MEETING MINUTES

FACA Subcommittee for Ozone, Particulate Matter, and

Regional Haze Implementation Programs

Portland, Oregon

Wednesday, August 13, 1997

William Hamilton [Designated Federal Officer, U.S. Environmental Protection Agency (EPA)] called the meeting to order at 8:40 AM. He welcomed participants and made opening remarks. Mr. Hamilton noted that John Seitz and Sally Shaver would not be attending the meeting. Bill Harnett would replace them over the next two days, and on Thursday Tom Curran would be the EPA co-chair. Mr. Hamilton introduced Gary Allen of the Metropolitan Washington Air Quality Commission as a new member of the FACA Subcommittee.

Mr. Hamilton noted that two evening sessions had been planned on National Ambient Air Quality Standards (NAAQS) and monitoring. He said the draft minutes from the June meeting were available on the Technology Transfer Network (TTN). Mr. Hamilton also asked attendees to submit their travel expenses to EPA as soon as possible.

Alan Krupnick (Resources for the Future) said that the meeting would focus on the Presidential Directive (PD) and the future of the Subcommittee. The PD had left a lot of issues on the table. Mr. Krupnick said that the members of the subcommittee should not be discouraged. From his viewpoint as an economist, the PD suggested movement toward incentive- and market-based strategies. The main issue mentioned was trading pollution credits in the Ozone Transport Assessment Group (OTAG). Mr. Krupnick said the Subcommittee should make this a reality. However, if the policy was to go to 85 percent nitrogen oxide (NOx) reduction, he questioned why they should even bother with trading. It might not be worth the trouble if only utilities were involved.

Mr. Krupnick talked about the Clean Air Investment Fund. One could view the $10,000/ton cost as a way to ensure that reductions occurred at the lowest possible cost. They might want to think of it in terms of effective tons. Mr. Krupnick thought there was time for pilot programs with economic incentives such as CMAT. Finally, he said that EPA had not joined the ozone and particulate matter (PM) groups, and that maybe EPA should join them.

Bill Harnett (EPA) talked about the PD and how it came about. He said there was no plan for it originally. The directive was developed as a part of a process that started with the Clean Air Act's (CAA) distinction between standards development, which was health-based, and their implementation. The CAA had always separated setting standards and implementing standards, and the two issues should be separate. The EPA Administrator, Carol Browner, intended to maintain this approach to standard setting, and in discussions, shared information about how she saw the issues and the time lines. Administrator Browner was clear on how to go forward and talked about the work coming from the FACA Subcommittee, the work from OTAG, all of the work on implementation at State and local levels, the PM standard at 2.5 microns, and the lack of a monitoring network. It was her view that implementation should be put in writing and explained to the public, showing how it would move and what the dates would be. That was what led to the PD. Also, other agencies felt strongly that items must be written down to bind EPA to a course of action.

Mr. Harnett said it was important for EPA to go in the direction of implementation. It was the right direction to move and it was a mandate. That was the reason the PD was written. It was originally much longer, with the draft at 50 pages. Other agencies participated in its development and had different views than States and local agencies would have. The PD focused on how EPA and other agencies would go forward. It moved on a faster time frame than most issues. In the monitoring proposal, for example, the PD said data from monitors initially would be used for science and not for designations or regulatory sanctions. EPA had proposed an Interim Implementation Plan (IIP), but they had modified it substantially based on feedback from congressional members who worked on the Clean Air Act Amendments (CAAA) of 1990, particularly Congressmen (John) Dingell (D-Michigan) and (Henry) Waxman (D-California). They adopted the point of view that CAAA Part 2 applied all the way through, which made a difference in how EPA proceeded.

Mr. Harnett said there would be bumps up; they would be triggered by failure to meet the 1-hour standard, not the 8-hour standard. The emphasis on public health protection was high. EPA felt that there would be reductions in the near term. The timetables for PM-fine were driven by the lack of monitoring data. EPA also revised the rules of New Source Review (NSR) for nonattainment and transitional areas.

As far as a regional strategy for ozone was concerned, Mr. Harnett said that EPA would come out in September with its analysis for the States. It had deferred designations in the East. If an area could get back into attainment through the regional strategy, they would not be put through the entire process. An area would be classified as transitional and held to its prior commitments. That was the original goal.

For areas in the West and areas that were close, Mr. Harnett said EPA would offer the same options to any place with a proper State Implementation Plan (SIP) that met the 1-hour standard from now until 2000. The 1-hour standard would be phased out as soon as it was attained. Then only the 8-hour standard would apply. Areas eligible for transitional classification outside of OTAG were only in California. They could use input on the requirements for areas that were close to attainment by 2000.

Mr. Harnett said that EPA's focus was the change in the standard. There was a stigma associated with nonattainment areas. Those areas that had worked with industry, transportation conformity, and NSR were the areas where nonattainment would be affected. At the same time, they would look at trying to not move industry from one area to another. The areas that would get no benefit were ones that did not submit a SIP by 2000, areas that did not request transitional classification, and areas that did not attain the 1-hour standard by 2000.

Mr. Harnett said that EPA believed cap-and-trade would work, but that it did not have the authority to implement a program; it would be up to the States to do that. EPA could accept several programs, which State governors would present.

EPA did not believe that PM-2.5 could be estimated without monitoring data. The monitoring program was in EPA's budget, and it would pay for speciation. Congress agreed that EPA needed the monitoring network and was including money in the budget to pay labor costs. Mr. Harnett thought that this commitment from Congress would hold. The most important thing was getting the monitors in place and doing speciation; EPA would designate areas later. Also, EPA would not implement national measures before it had three years of data. It would not act on designations until after the five-year science review was completed. This would allow speciated data from the new monitors to be tied into health studies. It would be considering data that were in place now. When one had to attain depended on the area's classification.

Mr. Harnett said that many rules were going into place, and implementation of these programs would continue.

Regarding implementation of PM-10 standards, Mr. Harnett noted that the standard had been relaxed from its present form. It was currently a 99th percentile. The 24-hour standard was making areas nonattainment under PM-10 but probably not under PM-2.5. They needed to address the standards in the SIP to get out of having to meet the relaxed PM-10 standard. On the implementation side, the commitment was to get those done by 1998. Then the States could choose whether they wanted to aim for a transitional classification.

Mr. Harnett said EPA felt that the $10,000/ton cutoff was arbitrary and wrong. This was because they traditionally overestimated costs and underestimated benefits. The Clean Air Investment Fund was suggested as a solution to this problem. Other parts of the Administration agreed. The States still must come in with attainment demonstrations.

EPA did not want to make local area decisions. For existing ozone nonattainment areas, EPA saw them as still aiming for their current timeline for the 1-hour standard. Then they could use the next three years to attain the 8-hour standard. Los Angeles still must meet both standards in 2010, and there was nothing they could do about this.

Alan Krupnick said that the goals for this session were to discuss important points of Mr. Harnett's presentation, provided the discussions were productive and of interest to everyone. Then they wanted to turn to the discussion of the Subcommittee's future.

Bill Harnett said it might be easier to discuss ozone first and then PM.

Alan Krupnick said they would discuss ozone, then PM, then integration.

Shawn Kendall (Phelps Dodge) asked whether the $10,000/ton was a capital cost or an annualized cost and whether it affected facilities that already had controls.

Bill Harnett said it was an annualized cost.

Shawn Kendall asked whether EPA would require a retrofit if a new technology became available.

Bill Harnett said assuming there was equivalent control, there would be no reason to switch.

Robert Wyman (Latham and Watkins) said he thought it would be important to show what they had previously done with caps. It would be good to have a background talk at the October, 1997 Subcommittee meeting.

Alan Krupnick said that the economic incentives group would meet at lunch and discuss options.

Bill Harnett said that there were other ways a State could handle this issue.

Sarah Peirce-Sandner (Eastman Kodak) asked what the $10,000/ton meant and whether it influenced SIPs. She also asked how EPA arrived at that number.

Bill Harnett said that a State was still required to show reductions and its measures for obtaining them. EPA was willing to give credit for a trust fund, and there would be opportunities in the SIP process to determine how much credit could be given to a fund that might allow a State to buy credits from someone else. EPA had not gone into the SIP process and how it would be implemented. EPA was using its estimates of the higher end of control costs. The other agencies accepted EPA's approach provided EPA gave the States the same goal that was given to those agencies. Maximum Achievable Control Technology (MACT) programs had their own standards and technologies that would not be affected. They were looking more toward control measures.

Dennis Lawler (Illinois EPA) asked whether States would have the option of joining this program.

Bill Harnett said that EPA thought it would run at the State level. EPA could help with the structure and the data bases, but could not mandate that two States work together.

Vincent Brisini (GPU Genco) asked whether the Clean Air Investment Fund was available to those areas that did not meet the standard.

Bill Harnett said it would be available to all areas.

David Hawkins (Natural Resources Defense Council) asked whether EPA would issue guidance or timelines.

Bill Harnett said that EPA was encouraging States to think about it, and it might put out some general guidance. Some areas not classified as serious would be able to set a cost and fix their plans.

Bill Luneberg (GASP) asked whether they would hear about EPA's views on how this affected transitional areas, given that NSR rules were revised.

Bill Harnett said that if the transitional areas operated close to attainment areas, he was not sure EPA knew where it would come from. The NSR people were not involved.

Mike Wright (Steelworkers' Union) asked whether it was fair to say that EPA would look favorably on considering costs during planning. He also asked whether the need to comply would be the determining factor in some areas.

Bill Harnett said that the SIPs still had to meet the standards. For example, inspection/maintenance (I/M) programs worked very well in some areas but not in others. EPA did not think one should surpass those costs, but there still needed to be a lot of work.

Jim West (affiliation unknown) said that the Clean Air Fund was under suit for alleged violations of environmental justice. He asked what effect this action was having on EPA.

Bill Harnett said it was an issue.

Beverly Hartsock (Texas NRCC) asked whether there would be any new areas designated for the 1-
hour standard, whether there would be multiple decision processes, and whether there were options available for areas in the West in the coarse grid.

Bill Harnett said that there might be some re-designations. For the ozone timeline, EPA was already looking at 2007 and limiting itself to that year. EPA staff felt that it was unlikely. For PM-2.5 more data still were needed on implementation. The longer deadlines were not a bad feature. On the coarse grid, the transitional classification was still available to all areas of the country. The distinction was that groups that did regional planning would not have to go through it again.

John Crouch (Hearth Products Association) asked whether Areas of Influence (AOIs) and Areas of Violation (AOVs) were totally off the table.

Bill Harnett said no, not by any means. It was left out for clarity and did not need to be part of his discussion. EPA believed AOIs/AOVs were the way to go. They would designate the counties and not just the Consolidated Metropolitan Statistical Area (CMSA). Again for PM fines, EPA was lacking information. There was a significant regional component. There was a different kind of strategy in the East going on regionally right then for ozone. It would clearly be there for PM.

Nancy Kruger (STAPPA/ALAPCO) said the PD indicated that new areas would be designated in next few months. She asked how many and which years EPA would be looking at.

Bill Harnett said 2007.

Nancy Kruger asked what the significance of 2010 or 2012 was.

Bill Harnett said that 2012 applied to other areas that were not transitional or nonattainment areas. EPA was offering this to people who came in early and attained by 2007. If they did not do that, they would be functioning like a non-attainment area. The only areas that EPA might re-designate were the ones that EPA thought might be falling into nonattainment. EPA was looking at the most recent data and would put out a notice that said which areas EPA saw as meeting the new standards and then allow comments.

Jim Lents (University of California-Riverside) said Bill Harnett was indicating that they should look at the 1-hour standard, but it might be better to look at the 8-hour standard.

Bill Harnett said that if one did not meet 1-hour standard or 8-hour standard, plans must show how one was going to meet both.

******BREAK******

William Hamilton resumed the discussion on the same issue after the break.

Mike Silverstein (Colorado CDPHE) referred to ozone areas that attained the old standard and asked whether EPA would require continued controls and maintenance of controls.

Bill Harnett said that removing something from a SIP required proof that it would not affect a State's ability to meet requirements. As for SIP maintenance plans, it depended on which classification the State wanted.

