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Tom Moore 11/13/97

Science and Technical Support Work Group's Position on AOI/AOV Papers

The Science and Technology Support Work Group has spent considerable time and effort in its attempt to provide a technical framework explaining how to develop planning tools and plans to meet the new standards in a cost effective manner. This body of work has been presented in the Conceptual Model report and in numerous issue papers that STSWG developed in response to questions from other work groups.

STSWG recognizes that planning will always have inherent uncertainties, and STSWG has recommended the use of an iterative process which links observed data to the predicted changes in air quality. The iterative planning process is viewed as a means of moving effectively towards attainment of the standards.

Two recent non-STSWG issue papers have appeared that recommend mechanisms by which the EPA could move forward to address both ozone and PM nonattainment issues. STSWG believes that these papers do not fully reflect the technical processes that STSWG has suggested and instead reflect a political response to planning requirements.

The first of these papers is anonymous from the EPA and is titled "The Regional Air Management Partnership (RAMP) and the Area of Influence (AOI) Process." The paper notes that the EPA considers that the OTAG process has essentially demonstrated itself as a de facto RAMP and therefore the RAMP/AOI process has worked successfully for ozone. The RAMP/AOI paper then suggests that now is the time to address PM issues with the establishment of two RAMPs nationwide.

The second paper, "A Framework for Areas of Influence/Areas of Violation (AOI/AOV): Responsibility for Reaching Attainment," is a product of a small ad hoc group trying to resolve the problem of the present approach to nonattainment. The Framework paper recommends that those areas which would be classified as nonattainment under the new standards make early reductions to improve air quality or even reach attainment prior to implementing a major SIP process. Among the assumptions in this Framework paper is the desirability of developing a presumptive list of control measures that should be implemented by the AOV in the years preceding the SIP process. The paper assumes that the AOV can be exempted from some control measures by using a set of simple criteria and will not need a rigorous SIP analysis to determine what measures are necessary.

The following seven eight points represent the STSWG criticism of these two papers:

1.	STSWG felt that neither paper supports the idea that the underlying foundation beneath EPA's air management process should be the development of adequate tools and databases (both modeling and economic). STSWG has consistently recommended that there is a need to improve air quality models, databases, and data analysis prior to planning decisions. If sufficient analysis is not undertaken, then the use of modeling tools to develop realistic approaches for improving air quality will be questionable. STSWG believes that the mechanisms of ozone formation are not yet fully understood, and assessments by STSWG and NARSTO show that the models and databases are currently insufficient to plan for PM standards or integrated plans for PM and ozone.

2.	STSWG would like to recognize that a model's strength is in evaluating past episodes and not in making future predictions of meteorological events. Even if models are perfect predictors for historic cases, the atmosphere is stochastic and predictions for future years must be based on forecasts. This will always introduce uncertainty into the planning process.

3.	STSWG supports the idea that model predictions should be compared to ambient air quality measurements in the future and midcourse corrections should be made when necessary. Because of the uncertainties in the planning process, STSWG calls for an iterative process to be introduced into the planning process. Model predictions should be compared with ambient air quality measurements at some point in the future (e.g., five or six years after the adoption of the plan), and the effectiveness of the model and the control measures should be re- evaluated. A midcourse correction could be made where necessary. This concept is also embedded in the Reasonable Further Progress issue paper.

At this time, EPA is justifying its plan for major NOx reductions (80 to 90 percent) predicated on OTAG analyses. Some reductions cannot yet be identified (i.e., they are Tier 3 "black box" reductions), and the question still exists about whether the 8-hour standard is achievable from a practical standpoint. Therefore, it will be necessary to look at the effects of implementing NOx controls over time, determine if there are interim disbenefits, and readjust the planning process. While the decisions about appropriate strategies are political, the assessments are technical in nature and should be available to decision-makers prior to the selection of strategies.

