Draft Summary of the Federal Advisory Committee Act (FACA)

Science and Technical Support Work Group Meeting

Mutual Building, Room 1019

November 12, 1996

Durham, North Carolina

The Science and Technical Support Work Group (STSWG) of the FACA Subcommittee met on Tuesday, November 12, 1996 between 1:30 pm and 3:00 pm EDT in Room 1019 of the Mutual Building, Durham, North Carolina. A list of the 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

David Chock	Ford Motor Company

Kirit Chaudhari	Virginia DEQ

Ellis Cowling	SOS

Tom Moore	Arizona

S.T. Rao	New York ARB

Steve Ziman	Chevron Corporation

Jay Rosenthal	Navy

Dan Weiss	Cinergy Corporation

John Cabaniss	AIAM

Dave McNeill	Utah DEQ

Jay Turner	Washington University/DOT

Mark Scruggs	DOI

Leon Outlaw (for Jay Hudson)	Santee Cooper

John Core	WESTAR

Work Group Members Not Participating

Tom Helms, Co-Chair	U.S. EPA

Bruce Hill	Appalachian Mountain Club

Jeffrey West	GPU Services Corp.

Glen Cass	Cal Tech

David Kelly	Navajo EPA

Rich Poirot	Vermont

Manop Vanichchagorn	Louisiana DEQ

Non-Work Group Participants

Bob Wayland, SAIC; Mike Teague, UARG; Pradeep Saxena, EPRI; Bob Judge, U.S. EPA/Region 1; Chris Hawk, U.S. EPA/OMS; Bill Kuykendal and Rich Scheffe, U.S. EPA/EMAD; Bill Johnson, David Cole and David Sanders, U.S. EPA/OPSG.

Summary of Meeting

David Sanders began the meeting by stating that Tom Helms would not be available for today's call. He indicated that the emphasis for today's meeting should be to go over the four Issue Papers which are scheduled to be discussed at the Denver FACA meeting on the 19th and 20th of this month. As was discussed in last week's call, the Group's action item was to encourage the primary authors of each paper to David Sanders a one-page summary that could be distributed to the membership prior to the Denver meeting.

David Chock indicated that he had promised Harvey Jeffries that he would write something on the scientific issues associated with AOI/AOV. He told the Group that he had not completed this effort yet, but will have it completed before the Denver meeting.

David Sanders indicated that this approach was okay. He said that the TTN deadline was designed to bring things to closure, but that bringing the completed paper to Denver next was also acceptable.

Harvey Jeffries brought up the recurring concern regarding attachments to electronic mail messages. He strongly urged David Sanders to post the information either to the TTN or to his UNC Web Site. David Sanders indicated that the had been forwarding messages to Work Group members up to this point. However, he now understands that this is not the proper procedure, because the recipients are unable to open the documents. He indicated that a revised procedure would be utilized in the future. Steve Ziman suggested that it would be easiest to put this information in the comments section of the TTN/BBS where everyone could have equal access.

Harvey Jeffries indicated that there is one additional item that needs to be on the agenda, which is a presentation by Glen Cass. NRDC contacted Glen Cass to draft a position paper on particulate matter monitoring, and Glen has sent Harvey a copy of the manuscript. Harvey indicated that he has talked with Deborah Sphrentz, and this issue will come-up at the Denver meeting. Thus, Harvey suggested that we need to give Glen some time on the STSWG agenda to discuss this issue, prior to the full FACA Subcommittee meeting. In addition to Glen's document, Deborah also sent Harvey a copy of what she was planning to bring forward to the Subcommittee next week. Harvey indicated that this will come as a recommendation to EPA from NRDC; however, it may/may not be pushed "hard" by the STSWG - we will need to discuss this next week in Denver.

Diana Andrews asked if anyone was planning to sit in on the Coordination Group call tomorrow. Harvey Jeffries responded that generally Tom Helms does this. David Sanders indicated that Tom was on travel and would not be available for the call.

Harvey Jeffries suggested that we move on to the discussion of the four Issue Papers that would be the focus of attention during the Denver meeting.