Mike Silverstein asked what EPA intended to do about transportation conformity.

Gay MacGregor (EPA, Office of Mobile Sources) said that if an area was re-designated, then the maintenance plan would not be required.

Bill Harnett said that they were talking about areas that did not currently have maintenance plans.

David Hawkins asked how EPA would handle an area that met the standard from 1994 to 1996 but not in 1997.

Bill Harnett said that a decision had not been made.

David Hawkins said he understood that EPA would take comment on those areas.

Bill Harnett said EPA would present it as a finding and then take public comments.

David Hawkins said that if there was a replacement plan to consider the 8-hour standard, it would make sense to let the plan change. However, it appeared there was a gap between the 1-hour standard and the 8-hour standard. He wanted to know how locked in EPA's thinking was on this issue. Mr. Hawkins said he did not see this issue addressed in the PD. He asked what the nature of EPA's thinking was on this decision and whether it would it take comment or just make a declaration.

Bill Harnett said the understanding was that they would not require maintenance plans. The 1-hour standard was no longer the interim standard. There were a number of incentives in the system. An area should be trying to meet the 8-hour standard if it just got out of the 1-hour standard. EPA also felt that the regional reductions in the East would keep things moving forward. EPA thought these were the things to be pushing now. Mr. Harnett said he thought that the movement was there in terms of implementation plans.

Steve Gerritson (LADCO) asked whether the evaluation of the 8-hour standard would be a one-time thing. He also asked about AOIs and AOVs, noting the need for EPA to be flexible. He said he wanted some assurance that the way they dealt with transport was considered in the PD. Mr. Gerritson thought it would be helpful to let everyone know their responsibilities. If they could integrate planning, it would help.

Bill Harnett replied that designations were never "one time". He thought they were looking at ozone changing so that all areas in the East, including attainment areas, would benefit. In the West, he thought there were areas that might become ozone problems and move out of attainment; designations in the West must be well-managed. In reference to AOIs/AOVs, Mr. Harnett said it was not yet clear how they would play in particular plans for ozone. The AOI would be a broad concept. For other pollutants, they were willing to consider this. He thought Subpart 2 still allowed AOIs. He did not know what level of detail in modeling would be necessary for the 1-hour standard; there would be a lot of attainment demonstrations for it. Mr. Harnett noted that ozone was on a different schedule. EPA had waited a while, but it was time to look forward. EPA thought the planning was appropriate now, so they should move forward. There was flexibility for other constituents, but not for ozone.

Bill Luneberg said that it would seem to be in the best interest of some States to follow the regional approach, then just hope that they were right.

Bill Harnett said there was always uncertainty about whether they all would end up in the right place. If an area strongly believed that the health of its residents was threatened, and local measures were not adequate, assistance would be made available. The area ought to take action. State regulators would have an obligation to protect the public.

Greg Green (Oregon DEQ) said there was more to the West than California. In terms of re-
designating to attainment, there was the potential for backsliding, especially in transportation. He would expect significant backsliding.

Bill Harnett said he appreciated Greg Green's concern.

Richard Phelps (Eastman) asked Bill Harnett to please comment on the fact that some eastern States were calling for the Federal government to take targeted action under Section 126.

Bill Harnett said EPA had not received any petition yet. EPA felt that the target levels should be set for a State rather than source by source. A State's overall emissions should be addressed. EPA was heading in that direction. Mr. Harnett said that EPA would deal with the petition if it came in.

Jeb Stuart (Construction Industry Air Quality Coalition) asked what the scientific review would include.

Bill Harnett said EPA would look at health effects, but speciated data would not be available in time from existing monitors. EPA would look at implementation time frames. The standard was based on public health with an adequate margin of safety. The review would include health science.

Glen Cass (California Institute of Technology) said that in the PD, the 10,000 number applied to both PM and ozone. He thought that a one-size-fits-all approach could distort PM technology programs and seriously affect particulate issues. The gaseous precursors represented a different weight. For ammonium nitrate problems, based on molecular weight, one should be willing to spend more money per ton. A single cost of control should be re-thought.

Bill Harnett said that Glen Cass was correct and EPA would consider his point.

Bruce Hill (Appalachian Mountain Club) asked what the logic was behind designating after the NAAQS review.

Bill Harnett said that the timetable led EPA to that conclusion because of when the monitors would be in place. EPA would not have the data in until then, which extended beyond the five year review. People wanted agreement that the next five year review would be done on time as EPA was required by law, and they did not see a problem with making that commitment.

Bruce Hill said that obviously PM-fine monitoring data were lacking, but there were substantial data from the IMPROVE network showing that light extinction was related to PM-fine. The science was not unclear with respect to haze. There could be integration of the programs for regional haze to get there sooner.

Bill Harnett said Mr. Hill's approach was considered, but it seemed more prudent to wait for local data. EPA did not see how one could follow this approach without making some mistakes first.

Bruce Hill said he would challenge EPA that it would not make mistakes because PM was less prone to hotspots. He thought EPA could go forward now and did not see the potential downside.

Bill Harnett said that without data and speciation, he did not think EPA understood the problem well enough to meet the need for control strategies.

Bob Palzer (Sierra Club) asked Bill Harnett to explain what would happen to an area that did not have an approved SIP but it still met the standard. He wanted to know what position that area would be in under the new guidelines.

Bill Harnett said areas that attained both standards must meet SIP requirements for the standards. After a demonstration of the new SIP, they would drop the old requirements. The requirements did not specify the demonstration.

Bob Palzer noted that in the preamble there was a paragraph stating that modeling demonstrations would not be required. He asked whether it still would be appropriate if modeling had been done.

Bill Harnett said yes. Modeling was not required; EPA would be looking at air quality data only in determining whether to revoke a designation.

Bob Palzer said it seemed like backsliding if the model did not show attainment.

Bill Harnett said that there would still be a PM-10 standard in place, but it would be the 99th percentile standard.

Mike Wright asked whether Bill Harnett saw the development of control strategies as a State responsibility or Federal activity. He also wanted to know whether EPA saw the process of devising control strategies occurring over several years and asked how stakeholders would be involved.

Bill Harnett said data would be available so researchers and others could get the information they needed, including speciated data. EPA was not going to wait until the end. Transportation and Energy Department representatives had strong views about speciation. Mr. Harnett thought there would be more than one component down the road. There would be needs for local, regional, and national controls. It would be appropriate to deal with interstate issues, but they were not clear yet. Stakeholders would have access to the data. Mr. Harnett thought that emissions inventory development and other issues needed to be worked on from a technical point of view.

Mike Silverstein asked whether PM-10 areas that were now attaining the old standards would be able to remove parts of an approved SIP.

Bill Harnett said they would have to do the demonstration.

Mike Silverstein asked whether conformity would apply.

Gay MacGregor said if one was in a maintenance area, one would still have to comply.

Mike Silverstein asked whether general conformity still would be necessary.

Bill Harnett said he did not think so.

Robert Wyman asked whether the cost per ton was the same as a surrogate for cost per air quality benefit. He also asked whether they could improve the benchmark, as Glen Cass had suggested.

Glen Cass said given that this was a PD, he did not think they could control the benchmark.

Bill Harnett said that EPA did have control of the benchmark as long as they continued to cap the cost. It would still be in line with the PD.

Ted Russell (Georgia Institute of Technology) said he thought they could talk about effective tons in terms of ozone.

David Baron (Arizona Center for Law in the Public Interest) asked whether States would be required to start all over again for areas that currently violated both the old and new standards.

Bill Harnett said no, they would be required to continue along the same track. There would not be a new schedule.

David Baron said he urged EPA to not allow States to drop the ball in the transition. EPA should not allow backsliding and should ensure progress at the same rate.

Bill Harnett said EPA would consider those comments.

Shawn Kendall said that integration was a reality, not a concept. They were doing a lot right now as they controlled ozone, sulfur dioxide (SO2), and PM-10. One would also affect regional haze. Having a control strategy in a SIP in one State could help another State. It was important to know what the SIPs from other States would do.

Bill Harnett said he did not think they could get to full integration until the final steps. When they started seeing the data, full integration would be done.

Richard Dworek (U.S. Steel) said he understood that the 99th percentile would take precedence over the maximum and wondered whether this would take place immediately.

Bill Harnett said one must show attainment with the old standard first.

Richard Dworek said he thought that the FACA Subcommittee was pleased that monitoring and speciation would be done. They had some limited meteorological data. He hoped that the PM-2.5/PM- 10 differences could be considered.

David Hawkins asked whether EPA could indicate how the monitors would be placed.

Bill Hunt (EPA) said that target would be to have the ozone index by the spring of 1998. With respect to PM-2.5, they would need continuous monitoring at some sites that compared favorably with the Federal reference method. EPA needed that information before they set the index.

David Hawkins asked whether the data would be available.

Bill Hunt said yes.

David Hawkins referred to the comment on making mistakes about PM-2.5 data. He said he was not aware of a firm basis for that conclusion with the early implementation of measures; he was not aware that they had made mistakes. Doing nothing was a mistake in terms of setting up SIPs. Mr. Hawkins was concerned that Mr. Harnett's comments indicated that EPA would not try to reduce precursors until it had three years of data. EPA should consider what to do in the interim in terms of health protection.

Bill Harnett said he felt it was important to get a larger monitoring data base before one made control strategy decisions. It would not require three years of data in hand. There was a lot of work that could be done in the interim, that did not need to wait on the monitoring data. EPA would not designate until it had three years of data.

Shawn Kendall said he thought the state-of-the-science was not there strongly enough to justify the changes for PM-2.5. He would hesitate putting in PM-2.5 strategies, because his ozone controls might bring the PM-2.5 in line.

David Baron addressed a concern raised by David Hawkins. He noted that the schedule that Bill Harnett handed out said the States had up to ten years to attain. The statute did not automatically give ten years. It gave five years with maybe another five.

Bill Harnett said David Baron was correct.

Susan Stark (ARCO) spoke about timing asking whether it was coupled with data collection, speciation, and science review.

Bill Harnett said that within the time frame, EPA would not go forth with designations until they completed the next review.

Bob Palzer asked Bill Harnett what EPA would do with the standard taking effect in mid-year 1997 and how it would account for part of the year.

Bill Harnett said EPA had not decided on the years it would use. It would not split the year if it chose 1997.

Alan Krupnick thanked Bill Harnett for handling all of the questions directed to him. He said that the next item would be future of the FACA Subcommittee. In the Coordination Group, they had reached a consensus that there would be two more meetings. They would attempt to close out all remaining issue papers. They would discuss OTAG SIP calls and the revised IIP that would be coming out. The December meeting would close out the FACA process. If EPA came to the Subcommittee with some specific questions, then they would reconvene. The logic for continuing was that they had a lot of issue papers to wrap up. There was some hesitancy to continue beyond December because of the tight timeline EPA was facing. Writers of the issue papers would be given guidance from the Coordination Group in figuring out how to finish things up. Mr. Krupnick opened the topic up for discussion.

Bill Luneberg said that if the Subcommittee continued that long, he would like to keep discussing NSR.

William Hamilton said EPA planned to meet the PD schedule. Bringing NSR back would not necessarily be beneficial. Input after that time might not be helpful.

Vincent Brisini asked what items in the issue papers was open to discussion and what the boundaries of the box were.

Alan Krupnick said he saw two boxes; Box A was the CAA and Box B was the PD. To the extent the papers were outside one or more of those boxes, ideas should not be eliminated. They should put effort into some things outside the boxes. He thought the papers should be flagged for what was outside the box. Mr. Krupnick said he would bring them up next week in the Coordination Group.

Tim O'Brien (Ford Motor Company) asked how EPA was defining the size and dimensions of the boxes.

Alan Krupnick said the Subcommittee had a matrix that presented this information in one light, which was the CAA box.

Harvey Jeffries (University of North Carolina) said he did not have that matrix.

Alan Krupnick said the matrix was the August 1 document and asked who had the matrix. He asked whether EPA could come up with a better definition of Box B.

Bill Harnett said he thought the PD drew certain lines about ozone and timelines. The regional air management partnership (RAMP) planning was left open. He thought that cap-and-trade was addressed, but it allowed other areas to be considered. He asked what kind of input would come from this group and what the priorities were for things that would come from it.

