Draft Summary of the Federal Advisory Committee Act (FACA)

Science and Technical Support Work Group Meeting

EPA Environmental Research Center, Classroom #1

July 18, 1997

Research Triangle Park, North Carolina

The Science and Technical Support Work Group (STSWG) of the FACA Subcommittee met on Friday, July 18, 1997 in Research Triangle Park, North Carolina in conjunction with the Source Attribution Workshop. 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

Tom Helms, Co-Chair	U.S. EPA

Cyril Durrenberger	TNRCC

Jeff MacGillivray	New Hampshire State Representative

Dave McNeill	Utah DEQ

Steve Ziman	Chevron

Work Group Members Not Present

Diana Andrews	Kentucky DEP

John Cabaniss	AIAM

Glen Cass	Cal Tech

Kirit Chaudhari	Virginia DEQ

David Chock	Ford Motor Company

John Core	WESTAR

Ellis Cowling	SOS

Bruce Hill	Appalachian Mountain Club

Jay Hudson	Santee-Cooper

David Kelly	Navajo EPA

George Lauer	ARCO

Tom Moore	Arizona

Rich Poirot	Vermont

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

Jay Rosenthal	U.S. Navy

Mark Scruggs	DOI

Jay Turner	DOT

Manop Vanichchagorn	Louisiana DEQ

Dan Weiss	Cinergy Corporation

Jeffrey West	GPU Services Corporation

Non-Work Group Participants

Bob Wayland, SAIC; Ted Russell, GIT; Prem Bhardwaja, SRP/Phoenix; Mike Teague, Hunton & Williams; John Jansen, Southern Company; Brock LeBaron, Utah DEQ; Bright Dornblasser, TNRCC; Ned Meyer, U.S. EPA/AQMG; Allen Basalla, U.S. EPA/VEPG; David Sanders and David Stonefield, U.S. EPA/OPSG.

Summary of the Meeting

Ned Meyer opened the meeting by reminding the attendees that there would be other presentations being given this morning over at the 4201 EPA Building. These presentations would be from individuals who were not selected for the Workshop; but, would cover information that was relevant to Source Attribution. The schedule would be as follows: 9:00 a.m. - Sandy Sillman; 11:00 a.m. - Donna Kenski. Mr. Meyer stated that both presentations would be in the 4th Floor Conference Room of the 4201 Building, which was located just across the street from the EPA ERC facility.

Harvey Jeffries stated this would be STSWG's last chance to review the paper generated by Ted Russell and NRSWG. He said that the current version needed to address the concerns that had been received from Tom Moore. The version from Mr. Moore already contained the earlier comments from David Chock and Ken Schere. Mr. Jeffries stated that the second issue on today's agenda was to finalize the RFP Metrics paper that Steve Ziman and Cyril Durrenberger had been working on.

David Sanders interjected that Steve Ziman would also like to discuss Al LeFohn's paper.

Steve Ziman replied that he could do this very quickly, because he did not think that most people had read it yet. He indicated that he would like to review the paper in detail during the regular STSWG call, which was slated for Tuesday, July 22, 1997 at 1:00 p.m. EDT. Mr. Ziman requested that each Work Group member critically review the document, and get comments to him prior to the first of August. He requested that the group allow time in Portland, Oregon at the next Face-to-Face Meeting to discuss this paper. Mr. Ziman requested that everyone respond in writing with their comments.

Tom Helms asked Mr. Ziman if he was aware that the concerns raised in his earlier paper were addressed in the comments to the Standard? Mr. Helms stated that this information should be contained in the Docket.

Harvey Jeffries asked how much information was actually contained in the Docket on these issues?

Tom Helms responded that it was short enough that he could photocopy the material and fax it to each member of the Work Group.

David McNeill reminded Mr. Helms that the STSWG did not want to look like idiots on this issue, nor did they want to embarrass EPA. He concluded that the more information available, the better the end result would be.

Harvey Jeffries suggested that the group move its attention to Ted Russell's paper at this time, as several members of the group needed to leave shortly.

