Draft Summary of the Federal Advisory Committee Act (FACA)

Joint Meeting of the

Science and Technical Support Work Group

and

National and Regional Strategies Work Group

July 23, 1996

Sheraton-Washington Hotel

Washington, DC

The Science and Technical Support Work Group (STSWG) of the FACA Subcommittee held a joint meeting with the National and Regional Strategies Work Group (NRSWG) Tuesday, July 23, 1996 at the Sheraton-Washington Hotel in Washington, DC. A list of participants and a summary of the meeting follows.

Work Group Participants:

Name	Affiliation

STSWG Members

Tom Helms, Co-Chair	U.S. EPA/OAPQS

Harvey Jeffries, Co-Chair	UNC-Chapel Hill

Diana Andrews	Kentucky

Kirit Chaudhari	Virginia

Tom Moore	WESTAR

S.T. Rao	New York

Dave McNeill	Utah

Jeffrey West	NARSTO-NE

John M. Cabaniss, Jr.	AIAM

David Chock	Ford Motor Company

Steve Ziman	Chevron

Dan Weiss	Cinergy Corp

Mark Scruggs	DOI/NPS

Leon Outlaw (for Jay Hudson)	Santee Cooper

Jay Rosenthal	U.S. Navy

Rich Poirot	Vermont

NRSWG Members

David Mobley, Co-Chair	U.S. EPA/OAQPS

Don Theiler, Co-Chair	Wisconsin

Chris Shaver	EDF

Joe Belanger	Connecticut DEP

John Leary	Western Governor's Association

Marvin Lowry	Georgia

Dan Johnson	Washington

Joe Francis	Nebraska

Dewayne Huckabay	Houston

Sara Pierce-Sander	Kodak

Lydia Salmon	Kenecott Copper Company

Amy M. Lilly	AIAM

Jon Heuss	General Motors Corporation

Bruce Craig	NGSA

Andrew Aitken	N. England Power Service Company

Cliff Doumas	Mobil

Larry Feldcamp	Baker and Botts

Donna Lamb	USDA/Forest Service

Non-Work Group Participants

Pradeep Saxena, Electric Power Research Institute; Mike Teague, Hunton and Williams; Larry Bruss, Wisconsin/DNR; Chuck Mueller and Cyril Durrenberger, Texas; Steve Gerritson, LADCO; Rich Risher, USFS; Ira Silverberg, TVA; Steven Howards, Enti Strategies CPP Inc.; Vickie Patton, U.S. EPA/OGC; Bob Judge, U.S. EPA/Region 1; Kay Prince, U.S. EPA/Region 4; John Chamberlin, U.S. EPA/OPPE; Joe Paisie, Tom Rosendahl, Charlene Spells and Robin Dunkins, U.S. EPA/IPSG; David Sanders, Sharon Reinders and Bill Johnson, U.S. EPA/OPSG; Bill Kuykendal and Tom Pace, U.S. EPA/EFIG; Ned Meyer, U.S. EPA/AQMG; Neil Frank, U.S. EPA/MQAG; Rosalina Rodriguez, U.S. EPA/VEPG.

Introductions and Opening Remarks

John Ehrman, of the Keystone Center, opened the meeting asking the individuals seated around the table to introduce themselves (including affiliations), and then asked the members of the audience to do likewise. Following the introductions, a brief time was spent reviewing the agenda for the meeting. Essentially, the meeting was designed to facilitate interaction and consensus-building on the Issue Papers. Mr. Ehrman stressed that some degree of consensus was needed prior to the close of today's meeting in order to take reasonable approaches before the Full FACA Subcommittee next Tuesday.

At this time, Donna Lamb of the U.S. Forest Service was recognized and asked to make her presentation on the Designations Issue Paper. The following is a summary of Ms. Lamb's remarks:

Control Regions for Class I Areas

What and Where are Class I Areas?

-	National Parks and Wildernesses > 5000 acres (designated in 1977)

-	Maximum protection under the PSD regulations

-	Visibility (e.g. people can actually see what they came to see!)