Alan Krupnick asked whether there would be a time when the Subcommittee got a priority list from EPA so that those issues could be covered as well as possible.

Bill Harnett said EPA could commit to providing a list to the Subcommittee. The Subcommittee's input would be welcome as soon as possible. By October, EPA's work would have taken on a specific shape. First the priorities for EPA would be NSR and transportation conformity. Second would be PM-10 areas and what should be required in attainment and demonstration, and third the 1-hour standard demonstrations and how EPA should proceed.

John Crouch asked why they were going to address AOV boundaries if EPA needed something else first. He wanted to know why the Subcommittee was doing papers that were not on EPA's hit list and whether they were doing the papers just to check them off.

Gay MacGregor said EPA was ready to come forward with its approach in terms of conformity and get the Subcommittee's comments. The PD had changed some of EPA's direction, but the paper they would be looking at tomorrow was still good. EPA wanted stakeholder comments.

Alan Krupnick said one set of issues was where should they put their efforts and how the papers should be scheduled.

Mike Wright said he thought there needed to be an ongoing committee, with perhaps a way to avoid congressional re-appointment.

Vincent Brisini said that there were a lot of implications. They needed to make sure that the Subcommittee could have an effect. He wanted to leave alone the areas where decisions had been made.

Bill Harnett said that EPA was in the lead to implement the directive. EPA understood and could speak for the process.

******LUNCH******

Alan Krupnick said that in terms of the four issue papers scheduled for the next day, they were still relevant and timely. EPA folks would make comments before each presentation about their concerns with the paper. This information would be communicated to each presenter in advance; there would be no surprises. The matrix was already in flux based on yesterday's talks. There would be more guidance from EPA on these issues. Most of the issues were still pretty open. Bill Harnett would be giving guidance to chair people that included more specificity for the papers. Mr. Krupnick said that the Subcommittee should take the initiative and give feedback to EPA, assuming that their ideas would be heard by the EPA. He asked for other comments on the future of the FACA Subcommittee.

Bruce Hill said he had heard that a science stakeholder group should probably continue.

David Hawkins said there would be a lot of details left unresolved after September. There was a lot of uncharted water ahead. It would be wise to preserve the ability of a Subcommittee to review and provide feedback to EPA. Mr. Hawkins said they would be learning a lot about what these strategies meant in the future.

Pat Raher (Hogan and Hartson) said that EPA was clarifying where it was during these sessions. This was a good thing because the different interests in EPA must come together to address where they were. The Subcommittee forced EPA to do that.

Alan Krupnick asked whether there was consensus that they should finish issue papers, continue through December, listen to EPA, and answer specific questions that EPA raised.

Consensus was reached on Mr. Krupnick's statement.

Alan Krupnick then announced that the next order of business was the Coordination Group, which would provide an update on the IIP and a legal caucus report.

Pat Raher said that EPA was overhauling the NSR issue, so the Coordination Group was withholding the Subcommittee's comments. For AOI/AOV, they should have a paper out before the October meeting.

Dennis Lawler asked whether there was going to be an IIP and a paper about it.

Pat Raher said yes, there would be a document. It would come out some time in the fall of 1997.

Alan Krupnick said it would be presented this fall to the Subcommittee.

Revised NAAQS for PM in Part 50 -- Bill Hunt

Bill Hunt said Neil Frank of EPA was there and would help answer questions about PM-2.5. He then presented a set of slides highlighted below.

Overview of New PM Monitoring Program

The current samplers could continue to be used.

PM-2.5 would be required in 2 to 3 years.

Daily sampling would be required.

New reference method was in place (one manual method and one that sampled sequentially)

Population-oriented hotspots would be targeted.

New PM-2.5 Standards

There were both annual and 24-hour standards.

New PM standard

Annual standard - 15 Fg/m3

Using one or more community-oriented monitors

Spatial averaging would be allowed

2-hour standard - 65 Fg/m3

Concentration based, 98th percentile.

Changes to PM-10 Monitoring

Continue to use current monitoring methodology.

They would scale down the program and keep the high concentration sites.

They would drop down to about 1,000 monitors.

EPA would grant waivers to allow one sample every six days.

The monitors might operate only during certain seasons.

New Federal Reference Method (FRM)

Readily available under a wide range of conditions.

Further speciation must be possible.

Should have a sharp cut point.

Offered higher measurement precision.

Other Fine Particle Monitors

Equivalent PM-2.5 samplers

Sequential samplers, other mass samplers, and continuous analyzers.

Non-FRM PM-2.5. samplers

Continuous for daily reporting requirements

Encourage the use of IMPROVE (Interagency Monitoring of Protocol Visual Environments) samplers.

Phase-In of New State PM Networks

Two-year phase-in of new PM-2.5 and downsized PM-10 monitors.

Initial focus on high population, potential PM problem areas, and serious, severe, and extreme O3 (ozone) areas PAMS (photochemical assessment monitoring stations).

All required PM-2.5 sites on-line in 1999.

Types of PM-2.5 Sites

State/Local Air Monitoring Stations (SLAMS) sites were community oriented, co-located at
PAMS sites, regional background and regional transport sites; there was a subset of core monitors for trends National Air Monitoring Stations (NAMS) sites and hotspots (SLAMS sites).

NAMS sites would look at trends and the effectiveness of control strategies.

Hotspot sites would reflect maximum hotspot concerns and only had to comply with the	24-hour	standard.

Required PM-2.5 SLAMS Monitoring

Minimum number of new core SLAMS requirements given.

Regional background core PM-2.5 SLAMS.

What Type of Sites Would EPA Target First?

They would have 30 to 50 instruments in early 1998 and would provide them free to States
through EPA regional offices.

Others should be available by May and they wanted to be able to place them.

Chemical speciation would start at 50 to 100 sites but probably would be expanded to up to 300 sites. EPA wanted to encourage speciation.

EPA was looking at ways to make this happen. It was asking that the filters be archived for one	year.

Quality assurance would be required for SLAMS and Special Purpose Monitors (SPMs). EPA	would require four field audits each year.

Other SLAMS monitoring activity would be quality assured as necessary.

Special Purpose Monitors

EPA believed they were needed for several reasons:

Two-year moratorium on data comparisons with NAAQS.

Opportunity for support from the private sector.

Comparisons to the NAAQS

With PM-10, it was the maximum concentration location.

For PM-2.5, the 24-hour standard would be population-oriented and a maximum concentration	location.

The annual standard would use spatial averaging.

Bill Hunt said that Neil Frank had written the next part of the presentation.

Neil Frank (EPA) said there was a different monitoring location for the monitors used in spatial averaging. An area at least ½ km in diameter must be represented. It allowed a State to use individual monitors or employ the averaging of one or more monitors. EPA intended to identify the spatial distinctions between these areas. It was not intended to average away a problem.

For those States that chose the spatial averaging approach within a community monitoring zone (CMZ):

The annual averages must be within +/- 20 percent of one another.

They must have had the same sources.

They must be reasonably correlated.

David Hawkins asked whether this was a circular calculation.

Neil Frank said no, one could be 12 and another 18 with an average of 15. A State might choose to look at individual monitors or averages. Three different types of monitors could exist in a community. This system could become as complicated as a State chose to make it. It provided an incentive for more monitoring. If they looked at an east-west profile (showing a map with potential monitors for averaging), Mr. Frank noted that certain monitors would not be within the zone. They would have to be considered to be in a separate CMZ. At this point he opened the subject for discussion.

Shawn Kendall asked the Subcommittee to discuss the methods for speciation and what they could measure.

Neil Frank said EPA would be offering guidance. They were considering the IMPROVE site methods. They were looking for selected elements, cations, and anions.

Dan Johnson (State of Washington) said he heard there were resources. It sounded like a 50 percent increase in monitors. They were clear that EPA might not be helping States operate the network. Mr. Johnson wanted to know whether States were going to have the resources to make the monitoring plan work correctly.

Bill Hunt said they were hopeful that EPA would be able to pay for help to the States in the first few years.

Bill Harnett said he believed the House was at $25 million and the Senate at $10 million in terms of allocation. The issue came up when they went beyond the first two years. They did not know how this would play out. Their budgets would go in asking for additional money. They could buy the monitors, but they only had a fixed size to work from. Others would have to play in.

Alan Krupnick asked who had control of the funding of the monitors in EPA, whether it was Office of Research and Development (ORD) or Office of Air and Radiation (OAR).

Bill Hunt said that money would come through as Section 105 or 103 money. He could not go beyond that to any great degree.

Bill Harnett said it would be through EPA's air office.

Bill Hunt said that the regions and the air office would have a more active role in quality assurance.

Bruce Hill asked whether they had any criteria for speciation.

Neil Frank said it was a non-mandatory recommendation by EPA. They would offer guidance.

Harvey Jeffries asked what fraction of the money would be allocated for analysis and interpretation of the data.

Bill Hunt said that they had allocated money for analysis and for special studies. It would probably be 5 to 10 percent.

Bill Harnett said there would be a major dump into the research side. National Institute of Environmental Health Sciences (NIEHS) would lead that effort. There did seem to be a strong commitment from Congress. He expected this to be in the 1998 budget.

Sarah Peirce-Sandner asked whether the monitors that were averaged could change from year to year.

Bill Hunt said yes, under extreme cases. The data interpretation would suggest that they were actually different zones.

Sarah Peirce-Sandner asked whether it was possible that EPA would not have enough monitors to represent air quality.

Neil Frank said that States had the flexibility to add more monitors. They estimated that another 650 monitors might be added to the list.

Chris Shaver (Environmental Defense Fund) asked whether the data from SPMs could be used.

Neil Frank said he would say it could be used.

Chris Shaver said there was an IMPROVE monitor site in Washington, DC. It could be used to look at and validate models today. It might be used to show the index.

Neil Frank said it was located at Haines Point next to the golf course.

David Baron said the plan indicated that PM-10 monitoring would be cut back. He asked whether EPA retained the flexibility to address PM-10 in certain areas.

Bill Hunt said that only monitors where the PM-10 was less than 60 percent of the standard would be removed.

David Baron said there were areas where it might be necessary to raise the number of PM-10 monitors.

Bill Hunt said he was talking about a national number.

Neil Frank said the States would talk about the monitoring plan, and it would be done through a partnership with the States.

David Baron asked a question about spacing, wanting to know whether a CMZ could be as big as a county and whether in the West, they could be 80 miles apart.

Bill Hunt said they had to correlate data as well. They had to collect the data first before they could make intelligent decisions about spatial averaging zones.

David Baron said there was potential for mischief.

Mike Wright said the higher the hotspot, the more likely it would affect the average.

Bill Hunt said a hotspot would fall into the 24-hour statistic.

Neil Frank said that a local impact area representing a large domain was one example. That would be eligible for comparison to the annual standard. He said he also showed that a monitor outside of the +/- 20 percent zone would constitute its own area.

Mike Wright said there were some environmental equity issues here. They were saying that the annual standard would not apply to certain areas. There could be unique hotspots, but those situations were expected to be very rare.

Neil Frank said the considerations were based on risk and there could be isolated unique hot spot situations that were not represented. He expected there would be few situations and they would be unique.

Bill Harnett said the health-based standards were related to community-oriented situations. The studies EPA had looked at had two types of monitors, and they had to set city-wide averages. There could be single source problems that usually would be 24-hour problems. For now, in setting the standards, they did not have the health studies that said individuals were affected.

David Hawkins said he did not understand.

Bill Harnett said that the health data did not answer these questions since they only had city-wide numbers.

David Hawkins said he thought Bill Harnett meant to say that the source would affect the annual average.

William Hamilton invited David Hawkins to come to the evening session if he wanted more questions answered.

Richard Phelps asked about continuous ambient monitoring and what incentives would be provided to the private sector to place SPMs or to do speciation.

Bill Hunt said the FRM monitors would collect good estimates of speciation. These data would be useful for corroborating emissions inventories. As to the first question about continuous ambient monitoring, they must start to look at how it correlated with FRM monitors.

Shawn Kendall asked how much would it cost compared to the IMPROVE monitors, and how long it would be before delivery of the monitors.

