Compilation of Status Reports on the Implementation of Recommendations Made to EPA by the CAAAC on Air Quality Management (Phase 1)


November 2005

Compilation of Status Reports on the Implementation of Recommendations Made to EPA
by the CAAAC on Air Quality Management (Phase 1)

The papers included in this package have been developed by EPA staff in conjunction with,

in some cases, stakeholders. They are a report on the activities and plans of the teams
working on the 38 Phase 1 recommendations. They should not be read as a final plan for

agency action.

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1.1 Improved Emissions Measurements and Reporting:

Recommendation: EPA, in conjunction with S/L/T and affected stakeholders, should pursue
improving emissions measurements and reporting to enhance emissions databases for more
accurate air quality assessments and tracking progress.

AQMWG Priority Level: High

Workgroup Participants:

Conniesue Oldham, Air Measurements and Quality Assurance, OAQPS (919) 541-7774

Fred Thompson, Emissions Factors and Policy Applications, OAQPS (919) 541-2707

Lula Melton, Emissions Inventory, OAQPS (919) 541-2910

Rey Forte, Clean Air Markets Division, OAP (202) 343-9134

J. Stephen Hartsfield, NTAA Operations Coordinator, NTEC, (505) 242-2175 x 106

Approach:

In an effort to improve emissions reporting, EPA (Emissions Inventory Group) is currently
modifying an existing rule regarding air emissions inventory reporting. The amendments would
require new State emission reporting provisions needed to verify reductions of particulate matter
and ozone required by the Clean Air Interstate Rule (CAIR); change the required content of and
schedule for States to report air emissions related data to EPA for use in evaluating the success
of air quality management programs; and consolidate and harmonize the new emission reporting
requirements with pre-existing requirements. The Emissions Inventory Group is also assessing a
plan to re-engineer the current National Emissions Inventory. The goal of the plan is to compile
NEI data more quickly while, at the same time, enhancing data quality and providing much
broader access to NEI users.

In an effort to improve emissions measurements, EPA (Air Measurements and Quality
Assurance Group) is conducting a study to identify (1) relevant existing emissions measurement
methodologies, categories to which these methodologies are necessary and appropriate, and
protocols for conducting these measurements, (2) identify efforts needed to develop new
emissions measurement methodologies and technologies for other source categories (3) identify
costs to conduct emission measurements. Currently, the Air Measurements and Quality
Assurance Group has ongoing activities that also contribute to measurement improvement (e.g.,
development of multipollutant performance specifications, enhancement of the mercury CEMS
performance specification, revision of method 301 validation procedures, and the development
of remote sensing protocols.)

In an effort to evaluate the need and appropriateness of regulations to require emissions
measurements, EPA (EFPAG) has developed a monitoring regulation for Title V, and is
assessing similar needs for other programs.

Estimated Date for Responding to Recommendation:

Final Products:

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Air Emissions Reporting Requirements Rule - Proposal November 2005
Re-engineered National Emissions Inventory - Currently Ongoing (2008)

Study for new emissions measurement methodologies and technologies - December 2005
Title V Monitoring Regulation (Coincides w/ Recommendation 1.2) - Completed

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1.2 Emissions Factors and Estimation Methods:

Recommendation: Where emissions measurement-based information is impractical to obtain
for air quality assessments, or where improved projections are needed, EPA, in conjunction with
S/L/T and affected stakeholders, should improve emissions factors and emission estimation
methods.

AQMWG Priority Level: High
Workgroup Participants:

Fred Thompson, Emissions Factors and Policy Applications, OAQPS (919) 541-2707

Lula Melton, Emissions Inventory, OAQPS (919) 541-2910

J. Stephen Hartsfield, NTAA Operations Coordinator, NTEC, (505) 242-2175 x 106

Approach:

In an effort to improve the emissions factors process, the Emissions Factors and Policy
Applications Group has over hauled EPA's emissions factors program and developed four main
products that should improve the use and development of emission factors. These products are
the emission factors and monitoring policy applications guidance, an electronic emissions data
reporting protocol, the emission factors and monitoring resource tool, and the Monitoring
Knowledge Base Tool.

In an effort to review existing source profiles used in source-based (and receptor-based)
modeling to identify the most significant source profile needs, the Emissions Inventory Group
and the Office of Research and Development are conducting a joint project to collect, review,
and consolidate a number of source profiles. Over 2000 profiles will be added to the electronic
data base.

In an effort to address the reconciliation of current emissions inventories with ambient
measurements, EPA has an emissions inventory / ambient reconciliation project on inverse
modeling of carbon PM, inverse modeling project for NH3, a comparison project of MOBILE6
Estimates to Findings of Top-Down Ambient/Receptor Analyses, as well as the utilization of data
in the 1999 National Air Toxics Assessment (NATA).

