Draft Summary of the Federal Advisory Committee Act (FACA)

Science and Technical Support Work Group Meeting

Mutual Building, Tom Helms' Office

June 3, 1997

Durham, North Carolina

The Science and Technical Support Work Group (STSWG) of the FACA Subcommittee met on Tuesday, June 3, 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

John Cabaniss	AIAM

Glen Cass	Cal Tech

Kirit Chaudhari	Virginia DEQ

David Chock	Ford Motor Company

Ellis Cowling	SOS

Russell Koch	Technical Coatings Laboratory

George Lauer	ARCO

Dave McNeill	Utah DEQ

Mark Scruggs	DOI

Steve Ziman	Chevron Corporation

Work Group Members Not Participating

Tom Helms, Co-Chair	U.S. EPA

Diana Andrews	Kentucky DEP

John Core	WESTAR

Cyril Durrenberger	TNRCC

Bruce Hill	Appalachian Mountain Club

Jay Hudson	Santee Cooper

David Kelly	Navajo EPA

Tom Moore	Arizona

Rich Poirot	Vermont

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

Jay Rosenthal	Navy

Jay Turner	DOT

Manop Vanichchagorn	Louisiana DEQ

Dan Weiss	Cinergy Corporation

Jeffrey West	GPU Services Corporation

Non-Work Group Participants

Bob Wayland, SAIC; Pradeep Saxena, EPRI; Cynthia Marvin and Don McNerney, CARB; Tom Murphy, Santa Barbara; Bob Judge, U.S. EPA/Region 1; Ken Schere and Jim Vickery, U.S. EPA/NERL; Harvey Richmond, U.S. EPA; Tom Braverman and Ned Meyer, U.S. EPA/AQMG; Bill Kuykendal, U.S. EPA/EFIG; Tom Rosendahl, U.S. EPA/IPSG; David Sanders and John Silvasi, U.S. EPA/OPSG.

Summary of the Meeting

John Silvasi opened the meeting, and stated that the Reasonable Further Progress (RFP) update would be the key agenda item for this call. He stated that his goal for success today would be to get the following information: (1) agree to send recommendations on both meteorological variability and RFP metrics to the RFP subgroup and the National and Regional Strategies Work Group (NRSWG), where we characterize the different opinions of this Work Group.

Harvey Jeffries concurred with this approach.

David Sanders announced that the Work Group has two new members, which have been added for today's call: (1) Russell Koch, Technical Coating Laboratory; and, (2) Jeffrey McGilivray, background in physics, legislator for the State of New Hampshire).

Harvey Jeffries questioned when the full RFP issue was going back to the Full Subcommittee?

John Silvasi responded that this was not scheduled to occur until the August FACA meeting in Portland, Oregon.

Harvey Jeffries voiced agreement with this idea, and stated that the STSWG would then have adequate time to discuss this paper next week at the Face-to-Face meeting in Durham, and then revisit this issue prior to the August FACA meeting.

David Sanders replied that the Work Group must make sure that it completes the RFP issues prior to the August FACA meeting.

John Silvasi interjected that there would also be a discussion at the Face-to-Face meeting next week on the EPA's Models-3 program. He stated that Joan Novak had called him this morning and indicated that she (and probably Robin Dennis) would attend next week's meeting. Mr. Silvasi also said that Bill Benjey would also be there to discuss any emissions-related questions.

Harvey Jeffries responded that he understood that Ms. Novak was also coming to the meetings next week to participate in the Work Group's discussions.

Steve Ziman questioned if there would be a similar procedure for calling in for the afternoon meeting next week? He said that he had already received the call-in number for the morning meetings.

David Sanders stated that the line was reserved for the entire day on Monday, June 9, 1997. Mr. Sanders said he forward the necessary information to Mr. Ziman.

George Lauer asked if Mr. Sanders could also send him the call-in information.

David Sanders acknowledged that he would do this.

Reasonable Further Progress (RFP) Updates

John Silvasi began the RFP update by saying that these documents were intentionally left off of the Bulletin Board Service (BBS), until the entire STSWG had the opportunity to review information. He indicated that the documents were either mailed electronically or sent by facsimile to each member of the STSWG. Mr. Silvasi reminded everyone of how he had defined success earlier on this call, and asked Mr. Ziman to lead the discussion of the RFP Metrics Paper.

Steve Ziman stated that everyone had be asked to review this material prior to today's call. He said that he and Cyril Durrenberger had attempted to look at the different metrics which were available to be used both prospectively and retrospectively.

Harvey Jeffries asked for a clarification on the issue of air quality versus emissions metrics. He questioned whether Mr. Ziman was only considering air quality metrics, and not an emissions metrics?