Bill Hunt said he had a contractual effort going, but he had to watch his answer.

Neil Frank said that a single channel cost $5,000 to $6,000. A few thousand dollars more would be needed for the sequential units. The cost of the four-channel IMPROVE monitor was around $16,000.

Shawn Kendall asked about three side-by-side monitors.

Neil Frank said EPA expected the vendors would step forward with economical solutions.

Shawn Kendall asked how they measured up with respect to equivalence to IMPROVE.

Neil Frank said they had done some side-by-side testing in Denver. The IMPROVE monitor read about 10 percent higher.

Shawn Kendall asked how the comparison was made.

Neil Frank said it was done only on a mass basis. The IMPROVE monitor did not have as sharp a cut point as the other monitor.

Shawn Kendall asked what the side-by-side tests had shown.

Neil Frank said the FRM field tested at 3 percent with a minimum detection level of 2 micrograms per cubic meter. It could be reduced further.

Shawn Kendall asked what the threshold was for the IMPROVE monitors.

Neil Frank said that the University of California-Davis laboratory handled all the samples and might be good at determining thresholds.

Gary Allen (Metropolitan Washington Air Quality Commission) asked how monitoring would overlap State boundaries and what EPA would do with regard to that issue.

Bill Harnett said he thought EPA was waiting to see what some of the data showed.

Gary Allen said he was concerned that this could become a new unfunded mandate.

Bill Harnett said he heard Gary Allen's concerns.

John Dunlap (California Air Resources Board) said he would like to have a place holder. When they tried to establish equivalency in the West, terrain and population needed to be considered. He also would like to see EPA show a stronger commitment to getting the dollars. The States needed some Federal help. Perhaps they could get the EPA Administrator to go to Congress and ask for help. That would be essential.

William Hamilton invited everyone to come to the evening session if they still had questions or to find Bill Hunt and Neil Frank during the break.

******BREAK******

Regional Haze Program -- Bruce Polkowsky (EPA)

Bruce Polkowsky introduced Rich Damberg of EPA who helped write the material on regional haze. Mr. Polkowsky said he would introduce the process and also show some differences in the parks.

Overview

Regional haze impairment was well documented nationally.

The regional haze rule set the framework for Class I areas.

GCVTC (Grand Canyon Visibility Transport Commission) reports, the National Academy of Science study, and FACA Subcommittee	deliberations were considered.

Background

There were numerous sources of fine particle pollution.

They were looking at a national program.

All of the areas in the map showed Class I areas that must meet a requirement of no manmade	contribution.

Regional Haze Program Elements

Who did it apply to?

Implementation plan revisions must be addressed.

Best available retrofit technology (BART) must be considered if a facility was built during
certain years.

It should include any source that caused visibility impairment.

Regional Haze Program Timeline

The first year's actions would list actions the States would take.

The key to the rule was that one showed a haze monitor or an equivalent monitor nearby.

The SIPs were due for haze emission reduction strategies in February 2003 (July 2005	for PM-	2.5 nonattainment areas).

One had to make sure that one was staying on target and meeting the targets.

Would the States need complex programs? It depended on the State, but all States would be	involved.

Reasonable Progress Targets

There were some common metrics:

All of these were based on light extinction but they chose deciview because it showed a	linear relationship.

One deciview improvement was usually considered perceptible; they took comment on	the one.

There were some common metrics:

It maintained the best visibility days and sought to improve the worst days.

They allowed for alternative progress targets with public debate.

One must set up a baseline for somewhere between the three year minimum and the nine year	maximum. Otherwise one showed trends instead of the baseline. This was a running block average.

Example Comparison of Metrics

Compared the change in the visible perceptible range in Shenandoah and the Grand Canyon.

Deciview in terms of PM concentration: the deciview was the effect that changed and	demanded	control strategies.

A graph was displayed showing visibility versus the number of days in certain ranges.	Three	curves showed current, future, and background levels.

Implementation Plan Revisions

EPA would look at sources with BART in a regional way to determine what the delta	would be
and where existing major sources were that met certain conditions. This would be used for a long-term strategy. The schedule would allow them to include BART and planning for BART.

Visibility Monitoring

IMPROVE at more than 60 Class I sites.

Very successful efforts for EPA.

The program required one to contact regional land managers.

The PM-2.5 network could use IMPROVE sites.

Long-term Strategy

Currently evaluation was required every three years.

One needed to talk to neighboring States and Tribes.

This resulted from the work of the GCVTC.

They were counting on the same system using a regional planning process.

They would check the emission reductions at the three-year review.

They would determine whether more measurements were needed.

One could consider costs as well.

Technical Activities

Determining current conditions needed to be done now.

They had default levels.

Anything that was not source-specific would require tracking.

This work would require trends analysis.

Mr. Polkowsky showed some pictures of a deciview in the West and the East (Grand Canyon and Shenandoah). He also showed Denver since it was an issue of transport as well.

Jean Vernet (Department of Energy) asked why EPA took comments if one deciview was the proposed limit. She also wanted to know why regional sources could trade out of BART changes.

Bruce Polkowsky said one had a target of no degradation on clean days.

Jean Vernet asked why one would not use up to one deciview on the clean days.

Bill Harnett said unless there was a one deciview change, one could not perceive a change.

Bruce Polkowsky said they were aiming for less than 0.1 change. GCVTC felt that cap-and-trade was okay, so they felt it was okay.

Robert Wyman asked to what extent States could use trading. If one changed that policy, it would change his group's comments.

Bruce Polkowsky said this was his chance to comment on that.

Robert Wyman said he found it odd that EPA used BART because it eliminated the significance findings. If one made a BART finding as part of the reasonable attribution program, the significance finding, it could be lumped in with other benefits. To get to the target, one picked whatever means one thought would be most effective.

Bruce Polkowsky said EPA asked for comment directly on that issue. One would have to develop a list of sources and their effect on the region.

Robert Wyman said he thought they would look at broader source categories. As he noted earlier, it eliminated the significance finding.

Bruce Polkowsky said if they did not have a lot of sources, it would not be effective.

Robert Wyman asked how much they could take cost into account.

Bruce Polkowsky said he did not have an answer today in terms of amounts. They would vary from one part of the country to another, for example, Title IV in the East. He did not think cost should be in there.

Glen Cass said the CAA called for no impairment from man-made sources. It seemed that EPA was counting the smallest perceptible changes.

Bruce Polkowsky said EPA was taking comment on the rate.

Bruce Hill said one picked the 20 percent best days as the criterion. He did not consider that sufficient or equal in his mind to visual impairment from anthropogenic sources.

Bruce Polkowsky said they had been looking at some trends. Even if the target was the dirty days, it would improve the clean days. They found this to be true in all of the parks. He asked what the appropriate way was to structure it in the rule.

David Hawkins said his guess was that the trend was from Mt. Pinatubo.

George Bluhm (Department of Agriculture) asked how EPA would take out wildfires and prescribed burning when trying to do this at the State level.

Bruce Polkowsky said that one thing EPA had to do was determine the background and natural conditions. Wildfire was one such event. Prescribed fire was an issue. If it was done on a regional basis, the dotted line (natural) should account for wildfires.

George Bluhm it was approximated by (Neil Sampson?) of American Foresters that they had cut back 130 times.

Bruce Polkowsky said Congress told them they only had to deal with the man-made issues.

Shawn Kendall said that with respect to the proposal, the small increments at the bottom were the toughest to reach. He asked whether EPA could change the increments down there.

Bruce Polkowsky said he did not see a problem as long as the change was perceptible over time.

Shawn Kendall asked what they should do about Mexico.

Sarah Peirce-Sandner noted that the mass value of fines might be different in the East than in California.

Bruce Polkowsky said sulfates inhibited visibility more.

Sarah Peirce-Sandner asked whether EPA anticipated needing more monitors than would be in the PM- 2.5 network.

Bruce Polkowsky said the States might consider monitors in Class I areas when setting background monitors.

Gary Allen asked how EPA saw the role of the many different affected organizations and how it would ensure cooperation.

Bruce Polkowsky said it had worked in the West. He thought they would see some guidance this fall about the NAAQS.

Bill Harnett said he thought integration would go forward when bringing the States together. It could still need smaller subsets. What they were trying to avoid was too many meetings.

James Souby (Western Governors' Association) said they would say no less than East and West. The deciview was an end result except that it was very difficult to see what led to the change. He saw the deciview useful as a tool, but the GCVTC work was related to emissions. Mr. Souby also wanted to add to the market trading and BART issue. He said the BART question could confuse the issue. He was interested in the rule's retrospective approach and wanted to know how they applied alternative status immediately. He wanted to know how the western region's program stepped into this.

Bruce Polkowsky said they should ensure reasonable further progress. That was the reason based on the congressional mandate. EPA wanted the States to figure that out in terms of emissions.

James Souby asked how their plan fitted into this.

Bruce Polkowsky said he thought they needed to think about this. They had to think about how they wanted it to happen. He could not require them to submit anything in a rule that did not yet exist.

Bill Harnett said EPA thought that GCVTC was consistent with this rule.

James Souby said he was not sure they got the one deciview improvement. With respect to visibility, the economic analysis showed that the costs were higher in the West.

Bruce Polkowsky made a comment about strategies to meet the PM-fine levels.

Beverly Hartsock said they had talked about who was going to pay for PM-fine. She wanted to know who would pay for IMPROVE.

Bruce Polkowsky said the money was now combined with PM-fine.

Bill Harnett said that within IMPROVE, they were proposing to get monitors in every location. A decision needed to be made on whether they needed a monitor in every area. EPA wanted to reduce the overall burden. He could not say anything definite until that decision was made and EPA decided whether they could use multiple representations from a single monitor. EPA planned to work with other Federal agencies to get money.

Beverly Hartsock said that because EPA was looking at regional plans, it was really allowing areas to set their own regional plans.

Bruce Polkowsky said EPA was expecting to give great weight to regional plans.

Bill Harnett said that EPA would not start over. EPA staff felt comfortable with the GCVTC work. They would express their comments along the way.

Bruce Polkowsky said EPA had already committed to participate in the Grand Canyon follow-up.

Beverly Hartsock said the international issue must be considered too. EPA might find that this issue drove other things. She thought planning was coming along fast.

Bruce Polkowsky said he felt that this was all going fast.

Nader Mansour (Southern California Edison) asked whether EPA would encourage SIPs to include the Clean Air Investment Funds.

Bruce Polkowsky said he would not presume strategies.

Nader Mansour said that a lot had been said about GCVTC. BART and one deciview were not achieved by GCVTC, but Bruce Polkowsky said that it was acceptable.

Bill Harnett said his understanding was that it would still be acceptable.

OTAG Status Report -- Tom Helms (EPA)

Tom Helms said his purpose was to give the Subcommittee a report of OTAG's status. The presentation would be on the Web but there were no hard copies. He said he would talk about the formation of OTAG, its modeling, and its findings.

To set the OTAG activity in perspective, nonattainment areas were designated and classified in 1990. SIPs were due for these areas. The serious areas had complicated plans. A modeling analysis required boundary conditions that were very high. A group of stakeholders came to EPA asking to work together. OTAG was formed in response to a memorandum from EPA in March 1995 on attainment area policy. Mary Gade of the Illinois EPA sent a letter to the States that got things going in April 1995.

The goal of OTAG was not an attainment strategy for an individual area. The goal was to reduce transport. There were 37 states involved, some more than others.

Air quality modeling was critical with four modeling centers set up. Four episodes were run. There were five sets of modeling runs that evaluated the effectiveness of different control strategies and examined different levels of control. The modeling efforts used fine and coarse grid states. OTAG treated the states differently. The sub-regional modeling run showed the range of transport.

OTAG looked at sector controls (utilities, mobile, etc.) In the Round 3, one could see the levels of controls looked at in Runs A through I. OTAG recommendations included:

Technical Findings

They established the best, most complete emission inventories ever.

State-of-the-art modeling was done.

New ways were used to look at data.

Modeling/Air Quality Conclusions

Regional NOx reductions were effective.

Benefits decreased with distance.

VOC reductions were effective locally and in urban areas.

Ozone was pervasive at least from day to day.

The range of ozone transport was longer in the North.

