the papers you have published, and distribute these, as well as compiling a "trends analysis 101" type of approach. We need some really good examples of how this works, and how it can be applied.

David Sanders concurred that was exactly what was needed. He noted that Tom Helms had discussed this with him as well and that John Silvasi had suggested the establishment of a set of principles that could be derived from the notes from these subgroup conference calls .

Harvey Jeffries interjected that this sounded an awful lot like a conceptual model.

David Sanders said that he hoped that it wouldn't turn into another one of those!

Harvey Jeffries emphasized that it was necessary to keep bouncing this back and forth within the subgroup until they were comfortable with it, and then forward it to the policy groups.

Issue Papers on Modeling Requirements

David Sanders commented that he had received (from Robin Dunkins) the first draft of the paper that Ted Russell had drafted. He noted that Ted had changed the title, as was discussed during the previous week's call. He asked Harvey Jeffries to lead the discussion.

Harvey Jeffries began by stating that Ted had the lead on this, and that this was a paper for the NRSWG. However, he noted that Ted was working closely with them and other individuals. This paper has the general attention to the other Issue Papers, so that the reader can see where it fits in with respect to the other papers. It's purpose is to discuss the use of air quality models with various issues. The current title is:

"The Modeling Process and Emissions Inventories: Their Availability, Evaluation, Use and Limitations"

Issue 1.0	Current models have limitations.

Issue 1.0a	Future models will have limitations.

Issue 2.0	Integrated implementation will place new demands on air quality modeling capabilities. Are the tools currently, or soon, available to deal with the envisioned uses? Further, is there guidance on how to proceed if the desired tools are not available?

Issue 3.0	New approaches to RFP may involve both the analysis of emissions estimates as well as changes in air quality. Setting air quality goals, as well as the analysis of meeting those goals, may involve modeling and emissions inventory analyses beyond the current approach.

Issue 4.0	It is believed by many, in the regulatory, regulated and scientific communities, that the modeling process is currently flawed, and that too much is expected from the models. Uncertainties are not well characterized or expressed. Further, the current process is too open and prone to gaming. What are those flaws, which are readily solvable, and how should we proceed? What should we expect, and not expect, from air quality models? How can gaming be minimized?

Issue 5.0	Modeling and emission inventory development are resource intensive. Necessary resources include skilled personnel as well as computational facilities. These are not always available within the constraints of the air quality management process.

Cyril Durrenberger commented that all five issues apply equally well to emissions inventories and to modeling. He further stated that emission inventory techniques themselves involve a great deal of uncertainty.

Ned Meyer asked where one would put regionality and the difficulty of changing institutional mechanisms?

Harvey Jeffries interjected that he was basically providing a group of statements in response to the issues that he had raised. Modeling should be viewed as a process (see statements #1 and #2)

Ned Meyer stated that he thought that they were facing a type of modeling that they hadn't attempted to do before, and that he was concerned.

Harvey Jeffries responded that he was correct, and that this issue had not been addressed in the paper. This is in support of the integrated implementation paper, and perhaps it should address some of this.

David Sanders stated that he had compiled a separate list of key issues, which were different from what Ted had presented. Ted has mentioned meteorology, grid resolution, etc., and these issues really do not appear here.

Harvey Jeffries commented that he had a much more abstract understanding of modeling in the document. It is not how to do grid-scale modeling activities, but rather the first level is more on the limitations we have with models in the current world. That is not to say that we cannot push this paper further down into the details. He has a good fundamental understanding of the modeling limitations; perhaps we need to delve more into the problems associated with modeling. Where is the agency on this?

Ned Meyer stated that he thought that they had already started to move toward the weight of evidence, and that had current standards been maintained, then we would have used this for a demonstration tool.

Cyril Durrenberger asked if this was a process question? (A modeling tool), are we providing only directional type guidance, because of the lack of certainty? This is why we need an iterative process.

Ned Meyer asked for clarification. By process, do you mean a series of best guesses in conjunction with other analyses, which can involve mid-course corrections?

Harvey Jeffries said yes, exactly. I think he means this process will require many more forward and backward steps to build confidence and credibility in the approach that you are currently taking.

Cyril Durrenberger suggested that a sixth issue, the institutional aspects, needed to be included. Who is going to do what? Who will have the technical capabilities?

Harvey Jeffries added that it does not say much about the availability of tools.