-	Trying to protect AQRVs in these areas; in wilderness areas, the number of AQRVs are greater in number than just visibility.

The FACA Process

-	Designations

-	NSR

-	Regional Haze

Nonattainment Areas versus Class I Areas

Nonattainment Area	Class I Area

•Flexibility in what you designate	•Designation is fixed

as nonattainment

•Kicks-off a SIP	•Only PSD, visibility issues and SIP

•Controls are focused on internal	•Controls are mainly on sources

sources	which are external to the area

•Track emissions progress	•Model impacts of external sources on

the area

•Goal - meet the NAAQS	•Goal - protect visibility and AQRVs (these are

different for each area)

•All pollutants regulated	•Pollutants which have PSD increments, visibility,

AQRVs

•All sources important	•Only new sources or impairing sources are

considered

Lessons Learned from Class I Areas

(1)	AQRVs - Standards

(2)	Areas of Influence (as defined by the Forest Service)

-	50-km guidance (from EPA)

-	deminimus requirements

-	200-km FR notice (from Park Service for the Great Smokies)

-	NSR 200- to 100-km (currently at 100-km, even though there were discussions about 200-km)

-	No buffers (under the some of the Wilderness Acts)

(3)	Sources of Influence

-	Navajo Example Discussed

Class I Areas as an "Area of Violation"

•	Iowa is quite possibly the only state with no overlap between the Area of Influence (AOI) and the Area of Violation (AOV).

•	Los Angeles is a good example of overlapping AOIs and AOVs.

•	The final example is where the AOV for the health standard is very similar to the AOI for the Class I area.

Pollution as a Continuum

•	Some sort of background underlies the continuum; there will be places where you have violations, and others where you do not have violations. You will have PSD increments and visibility issues which are overlain on this particular continuum.

Following Donna Lamb's presentation, Don Theiler asked what the current mechanism for Class I areas was. Ms. Lamb responded that the current mechanism is not well defined because it is part of the new NSR policy, which is currently being reviewed. The proposed NSR rule, which is currently not out, discusses limits of 100- km; however, this will vary from state to state. It is currently not very well defined. Ms. Lamb suggested that some states would continue to use the deminimus requirements.

Andrew Aitken questioned what the institutional mechanism for this type of approach would be. Donna Lamb responded that the current methodology could perhaps provide an appropriate institutional mechanism, but cautioned the group to be very careful in the implementation of such a policy. Christine Shaver indicated that there was an institutional mechanism for what Ms. Lamb had been discussing. She indicated that under the current CAAA, a Visibility Transport Region could be established to meet these goals. Ms. Shaver indicated that this had been done in the western United States, and could easily be done in the eastern U.S.

David Mobley asked someone to clarify the relationship between haze, visibility and AQRVs. Vicky Patton explained that under the CAA, the PSD program which governs new sources adjacent to Class I areas (e.g. notification responsibility with the Federal Land Managers) would provide the distinction on these three issues. She continued by stating that under PSD, perhaps one of the AQRVs is visibility. She also indicated that we have a visibility protection program, which is aimed at targeting existing sources.

Sarah Pierce-Sander stated that if separate AOIs and AOVs were established for both PM-fines and ozone, then the regional haze/visibility issue should solve itself. Ms. Pierce- Sander was also concerned that she was understanding Ms. Lamb to state that the visibility standard would be more difficult to attain than either the PM-fines or ozone standards. Ms. Lamb clarified this statement by indicating that this could potentially be the result. Ms. Lamb indicated that simply looking at AOIs and AOVs may not be enough to solve the visibility issues in and surrounding Class I areas.

The AOI and AOV Issue

Harvey Jeffries indicated that the STSWG spent a good deal of time in their meeting yesterday reviewing this issue. He also indicated that Tom Moore would be briefing this group a little later in the agenda, to summarize the STSWG approach to the AOI and AOV issue. Mr. Jeffries also indicated to the audience that the STSWG would be mailing out a technical discussion of the integration/implementation of the joint particulate matter, ozone and regional haze issues (e.g. Rich Scheffe's ANPR Science Document). Mr. Jeffries concluded by suggesting that most of the issues of concern discussed today are adequately treated within this document.