Coarse grid impacts might be minimal.

Other Recommendations

States and EPA should work together to issue SIP calls, evaluate NOx control dis-
benefits, and evaluate tonnage changes.

Show whether the budgets were sufficient.

EPA would evaluate submittals before going final.

Sector specific recommendations also were made.

What about the future?

EPA had looked at technical data and drafted a Federal Register notice on SIP calls.

EPA would look at what was significant based on a weight of evidence approach.

There would be a SIP call for NOx reductions.

OTAG Summary

Assessed ozone transport possibilities.

Extensive technical work completed.

Findings made relative to controls and technology.

Recommendations made to EPA in June.

EPA making SIP call in September.

Gary Allen said that OTAG was initially supposed to help States through volunteer efforts.

Tom Helms said they needed more than OTAG recommendations. They needed clean days to avoid the classification. Expeditious controls would help.

Larry Feldcamp (Baker and Botts) asked what the strategy was for introducing the IIP.

William Hamilton said that they were not answering questions directly about the IIP.

Larry Feldcamp asked when their demonstration would be due and what was necessary for it.

Tom Helms said that OTAG did not perform a Texas run. Texas was off to do its thing internally. The attainment demonstration would allow more time. Texas, Office of Air Quality Planning and Strategy (OAQPS), and the Regional office would have to work this out, probably next April. They were really interested in getting to the new standard, not the old one.

Larry Feldcamp asked whether that meant the IIP would not be specific but would be flexible.

Tom Helms said EPA promised that they would not create a whole new world of modeling.

Larry Feldcamp said that the September document would not go into what the model should do.

Vincent Brisini asked which Web site would contain the document.

Jan Kleeman (EPA) said it would be on the FACA Science and Technical Support Work Group (STSWG) bulletin board or the OTAG bulletin board.

Tom Helms said it would be under the STSWG bulletin board.

William Hamilton said he had three announcements. The Subcommittee would meet at 8:00 a.m. the next day. There would be two evening sessions. Robert Wyman had provided copies of a booklet outside.

Robert Wyman said his group was moving forward aggressively and anyone who wanted to help should call him.

Thursday, August 14, 1997

William Hamilton called the meeting to order at 8:18 a.m. He began by saying that they had a full agenda. He urged attendees to sign in if they were here for the first time. He announced that Tom Curran would be the EPA co-chair that day.

Tom Curran (EPA) said that work group co-chairs would state what they felt was still relevant. They recognized the Subcommittee's frustration since things were being pulled, such as NSR. They brought David Solomon out to meet with the work groups and get input.

FACA Ad Hoc Group on Monitoring Incentives -- Rich Halvey

Summary

5 Consensus recommendations

6 Limited consensus recommendations

6 Options not considered for consensus

Issue: Could the group come up with any consensus on decoupling?

Result: Environmental groups opposed it.

Arguments against:

Monitoring requirements should be based on Federal regulation.

Decoupling may postpone addressing pollution problems (SIP development).

SIPs would not be done because they would not be required.

Environmental groups could not agree to these measures.

Arguments for:

Decoupling would be designed to achieve equivalent or better public health in a shorter time frame under the decoupling process.

Formal agreements would be negotiated with schedules and timelines.

Flexibility for States.

Targeted strategies toward particular sources.

Would be unbiased monitor siting.

EPA would still retain authority to designate and impose requirements for States failing to meet agreement.

Relation to PD:

PD raised some issues related to decoupling.

Transitional classifications could be used.

A moratorium was placed on data for PM.

Three years of data were required for designation.

Mr. Halvey said their work was concluded and they were submitting it to the Subcommittee.

David Mobley (EPA) noted that this paper was finalized before the PD came out.

Progress During SIP Development-- Nina Dougherty (Sierra Club)

Ms. Dougherty said they would compare their work with the PD at the end of her presentation.

Background

The paper was referred to a special subgroup at the April FACA Subcommittee meeting. Members of this group included a balance of environmental interests, industry, and State representatives.

Status

The subgroup had continued discussions since the June meeting. The paper was finished independently of the PD; a comparison of the PD and this paper would be presented.

Working Assumptions

The subgroup maintained neutrality on whether the current nonattainment system would be
retained or the AOI/AOV concept adopted.

They covered all areas that potentially violated or contributed to a violation of the new/revised	standards.

They did not address any changes to RFP (reasonable further progress) requirements for current	nonattainment areas as described in the IIP.

Issue 1. When should progress begin?

It should begin when the NAAQS was promulgated.

Issue 2. Where should progress apply?

It was agreed that it should be nationwide.

Issue 3: What would progress be?

a. It would be national measures adopted by the EPA, which should be charged with specifying
appropriate measures.

b. State and local planning efforts should be required in conjunction with RAMP activities.

c. Progress should include implementing State and local control measures prior to SIP approval.	The nature of the controls should depend on the area.

d. A preliminary AOI or nonattainment area was expected to implement a prescribed list of	measures.

e. For areas highly probable to be designated as AOI or nonattainment, emission reductions	should be pursued in an expeditious and prudent manner, to include regional controls and/or market-based strategies.

f. For areas where there was not an adequate indication of violation, no new controls would be	expected. However, it was presumed those areas would participate fully in State planning and RAMP activities.

Issue 4. What is the authority for progress requirements?

This issue should be referred to the EPA Office of General Counsel.

Issue 5: Should progress for PM, regional haze, and ozone be treated the same or differently?

The policy elements of progress should be the same. However, it was apparent that the timing
of implementation for different pollutants would vary.

Comparison of PD and Recommendations on Progress

State and regional planning activities -- both endorsed.

Federal measures -- FACA: pursue additional measures. PD: implement current programs,	then reassess.

State emission reductions -- FACA: after designation/before SIP approval, States implement	certain measures; before designation/problem characterized, States implement regional recommendations and pursue market-based strategies and measures adopted voluntarily by States. PD: endorsed regional approaches, market-based strategies, and early action, and established requirements for transitional areas for ozone.

Conclusion -- PD and FACA work are generally consistent; further revision of the issue paper	was not warranted, but a postscript would be added; economic incentives paper should amplify appropriate incentives for early reductions; and control strategies issue paper should include recommendations on a list of measures.

Shawn Kendall made a reference to page 6, bullet 5 of the issue paper, asking a question about progress for PM being treated differently.

Nina Dougherty referred the question to David Mobley.

David Mobley said whether they should address different measures was the question. Progress for all three was consistent.

Shawn Kendall said he saw two as health issues and one as welfare, and did not think they should be handled the same way.

David Mobley said they did not try to differentiate between the three standards.

Shawn Kendall said he did not know whether it was a separate issue during the interim.

David Hawkins said the attempt was to determine the types of efforts and a different set of policy elements (national measures, State planning measures), and they decided that each of those elements should be addressed and play a role in each of the problems.

Mark Silverstein said in regard to State control, specifics were not addressed in the paper and end reductions should be creditable.

Nina Dougherty said that in the background paper, they did not address specifics.

David Mobley said they assumed it would show up in the SIPs.

Mark Silverstein said he thought that States should be given credit for the investigation of these measures. If they were State-only measures, it would give States flexibility before they became mandatory measures.

Beverly Hartsock asked whether they interpreted the PD as saying that areas moving toward transitional status were being mandated. She wanted to know whether they saw the PD differently than she did. Ms. Hartsock said the issue paper recommended that there be required State measures. She saw the PD calling for incentives.

David Hawkins said the PD was a statement of how EPA would carry out its authority. The policy recommendation from the Subcommittee started from the realization that it would be a long time before things were required to be done. The relationship to the PD was not changed much. This was an attempt to say that it made sense for EPA to do things at that point even if EPA could not mandate them. This Subcommittee was prepared to say that things could be done.

Alan Krupnick said that they faced a generic issue in terms of what to do about the papers and the final report. They had four categories of consensus when they wrote the Phase I report. He asked whether these four categories were still appropriate after the PD. Mr. Krupnick thought so. The Subcommittee was not bound by the PD or the CAA. If they could agree, they could move this forward. They should adopt this philosophy. The only further issue was whether the paper addressed the PD.

David Hawkins said that Mr. Krupnick's point was helpful. To add clarification, it might be useful to divide the categories into smaller subsets. At the one extreme, the Administrator could choose to accept it or not. The PD topics were in the middle. If they were not consistent with the PD, EPA would take the Subcommittee's recommendations to the interagency committee if it felt that they were appropriate. The Subcommittee should move forward.

Alan Krupnick wanted to take comments on this first. He asked whether there was any disagreement on the four categories of consensus.

David Hawkins said there were statutes and there was guidance. EPA must decide. He did not think they needed to tag each one of the issues.

Mike Wright said that these papers would be read by people outside EPA. He thought it would be good to recognize which things were inconsistent with the CAA or PD. That way it would be recognized immediately.

Alan Krupnick said they would try to do this for the big report.

Beverly Hartsock asked whether they wanted to discuss the theory or this issue.

Alan Krupnick said the theory.

Beverly Hartsock said then he was right.

Alan Krupnick said they would turn back to the paper.

Beverly Hartsock said that what occurred in the paper was what happened in Texas. She hoped that they could debate the conceptual differences between mandated and voluntary incentives. The idea of incentives versus mandates was an issue. They needed to make sure they were accurate.

Mark Brownstein (Public Service Electric and Gas Company) said when he saw areas in nonattainment, they had to continue to try toward attainment. For areas that did not meet the 8-hour standard, those areas should probably be looking at these measures, but it was voluntary. Economic incentives should be encouraged here. Where they did not know enough, no new controls were expected. That was how he saw this paper. It seemed consistent with the PD.

Beverly Hartsock said she read 3b as something that should happen. In the PD, it looked like an option.

Larry Feldcamp said that with 3b, he interpreted it as after the designation. The PD had it as an incentive. They set it up as a mechanism. It was trying to do something early after designation. The principle was consistent. The group did not feel that it needed to change its designation.

Alan Krupnick said he saw a new issue and asked whether the papers should be rewritten in the form of the PD. This was a question, he was not advocating this. They could add a section to the end or rewrite the paper. It would drop consensus.

Mark Brownstein said they could address the groups that chose not to avail themselves of the flexibility under the PD.

Pat Raher said he did not think it would be good to rewrite in terms of the PD. He did not see 3b as inconsistent with the two approaches for the States (mandated and incentivized). The States did claim credits from that. He agreed that they were different. If they added a piece at the end, they could address this issue.

John Dunlap said when they looked at the paper, there was a shift from the last meeting. They wanted as much flexibility as possible in his State. This seemed more prescriptive. He understood that time was important. They did not want a RAMP dictating specific measures. It had moved away from overall reduction goals and into a prescriptive approach.

Alan Krupnick asked whether John Dunlap would be satisfied with a change in the section at the end.

John Dunlap said he would like to see some examples, such as what a RAMP could do. He did not want to go back to his State and say that they were empowering a region.

Alan Krupnick said that the same comments would come up from all of the stakeholders. He wanted to add a section at the end so that they could move forward.

John Dunlap said he thought they wanted the States with them. It would be worth bringing them along.

David Mobley said that as secretary to the work group, he did not think they wanted to rewrite the paper. They recommended a postscript about the PD.

Vincent Brisini asked whether there was something they wanted to say that was different, and did they want to spend more time on this issue.

Steve Gerritson said that as a State preparer on this paper, it was written before the PD. Existing areas must make progress anyway. They were concerned about the new areas. They all had a problem with this from a public health viewpoint. The compromise was that prior to submittal of the SIP, certain things had to be done to protect human health. The PD added a new twist and raised the question of what the appropriate action was.

David Hawkins returned to Beverly Hartsock's comment, saying that the issue paper called on States to do more than the minimum. That was the question before the Subcommittee: was it good policy to ask the States to do more than the minimum? This paper would not be approved if they could not endorse that idea. Mr. Hawkins continued that the paper should be understood for what it did not say. It did not say that the list should be more than advisory. If a set of measures could be agreed upon, it should be implemented just as Congress did in the CAA. Mr. Hawkins said he could understand John Dunlap's concerns. The words were "should be", and should not be seen as mandatory. The ground rules for RAMPs had not been made yet.