Areas of Influence (AOI) / Areas of Violation (AOV) - S.T. Rao and Tom Moore

S.T. Rao indicated that at this point the paper basically summarizes the various approaches to AOI/AOV. He state that they have not really prescribed any methodology, however, the rationale is clearly articulated. Mr. Rao indicated that he would like to provide the scientific basis for describing AOI/AOV, which is a missing piece of this document. He suggested that one approach would be to begin by discussing time and space scales in ozone data, and try to come to consensus on what they mean and how we use them to develop AOI/AOV.

Harvey Jeffries stated that he was interested in having the scientific basis for determining AOI/AOV, but did not think that the group needed to get into specific details (e.g. individual research, or group works (e.g. OTAG, etc.)).

David Chock offered that he was currently trying to assemble this information, and at this time it was still in a very general format.

Harvey Jeffries asked if there was anyone that disagrees with the AOI/AOV approach?

S.T. Rao responded that it is an acceptable approach provided that you are using robust methodologies. Mr. Rao indicated the reality that any one technique may have limitations. However, the key here scientifically is to guarantee a robust scientific methodology to determine AOI/AOV. He reiterated that he would like to get back to determining the time and space scales for ozone data and state that Harvey Jeffries indicated at the last meeting that this type of analysis was required. Thus, S.T. Rao suggested that we do some of this analysis on existing ambient data.

Steve Ziman said that we need to look at available data and set down a set of specific analyses to determine exactly what we are interested in relative to AOI and AOV. A real question that we need to deal with is the recurrence interval of a particular class of episodes. What is appropriate as a tool for delineating such concepts? We don't want to answer this question, rather we want to caution the group on the suite of tools that are available (with there limitations, merits) to determine the existence of AOI/AOV.

David Sanders stated that this was exactly what the group needed to be doing.

Harvey Jeffries stated that he did not think that you can do this in STSWG's time frame. He reminded the Work Group that we need to determine is it doable or not doable in some prescribed time frame.

Diana Andrews suggested that somewhere along the line, we should identify the tools that are available to do an AOI/AOV determination.

Steve Ziman cautioned the group, stating that we must take a more rigorous attempt to prove that AOI/AOV determinations can/cannot be done, given the available data.

Tom Moore said that we cannot simply let the policy people develop it on their own. He stated that there must be truth in planning. The technical details of such an approach, e.g. selecting an AOI and AOV, is simply overwhelming. We do not need to determine the methodology, but we need to get the information out on the table as to how difficult this process really is.

Harvey Jeffries voiced his concurrence with this latter statement, and asked where Tom and S.T. are with all this.

S.T. Rao responded that this is going to be an extremely complex task. No matter what approach you take, people will criticize it. Thus, we need say that this might be a good theory, but a nightmare in reality.

Harvey Jeffries stated that this is basically a very non-linear problem. There are a lot of people who propose different techniques, but every technique has its limitations, uncertainties and assumptions. There is a difference in determining the size and extent of the AOI, and determining the size of reductions within an AOI required to reach attainment.

S.T. questioned what the "charge" was that was placed before the STSWG?

Tom Moore suggested that we split the issue into two groups. Initially, the group can tackle the easy part - defining the tools and the resources required for establishing and AOV. Mr. Moore suggested that perhaps the work of S.T., given its limitations, could be used as one approach. The second step, defining the AOI, could come at a later date. Steve Ziman reminded the Work Group that a lot of discussion was had in Dallas regarding S.T.'s work its limitations. However, Mr. Ziman continued, if you take the knowledge gained from S.T.'s efforts, and link this with additional data/results, we probably could move forward.

Harvey Jeffries suggested that S.T. Rao, Tom Moore and David Chock work on a document that will be handed-out next week at the Denver meeting, which we could discuss. In this document, list the different approaches, the limitations, uncertainties, etc.

David Chock concurred with this approach, and indicated that he currently had a draft that he could send to these individuals for review. Then their comments could be incorporated and it could then be formulated into an Issue Paper.

As a clarification, Tom Moore stated that we are simply going to list the tools, research needs, and the time line for determining the AOV only?

Harvey Jeffries responded that the AOV should be determined by monitoring only. The AOI is where the data analysis comes in.

Diana Andrews then questioned, how do you define a violation?

Harvey Jeffries responded that it is any monitored violation.

Tom Moore then questioned, what is the monitors area of representativeness? Mr. Moore then concluded that we should stop and say that these are the science issues related to the data and the determination of the AOV, and if the other Work Groups can accept this, then we can develop a second list of tools for the determination of the AOI.