Designations and Control Regions

Steve Ziman made a point to stress the lack of data in completing the necessary analyses to resolve this issue scientifically. Mr. Ziman stated that it is simply not possible to define the "airshed", given the limited amount of data that is available. He stated that the bottom line was that no matter what policy this group devises, if we do not have sufficient data to support it, then the policy is destined to fail. Mr. Ziman urged the group to undertake a broader data collection and analysis effort, prior to proceeding with the policy development.

Jeff West indicated that the overall tone of this document was negative. He suggested that the authors were not really sure of what they were saying on pages 3 and 4 of this paper. Harvey Jeffries concurred that he had a similar initial response, and as a result had provided Don Theiler some detailed comments. Mr. Jeffries indicated the STSWG solution to this issue was

twofold: increased monitoring, data collection and analysis; and, use of comprehensive models. Mr. Jeffries indicated that it must be a joint, but unified approach.

In defense of the document, Steve Gerritson agreed that the overall tone was negative; however, he stated that it was not the original intention. He indicated that the document started- out to identify the limitations of the current modeling and monitoring networks, rather than an overall negative document.

Dan Weiss discussed his concern over losing the localized approach because of the group's insistence on a more regional approach. Steve Gerritson responded that it was the intention of the authors to move away from the one size fits all approach that EPA has used in the past.

Tom Moore STSWG Presentation (Part 1):

The Current Regulatory Framework - Is it Really the (An) old (read Useless) Paradigm?

-	PM-10 by nature and form varies from site to site

-	Coarse fraction excursions - variety of sources

-	Fine fraction (PM-2.5) also can be expected to behave somewhat the same as with PM-10 at a given site.

-	What do we think we know about PM-2.5, based on what we already know from PM-10.

Technical Fixes Focus on Contributing PM-10 Sources - What does that mean?

-	Share the Pain!

-	Class-specific source category Regulations of the CAA - That is Stationary Sources

-	Mobile and Area sources more problematic

-	Tragedy of Commons

Monitoring Data Bottom Line

-	Air quality remains unhealthy at the monitor

-	Scale of measurement dimensionless at the site

-	scale is in the eye of the beholder

-	scale does not address frequency/ marginality of violations

-	scale is related to health exposure for the primary NAAQS and welfare effects of the secondary NAAQS

Ambient Monitoring Data

-	Definition of the NAAQS

-	Purpose of monitoring data

-	Goals of nonattainment sites' data collection

Model Performance Issues

-	Spatial advantages limit point-specific accuracy for the following reasons:

-	Fundamentals of "good" modeling in order: emissions, meteorology, chemistry, dispersion and predicted (but unknowable) air quality improvement (until it actually happens and is recorded at the monitor).

Need Feedback Loop Incentives Package

-	Monitoring drives the need for accurate, precise emissions data

-	Level of Effort for developing emissions and meteorology drives the model(s) selected

-	Model tests sources sensitive to emissions reductions resulting in air quality improvement

-	These must be wrapped into a coherent package

Steve Ziman cautioned the Work Groups that in recent years it has been traditional to "bash" models as the culprit of all evils related to air quality management issues. He suggested that this time, it was more a lack of data than it was the inability of the models to perform appropriately.

Tom Moore stated that there was also considerable support within the STSWG to deal with individual situations, and not force everything into a regional framework. There will be some issues that need to be dealt with locally, but a greater suite of issues that can be handled with a regional approach. Joe Paisie echoed these comments, by stating that not every problem around the country is a multi-state regional problem. He reminded the audience that truly local problems need to be (and will be) dealt with expeditiously.