Bob Palzer said he heartily agreed with Dave Hawkins. They had a lot of points that could be done in the postscript.

Joe Williams (WESTAR) said he saw many ways to do this, maybe through public outreach. He liked Pat Raher's comments. The regional initiative might work and might not. He thought the paper missed the point that many problems might be localized. He thought the fine PM measures were often local, and that seemed to be missing from this paper.

Mark Brownstein thought they could say "could" instead of "should". They might do something else. He thought that preserved the concerns of the environmentalists.

Shawn Kendall said if there was something on the list, one had to show why one was not using it. He thought it should be a menu of options. In looking at the summary of this document, Mr. Kendall said he could support it although he took exception to some statements in the paper. On page 4, the parenthetical expression should be removed.

Larry Feldcamp said there should be non-controversial measures from off-the-shelf. That was his understanding of what they should do. They wanted to suggest that it was some measure that would definitely end up in the SIP.

Alex Johnson (CCCA LMB) said he saw these talks as do-able. It would be applied to Class I areas. There was no penalty for the States not doing anything. Item 3b allowed the States to get credit for early reductions. Some words could be changed. He thought the paper was there and they should reach consensus.

Sarah Peirce-Sandner said if one had strong opposition to something in the PD, it should be stated. Since this paper was not fundamentally different from the PD, they did not need to continue along this road.

Beverly Hartsock said the discussion had been useful. If they were going to add a section about the PD, they could allow State representatives to review the draft. She thought that they could finish it up in October if it was in writing.

John Dunlap said that California would support that.

Alan Krupnick asked whether they could give them a provisional consensus until the postscript was written. He originally thought that this paper was against the PD, but it turned out that it was not.

Nader Mansour said they would decide later whether they had consensus.

Alan Krupnick said he did not want to bring the whole paper back later.

Nader Mansour said he thought that consensus depended on the full paper.

David Hawkins asked whether they had all of the issues flagged. If there were additional statements, they needed to get them first. He saw Mr. Krupnick's asking for consensus as a way of saying that there were no new concerns here.

Nader Mansour said he believed that all issues had been raised.

Bob Palzer said the approach made sense.

Alan Krupnick asked whether anyone else had a concern.

******BREAK******

Update from the Communications and Outreach Work Group -- Tom Curran and Ron White (American Lung Association)

NAAQS Communication:

Internet had fact sheets, rule packages, brochure, final revisions.

Satellite broadcast went out on July 24:

4,000 to 5,000 people.

Largest broadcast they had done.

Mr. Curran showed a picture of the Web page. Airlinks was on the front page of the EPA home page. He said that TTN had 2000 file downloads. There was a drop in the old BBS usage. Clean Air Act technical area pages leveled the playing field inside and outside the Beltway. Mr. Curran presented a graph showing which Internet files were downloaded and which fact sheets had been downloaded.

Ron White spoke about the issue paper summaries.

Completed "working draft" summaries of:

Areas at Risk.

Institutional Mechanisms (might be revisited).

Pending "working draft" summaries -- completed but may need revision:

RAMP/AOI (coming back in October).

AOV Boundaries (could be finished today).

Classifications (maybe December or October).

In progress summaries:

RFP (October)

Progress During SIP Development (October).

Despite efforts to get the papers out there, it had been a "hurry up and wait" approach until the full Subcommittee accepted the papers. They would continue to work on the ones that seemed viable.

Tom Curran spoke about the Pollutant Standards Index (PSI) in Part 58. He said there were communications issues in terms of clarity and simplicity. He raised the issue of why it was an implementation concern:

In the Northeast, ozone maps had been effective tools.

It could illustrate transport.

It could provide information on control actions.

Mr. Curran said one could get the public's attention for a few days, but thought people would become immune to it when the information seemed more status quo. The ozone isopleth maps went from North Carolina to Maine, and they were available on the Internet and to television stations.

Ron White said EPA had developed a new four-page fact sheet that was in production and reflected the final revisions to the new NAAQS. Black-and-white advance copies were out. The fact sheet would be available at the end of the month.

Pat Raher said that as they moved into September, there was clearly going to be a move away from EPA to State and local levels. He wondered if there were some communication forums or suggestions for State and local agencies.

Tom Curran said EPA should have paid more attention to this need. For the October and December meetings they probably should examined.

Beverly Hartsock said it was useful to see what was happening on the Web site. She asked whether there had been discussion at EPA on speaker forums and plans for outreach, or any national movement toward getting out information to news media.

Tom Curran said the speaker list would come back later as they got it firmed up. It was fairly close to completion. Whether they could put it out on the Internet was the question. As far as national distribution of real-time data was concerned, the President spoke in Kalamazoo about an initiative IMPACT (Integrated Model of Plumes and Atmosphere in Complex Terrain) to let people know what pollution levels were. The Northeast had put a lot of effort into it, and they were seeing how it worked there.

Joe Williams brought up a worst case at 99 percent where an area could have seven exceedance days in a row. He wondered how EPA would deal with that from a public information standpoint.

Tom Curran said determining what to communicate about a forecast of future violations was difficult. People in his work group were interested in how they would communicate this information.

Ron White said PSI information and noncompliance were two different issues.

Joe Williams said he got feedback from people that the public needed to be informed when the air violated standards.

Tom Curran said that what a good coherent message would be was still not clear.

Science and Technical Support Work Group Update -- Harvey Jeffries

Harvey Jeffries said he would first review one of the technical papers his group had studied. They were asked several specific questions by Sarah Peirce-Sandner about metrics. The work group was strongly endorsing the other two papers.

Mr. Jeffries began with reasonable further progress (RFP) metrics. He said they should be used for planning and for retrospective measures, such as measuring RFP. These went hand-in-hand with modeling. No single metric was adequate. Mr. Jeffries said that metrics were not prescriptive and should be SIP-specific. In some cases, the data might not be available.

There were administrative metrics, emissions metrics, and air quality metrics. The air quality metrics showed peak value concentrations, areal exposure, and were population-weighted. The metrics might show progress depending on which metric was used. The paper on metrics was posted at the science and technical section of the Web site.

Mr. Jeffries then discussed the Source Attribution Workshop. It was held in Research Triangle Park in mid-July. The content of the Workshop was based on questions about several techniques. They recognized a need for collaborative approaches and a need to address the increasing complexity of the models.

Reviewers made up a 6 member panel chaired by Ken Demerjian. Each presenter was asked to answer questions, and then the panel was asked to answer a series of questions for EPA:

Did the method seem scientifically plausible?

What were the methods strengths and weaknesses?

Had the method been adequately reviewed/demonstrated?

What, if any, additional review would they recommend?

Was the method practical for use in the next 18 months?

For what application was the method appropriate?

Quality assurance inventory estimates.

Quantifying preliminary areas of influence.

Assisting in episode selection.

Evaluating air quality.

The 10 presentations were grouped into methods using nested grid model results, methods using other models, and observational models/data analysis. The group was writing a full report.

General conclusions were:

Techniques considered should be peer reviewed.

No tools that were proprietary should be considered.

There should be some basis for evaluating an approach before its use in regulatory	applications.

The methods would be more useful if used together.

If the model was bad, the outcome was bad.

A technical presentation was made of Kevin Perry's research on long-range transport of North African dust to the eastern United States from the Journal of Geophysical Research in May 1997. Particles did come from Africa to the southeastern United States during certain times of year. These events primarily occurred in July. They would not influence the annual standard. On an individual day, they might contribute half.

A second paper addressed issues related to attaining the 8-hour standard. In some areas, emissions reductions were tougher with the 8-hour standard than with the 1-hour standard. There was a lot of disagreement about the fact that clean sites may have 65 ppb. With the bright line of a standard, there would be many areas that flipped in and out of compliance based on meteorology. EPA needed to recognize this, even if it was just in guidance.

Mr. Jeffries said he would talk about attaining the 8-hour standard. In Houston, there was no benefit to reduced NOx. For areal exposure, they found that the responses were very different, but a regional point source NOx reduction scheme showed no benefit. Even when looking at all NOx reductions, it would require at least 60 percent reductions to make a difference. Any analysis of Air Information Retrieval System (AIRS) data could not be forecasted into the future. There were times when one might be in compliance for a few years but not overall. It was difficult to tell whether one was actually making progress.

Jeffrey MacGillvray (New Hampshire House of Representatives) had conducted a regional assessment of culpability that Mr. Jeffries said should have been included in the Source Attribution Workshop. If there were flaws in the model, there were flaws in the analyses. Recognizing the nonlinear relationship, Mr. MacGillvray was able to track contributions to the sub-regions. Mr. MacGillvray had gone on to consider the costs of reductions in different sub- regions. He gave several examples of the work and presented a percent culpability map that showed which areas affected certain cities.

Alan Krupnick said that New York was doing a study with S.T. Rao. A statistical regression analysis and cost analysis also were being done. These efforts deserved some attention.

Harvey Jeffries said that two days for the Source Attribution Workshop were too few, and they could do a lot more. Jeffrey MacGillvray's work was looking at the deep cuts.

Jeffrey MacGillvray said that S.T. Rao's work showed smaller cuts. He had done more runs and showed good correlation.

Alan Krupnick said that this information would show up in the Science and Technical Support Work Group report. He wanted to know whether S.T. Rao's work would be included as well.

Harvey Jeffries said that several members believed that a SIP development workshop should be held in the next year. Many of the elements could be integrated. S.T. Rao's preliminary results would be available by the end of the month. Jeffrey MacGillvray's results should be ready for October. Mr. Jeffries said they would present it the same way in October.

Richard Phelps said he liked their work, including the too-close-to-call areas. These discussions were well-founded but he had not seen much recognition of them in policy development. He supported the idea of a SIP development workshop and said they needed to include these scientific studies in policy decisions. Mr. Phelps was concerned about some of this not getting into policy.

Alan Krupnick said that policy makers would have the information.

Sarah Peirce-Sandner told Harvey Jeffries that his Group's work was helpful. She asked whether the 12 percent equaled one-eighth and if the relationship was linear.

Jeffrey MacGillvray said yes, that was their interpretation.

Harvey Jeffries said he did make an effort to account for the nonlinearity of ozone production.

Alan Krupnick said that as more got done, it would be more useful.

Harvey Jeffries said they would see more in the future, but the money had not been there before.

Sarah Peirce-Sandner said that she thought percent culpability was something they knew but had not seen expressed before. This differed sharply from mandatory uniform cuts based on the SIP calls. The FACA Subcommittee had taken on this subject.

Tom Helms said they did not have all of the answers from the Administrator. Once a State had a budget, the State determined the mix of measures it would use.

Sarah Peirce-Sandner said it sounded as though all States would be provided with the same burden.

Tom Helms said EPA would lay those out and would accept comments. EPA would try to do it as justly as it could.

Edwin Meyer (EPA) said that the results presented were based on the endpoint. Had the endpoint been in Ohio instead of New York, the culpability would be in Ohio. He said that uniform NOx reductions were aimed at reducing all of the levels. That was the underlying reason for the rationale in the PD.

David Hawkins said this was an example of, "misplaced concreteness." Once one started to look at the fact that there were numerous effects, the optimization was much more complicated. If one looked at multiple ozone seasons, it sometimes went in different directions. One came to the conclusion that it was an issue of optimization because the question was for which endpoint was one trying to optimize. Mr. Hawkins said his second point was that it was easy to confuse the economic pattern of emission reductions with the cost of emission reductions. In the case of acid rain, the market was allowed to make the decisions. A ton anywhere in the regime was workable. The challenge in the ozone arena would be to assign weighting in a market. That did not assign responsibility. It was a political science issue, not a science issue. The task of internalizing costs became difficult. It was not obvious where the costs would lie. On the flipping in and out of attainment, one designed a bridge that dealt with floodwaters. If an area reduced emissions enough, it would stay in attainment.

Alan Krupnick said if EPA did not take the effect into account in a trading program, there would be ozone benefits left on the table.

Sarah Peirce-Sandner said she did not try to look at individual endpoints. One could not have 15 custom programs. She did not feel that they could use a one-size-fits-all approach. Ms. Peirce-Sandner said OTAG needed at least two or three different programs.

