Reasonable Further Progress (RFP) Metrics Subgroup Call

May 22, 1997

11:00 am - 12:30 pm

Attendees:

John Silvasi

Steve Ziman

David Sanders

Cyril Durrenberger

Contractor Support:

Bob Wayland

John Silvasi opened the call by informing the group that Tom Moore had indicated that Areal Exposure would not work for particulate matter.

Steve Ziman responded that we have to be careful how we phrase our response. Mr. Ziman stated that our approach was founded in ozone, however, conceptually what we are proposing should work for PM.

Cyril Durrenberger stated that he did not understand why this approach would not work for PM.

Steve Ziman agreed, stating that especially when dealing with gasses, this approach should work for fine particles. However, he agreed that we were nowhere near in our ability to use models which would allow us to deal with PM (e.g., the Eulerian framework type of models). He said that to look at episodic situations for PM, we simply were not there yet scientifically. It all comes down to models, inventories and data analysis. It will be unmitigated disaster if anyone attempts to apply a 3-D Eulerian model for a SIP determination for PM - we should simply admit we do not know what we are doing with regard to PM.

Cyril Durrenberger responded that if it turns out that we have the techniques and tools to do PM, we can do it; however, for the time being this aspect is unknown. We must have metrics that are somewhat customized for the SIP process. We need a philosophical approach, which is illustrated with some well-chosen examples. We need to show how this approach is superior to the approaches taken in the past. However, we need to state that it is unknown whether these approaches will work for PM at this time. We simply do not know how this will work for PM. Thus, we have to base it on our approach for ozone. That is all that we have to go on.

John Silvasi asked if either Mr. Ziman or Mr. Durrenberger would like to take a crack at drafting something, or whether they would prefer to have the contractor make the first draft?

Both Cyril Durrenberger and Steve Ziman indicated that they would prefer the contractor to make the first draft, and allow them to review it.

David Sanders defended Tom Moore's statement, saying that he believed that this was what Mr. Moore meant. Mr. Sanders stated that Mr. Moore simply wanted recognition that these approaches were based on ozone, and they there was considerable work that needed to be done regarding PM.

Cyril Durrenberger reminded the group that the Areal Exposure technique was also being used in Texas and OTAG, as well as in California.

John Silvasi offered that New Hampshire had put together a culpability analysis. Mr. Silvasi said that he would send this information to Mr. Ziman and Mr. Durrenberger.

Steve Ziman asked Mr. Silvasi not to send him the information, because he had real reservations about the quality of that work. Mr. Ziman stated that he had real problems with states that had inadequate monitoring systems and invalid modeling techniques.

Cyril Durrenberger simply stated that "they did not know what the <expletive> they were doing!" Mr. Durrenberger indicated that it was bad science, which was designed to get the desired answers, because the original results were not acceptable. He stated that OTAG had done the original analysis, and the New Hampshire did not like the end result. Thus, they devise their own methodology. He said that they had applied linear processes on the back side of a non- linear modeling. Mr. Durrenberger concluded that this was simply not good science.

John Silvasi accepted Mr. Ziman's and Mr. Durrenberger's comments, and stated that he would not distribute these materials.

Cyril Durrenberger indicated that the New Hampshire effort was simply a misuse of the areal exposure metric. He expressed further his discomfort with their approach.

John Silvasi indicated to the group that Harvey Jeffries had suggested that we needed examples and graphics.

Both Mr. Durrenberger and Mr. Ziman responded that they simply did not have time to do this, prior to the June FACA meeting. Mr. Durrenberger suggested that we bring this to entire FACA for the August meeting. Perhaps we could get together either on the front or back of the Source Attribution Workshop in July, and pull this thing together. This is a key, pivotal issue, and we need to do this right - we need buy-in and we need some time to make this thing work.

John Silvasi stated that if we did this in July, then we would have to do it prior to the workshop. He also informed the group that there were no other FACA-related meetings during July.

Steve Ziman stated that he thought there was a degree of consensus on the primary metrics listed in the first draft of the paper.

John Silvasi replied that he would agree, except for Bruce Hill.

Cyril Durrenberger offered to talk with Mr. Hill and see if he could not get the problems cleared up.

John Silvasi asked to discuss time schedules for a moment. He reminded the group that Sarah Peirce-Sandner was hoping to get something from STSWG by the June Meeting. Mr. Silvasi asked if it would be possible to draft something that could be run by the STSWG on their next call on Tuesday, 5/27/97?

Steve Ziman indicated that this was very feasible.

Cyril Durrenberger replied that he would be out of the office after tomorrow until June 16, 1997.

Cyril Durrenberger suggested that he and Mr. Ziman fax comments on the initial draft directly to either Mr. Silvasi or the contractor. Mr. Durrenberger indicated that the would try and couple with this information, (e.g., from the paper Jim Smith and I wrote) some examples on areal exposure and population-weighted exposure. However, Mr. Durrenberger expressed some concern about doing this on such short notice.

Steve Ziman said that the explicit assumption in the secondary metrics that you can use models to project precursor reductions is somewhat problematic. He stated that it was conceptually nice, but not realistically practical! We have a lot less faith at using models to predict precursor reductions. We have tried to do more model performance evaluations on precursor estimates - the bias is on the order of 60-80% and the error in the 10-15% range. We understand the need to track precursors, but we do not want to put so many constraints on tracking precursors that it becomes impractical.