Steve Ziman responded that the recommendation was for an air quality metric; but, it did not decouple these metrics from the emissions metrics. Mr. Ziman concluded that these air quality metrics by themselves would still have to be utilized such that in the planing processes certain control measures would have to be implemented. He said that this strategy would result in an emissions reduction, but the order and the implementation of the metrics would be driven by changes in ambient air quality.

George Lauer asked if this paper was simply a menu of options for the local areas to choose from?

Steve Ziman acknowledged his assessment as being more or less correct. Mr. Ziman stated that he and Cyril were recommending a hierarchal approach, with the most desirable air quality metric being a population-weighted exposure metric. When using this metric, there would be some requirements that would assess the progress of the air quality attainment in the area. The second metric is similar to the first, and is an areal exposure metric. The targeted area would be the AOI and the AOV. The approach would be both prospective and retrospective, in order to determine the necessary reductions, and to assess whether you were getting the expected reductions. Modeling is not the panacea in either of these approaches - monitoring must be used in conjunction with the modeling.

Harvey Jeffries asked if the metrics were workable with ozone, particulate matter or both?

Steve Ziman responded that in general, these approaches apply to all criteria pollutants. Visibility is not a criteria pollutant. Conceptually, this approach should apply to PM-fines; however, to date, we do not realistically have the data to carry out this approach for PM-fines. We to a certain extent do have this level of comfort with ozone.

Don McNerney questioned the efficacy of a population-weighting metric?

Steve Ziman replied that it was very similar to what CARB was currently doing in California. Mr. Ziman stressed that the approach assesses how well a region is moving towards attainment. He said the ultimate goal was to reduce exposure as quickly as possible as you move toward attainment. The key here is that you are moving towards attainment. Mr. Ziman concluded his discussion of the approaches by talking about the design value consideration. However, he stated that this approach was not representative of the entire domain, and was thus not given a great deal of consideration.

John Silvasi reminded Mr. Ziman that the group had changed the name of this metric to be the "peak value concentration" as opposed to design value consideration.

Steve Ziman also told the STSWG membership that the RFP subgroup could not recommend that a stand alone metric be prescribed for set annual reductions (e.g., 3% per year, etc.).

Harvey Jeffries concurred, stating that you cannot verify that you are getting the reductions that you expected. Mr. Jeffries indicated that there appeared to be a missing piece in Mr. Ziman's methodology. He said that one of the air quality metrics should be a metric that was more closely related to primary emissions. Mr. Jeffries stated that he thought Bruce Hill would be very much in favor of this type of approach.

Steve Ziman replied that he thought this concept was contained in the later parts of this paper. He said that the subgroup did suggest that one would like to track the primary emissions (e.g., NOx and VOC) to see if the decreases that were observed were in fact real. He reminded the group that the RFP subgroup had talked about looking at the modeling of precursors; however, the subgroup acknowledged that this approach was more uncertain than any of our modeling approaches for ozone.

Harvey Jeffries acknowledged Mr. Ziman's response, and indicated that he simply had not read far enough into the document. Mr. Jeffries also questioned if the discussion of establishing the trend and using statistics would be expanded to some degree?

George Lauer asked how Mr. Ziman was addressing the Areas of Influence (AOIs) versus the Areas of Violation (AOVs) for the emissions?

Steve Ziman replied that if you were looking at a State Implementation Plan (SIP), you were looking at the emissions in the AOI. He concluded that looking at this retrospectively, you would need ambient measurements throughout this entire area to ensure that you were getting the reductions that you thought you were getting.

George Lauer questioned the situation where one AOI was affecting two AOVs?

Harvey Jeffries responded that it appeared to him that you would do whatever you had to do in order to get the necessary reductions.

John Silvasi replied that this one of the questions that has come-up in the discussions of the general RFP paper. He said that it was being addressed in the RFP paper, especially the question of where and when reductions can and cannot be counted. Mr. Silvasi stated that there were about 15 different issues under discussion in the total RFP paper. He said he believed that this would come-up on the TTN/BBS later this week.

Ned Meyer questioned the link between monitoring sites and performing population- weighted assessments. He asked what data would be used for the baseline, and how many monitors was enough monitors?

Steve Ziman responded that the baseline was going to be the baseline that you started with, which is actually when the designation is made. In terms of monitoring, Mr. Ziman said that the EPA would probably have to give some thought to monitor siting and provide some types of guidance.

Harvey Jeffries stated you would need some type of minimum siting requirements here for individual monitors.

Steve Ziman said that California was looking into some of these issues, especially in the work that McNerney was doing. He reminded the group that it was not good science to have one monitor being the decision tool for a large population.