John Erhman provided the following summary for the early morning session:

-	Improve the tone of the document

-	Making sure the local/regional distinction is clarified

-	Several other minor specific references (not mentioned in the summary) to certain questions within the paper that the authors had agreed to revise

Four Options for Designations:

(1)	Business as Usual - designating nonattainment areas as we have been;

(2)	Take advantage of the authority currently in the CAA, and expand it to much broader areas (e.g. areas which are influencing nonattainment areas);

(3)	Break away from the current CAA and the nonattainment designation process, and adopt the area of violation and area of influence concept. The area of violation would obviously be the region that is in violation of the NAAQS. In this case, the Class I area would be the impacted area, and would thus be used to determine the area of influence; and,

(4)	Construct a totally new approach..

Steve Ziman questioned Options 1 and 2 with regard to what types of regulations would be placed on a region that was in nonattainment. Don Theiler responded by explaining that Option 2 was still within the current framework. He continued by stating that Option 3 begins to "think outside the box", because it separates the area experiencing the violation (AOV) from the area causing the violation (AOI). Mr. Ziman asked if it was not possible to "un-hook" the nonattainment designation from the existing policy in the CAA? Joe Paisie responded that in some instances some things could be ignored, but not everything. He referred Mr. Ziman to the CAAA, Section 173, Subpart 2.

Don Theiler presented a series of maps/figures, outlining the AOI/AOV situation. Mr. Theiler stated that these figures were not based on science, but were created as explanatory examples. He reiterated that they were developed for discussion purposes only.

Area of Violation (AOV) - the ambient air quality standard (e.g. NAAQS) is being violated

Area of Influence (AOI) - sources within this region are influencing the area of violation

Possible Scenarios:

(1)	You can have an AOV, which does not belong to the AOI - e.g. the violation is totally due to transport.

(2)	You can have areas outside of the U.S., which are part of an AOI.

(3)	You can have overlapping AOIs. (e.g. LMOS and OTR) - How we deal with this institutionally or from a regulatory perspective has not been resolved at this time. The overlap could be for the same pollutant, or different pollutants.

(4)	You can have one AOI which contains multiple AOVs.

(5)	You can also have a very small AOI (e.g. one or two sources), which causes a much larger AOV.

(6)	You can have identical AOVs and AOIs.

Mr. Theiler explained that it was the recommendation of the NRSWG to accept Option 3. He stated that the issue to be resolved is, what does it mean to be in an "area of influence"? He stated that it currently means that you must be a part of the process to determine how to reduce the air quality problem.

Rich Poirot said that it was hard for him to understand a single source as an area of influence. He stated that he was confused on the concept of expressing the region of influence from a source perspective as opposed to the receptor perspective. Andy Aitken also voiced concern that with overlapping nonattainment areas, the people living in the "clean" areas had no incentives to help clean-up the problems downwind. Mr. Aitken stated that he was in favor of Option 2, because it removed all the gray areas in the argument, leaving only the obvious issues. He indicated that Option 3 was also acceptable, but noted that he did not like the stark distinction between AOIs and AOVs. He concluded by saying that perhaps we could simply adjust the wording slightly, to provide incentives for clean areas to help clean-up the AOVs.

Dewayne Huckaby stated that an AOV does not equate to nonattainment area, because we have now decoupled ourselves from the CAA. However, he continued, that what we do have to accomplish in these violation regions is to ensure the protection of public health and welfare. He went on to say that if the policy was going to be east of the Mississippi River and west of the Mississippi River, then he felt that we should simply adopt a national strategy/approach.

Christine Shaver stated that simply changing the name from nonattainment area to area of violation would not handle the legal requirements within the structure of the current CAA. Don Theiler reminded the group that area of influence does not imply any controls - it simply means that you must participate in the planning process to develop an effective strategy to remove the associated violation. Ms. Shaver stated that she was still uncomfortable with the wording changes. Ms. Shaver indicated that she liked the concept, but was just unsure of the legal ramifications.

Joe Belanger remarked that we need to carefully look at including the area of violation within the area of influence. Also, if we come down to the whole country being an area of influence, then we should rethink our broader sub-regional control options.

Tom Moore STSWG Presentation (Part 2):

Tom Moore stated that the STSWG was concerned with fugitive area sources, because of the complex nature of these source types. He indicated that this problem will become greater as we attempt to develop an integrated implementation package.