Modeling and Emissions Paper - Ted Russell

Ted Russell stated that he had incorporated all comments received to date, including those of Tom Moore, in the latest version. He said that David Sanders had a limited number of copies of this version available this morning. However, Mr. Russell indicated that there were a couple of Tom Moore's comments, which he had not had time to deal with at this time. All the previous comments have been incorporated. He requested that the group review the document, and that if anyone felt that he had not adequately responded, please get back to him and he could give them his reasoning on those specific comments. Mr. Russell stated that the schedule would be as follows over the next week or ten days: EPA personnel (e.g, Ned Meyer and David Sanders) will take the lead on going over and reviewing the document for scientific consistency and accurateness towards policy; following this, the paper will be turned over to the NRSWG for posting on the Web Site.

Ned Meyer voiced concern over the perception that EPA was writing this document.

Harvey Jeffries responded that this was not a problem.

Ned Meyer disagreed with Mr. Jeffries. He stated that if the Agency did an editorial job on the paper, then the Agency could "get fingered".

Ted Russell reminded Mr. Meyer that he was the ultimate reviewer of this document, and that he would have the final authority to accept/reject any changes proposed by the Agency.

Ned Meyer responded that he did not think the Agency would add anything to document, rather he believed that the Agency might remove considerable portions of the document.

Harvey Jeffries reminded Mr. Meyer that all the Agency was supposed to review the document for was to guarantee scientific integrity and adherence to EPA policies.

Ted Russell reiterated that he would like the Agency to make sure that the paper: (1) reads better; (2) that he had not misinterpreted what the current EPA process is; and, (3) get some input from the EPA emissions people.

David McNeill stated that he was not aware of the scope and breadth of Tom Moore's comments; however, he continued that now that we had a national ambient air quality "suggestion", he believed that this group should push EPA to go out and do something to encourage people to collect data before we had to designate AOIs. He reminded that group that it would not productive for us to sit around for three years and do nothing.

Cyril Durrenberger stated that a 1996 emissions inventory was already in progress.

David McNeill responded that he was not talking about inventories, rather he was referring to emission factors, emission rates, etc.

Ted Russell interjected that the group had agreed to start with the current information for the preliminary AOIs.

David McNeill suggested that this approach was irrelevant, because we did not have any data at this time. Thus, Mr. McNeill concluded that there would not be any AOIs for a while.

Harvey Jeffries questioned if that was what the Administrator had said?

Tom Helms replied that the Agency made a big deal about the standard, flexibility, cost effectiveness, importance of a regional strategy for ozone in the earlier years, local control measures, etc. Mr. Helms suggested the group simply needed to "stay tuned".

Harvey Jeffries questioned if there would be any nonattainment/attainment decisions mad prior to promulgation?

Tom Helms responded affirmatively, and stated that these would be based on 1997, 1998 and 1999 data for both ozone and PM.

David McNeill replied that this time needed to be used effectively.

Steve Ziman said that if all this time was used for was to improve emissions, then this process will be a failure. He recommended that all types of data needed to be collected - meteorological data, emissions, etc. He suggested that it would take you 3-5 years to run the entire program and produce something credible to hang our hats on.

David McNeill reminded the group of a point made several months ago by Glen Cass - there is a great deal of data that needs to be collected to make this thing run. Mr. McNeill concluded saying that he basically was agreeing with Mr. Ziman.

Steve Ziman continued stating that the data collection needed to be streamlined for modeling and model output analysis and verification.

Cyril Durrenberger voiced his agreement with Mr. Ziman and Mr. McNeill, but stated that the emissions inventory was the key to all of this. He said that without a good emissions inventory you had absolutely nothing from which to build a program. He concluded that we needed emission factors and all kinds of other material to make this thing go.

David McNeill said that we also needed emission control efficiency information.

Harvey Jeffries suggested that Ted Russell generate a quick table for the front of his document, which would outline the missing information, and anything else that was needed?

David McNeill indicated that it would take FACA pushing EPA to make these things happen.