Harvey Jeffries agreed with this approach. We must determine what the credibility of the data is up front. However, if we do not make more progress than this prior to the meeting, I think we are going to be left behind.

S.T. Rao indicated that we need to raise all of these issues at the meeting next week with regard to the temporal and spatial representativeness of the monitor.

Harvey Jeffries, I am more in line with what you are saying S.T. than the previous discussion by Tom Moore.

Ellis Cowling said that when the FACA process started, Tom Helms reminded us that when the AQCR was developed in 1965, it dealt with entire regions. Then we moved toward nonattainment counties and local designations. Now in 1996, we have returned to look at the regionality of the ozone problem. The concept of thinking about and AQCR as large as half the continent, is very relevant to what is happening today. Is it not worthwhile to go back to these original concepts, of AQCR as large as 35 or so states?

Harvey Jeffries agreed that the SIP approach is not valid; however, he could not embrace the 35-state AQCR approach. Mr. Jeffries stated that this was what he liked about the AOI/AOV approach - it allows you to deal with things on their respective space and time scales.

S.T. agreed, stating that we need to quantify the temporal and spatial scales of influence for ozone and particulate matter. He also said that we need to get away from the episode concepts and look at climatological forcing of AOI/AOV.

Harvey Jeffries agreed.

David Sanders stated that perhaps we should agree in the short-term that this is mainly a policy call. However, we should acknowledge that the policy should be tempered by scientific input. The policy may go ahead and establish a base concept of AOI/AOV, and as science is able to support further refinements, then we can move forward from a scientific perspective. If we can accept the fact that the policy people will make this initial call with input from us, then perhaps we can move forward.

Harvey Jeffries responded that he was reluctant to approach the solution this way. There are a lot of advantages to this approach. He indicated that we should embrace the concept that AOI/AOV permits us to deal with the issue on the appropriate space and time scales. However, we should also clarify that we have definite problems trying to determine exactly what the appropriate space and time scales are.

Ellis Cowling agreed with Mr. Jeffries. He advocated starting with the 35 or so states in the OTAG region and then shrinking this down to determine the appropriate areas of influence for each individual area of violation.

Harvey Jeffries stated that Ellis' approach was dead wrong. Mr. Jeffries indicated that Mr. Cowling's approach was a policy approach, not a scientific methodology.

Steve Ziman responded that taking this approach, would increase the risk of everything being lost in the shuffle.

In summary, Harvey Jeffries said that we need to embrace AOI/AOV, stating the tools that are available and the available data, and then delineate the pieces of the puzzle that are missing, and then attach a time table for accomplishing this type of approach.

Rich Scheffe added that this was shaping up real nice. He offered that the classic tendency here is to determine a one size fits all approach, and the current discussions are not trying to force this mode of thinking.

Dan Weiss stated that he liked what was being said so far. He reminded the STSWG that we need to develop the tools that will help us all develop the representative time and space scales for ozone and particulate matter. He finished by reminding the group that there are important regional differences, and thus we must stay away from the one size fits all approach.

Mike Teague stated that he agreed 100% with this thinking. He indicated that this was the approach he has been trying to get STSWG members to embrace all along - simply identify what we want to do, how we will get there, and then how long it will take us to get there.

Harvey Jeffries concluded that the STSWG would look at the package that David Chock has put together, and then we will present this next Monday in Denver for discussion by the Work Group.

David Chock indicated his straw man would go out tomorrow.

Harvey Jeffries reminded that the group that we may simply have to prepare our own issue paper on this subject. He concluded that responding to Don Theiler's paper is simply not sufficient to deal with this issue.

S.T. Rao asked if we were going to address actual the actual space and time scales?

Harvey Jeffries responded, no, because I do not think we can do this between now and Monday.

Diana Andrews suggested that this probably was a Phase II issue - we need to determine if it is doable for Phase I, and then worry about how to do it under Phase II.