STSWG Recommended Changes to AOV and AOI

Option 3 Recommended.

Benefits:	Would push technical analyses to support public policy - e.g. a policy-driven approach to science

Challenges:	Likely to be complex for users

-	Still a "snapshot" - from a technical point of view

-	Integration of PM and ozone at a particular point in time is problematic

-	Changing polygons of AOI and AOV, due to the use of snapshots at any one point in space and time

-	One thing to consider to use this policy-driven approach, is to use a hybrid of Options 3 and 4.

Steve Ziman again made his case for obtaining more data and better data for dealing with this issue. Mr. Ziman stated that the science is simply not good enough to support these decisions at this time. Secondly, the consensus process is not necessarily working. Everyone is trying to protect his/her own turf.

John Cabaniss stated that he could not think of a better way to do handle the AOI - AOV issue. He did indicate that there was a potential practicality issue here, for the state that finds itself in the middle of multiple AOIs. How will they have the resources to participate in multiple planning episodes for each of the mandated AOIs? Don Theiler responded that this was a Phase 2 implementation issue, that had not been resolved at this time.

John Ehrman summarized the discussion as follows:

-	A number of very useful comments were given to the drafters of this document; and,

-	4 options were provided, with a preference for Option 3.

Steve Gerritson began the discussion on the implementation of AOIs and AOVs. He stated that once you make the conceptual decision to use AOIs and AOVs, then you have to think about how to implement them.

Options:

(1)	Solely on the geographic representation from monitors, supplemented by any number of analytical tools;

(2)	Identify an AOV based on monitoring data, and then designate this geo-political region as the AOV; and,

(3)	Monitors that measure violations of PM-fine and ozone must be impacted by local sources.

The recommendation is Option 1 - defining the boundaries based on monitoring supplemented by analytical tools.

Tom Moore's STSWG Presentation (Part 3):

Option 1 recommended.

Benefits:	Not necessarily different than the present nonattainment area policy

Challenges:	Data acquisition to support policy decisions

-	Health Exposure

-	Modeling/Monitoring/Emissions Data Feedback

-	Criteria for AOV Boundary(ies) likely to be driven by non-scientific considerations, given the uncertainties, quality and amount of current data.

Following this recommendation, the meeting was adjourned briefly, while the members of the Work Groups selected lunch and then reconvened for a "working lunch".

During the "working lunch" there was considerable discussion regarding AOVs. The consensus of the group was that there was no need to limit AOVs to geo-political boundaries. Jeff West suggested that a study on the accuracy of monitoring sites be undertaken to determine their ability to accurately measure violations of the ozone and particulate matter standards. Neil Frank asked to comment on monitoring and using monitoring results to explain AOVs. He suggested that there may be some tools that have not yet been used in the traditional methods to assist in defining the range of influence of a particular monitor. He cautioned the group to remember that a monitor average is a spatial average, not a temporal average. Don Theiler added the comment that an AOV does not trigger anything. All AOV means is the notification of the population, and an agreement to participate in the planning process.

Donna Lamb requested that the Class I option be included in this somewhere. Joe Paisie responded that the modified NSR rule would be considering these options. Don Theiler requested, for the sake of simplicity, that the discussions be restricted to existing sources.

Issue #3: How should AOIs be defined and identified?

Don Theiler stated that the Area of Influence is the area that has to prepare the spatially integrated plan. By spatially integrated plan the group means that the States and local regions involved must get together and hammer-out all the issues.

Sub-Issue A:	Should AOIs be identified based on all emissions including concentrations of non- anthropogenic emissions or should the designation be limited to a consideration of only anthropogenic emissions?

Steve Ziman noted that this decision should be based on the initial determination of the AOI. Don Theiler indicated that for now, the AOI is an area where only emission controls on the anthropogenic sources will be considered.

Sub-Issue B:	What geographic subdivision should be used to identify AOIs?

(1)	OTAG and OTC have simply designated entire states.

(2)	Another option is to go down to the MSA or county-level designation for the boundary determination.