George Lauer suggested that 40 CFR 58 had a good deal of monitoring information and that it might provide a good starting point for this discussion.

Steve Ziman responded that his group had looked at this, and that it was insufficient.

Harvey Jeffries questioned whether this issue really went in this paper, or in another paper?

Steve Ziman stated that he did not think we had viable solution at this time.

Harvey Jeffries reminded Mr. Ziman that you did not necessarily need a solution; rather, you need to identify a set of issues that need further work beyond the FACA process.

Steve Ziman acknowledged Mr. Jeffries statement as a good point.

Glen Cass stated that he was glad to see data from California being used in this discussion. However, Mr. Cass pointed-out that the group needed to make sure that "hot spots" did not get wiped-out in the types of analyses that were being discussed. Mr. Cass sited an example in Riverside, CA for fine particles.

Steve Ziman said "hot spots" were his concern when the group discussed the issues related to monitor siting. Mr. Ziman concluded that the subgroup did not want to skew the weighting schemes such that things like "hot spots" got swept under the rug.

George Lauer emphasized that you needed to make sure that you had a good handle on the general trend in any area, prior to choosing metrics.

Steve Ziman thanked everyone for identifying these potential problems. He said that the subgroup did not air quality metrics to be torn apart over such simple issues not being included.

Harvey Jeffries reminded the membership, that this paper did not advocate one metric that would supersede all other metrics. He said that this was a hierarchal approach.

Glen Cass suggested that these metrics be tested on the California data base, because it would be a good test for fine particles.

Steve Ziman reminded Mr. Cass, that to date, all that had been reviewed was ozone, because that was where the majority of the data existed.

Harvey Jeffries asked how the group could wrap this discussion up, and move forward? He asked if anybody had any serious comments on the status of this current document?

John Silvasi stated that at next Monday's meeting he would like to raise any issues which anyone has particular concern over, then resolve them and put something in the RFP Group's hands after next week's meeting here in Durham.

David Chock commented on the population-weighting and area approaches saying that they were important only when there was a counter effect - e.g., a benefit on one area and a disbenefit on a subsequent area, due some specific control strategy.

Steve Ziman reminded Mr. Chock that there would be areas where the standard would be met, and there would be areas where the standard was not going to be met. For areas which may not be able to show how they would get to attainment, any strategy that would be derived that shows reduced exposure on the way to attainment, would obviously be the preferred approach. You want to get the biggest bang for your buck in terms of reducing overall pollutant exposure. A dollars for tons exchange does not work as well as a dollars for ppm-hours; and, this was what we were proposing here.

Harvey Jeffries reminded Mr. Chock that there are certain metrics that would respond differentially - e.g., one may respond better to NOx changes, while another may respond better to VOC changes. Thus, showing the different responses could be useful in terms of getting additional controls.

Steve Ziman concluded stating that these were the recommendations for the metrics. The individual areas (e.g., RAMPs, etc.) would make the political decisions on which ones they pick or choose. He said he and Cyril were simply trying to get away from a simple 3% per annum-type reduction.

Harvey Jeffries asked if anyone had any problems with providing this to the other two Work Groups for discussion on Monday?

Bob Judge said that the group was essentially saying that we were using an air quality model to set the path for emissions reductions. Mr. Judge indicated that he was still not sure why targeted emissions reductions (e.g, 3% per year) were not the way to go. He said that it appeared tp him that the group was making a policy decision here, and not a scientific decision.

Cynthia Marvin stated that CARB had some concerns. Ms. Marvin stated that California would be concerned about the use of any metric which can not be controlled. We have a lot of concern about using a population-based metric for this reason. We have technical concerns about our ability to use population-based metrics. Don McNerney, Rich Bradley would like to discuss some of these technical concerns with this group.

Harvey Jeffries stated that we did not have the time on today's call; but, he asked Ms. Marvin to submit these comments to John Silvasi and Steve Ziman, such that we could integrate them into our discussions. He reminded the membership that this was not going to the FACA Subcommittee; we were simply discussing these among our Work Group members. He said that we should be focused only on technical issues at this time.

Bob Judge replied that this was why he asked the initial, general question. He said that once you add additional complications on top of doing model runs, he did not think that you could be more confident prospectively with this approach.

Harvey Jeffries stated the confidence came from dealing with real data. He said that you had to have constant mid-course corrections.

Steve Ziman said that it could be viewed as whether you want to make "smart emissions reductions or dumb emissions reductions" (as stated earlier by John Silvasi). He reminded the group that the goal was to get air quality improvements through the use of "smart emissions reductions". Mr. Ziman stated that SIPs are accomplished with modeling and this was a simple fact of life. He admitted that most people did not like this; however, this was the only viable approach to do attainment demonstrations.