4.	From a technical perspective, there is a continued need to obtain air quality, emissions and meteorological data, and carry out sufficient data analyses which are, at a minimum, regionally standardized. Whether done by fiat from the EPA, by scientists from groups of agencies and organizations with similar regional air quality issues, or by decentralized individual interests based on national/regional/peer-reviewed data collection/analysis standards, these data are needed sooner rather than later. The FACA Subcommittee should explicitly state the need and importance of these data for future policy decisions.

New 5. Old 4.	STSWG questions the recommendation notes again that requiring an AOV to should implement a presumptive set of controls to address air quality issues for secondary pollutants creates a risk or tradeoff in knowledge versus belief for policymakers. The STSWG re-emphasizes that only through the addition of scientific knowledge and repeated review of control strategy effectiveness will the determination of the success of presumptive controls be possible. A method of presumptive controls may be adequate in some cases for controlling primary pollutants and preclude the necessity of detailed modeling but should not be used for secondary pollutants. Without understanding the complex non-linear chemistry producing ozone or secondary aerosols, no simple mechanism exists to judge if the presumptive controls will benefit air quality or provide cost-effective solutions.

New 6. Old 5.	The definitions and roles of RAMPs, AOIs, and modeling centers should be stated explicitly in such a way that political entities will support rather than hinder the scientific community. STSWG views RAMPs as political entities which identify technical people, establish the funding sources for the modeling centers, and approve the scientific findings. The decisions about RAMP boundaries should not interfere with the science. This is well-stated - Go team !!

New 7. Old 6.	STSWG does not agree with the automatic presumption that there is no need for ozone RAMPs. STSWG also questions the formation of exactly two RAMPs to address PM issues. ( move to New 4, above as the basis of that bullet, insert sentence to replace this one, dealing with PM and Ozone knowledge and what we "know" about how a RAMP should be constructed) the local and regional scale formation of ozone in various parts of the country, both for the one and 8-hour standards. STSWG has recently stressed the need to consider the concept of a linkage between air quality models (provided that they have undergone rigorous evaluation) and economic models, such as the one developed by the Cornell Institute of Social and Economic Research in conjunction with the Department of Atmospheric Sciences at SUNY. A linkage of air quality and economic models could provide a least-cost alternative to a command-and-control approach to ozone improvements (EPA OAQPS asked STSWG for feedback on this approach since OAQPS is considering the value of the linkage in SIP planning). STSWG believes that the economic models also need to undergo a rigorous evaluation of their underlying assumptions. One major mechanism upon which this linked approach lies is the ability to establish a trading program to address both local and transported ozone precursors.

A concern that results from a linked approach would be negated by the adoption of the recommendations in the RAMP/AOI and Framework papers. The concern is that there may be differences in the ranking of control measures (including the spatial nature of the measure) when considering strategies for the one- and 8-hour standards using a least-cost approach. Pursuit of a strategy that moves to meet the one-hour standard may be likely to show improvements in air quality with respect to the corresponding 8-hour standard. However, these controls may not be optimal for meeting the 8-hour standard in a cost-effective manner. Implementation of a control program for the one-hour standard could adversely affect the liquidity of the market needed to devise a least-cost program for the 8-hour standard. Adoption of a set of presumptive controls would also have a negative impact by including options which would not be used in a least-cost approach.

New 8. Old 7.	STSWG does not feel that the OTAG process can be described as a success in terms of technically sound planning. The OTAG process was adversarial and did not achieve a successful buy-in from all stakeholders on which solutions would be effective. In order to deal with the increasingly complex issues associated with the new PM and ozone standards, a cooperative process will be necessary which involves all stakeholders. The RAMP process may be more successful if two levels of RAMPs are recognized. The first RAMP could be large and political in nature with the goal of directing the initial analyses and defining the AOIs and AOVs. The AOI and AOV boundaries would then define the second RAMP, and the second RAMP could proceed with the technical development and the assessment of planning tools and control strategies.