(3)	Designate at a level smaller than the county-level. However, this would be difficult, because most of our emissions are only aggregated down to the county level.

(4)	Designate based on a modeling grid..

The rational for geographic boundaries on the AOV is that it does not trigger any control strategies; however, when considering the AOI, the issue becomes more political here because of the focus on emission control strategies.

Sub-Issue C:	Should zones of influence be made an integral part of the AOI designation process?

Joe Belanger stated that he did not think this issue could be addressed, without opening up an entirely new set of plans. He noted that you really cannot separate new and existing sources. He asked to revisit sub-issue B, and include within the AOI the issue of biogenic emissions. I think we need a little more expansive view of defining AOI, such that all necessary parties are identified and involved in the planning process.

Tom Moore's STSWG Presentation (Part 4):

Definition of AOI

Sub-Issue A - All emissions to ID?: Non-anthropogenic and anthropogenic?

Both are preferred (because they are needed).

Benefits:	Complete data picture.

Challenges:	Earlier details mentioned for monitoring networks, emissions data and modeling tools; and, integrated data for PM, ozone and RH.

Sub-issue B	What geographic subdivision should identify the AOI?

Generally support Alternative B with some qualifiers (e.g. use airshed approach).

Benefits:	Complete data for snapshot of AOV.

Challenges:	Policy-driven applied research, can build upon GCVTC, OTAG and OTC if data	are available.

Sub-Issue C	Should Zones of Influence be included in the AOI designation process?

Alternative B preferred.

Benefits:	Allows applied science to "catch-up"; should focus on airshed management.

Challenges:	Policy driven science, with earlier needs mentioned for monitoring networks,	emissions data and modeling tools.

Ned Meyer questioned how this type of suggestion would be implemented. He remarked that there should be a Sub-Issue D which detailed how many episodes, and what types of episodes we should be dealing with in terms of establishing the AOIs. Mr. Meyer also suggested that there should be limits put on the number of episodes considered, and how far back in time we should go. He stated that if we continue to go back to 1988, then we are dealing with a much different source configuration than will be available to us in the year 2005. Don Theiler commented that he looks at these problems as Phase II questions, that would be dealt with under the implementation process.

Rich Poirot remarked that however regions of influence are defined, in the end we must recognize that we are faced with an administrative decision. Essentially, the issue is global, and it comes down to how much we are willing to accept as being indicative. Mr. Poirot indicated that this could be handled based on meteorology; selecting the potential for meteorological influence for a given geographic region.

Christine Shaver stated that the AOI planning process should be used to reduce the size of the area of influence. Otherwise, states will not have the resources to operate in three or four different planning processes. She also commented that everyone must be involved from day 1, and then shrink the size of the AOI if possible. Ms. Shaver concluded that larger is better for the AOI issue, at least for the initial discussions.

General Assumptions - Basis for Phase II (developed by the NRSWG)

David Mobley commented that the NRSWG had struggled for some time with the form and format of the new standard, and exactly how we implement this strategy, and how do we integrate these strategies with the STSWG. Mr. Mobley indicated that the group started with 10 assumptions.

(1)	All areas can reach attainment.

(2)	The Haze Program will require involvement, and a plan, from all States.

(3)	Regional/National strategies are needed for attainment.

(4)	Control of transported pollutants must be considered as an element of haze, ozone and	particulate matter air quality programs.

(5)	Different strategies may be needed for different regions and seasons.

(6)	Scientific understanding and analytical tools shall be available to integrate strategies, define control regions and track progress in reaching attainment.

(7)	FACA recommendations will be based primarily on qualitative rather than quantitative assessments.

(8)	Quantitative tools will be used for rank ordering of integrated control measures and their resulting effects over multiple pollutants and across interacting control regions.

(9)	Integrated implementation will be applied uniformly within transport regions and integrated measures can be classified as helpful, detrimental or neutral for any of the integrated pollutants.

(10)	A common currency based on 'best integrated overall benefit' can be developed for the purpose of multi-pollutant trading.