Jeff MacGillivray said that given the importance of this table, perhaps a simple starter table would suffice at this time, and the group could refine it over the coming weeks.

Steve Ziman reminded the group that most of the participants are focused on ozone. He stated that we really did not know what was needed to collect data for fine particles in order to set-up a model, run the model and then evaluate the model. The concept of nonattainment has to recognize that the recommendations for particles will simply have to evolve over time. EPA should be thinking about getting guidance out on these issues as soon as possible.

Cyril Durrenberger stated that the Modeling and Emissions Inventory Group said that we needed speciated data.

Harvey Jeffries interjected that this changed after his remarks yesterday. Mr. Jeffries stated that twice the number of PAMS sites will be online, providing speciated data. He said that Neil Frank told him yesterday that he (e.g., Mr. Frank) would be making a presentation to FACA in Portland, OR. This has been completely turned around, and EPA has moved very quickly on all of this. We just tasked Ted with something that is going to be very difficult to do - this list will not be easy to generate.

Jeff MacGillivray stated that he did not think that a complete list could be attached to this document at this time.	He suggested that Mr. Russell generate a short list on his own, and then the STSWG could refine this list over the next several months.

Steve Ziman replied that this should simply be a "red flag" list to get people's attention.

David McNeill suggested that since we were not doing AOIs immediately, that the country needed an intensive program to meet the data shortfalls.

Ted Russell admitted that there were deficiencies; however, he also agreed that EPA knows what these deficiencies are and that they will cost money.

Tom Helms stated that this process would be done in a budgetary manner. He said that there would not be tons of extra money floating around; however, the Agency would likely get more than it would have gotten without this document. Thus, he encouraged the group to make the best of what it had.

David McNeill agreed with Mr. Helms, and said that we should go to Congress and say that we gave them the delayed implementation they wanted, so give us the necessary money to do this, and to do it correctly the first time.

Steve Ziman indicated that he could provide examples of successful public-private partnerships.

Ted Russell agreed and stated that these approaches were included in the back of the paper. The more open this process, the more successful it will be - it could probably be enhanced.

Steve Ziman expressed his thanks to Mr. Russell for including this concept in the paper.

Cyril Durrenberger questioned whether the group needed specific paper on emissions inventories?

Ted Russell responded that his paper was it at the current time with regard to emissions inventories. He continued saying that Issue 4 did not have a recommendation; however it should be coordinated with RFP. He concluded that Issue 4 was really a statement, not an issue; likewise, Issue 0 was a statement as well.

Harvey Jeffries suggested that the paper did not need issues, merely simply declarative statements.

Ted Russell agreed with Mr. Jeffries. However, Mr. Russell stated that Issue 1 was still very much an issue and could not be recast as a statement.

Ned Meyer questioned if some of these issues could not be "boiled down" into more general statements?

Ted Russell agreed, and asked Mr. Meyer to identify some of these for him.

Tom Helms asked that the group not request too much from Mr. Russell. He stated that there was a finite amount of time within which for Mr. Russell to complete this effort.

Ted Russell indicated that he had essentially one week to take care of this. On Thursday, at the close of business, there is supposed to be a final version, and people will have 24 hours to comment, and then send me their comments. Over the weekend, I plan to incorporate these comments, write a four-page executive summary, and then get them back to EPA and the contractor and get them back to STSWG and NRSWG. I would prefer that people use MS-Word with the strike-out feature.

Harvey Jeffries asked Mr. Russell what concerned him at this point in the process?

Ted Russell replied that his biggest concern was that most of the options and issues contained within the paper were off the top of his head (e.g., there was too much Ted Russell in this paper). He indicated he would like to see more discussion of the pros and cons on a lot of the different issues.

Mike Teague commented that the title of the paper implied a modeling process; however, the first third of the paper questions if there would be one. He suggested that pros and cons were only valuable if they were presented properly.

Harvey Jeffries stated that there simply was not time for these ideas.

Tom Helms reminded the group that perfection can be their downfall.