David Hawkins said that cap-and-trade would not be inconsistent with science.

Harvey Jeffries said he did not want them to take one example as the state of the science. An AOI was a complicated beast. OTAG only looked at four episodes. The amount of money spent on scientific analysis was very small compared to control strategies. They might agree that it was too complicated but the analyses needed to be done. Mr. Jeffries said they recognized that a State would have to design for a 100-year flood. The better one built it, the more it cost. The technologies were not even available yet and they were taking the bridge that high. If they were willing to tolerate certain variability, they could reduce the costs.

Mark Brownstein (Public Service Electric and Gas Company) said he must take exception to the notion that OTAG efforts were superficial. All of the issues they had discussed here had been discussed in the OTAG process. They now had to make some decisions. Mr. Brownstein said they did not want to forestall improvements while waiting for the analysis. Using models only would be a mistake. They learned a great deal with all of the information presented to them. Mr. Brownstein said they had a tough road ahead of them. His company would have to do substantially more to protect people. They might not know what the technologies to get them into attainment were, but they wanted to create the incentives.

Harvey Jeffries said he did not disagree with Mark Brownstein. A model was a tool. Operational tools were very distorted. That was why Mr. Jeffries had pushed a conceptual model. If one needed to make a prediction, one needed to use a model. The message was that one needed large reductions.

Beverly Hartsock said she thought the emphasis had shown them that area-wide controls must be used. She would like to see a SIP development workshop. Ms. Hartsock wanted to know what the proper forum was for the economic and political discussion.

Alan Krupnick said he did not think the analyses were deep enough for the Subcommittee, but a workshop in the spring sounded useful.

James Lents said that in Los Angeles, certain VOCs and NOx did not have the same impacts. It all had to balance out. He thought EPA had to weigh a lot of issues.

******LUNCH******

AOV Boundaries -- John Crouch

John Crouch noted that the PD did not say anything about boundaries. With respect to the CAA, there was no presumption or prescription about drawing boundaries. Mr. Crouch said the Base Programs Analyses and Policies Work Group reaffirmed this paper. He directed them to the last page where the recommendations were grouped.

Overview of the Issue Paper

Focused on the AOV boundaries portion of the designation process:

AOV boundaries defined regions that violated ambient air quality boundaries.

Boundaries might be based on monitored data or on a combination of monitored and modeled data.

AOV boundaries might be refined by analytical methods.

The paper did not assume that AOV was synonymous with nonattainment boundaries.

The paper did not assume which emission sources should be controlled.

The paper assumed that a State or set of States would work together to identify which	emission sources needed to be controlled.

AOVs tended to initiate the planning process.

AOVs did not draw firm lines according to the science.

Issue 1. What was the purpose behind drawing AOV boundaries?

AOVs initiated the planning process.

AOVs identified the spatial extent of areas with potential health hazards.

AOVs should not be equated with control regions.

Issue 2. How should PM and ozone AOV boundaries be determined?

Political boundaries and minimal analyses were sufficient.

Boundaries should be determined quickly.

EPA should provide guidance on criteria for determining boundaries.

Boundaries should be of a minimal size.

Issue 3. How should regional haze area of concern (AOC) boundaries be determined?

Regional haze AOCs would not require new boundaries. They were already defined.

Issue 4. Should AOV boundaries be defined for individual pollutants or should boundaries encompass ozone and PM-fine violations and visibility impairment?

Purpose of merging AOVs should be determined.

Integrated analysis was needed so control measures for one pollutant did not exacerbate	another.

Issues 5 and 6 were thrown out by the PD. They should be deleted.

What were the implications of the PD?

Boundaries: According to Bill Harnett, AOVs were still allowed and had not been thrown out. Mr. Crouch said he heard nothing yesterday that indicated AOVs were a bad idea.

Regional Coordination: The PD discussed the need for coordination and regional strategies but did not refer to RAMPs or AOIs. The work group could replace references to RAMPs and AOIs with references to coordination groups and control strategy development, or it could reaffirm its commitment to the concepts of AOV and AOI.

Issue 1: The PD mentioned New Source Review and conformity in relation to nonattainment areas. However, it also stated a goal of minimizing planning and regulatory burdens where air quality problems were regional, not local. The issue paper could continue to remind EPA of problems in equating nonattainment areas with control regions.

Issue 2: It discussed how to determine PM and ozone AOV boundaries. The PD did not mention boundaries, and the paper's recommendations were still valid.

Issue 3: The recommendation not to define boundaries for regional haze was valid.

Issue 4: They discussed boundaries for individual pollutants versus all-encompassing boundaries. The recommendations to define the purpose of merging AOV boundaries before doing so, as well as to consider impacts of control strategies on multiple pollutants, were still valid.

John Crouch asked whether anyone wished to register strong support or consensus about the issues.

David Kelly (Navajo EPA) said that most of these issues and recommendations referred to states, and he wanted Tribes to be mentioned as well. They did not want to be forgotten.

Gary Allen said that from his standpoint, nonattainment areas and AOVs seemed quite similar. If they had monitors in place, he wanted to know what the role of the present monitoring network was in defining boundaries.

John Crouch said that the control strategies might not matter within an AOV. The area would have the smallest definable boundary, and then they could focus on the areas influencing it. It had other implications including NSR.

Gary Allen asked how the boundaries might change in light of the new monitoring network.

Tom Curran said that the idea was that there would be more flexibility and it allowed them to look at areas further away. There was a potential for difference, but the basis was to identify where the controls should be implemented.

Gary Allen asked whether the discussion of monitor locations had to be tied into these areas.

John Crouch said the monitors would help with designation.

Shawn Kendall said the question of when they would merge AOIs might be more relevant.

John Crouch said the framework for this paper was to look at AOVs.

Beverly Hartsock said this dealt with those areas that fell under the new standard. Some areas would still be nonattainment areas under the old standard. She asked how that would work.

John Crouch said he did not know.

Tom Curran said it needed to be addressed.

Beverly Hartsock said that some nonattainment areas in a Metropolitan Statistical Area would not have problems. One would have two different systems.

John Crouch said he heard from the work group that they should not surrender this concept.

Mike Silverstein said he did not think the PD precluded AOVs and AOIs. He suggested that they keep the concepts alive.

David Baron wanted to know whether the Subcommittee was being asked to do something with this paper.

Alan Krupnick said that was next.

David Baron said he thought the PD said that these issues were of little relevance. He would be against saying that there was any support other than that it should be considered.

John Crouch asked whether it would be helpful to say that some members of the environmental group did not support parts of the issue paper.

David Baron said he did not think the PD supported these concepts.

John Crouch asked Mr. Baron to help him out in terms of what he saw the PD speaking to, particularly in the West.

David Baron said that as he understood it yesterday, it was unlikely that many western areas would fall into it. He heard Bill Harnett say yesterday that some areas might qualify for transitional status.

Joe Paisie (EPA) noted that convenient political boundaries were what the PD said. He gave background from the CAAA of 1990. They were still looking at pre-1990 and asking how they wanted them to do it.

Larry Feldcamp said what he understood was that the AOI/AOV concept was taken out because it caused public confusion. From Tuesday's talks, he understood that it was still being considered and that direction from the Coordination Group should be forthcoming. Mr. Feldcamp said he thought they had consensus from at least a majority of the group. The Subcommittee could still give direction on in-the-box and out-of-the-box ideas. He hoped that AOI and AOV were still on the table. They should not be negative and should be consistent with the PD.

William Hamilton clarified the language.

Alex Johnson said they needed to move forward with AOVs, AOIs, and RAMPS together, not individually.

Alan Krupnick asked whether, with the exception of this point about the whole package, they had consensus on this.

Alex Johnson said no, they were not ready yet to declare consensus.

Alan Krupnick asked how they could move forward on these three concepts together.

David Hawkins said that the concerns of the environmental community about this paper had been highlighted. From the standpoint of emission reductions, designating metropolitan statistical areas (MSAs) had been an effective way to establish controls in the past. If they moved to the AOV/AOI concept, they were asked to give up the presumptive controls. This had never been tried. It might be a prolonged approach without the appropriate checks to get it done. The environmental community had not heard a reasonable approach to this giving up of controls. Until those disputes were resolved, the controls would not be put into place. Mr. Hawkins said of course they should look outside the box. The statutory scheme had never prevented them from looking outside, but the States had authority before. The tools had been there. It was the decoupling that they were concerned with.

Tom Curran asked if that meant Mr. Hawkins did not want to vote on this issue yet.

David Hawkins said he would vote no. He did not think it would work or get the emission reductions.

Beverly Hartsock said she would like some discussion on spatial averaging and how that concept applied here. She would like David Hawkins to address his concerns about transitional areas as well.

Joe Paisie said spatial averaging suggested a designation concept, but they had not gotten to that yet.

David Hawkins said that the implications of the transitional policy were that there were two types of categories. One category was in OTAG that could implement regional measures, and they had to sign up for their share of the requirements. In the AOV, those areas were off the hook from the beginning. That was the difference. The second set of areas must submit a SIP, so they could not rely on external regional planning.

Alan Krupnick asked whether there would there be more policies laid out before December.

Tom Curran said they would not propose NSR until March.

Joe Paisie said they would not have it by December of this year.

Gary Allen said he would like to hear what the legal basis of RAMPs was and their relationship to existing planning groups.

Tom Curran said the discussion of RAMPs and AOIs would take place at future meetings.

David Mobley said he would like to remind everyone that Don Theiler told the Subcommittee that stupid decisions had been made before. This process of AOVs and AOIs was set to avoid making stupid decisions in areas such as offsets or locating facilities just over the line.

David Hawkins said those were examples of States choosing to do stupid things, not being forced to do stupid things. Don Theiler could not get legislators to accept that. The State of Wisconsin would not do more than the minimum. That was not the policy direction where areas wanted to go. EPA could be very explicit in saying that they should look further outside of their boundaries.

David Mobley said they had intended to look at all of those issues with the rewrite. The PD had made it more difficult.

Alan Krupnick said they were not going to reach consensus as it was. Returning to the four categories, the Subcommittee was down at "not reaching consensus."

John Crouch said that this was a fill-in paper after the AOV/AOI paper.

Alan Krupnick said they could package the papers and get it up to a 2 consensus category or they could leave it at 4. He wanted to get to some resolution for this paper.

Larry Feldcamp said he did not think it was appropriate to spend any more time on the issue then.

Alan Krupnick asked whether that meant a provisional 4.

Larry Feldcamp said yes.

Bill Luneberg said he thought this paper showed the intellectual bankruptcy of the concept. It seemed to him that they could not draw anything more than political boundaries. They were just coming up with another inexact way of dealing with it. He thought it should be dropped.

Shawn Kendall said it needed to be bundled with AOI. He did not think that the AOV location should have no controls while some other area had controls.

David Baron said he did not see how the Subcommittee could air the issue any more thoroughly than they had in the last two years. He would talk about transport, but he would give it an absolute 4.

Alex Johnson said the issue was Manitowoc, an AOV that was not part of the AOI. It was inappropriate to define one without the other. He agreed with Shawn Kendall.

David Hawkins said Don Theiler was trying to accomplish some good things. EPA has come up with "overwhelming transport" and other such methods. They did not need to decouple. If one could make a showing of transport, then one could get that changed.

Alan Krupnick said this issue was a provisional 4 for now. The papers would have to cover the decoupling issue. It would come back to the Coordination Group for an issue paper explaining their thinking.

Emissions Inventories/Modeling Requirements -- Ted Russell

Ted Russell said his group looked at what would happen in the future, whether they could do integration in the future, and whether the models were up to their needs. He said there was significant criticism now about models. They needed to improve them and figure out how they would play. The paper was done with the work of 20 people and had undergone multiple revisions. He then went through his presentation.

Introduction

Air quality models and emission inventories should remain central to good air quality
management.

Thrust of recommendations: improve rigors of processes, develop confidence in process	and results, define an integrated process.