Don Theiler suggested that the two Work Groups seem to be approaching this issue as if it is something that we do not know how to deal with it. Mr. Theiler commented that other Federal programs have dealt with these types of issues (e.g. FEMA, water quality, etc.). He reminded the Work Groups that you can only design for the best case; if nature then comes along and throws you a curve ball, then you simply have to accept this level of environmental damage. He indicated that you simply say that this standard is designed to provide this level of protection, and if you have a bad meteorological season, and things go sour, then you simply have to accept it and move on. Tom Helms questioned Mr. Theiler if this was a design of the standard or a design of the implementation plan? Mr. Theiler responded that it was a function of the implementation plan. Steve Ziman commented that for both LMOS and California, that sufficient controls could not be identified for these regions in agreement with the alternative standard. Mr. Ziman stated that the reductions simply were not achievable. As an example, Mr. Ziman commented that in terms of PM in California, there is not an acceptable methodology for achieving the State standard.

Donna Lamb commented that on the issues of anthropogenic versus non-anthropogenic emissions, meteorological variability and natural events, that at some point you simply state that you have no control over these things, and you are forced to address them individually. Tom Moore agreed that the form of the standard is a complicated determination and that these two groups will most likely not address this issue. Mr. Moore encouraged the groups to think about the whole dialogue between science and strategy, and to keep the door open to let science support

the position of the policy/strategy people. Mr. Moore concluded that the group needed to give EPA the chance to manage these complex natural issues.

Assumption 2:	Haze Program

Rich Poirot noted that in Vermont's program, everyone east of the Mississippi River would be involved. However, Dan Weiss commented that Assumption 2 suffered a great deal of the same problems that Assumption 1 faces (e.g. it is sort of like a blank check). Mr. Weiss admitted that he did not really have a quantitative definition of regional haze and what the regional haze program is. Don Theiler commented that the Regional Haze Program seemed to be closely linked with Class I areas. Robin Dunkins reminded the group that the EPA was required to promulgate the RH rules within 18 months of the submission of the GCVTC report. Therefore, she indicated that the RH rule will be out prior to the other regulations.

Don Theiler responded that he was not aware that the NRSWG was dealing with the specifics of Class I areas, regional haze and all the other AQRVs. Robin Dunkins answered stating that we are not dealing with what is /is not a Class I area, rather we are simply looking at AOIs and how they affect these regions.

Assumption 3:

Harvey Jeffries stated that most of this was covered this morning in our discussion of AOIs, where we concluded that these would be done on a case specific basis.

Assumption 4:

Harvey Jeffries noted that the STSWG had attempted to address this issue in the ANPR Science Document.

Assumption 5 :

Harvey Jeffries stated that this assumption is a given for STSWG. He indicated that the introductory chapters of the Conceptual Model Document treat this subject very succinctly and completely.

Assumption 6:

Steve Ziman stated this should be an iterative process. He commented that for all the complaints about modeling, we still have no surrogate for environmental predictions, other than modeling. Mr. Ziman noted that we must recognize the limitations of these tools, and their benefits.

Assumption 7:

Harvey Jeffries indicated that there was no time or funding available for any quantitative work. The work that we do will be based on qualitative assumptions/decisions. Obviously, S.T. Rao's work and Robin Dennis' research is quantitative in nature; but, does not form the bulk of the STSWG's analyses.

Assumption 8:

No discussion.

Assumption 9:

No discussion.

Assumption 10:

The group concluded that we clearly do not have a common currency for a trading program at this time. Harvey Jeffries indicated that he was not confident that there is any science that could justify the existence of common currency for trading. Mr. Jeffries noted that you would have to use extremely complex models to ascertain these answers. He concluded that there is no way at this time to do a ton for ton, mole for mole type trading policy. However, Rich Poirot agreeing that this would not be a universal currency, indicated that he would not rule it out on a case by case basis.

In closing the meeting, David Mobley asked the audience to get comments to him by close of business on Friday on the above 10 assumptions. He also indicated that he was open to accepting new assumptions if they were proposed.