Don McNerney stated that when you are analyzing model outputs, and you have a lot of concentration gradients in regions of high population exposure, you could have high uncertainties.

Harvey Jeffries cautioned Mr. McNerney to not confuse the mixing of metrics. He stated that you would not replace a peak ozone value, with only population-weighted monitoring.

Don McNerney asked that this group not hold the state's feet to the fire on population- weighted monitoring.

Harvey Jeffries responded that he did not see that approach happening here at all.

Steve Ziman acknowledged that this was a new paradigm. He said that you are trying to get to attainment in the smartest way possible. In the past, we simply looked at the peak, and tried to reduce this peak.

Don McNerney disagreed, and stated that the use of population-weighting was wrong here; especially for an RFP metric.

Steve Ziman stated that STSWG concurred that an air quality metric was preferable to an emissions metrics.

Harvey Jeffries stated that he would agree with that fact.

McNerney reminded the group that population-weighting would require much better model performance, than what was currently being accomplished.

Harvey Jeffries agreed, and indicated that the paper covered this top quite well.

Steve Ziman stated that modeling would never meet everyone's demands and expectations. He told the group that the individual state's have to be able to make mid-course

corrections. Mr. Ziman concluded saying that we need to get away from making a SIP and then just letting things go.

Harvey Jeffries questioned what the requirements for using the metrics would be? He asked if a locale would have to "qualify" to use these metrics?

Steve Ziman responded affirmatively, saying the RFP subgroup was not trying to push these metrics where they should not be.

Harvey Jeffries reminded the group that the approach was hierarchal, and that if a state had the modeling and the monitoring equipment to do so, then they could choose one of these higher metrics.

Ned Meyer replied that what he was hearing was good; however, he did not think that it was clear in the paper.

Mr. Jeffries reminded that group that we were not writing the whole RFP paper here; but, that we were simply providing technical insights.

Steve Ziman stated that this paper was also linked to Ted Russell's paper, and other parts of the RFP paper. Once you go through the model performance evaluation, you then know whether the model was performing correctly.

Harvey Jeffries reminded the group that peak ozone concentrations could be predicted by mistake.

Don McNerney disagreed with Mr. Jeffries, and stated that peak ozone model performance was relatively good right now.

Harvey Jeffries stated that we needed to curtail this discussion at this time, and move on to the other agenda items. He asked if there was any objection to us moving this document on to our Face-to-Face discussions on Monday?

Ellis Cowling replied that he believed that this document was worthy of discussion at next Monday's meeting.

John Silvasi reminded the membership that the original intentions were to involve CARB in these discussions. However, he continued, that due to some logistical snags, CARB personnel had not been involved in this effort until today's call.

Harvey Jeffries said that it was incredibly easy for scientists to come-up with conceptual ideas that would be a nightmare for a state to implement. He assured the state agencies that this Work Group would not ignore their wishes and comments.

Modeling Requirements/Emission Inventories & Statements Issue Paper Update

David Sanders stated this paper would now get moved onto the August FACA agenda. He continued saying that in light of this new information, the two bullets on today's agenda were now no longer really relevant. However, he said he would still like to discuss the most recent version of Ted Russell's paper at this time. Mr. Sander's indicated that he had distributed this document via facsimile and electronically via mail.

Harvey Jeffries said that he believed that Ted had done a good job on the second version of the paper. He stated that the mechanics need some work, as well as some of the options, recommendations need additional attention. Mr. Jeffries suggested that the Work Group members bring a copy of this document to the STSWG Face-to-Face meeting next week.

Ellis Cowling asked if Ted Russell would be at Monday's meeting?

David Sanders said that he was not sure, but that he would check with Robin Dunkins and get his schedule.

Jim Vickery addressed the group about participating in joint steering effort for ozone and particular matter. Mr. Vickery is currently involved in NARSTO, and would like to see a similar national research effort for fine particles be developed. Mr. Vickery stated that he would like to put together a national coordinated research program which combined the issues of tropospheric ozone and particulate matter. He said that he would like to seek advice and input from the STSWG membership, and then work together in the future to put together this program.

Mr. Vickery indicated that NARSTO was unable to take the lead on these issues. He said that his goal was to define a research strategy for PM (follow-up on the science needs after the criteria document; make sure the science needs are addressed for attainment tools); handle the standards-related issues; and, establish a coordinated public private partnership for PM. Mr. Vickery indicated that his goal would be to hold a couple of workshops to set the agenda and bring together the health effects community with the transport community (e.g., modelers, data people). He concluded that a clear action plan need to be in place within the next couple of months, and he envisioned STSWG serving as an advisory board or as a conduit for communication in this process.