Attainment Dates - John Cabaniss

John Cabaniss referred the STSWG to his one-page handout, which summarized the attainment dates issues:

-	Measurements of RFP should be based on what is scientifically measurable in some reasonable manner;

-	Incentives for early reductions could be an integral part of attainment strategy, but must be based on scientific evidence showing that the resultant ozone reductions are equivalent to those expected from the normal SIP process;

-	There is a basic difficulty in how to go about defining "attainment" given that areas can be in attainment one year and not in attainment in another year, due to a variety of influences;

-	Measuring RFP is very difficult. Traditional methods for focussing on RFP in terms of emissions reductions have not proven meaningful. Using a variety of environmental indicators to measure RFP may be preferable to just focusing on ambient air quality monitors or emissions;

-	There is support for allowing an adequate amount of time for a reasonable planning period (up to 10 years in some cases) to allow the proper collection of relevant data and its analysis and use in appropriated modeling.

-	There is concern that it may not be feasible for some areas to attain the NAAQS in the foreseeable future.

Steve Ziman added that he would like to include the integrated approach into the planning period (e.g. monitoring, data analysis, modeling and more analysis).

John Cabaniss indicated that was exactly the approach of the Work Group. However, if Steve would send him some "words", he would get them incorporated into the document.

Harvey Jeffries had questions on the second paragraph, regarding ozone. Mr. Jeffries asked if we can we make this broader than just ozone?

New Source Review - Dave McNeill

Dave McNeill indicated that there are really two options within the paper. Mr. McNeill's only comment was that he and Leon Outlaw did not agree with allowing a cap and trade program for different pollutants (e.g. inter-pollutant trading). He indicated that the tools simply are not available at this time to do this. AOIs should be allowed to have different NSR requirements, but allow each area to develop there own plans. The other issue is that they do not ever mention what to do with a new or modified source that is not located in the AOI in terms of NSR requirements.

Leon Outlaw stated that this also falls on the heels of the earlier discussions regarding the determination of the AOI and AOV. These same mechanisms will have to be used in NSR to deal with modified sources and new sources with respect to AOI and AOV. With all the banking issues, it will be difficult to trade between AOIs, especially if we allow interpollutant trading.

Steve Ziman questioned if we have to be concerned when we are looking at this as to whether what is being proposed is an actual hindrance to NSR?

Harvey Jeffries stated that he was trying to figure-out what the science questions are here. I understand the new source versus the old source. Where I have problems, is this concept of asking new sources in different areas to do different things.

Dave McNeill offered that what Steve Ziman was discussing was actually a policy statement and not a science issue.

Leon Outlaw questioned whether in order to determine compliance within an AOI between two sources, that the modeling tools are available?

Harvey Jeffries responded that this is currently available. The whole issue here, is being able to defend a cap and trade program. I would agree with David that an interpollutant cap and trade program is very difficult, if not impossible, to implement at this stage. Remember, this cap and trade program cannot be your attainment strategy (e.g. there is a command and control at the end of the cap and trade option). Cap and trade may get you a particular large reduction, but it in itself will not solve all of your nonattainment problems. It may reduce your burden towards reaching attainment, but it will not solve all the nonattainment issues.

Integrated Implementation - Mark Scruggs

Mark Scruggs indicated that this paper was undergoing some major revisions. Mr. Scruggs said that Donna Lamb plans to extract the ending sections, which deal specifically with the tools, and replace this with basically Chapter 5 of the Conceptual Model Document.

Harvey Jeffries questioned if the issues that Donna read at the end of the Dallas meeting were incorporated into this paper?

Mark Scruggs responded that he was not sure; however, when they are done with all the revisions, the paper will be more concise and clearer to understand.

Harvey Jeffries also reminded the STSWG that presumably, integration could improve the bottom-line health situation, without individually improving any individual pollutant.

Steve Ziman stated that in Rich Scheffe's material, integration can be determined from modeling, monitoring and data analysis.

Diana Andrews responded that Donna Lamb says that integration should be taken in several contexts, of which monitoring and analysis is one option.

Harvey Jeffries concluded that pushing the concept of what is actually meant by integration is a valid concern. Some places it is clear, others it is not. In some cases integration makes great sense; however, in others it makes absolutely no sense at all.

Steve Ziman indicated that it was unclear to him what was meant by any of the health models. He requested further clarification on this aspect of the paper.

David Sanders closed the meeting, reminding all authors to submit one-page summaries to him as soon as possible for discussion at the Denver Face-to-Face Meeting. The time and date of the next conference was not discussed, as the Thanksgiving Holiday would follow the Denver meeting.