Estimated Date for Responding to Recommendation: FY 2006

Final Products:

Emissions factors and monitoring policy applications case study and final report/options paper -
Project Completed

Electronic Reporting Tool - Project Completed

Emissions Factors and Monitoring Resource Tool - Project Completed

Title V Monitoring ANPR - Project Completed

Monitoring Knowledge Base - Project Completed

Addition of over 2000 profiles to the electronic data base - 2006

Reconciliation of current emissions inventories with ambient measurements - 2006

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1.3 Uncertainty in Emissions Inventories and Modeling:

Recommendation: EPA, in conjunction with S/L/T and affected stakeholders, should quantify
and take actions to reduce uncertainty in emissions inventories and air quality modeling
applications, provide guidance for incorporating uncertainty assessments into SIP planning, and
improve communication of uncertainty to decision-makers.

AQMWG Priority Level: High

Workgroup Participants:

Lula Melton, Emissions Inventory, OAQPS (919) 541-2910

Tyler Fox, Air Quality Modeling, OAQPS (919) 541-5562

Ron Evans, Innovative Strategies and Economics, OAQPS (919) 541-5543

Larry Kertcher, Clean Air Markets Division, OAP, (202) 343-9121

Approach:

In an effort to evaluate sources of uncertainty in emissions inventories and modeling analyses for
all sources; identify needed data collection activities (and associated costs) to reduce the most
significant emissions uncertainties; and identify appropriate methods for incorporating
uncertainty in preparing emissions inventories and conducting modeling analyses, EMAD (Air
Quality Modeling Group) will coordinate an internal "workshop" with ISEG and ORD to get a
background and status update on ongoing work concerning developing taxonomy and conducting
an influence analysis focusing on benefit end-points.

EMAD also has a project underway to document alternative "reduced-form modeling"
approaches (e.g., EMAD/ISEG response surface modeling, Georgia Tech CMAQ-DDM
approach, Source apportionment modeling, etc) and will conduct workshop in early Fall 2005 to
review and compare their abilities to address source attribution of impacts and identification of
appropriate control strategies to meet ambient targets (i.e., NAAQS for 03 and PM). These
approaches allow for insights on the quality and influence of the emissions inventory and
meteorological data inputs for modeling.

EMAD's meteorological team is also conducting detailed performance evaluation of modeled
meteorological data for use in air quality modeling that should better inform EPA on confidence
in those data inputs.

In an effort to provide guidance for incorporating uncertainty assessments in SIP and Tribal
Implementation Plan (TIP) planning and improve communication of uncertainty to decision
makers and the general public, EMAD / AQSSD will construct a process to take inventory of the
various SIP-related guidance provided across technical areas of emissions, modeling,
monitoring, and ambient data analysis to better understand how to integrate where appropriate
and where to account for uncertainty analyses.

Estimated Date for Responding to Recommendation: FY 2006

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Final Products:

EPA "workshop" concerning Agency work pertaining to developing taxonomy and conducting
an influence analysis focusing on benefit end-points - Fall 2005

EPA internal workshops and inclusion of uncertainty characterization section in PM/Regional
Haze SIP modeling guidance (emissions, modeling, monitoring and ambient data analysis) -
Spring 2006

Performance evaluation of modeled meteorological data for use in air quality modeling - 2001
data (Completed) 2002 data ( summer 2006)

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1.4 Multipollutant Monitoring:

Recommendation: EPA, in conjunction with S/L/T and affected stakeholders, should promote
and improve integrated, multi-pollutant monitoring.

AQMWG Priority Level: High

Workgroup Participants:

Phil Lorang, Ambient Air Monitoring Group, OAQPS (919) 541-5463

Tyler Fox, Air Quality Modeling, OAQPS (919) 541-5562

James Hemby, Air Quality Data Analysis Group, OAQPS (919) 541-5459

Shao-Hang Chu, Integrated Policies and Strategies, OAQPS (919) 541-5382

Rey Forte, Clean Air Markets Division, OAP (202) 343-9134

J. Stephen Hartsfield, NTAA Operations Coordinator, NTEC, (505) 242-2175 x 106

Approach:

EPA is currently working to finalize its proposed national ambient monitoring strategy. The
existing monitoring networks are top-heavy on determining attainment / nonattainment and light
on addressing other monitoring objectives, especially control strategy development and tracking
progress. Future actions include changing the monitoring rule with NPRM in December 2005
and FRM in September 2006, working with monitoring program leaders in the states and regions
to initiate change, developing an OAR grant and technical guidance to reinforce the change and
to shift resources accordingly, and maintaining scientific advisory panel support for
recommended changes.