Tom Moore responded that these are rules and responsibilities of RAMP members - There needs to be an issue paper on this, or it needs to be folded into the integrated Implementation paper in great detail. This latter paper is already large, and I would like to see this information go somewhere else.

Harvey Jeffries asked if Robin was still present? What is the target audience for this paper and what are the uses and limitations of how you do modeling? This is a fairly high- level, abstract approach, which is different from the institutional requirements of how you operationally do this process. Is that what we want this paper to do? Do only one, or both? Should we spin off a separate paper to deal with RAMP member responsibilities?

Robin Dunkins responded that he didn't think this needed to be in the paper at this time.

Harvey Jeffries asked Robin to clarify the role of Ted's paper.

Robin Dunkins responded that the purpose was to identify or provide recommendations on what modeling tools would be available to assist states in defining their control strategies; additionally, to help states understand the limitations of these tools, and what can be used to support/replace Models-3?

Harvey Jeffries stated that this is a more abstract paper than that.

Tom Moore interjected that they were not asking the right questions here. The limitations are 90% of what we are discussing, and there is very little "meat" to use for guidance. Ned Meyer is correct that the agency needs some guidance on some of these issues.

Robin Dunkins asked whether or not he was saying that Ted's paper had missed the point?

Harvey Jeffries said no, but that it would take some time before the paper could include all the questions that had been raised by Ned Meyer and Tom Moore.

Tom Moore commented that the role of RAMP members is applicable to everyone, except the national EPA. Even the regional offices will be intimately involved in the RAMP process. We, at the state level, will be involved in the practical implementation of the RAMP process.

Harvey Jeffries said that he knew that John Seitz believes in this approach. OAQPS will have a limited involvement in the local RAMP process. He envisions the regional offices taking this role.

Robin Dunkins responded that they should hold off pursuing that issue for now. He would look into it and get back to them.

Jeffrey West asked what was the relationship of this paper to Ned's straw man which was issued on March 5, 1997?

Harvey Jeffries responded that was an internal document for EPA; Ted's document was prepared directly for NRSWG. There is this issue that Ted is discussing, which is using models in regulatory issues, and there is a chance that Ted's effort is simply too abstract. You could say that Ned has provided us a mechanism for using modeling in regulatory issues, and perhaps we could ask Ted to marry his paper to Ned's original concepts. Is that where you were going?

Jeffrey West said exactly.

Tom Moore commented that Ned's paper gives rather cursory treatment to some very complex issues. However, the goal here is to get some outside commentary on these issues.

Harvey Jeffries noted that they had decided not to flesh out Ned's document. We declined to answer the questions in the back of Ned's document.

Tom Moore agreed.

David Sanders interjected that the next call was scheduled for May 2, 1997, from 1:00 - 2:30. He further stated that Ted wanted to do the paper primarily by E-mail, and that Robin Dunkins would be in charge of leading the effort. He also noted that Harvey had suggested that they have a short two page summary in time for the June meeting. He asked if this had been scuttled?

Harvey Jeffries said absolutely not. This paper has not been presented to the FACA yet. This presentation of the issues must be summarized prior to the June meeting and presented to the FACA.

Tom Moore asked if he could send in a page and half summary of the rules and responsibilities. This would give us two pieces of information to work from. Then the powers that be can work from this.

Harvey Jeffries said that would be fine. We could also say that there are three clusters of issues: Ted is dealing with the uses and abuses of modeling, and you are dealing with the institutional issues.

David Chock asked Harvey if he would repeat the three issues.

Harvey Jeffries responded that availability is the original issue on the table. What are we going to do if Models-3 is available? We need to have the Models-3 people come in June and explain to us just where we are. The other issues are uses/evaluations and limitations.

Tom Moore interjected that he was interested in what was expected from RAMP members? Also, once you have model results, how do you make sure that control strategies are working and accomplishing the desired goals?

Report on the source attribution workshop - Bob Wayland

Bob Wayland reported that the Source Attribution Workshop had been scheduled for July 16-18, 1997 at the EPA ERC Building on Alexander Drive. Mr. Wayland indicated that each of the 10 presenters had been contacted, and that they had agreed to make a presentation at the meeting. Additionally, Mr. Wayland said that Ken Demerjian had been contacted to be the Chair of the Peer Review Panel; however, Mr. Demerjian had not accepted the position at this time.

David Sanders thanked the participants for their support, and indicated that we would have another call on Tuesday, May 13, 1997.