John Silvasi reminded Mr. Ziman that everyone would not be able to do precursor monitoring.

Steve Ziman agreed, and even acknowledged the limitations of the PAMS network.

Cyril Durrenberger stated this was simply the downside of this whole process. He agreed with Mr. Ziman that this posed a real dilemma. You can have expected emissions reductions, and the impact on the monitoring values may not be what you see in the ambient reductions. Basically, these reductions are expected reductions, and then you have to evaluate whether you are really getting these reductions at all. Did you really get the reductions that you claimed you did ? Without CEMs, I don't know of any other way to do this.

Steve Ziman questioned whether we were actually seeing precursor reductions? He stated that this was really a data analysis problem, and that you would need to look at both episode and non-episode days to make any real sense out of the data.

Cyril Durrenberger cautioned Mr. Silvasi that he and Mr. Ziman had only briefly discussed these concepts, and that more brainstorming would be required to finalize them.

John Silvasi acknowledged Mr. Durrenberger's concern, and stated that he tried to caveat this fact in Tuesday's call with the STSWG.

Cyril Durrenberger expressed his appreciation, but stated that he did not want to rush this issue forward any faster than was necessary.

Steve Ziman stated that there is a requirement within every rule and regulation that one passes for a SIP for compliance for some time of adjustment (e.g., CEMs, NOx waivers, fuel usage, etc.). Mr. Ziman cautioned the group not to supersede the idea of compliance. He indicated that people were going to question whether the emissions reductions were actually being made. However, in some respects we do not want to overemphasize this, because it would undermine the requirement to be in compliance.

Cyril Durrenberger suggested that the ancillary analysis should moved. He stated that we should have air quality metrics and emissions metrics, instead of primary and secondary metrics. We would do away with the concept of "ancillary analyses". However, we need to determine where the CEM issue would go.

Steve Ziman warned that because this is new and a different approach/paradigm, it was being unfairly held to a very different standard, particularly by those who did not like it.

Cyril Durrenberger suggested that ancillary analyses be changed to direct emissions metrics; and, the part below that could be called administrative emissions metrics; and, the last piece could be emissions air quality metrics. This would be the hierarchy of the emissions related metrics.

Steve Ziman agreed, saying that this had to be noted as being part of the tracking procedure, and not part of the primary metrics.

Cyril Durrenberger stated that the secondary metrics are implemented when the primary metrics were not working, or were shown to be ineffective. The hierarchy would be as follows: direct emissions metrics, administrative emissions metrics; and, air quality emissions metrics.

John Silvasi questioned in if the primary metrics were used prospectively?

Cyril Durrenberger responded that they could be used both prospectively and retrospectively. He continued saying that we had three (3) primary metrics: Population- Weighted Exposure; Areal Exposure; and, Peak Value. Mr. Durrenberger stated that if these did not work, then you would go to the secondary metrics. He stressed that the focus must be on whether you reduced the pollutant of concern. He concluded saying that the secondary metrics deal with the individual state's compliance.

Steve Ziman urged Mr. Durrenberger to try and pull something together on this issue.

Cyril Durrenberger agreed, asking Steve Ziman to handle the air quality metrics.

Steve Ziman agreed.

Cyril Durrenberger asked Mr. Ziman to link his discussion with the methodology for incorporating the existing monitoring networks.

John Silvasi asked if both Mr. Durrenberger and Mr. Ziman were going to fax him some materials and within what time frame?

Steve Ziman indicated that it would be within the hour.

Cyril Durrenberger stated that it would be prior to close of business on Friday.

John Silvasi said that he would be out of the office on Friday, and offered his home phone number (919 489-0422), stating that if Mr. Durrenberger would let him know when the material had been sent, he would come in and get it.

John Silvasi also said that we needed to address a couple of additional concerns (e.g., uncertainty, data requirements, and trading).

Steve Ziman agreed, but indicated that he thought it would be best to get initial consensus on these basic principles prior to worrying about some those issues. Most of these will be dealt with in the RAMP process.

John Silvasi agreed that this was not the time to do this; however, he said that he did not want these issues to be forgotten.

Cyril Durrenberger agreed that these were important issues, and that they did need to be discussed.

John Silvasi replied that he could envision someone asking about CEMs and going after the larger sources; however, if you allow trading between these major sources and say area sources, then your confidence could go down.

Cyril Durrenberger responded that this was why you go to your air quality metric, and determine whether or not you are getting the reductions that you thought you were getting. The primary metrics should answer these questions, and if not, then you can get the answers from your secondary emissions metrics. You have to come in and justify this - that is why we need examples. Mr. Durrenberger reminded the group that we were putting out a philosophical approach, and there would be certain things that had to be dealt with individually in the SIP process. He stated that we could not cover all aspects of everything in our work. We can illustrate with examples, but most of these types of things need to be SIP specific. He concluded saying that we were entering uncharted waters, and it would simply take time and effort to develop this new paradigm. Mr. Durrenberger questioned the dates of the August FACA meeting in Portland, OR?

John Silvasi indicated that the STSWG would meet on August 12, 1997, and that the FACA would meet on August 13/14, 1997. He thanked the members for participating, and indicated that he would work with contractor to get this information back to each of them as soon as possible.