Estimated Date for Responding to Recommendation: FY 2008
Final Response Product:

Complete proposal of Monitoring Strategy Monitoring Rule NPRM - Dec 2005 (Final 2006)
Developed monitoring implementation partnerships w/ program leaders - Ongoing
Scientific Advisory Panel - Ongoing

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1.5 Framework for Accountability:

Recommendation: To promote understanding and characterization of the impacts of air quality
changes on health and ecological outcomes, and to improve the scientific basis for more
informed policy decisions, including the need for and nature of air quality standards, EPA, in
partnership with atmospheric scientists, health and ecosystem experts, S/L/T, and affected
stakeholders, should undertake a systematic effort to track air quality achievements and evaluate
air program results. This effort should begin by focusing on the progression and associations of
air emissions as they interact and ultimately affect health and the environment. In order to move
beyond the current approach of relying predominately on air quality measurements, we need to
further develop and apply the capacity to monitor, assess, and report on how changes in
emissions impact air quality, atmospheric deposition, exposure, and effects on human health and
ecosystems. Emphasis should be placed on developing and enhancing appropriate health-and
ecosystem indicators, benchmarks, and subsequent analyses within this overarching
accountability framework.

AQMWG Priority Level: High

Coordinating Group

Rich Scheffe, EPA - OAR/OAQPS/EMAD, (919) 541-4650
James Vickery, EPA - ORD, (919) 541-2184
John Bachman, EPA - OAR / OAQPS, (919) 541- 5359
Fred Dimmick, EPA - ORD, (919) 541-5537
James Hemby, EPA - OAR/OAQPS/EMAD, (919) 541-5459
Rona Birnbaum, EPA - OAR/OAP/CAMD, (202) 343-9255
Dave Guinup, EPA - OAR/OAQPS/ESD (919) 541-5368
Susan Stone, EPA - OAR/OAQPS/AQSSD, (919) 541-1146
Tyler Fox, Air Quality Modeling, OAQPS (919) 541-5562

Air Quality

James Hemby, Air Quality Data Analysis Group, OAQPS (919) 541-5459
Tim Watkins, ORD, (919) 541- 5114

Phil Lorang, Ambient Air Monitoring Group, OAQPS (919) 541-5463

Ellen Baldridge, OAQPS

Tesh Rao, OAQPS

Norm Possiel, OAQPS

Brian Hubbell, OAQPS

Shao-Hang Chu, Integrated Policies and Strategies, OAQPS (919) 541-5382
Tom Rosendahl, Integrated Policies and Strategies, OAQPS (919) 541-5314
Dave Holland, ORD
Alice Gilliand, ORD

J. Stephen Hartsfield, NTAA Operations Coordinator, NTEC, (505) 242-2175 x 106

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Health

Susan Lyon Stone, AQSSD, OAQPS (919) 541-1146

Vickie Boothe, Environmental Public Health Tracking Program, CDC (404) 498-1082

Lillian Bradley, AQSSD, OAQPS (919) 541-5694

Aaron Cohen, Health Effects Institute (617) 886-9330, ext. 335

Christine Davis, ESD, OAQPS (919) 541-1565

Fred Dimmick, NERL, ORD (919) 541-5537

Neal Fann, PRRMS, OAQPS (919) 541-0209

David Mintz, EMAD, OAQPS (919) 541-5224

Scott Jenkins, ESD, OAQPS (919) 541-1167

Danelle Lobdell, NHEERL, ORD (919) 843-4434

Dennis Pagano, ESD, OAQPS (919) 541-0502

Zachary Pekar, AQSSD, OAQPS (919) 541-3704

Jerry Stubberfield, PRRMS, OAQPS (919) 541-0876

Lee Tooly, EMAD, OAQPS (919) 541-5292

Approach: In an effort to begin strengthening the partnership among atmospheric science,
health research, and program accountability efforts, the Office of Air and Radiation and the
Office of Research and Development are leading a collection of multi-disciplinary teams across
EPA to coordinate and interact across technical areas to understand our current and required
capabilities to monitor, assess, and report on how changes in emissions impact air quality,
atmospheric deposition, exposure, and effects on human health and ecosystems (i.e.,
accountability). These teams organized by types of indicators include a coordinating committee
which also serves an overall synthesis function for the effort; emissions indicators and
measurements; air quality indicators and measurements; human exposure indicators and
measurements; ecosystem deposition and effects indicators and measurements; and human health
effects indicators and measurements. These teams are responsible for the development of an
overarching framework for accountability that integrates the emissions, air quality (including
ambient monitoring and modeling), exposure, and economics with the appropriate health and
ecosystem indicators and identify the required predictive and observational capabilities. In
addition, these teams will work collaboratively in FY06/FY07 to conduct a retrospective
accountability assessment in two selected areas to explore impacts of air toxics and mobile
source control programs.