Harvey Jeffries guaranteed the group that there would be modeling.

Mike Teague suggested that if Harvey Jeffries was correct, then the ambiguity needed to be removed. He reminded the group that modeling could not be evaluated in a vacuum. Mr. Teague stated that it had to be evaluated against a viable option. He said it was not sufficient to simply acknowledge the uncertainties associated with modeling.

Ted Russell said he understood. He said that this issue arose primarily because he did not see what the other option were. Mr. Russell stated that people would generally say that models are too uncertain to use. He said that needed to ask specifically what the alternative options could be.

Harvey Jeffries questioned if Mr. Russell was referring to observational based modeling?

Mike Teague disagreed. Mr. Teague stated that the people telling Mr. Russell that modeling is inadequate should be forced to supply an option. He stated that he did not know what these people had in mind; however, he responded that they should be ones forced to make the alternative option known.

Harvey Jeffries replied that the question is raised in the very beginning.

Mike Teague agreed. He said if you raise the question initially, then it begs the suggestion of an alternative to modeling. Mr. Teague indicated that he had a second comment, which dealt with emission inventories - Option 4 on emissions refers to industry better defining there

emissions. Mr. Teague stated that nature is also a source of fine particulates, and thus would not single out industry.

Harvey Jeffries suggested that the group discuss Mr. Teague's question. Mr. Jeffries asked if this was an air management issue or an emissions reductions process? If it is air management, then there is no way around modeling.

Steve Ziman interjected that this went back to the 1988 Clean Air Act Amendments. He said if we chose not to do air management, then we would not need modeling. However, if we chose air management, then modeling would appear to be the only option.

Mike Teague stated that reducing emissions until we get to attainment is an air management issue.

Steve Ziman disagreed, stating that this approach was a technology assessment issue.

Ted Russell replied that we could just reduce emissions until attainment was reached, and this approach would set-up the rest of the approach nicely.

Ted Russell said that if this was an air management process, then it should based on a process that involves air quality models, with other data analysis methods. Otherwise, we would take technology-forcing approaches like emissions reductions until attainment was reached. He concluded that reducing emissions until attainment was not really a technology-forcing process.

Steve Ziman disagreed with Mr. Russell.

Harvey Jeffries agreed, and stated that this approach would allow this document to link better with the RFP Paper.

Steve Ziman suggested that this linkage could be voiced in the Executive Summary. He continued saying, if you accept Issue 1, you would have to accept Issue 2 in principle. These linkages must be made and outlined for people. These issues are all linked and are not stand alone.

Harvey Jeffries asked if the general approach was to focus more attention on the pros and cons?

Ted Russell responded affirmatively and asked comments to be sent directly to David Sanders.

RFP Issue Paper

Cyril Durrenberger suggested that this paper needed to be discussed in detail at the Portland, Oregon Face-to-Face meeting.

Harvey Jeffries stated that he did not think a workshop was needed at this time to review RFP metrics. He said that Sarah Peirce-Sandner may have gotten the wrong idea from him earlier when they discussed the possibility of workshop.

Cyril Durrenberger admitted that the population-weighting metric was problematic. He indicated that the group needed to review this in more detail, and to determine exactly how you would implement this metric. He suggested that EPA issue some specific guidance on this metric.

Harvey Jeffries suggested a peer review process for determining this guidance.

Tom Helms stated that the Agency was not ready to make a call on this issue at this time. He concluded that the Agency needed to conduct some further research into these metrics.

Cyril Durrenberger suggested that the Work Group discuss these metrics in detail in the coming weeks. He reminded the group that there needed to be some concrete examples to make people more comfortable with these metrics. He reminded the group that "flexibility" could be a dirty word to environmentalists. He also stated that there was a difference in the concept of planning and tracking metrics. Mr. Durrenberger indicated that if your planning metrics failed, this did not preclude you from using other metrics for your tracking process.

Tom Helms thanked the membership for participating, and indicated that these discussions would continue on next Tuesday's call; however, he would be in Chicago for the call.