Statements Concerning Modeling/Inventories

1. Models were available for designing SIPs and other regulatory purposes.

2. The availability of adequate emissions and other inputs was probably the greatest	limitation to the use of models.

3. Consistency in collecting and reporting emissions data was essential.

4. Regulatory demands on model outputs needed to be reconciled with limits on	resources.

5. Appropriate uses of models and inventories were iterative, linked processes with	several	essential steps.

6. Performance tests for air quality models should be more rigorous than current	practice.

7. Model attainment demonstrations and RFP-related modeling requirements should	be closely coordinated to provide a clear set of requirements to States and limit resource demands.

8. Much greater emphasis should be placed on scientific peer review of models and	emissions inventory approaches.

Air Quality Model and Emission Inventory Evaluation and Control Strategy Evaluation

More comprehensive model and emission inventory evaluation was key to improving
the process.

There should be greater evaluation of competing strategies.

What Were the Appropriate Uses of Models in Identifying Strategies Leading to Attainment and RFP Assessment?

Models should continue to be used for air quality management; when applied	correctly	they provided the best means of assessing the appropriate level of controls.

The process should be iterative and ongoing with periodic reassessment and should	involve stakeholders and technical review from the beginning.

There was a need to develop new guidelines to include more evaluation and increase	confidence.

Advanced use of models and more advanced models were key to improved air	quality	management.

Uncertainty

Uncertainty assessment was important, commonly done in environmental assessments,
the basis for risk assessment, currently done by some for air quality modeling, feasible, and provided greater confidence in results.

Quantitative uncertainty analysis should be conducted for each part of the emissions	inventory development and modeling process.

Overall uncertainty should be assessed and used to establish goals and expectations	(e.g., RFP).

Some areas might take more time than others to reduce uncertainties.

Choosing Models

Two questions: should a specific model be preferred by EPA over others; and should proprietary models be used for regulatory decision making?

EPA should emphasize use of the best set of tools and data with frequent review and comparison; or take a similar approach except each RAMP, AOI, or State would have a Technical Advisory Panel of experts along with stakeholders to review all aspects of the work. Either way, no default or preferred model would be prescribed.

No proprietary models should be used in developing a SIP, regionally integrated plan (RIP), or regulatory guidance. Any model used for regulatory guidance should be open and available to all parties. An appropriate mechanism would be necessary to compensate model developers and ensure continued model advancement.

Peer review meant scientifically peer-reviewed literature, not panels and	reports.

Use of Models and Inventories in Pre-AOI Identification

State-of-the-science, peer-reviewed techniques should be used.

EPA can help develop and assess methods and apply them to different regions.

The role of EPA in specifying pre-AOIs was uncertain.

Reducing Uncertainties in Emission Inventories

Start with existing inventories for preliminary AOI definition and switch to refined
inventories for final RIP/tribal implementation plan (TIP)/SIP.

Develop a mechanism to provide incentives to sources to better characterize their	emissions; could be a fee based on uncertainty or a requirement to increase control levels to make up for uncertainty. Should involve stakeholders in the process to ensure major sources have well-characterized emissions.

Shawn Kendall said in the Grand Canyon process, they had to have a consistent methodology. The meteorological data sets must be identical. It also was important to have consistent economic forecasts. Some groups would not be able to do it Cadillac-style. Mr. Kendall hoped they could do it more cheaply in the future, but budget constraints could affect complexity as well and might drive a simpler approach with less rigor.

Bill Hunt said if OTAG participants had used different models, it would not have worked.

Ted Russell said EPA should allow flexibility because it encouraged better inputs and more development and evolution of models. That was particularly true for integrating pollutants.

Glen Cass said in Southern California, the ozone planning process was contentious. Competitive modeling produced good results. It kept both parties more honest. The two groups analyzed one another and tried to find mistakes. In the long run, this was the cheapest way. A single model would retard the advance of other models. The real shortage was trained personnel, not models. Trained personnel normally only understood one model. They could not require a single model.

Bill Hunt said clearly EPA wanted to improve models. They could support a shoot-out of different models.

Ted Russell said all parties could develop models, but they were precluded by EPA. He gave an example of North Carolina wanting to use a better model but not being able to do so because of EPA.

Bill Hunt said that a prescribed model kept changing, and EPA would consider Mr. Russell's comments.

David Baron said his concerns were that it seemed to be an extremely inefficient process for developing new models. There would be delays and people would haggle a lot. It would add more delays, and that was a major concerns of his. The EPA folks reviewing SIPs would have to find high-level modeling expertise. He said he supported choices but not a free-for-all. There were more efficient ways of developing good models. He supported more rigorous oversight. EPA approved and said that they would do better next time, but they did not. Mr. Baron said he did not want his money to go for more model development rather than more controls.

Ted Russell said they were not diverting resources and were allowing the use of peer-reviewed models. The models could improve emission inventories. The group recommended more top- down, bottom-up approaches. They did not address how to go about this any further than what was in the paper.

Richard Phelps referred to Appendix E of the paper, the Consolidated Emission Inventory Reporting Rule. He said emission factors were imprecise and wanted to know who provided Appendix E.

Ted Russell said EPA provided this rule.

David Mobley said yes, they provided the rule. EPA was planning to merge this rule in with the regulatory package.

Richard Phelps asked whether it had received stakeholder input.

David Mobley said EPA had interacted with States and welcomed other input. They were trying to merge the requirements.

Richard Phelps said the term "consolidation" was well supported.

Ted Russell said that term was not associated with the paper or the work group.

Alex Johnson said he did support developing capabilities. Being able to review the models was difficult for them. It was important that one model was widely used, because it was easier for States to find the expertise to use it.

David Kelly asked whether the models identified uncontrolled sources. They needed to address some of these. During the modeling process at GCVTC, they saw that modeling pointed to ships in the Pacific and emissions in Mexico. Ultimately, the models were tweaked and changed in such a way the answer became different.

Ted Russell said that if one did not have the ability to tweak a model, it was important. Two competing models got rid of the ability to tweak.

Alan Krupnick said he would like to hear from a State representative about multiple models.

Joe Williams said that they were finding MM5 (modified method 5) was serving them better than what they had before.

Ted Russell said a representative from North Carolina wanted to use MAQSIP.

Kirit Chaudhari (Virginia DEQ) said if they had to use a proprietary model, it would cost a lot. They could uncouple the models to see how they worked but there was a lot of effort there.

Alan Krupnick asked whether the paper needed to add something addressing the delay associated with modeling and emissions inventories before they could get consensus from environmental groups.

David Hawkins asked what procedures could be put into play to avoid delays.

Alan Krupnick referred to SIP submittal deadlines.

Alex Johnson said it was a good question and he did not know the answer.

Ted Russell said the use of models had become routine and computers were faster. The choice of different models should not slow down the process.

Alex Johnson said that getting approval of models drew the situation out.

Bill Luneberg said that a considerable amount of delay did occur in Philadelphia.

Ted Russell said the reason was that the first model failed.

Bob Palzer said he rather liked this paper. He was more concerned with the possibility that modeling would not be used and might be deemed irrelevant.

Ted Russell said they were trying to look at policy beyond the next SIP call.

Bill Hunt said the guidance they put out for compliance with the 1-hour standard would not require any additional modeling.

Bob Palzer said in Oregon, there seemed to be some doubt about whether it was appropriate to do more modeling.

Bill Hunt said it would be for the PM-10 standard but not the PM-2.5 standard.

Mel Zeldin (South Coast Air Quality Management District) said if models could not be run and verified in the right time frame, they always defaulted to the previous version.

Alan Krupnick asked whether anyone disagreed that the Subcommittee had reached a consensus of 1.

David Hawkins said that David Baron had some concerns and was not there to see whether they were resolved. Others here might not object to the paper. Alex Johnson had also pointed out that it was great in a constraint-free universe. The proliferation of models would hurt the environmental community.

Alan Krupnick said there was a difference between 100 percent agreement and consensus.

Harvey Jeffries said he did not see that environmental groups had a limited ability. He invited the environmental community to join them. He said it was faster if they got the agreement up front. Environmental groups did not have to do the evaluation themselves.

Bill Luneberg said it was not that easy. They were oversimplifying the ease of finding experts. He knew he was personally not capable of evaluating models. They had significant difficulty responding to model results and needed outside capability.

Alex Johnson said the paper had noted it would be nice to have stakeholder involvement. Getting all stakeholders involved was hard, even in terms of travel. Resources needed to be better addressed.

Alan Krupnick asked whether the group would feel comfortable allowing Alex Johnson to work with Ted Russell in getting the paper toward consensus.

Bob Palzer volunteered to help.

Alan Krupnick said that Alex Johnson and Bob Palzer would work with Ted Russell.

Integrated Implementation -- Bob Lopez (Wisconsin DNR)

Bob Lopez began by saying that the issue paper was built from the November 1996 integrated implementation paper and was reviewed by the National and Regional Strategies Work Group. He then proceeded with a presentation.

Phase II Issue Area 1

Identify strategies and control measures with multiple pollutant benefits or problems.

Phase II Issue Area 2

Solve multiple pollutant problems when the assessment tools or planning timelines were different, where the benefit of integrating plans and controls was not obvious, or where an integrated controls response was negative.

Phase II Issue Area 3

Develop incentives for early implementation of integrated controls where indicated as positive. This issue would be partially addressed by the control strategies and economic incentives papers.

II-1: Recent Dialogue

Where time lines mismatched and direction was not obvious: which integration efforts should be pursued, even if no data or tools were available to support them; what early information and assurances were there for stakeholders to get early integrated actions.

II-2: Recent Dialogue

Where direction was obvious: weigh strategy on total or multi-pollutant benefit, focus on source sectors based on multi-pollutant impact potential, and integrate SIP analyses.

II-3: Recent Dialogue

Where there were differing problems and solutions: how to deal with spatial differences in violation and influence when trying to integrate SIPs; how to deal with differing violation episodes or seasons; and how to deal with differing air chemistry responses when attempting integration.

Integrated Implementation Recommendation 1 (Standing)

Optimize the assessment of ozone, PM-fine, and regional haze, along with related compliance and control strategies through consideration of all three pollutants in an integrated fashion rather than independently.

Integrated Implementation Recommendation 2 (Standing)

EPA should not force implementation time lines to coincide.

Integrated Implementation Recommendation 3

EPA needed to address the issue of regional haze improvement where early local NAAQS SIPs would not drive program development and automatic progress. This might involve incentives to pursue regional approaches to address transport where the science warranted a broader or more distant area response.

Integrated Implementation Recommendation 4

EPA should provide States with incentives and encouragement for "periodic" SIP-driven integrated plan evaluations rather than mandate mid-plan corrections for building integrated strategies and for refined integrated milestones.

Integrated Implementation Recommendation 5

Through implementation guidance, EPA needed to encourage greater or more flexible SIP attainment or progress credit for sources or source sectors investing in longer term, optimized multi-pollutant controls.

Integrated Implementation Recommendation 6

EPA and States should emphasize using control measures with multiple pollutant benefits in crafting SIP strategies addressing both NAAQS and haze.

Integrated Implementation Recommendation 7

EPA should consider a broadened criterion for possibly waiving or adjusting the timing or location of controls based on multi-pollutant and transport effects on public health and visibility.

Multimedia Impacts and Integrated Plans

Although not addressed in this forum, multimedia impacts were acknowledged and needed to be addressed in future integrated strategy assessments where greater emphasis was placed on the issue.

Alex Johnson said Item 7 language should incorporate multi-media so that it was clear what they meant.

Bob Lopez said they did not address multi-media originally.

Sarah Peirce-Sandner said the first sentence on Recommendation 3 might not account for Title IV in the East. She suggested they substitute "NAAQS and other programs planned in the near future" instead of "early local NAAQS SIPs."

Bruce Polkowsky indicated that Title IV would affect it anyway.

Bob Lopez said they could just add "and other programs."

Sarah Peirce-Sandner said okay.

Alan Krupnick asked whether they could call this a consensus document and if there was any disagreement.

Alan Krupnick paused and then said great, they had consensus.

William Hamilton thanked everyone for staying. He said that the next meeting would be in Chicago on October 9 and 10.

Tom Curran thanked everyone for coming. He said obviously the PD changed the landscape for EPA and for them. EPA sometimes had to move quickly, but they were listening to the Subcommittee's comments.

Alan Krupnick said they had a lot on October's agenda. They had set a path and a template for getting the job done. He adjourned the meeting.