In addition, there are several specific accountability efforts currently underway or recently
completed. EPA recently completed an assessment of the effects of the NOx SIP Call on
tropospheric ozone levels in the Eastern United States, and has published this report as an
Agency document. In FY06/FY07, EPA plans to continue the work begun in the assessment of
regional NOx control programs by conducting a more in-depth accountability study that is multi-
pollutant. As part of the Environmental Public Health Tracking effort, EPA, CDC and three
State agencies (NY, WI and ME) are conducting a pilot project, Public Health Air Surveillance
Evaluation (PHASE), linking highly spatially-resolved air quality and health information, that
will inform future public health tracking activities. EPA, CDC and the State agencies that
participated in PHASE are developing a manual for other States that may be interested in trying a

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similar approach to linking air quality and health surveillance information. In addition, the
current partners are holding a meeting in November to decide how best ot expand this effort to
other States through the CDC's next EPHT RFA. In the context of the Environmental Public
Health Tracking effort, staff is expanding on-going efforts by communicating with staff of State
and local public health agencies at national conferences and meetings about the potential
usefulness of public health tracking for EPA's accountability efforts. In addition OAR is
currently working with ORD on several accountability research activities, including ORD's
Accountability Initiative.

In FY 05, EPA formed a health indicator team with the purpose of understanding health and air
quality indicators for accountability. In February, the team held an internal workshop in
Research Triangle Park, attended by scientists from EPA to identify relevant research, related
activities, tools and databases for accountability work. This team will prepare a report that
provides a framework for development of indicators for accountability purposes. The report will
also identify important research, related activities (e.g., CDC Environmental Public Health
Tracking Program), health databases, and tools that can be used in the development of indicators
for accountability.

The team is evaluating the possibility of undertaking four indicator feasibility studies in FY06.
The studies would include the feasibility of: relating NATA risk estimates to cancer incidence
rates; acquiring and relating de-identified school absence data from the NMMAPS counties to air
quality data; using data from syndromic surveillance for accountability purposes; and, relating
health care utilization rates, from Federal databases such as Medicare, to regional air quality.

To meet the objective of facilitating communications among health research and program
accountability efforts, one step under consideration is to conduct a national accountability
workshop that would, among other objectives, provide a forum for external review and
enhancement of the health indicator team report as well as a the report on the EPA framework
for accountability. In addition to providing feedback on the reports, conducting the workshop
could feature accountability research and activities. It would be designed to further relationship
building between researchers and Federal, State and local air quality agency stakeholders for
expanding on-going efforts for public health and air quality accountability. Further specific
accountability efforts will result from the workshop, growing relationships, and multi-agency
projects. It should be anticipated that there will be accountability activities for recent national
and regional scale reductions in emissions (e.g., diesel requirements and CAIR).

Estimated Date for Responding to Recommendation: Final response products will be
completed in FY08. In the interim, key milestones and substantial progress in many areas will
be achieved (see below).

Final Response Product:

• EPA workshop on health indicators - COMPLETED

• NOx assessment report - COMPLETED

• Communication at national conferences: National Air Quality Conference (2/2006),
Environmental Public Health Tracking Partners Meeting (COMPLETED) and National

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Conference (4/2006), and Council of State and Territorial Epidemiologists annual
meeting (6/2006)

•	Multi-pollutant accountability report - FY06/FY07

•	Initial health indicators team report - early FY 06

•	Four health indicator feasibility studies - FY06

•	Report on retrospective accountability assessment in selected urban areas - FY06/FY07

•	Report on EPA framework for accountability - FY07

•	Final health indicators team report - FY 07

•	National accountability workshop (possible) - FY 07/08

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2.1 Industrial, Commercial, and Institutional Boilers:

Recommendation: EPA should complete as soon as possible a review of the contributions from
this category and the technical and economic feasibility of further controls, given the high
priority assigned to this sector. EPA should then initiate development of a regional or national
emissions control regulation for the category, or take alternative action consistent with the results
of this analysis.

AQMWG Priority Level: High

Workgroup Participants:

Peter Tsirigotis, EMAD/ OAQPS, 919-541-5536
Chris Recchia, MANE-VU, 202-508-3840
John Hornback, VISTAS, 404-361-4000
Mike Koerber, Midwest RPO, 847-296-2181
Chuck Layman, CENRAP, 405-378-7377
Patrick Cummins, WRAP, 970-884-4770
Bob Gruenig, WRAP, 505-242-2175 xl03

Approach: In coordination with EPA, the Regional Planning Organizations will collect and
analyze data concerning industrial, commercial, and institutional boilers to effectively
characterize these sources and their environmental impacts. Along with the RPOs, EPA plans to
include additional organizations (i.e. STAPPA /ALAPCO) to help with this comprehensive
approach. The information will focus on:

1.	emissions

2.	physical boiler characteristics

3.	utilization

4.	existing pollution controls

5.	performance of pollution controls

6.	costs of pollution controls

The information gathered will help characterize emissions from different source sectors.

In conjunction with the aforementioned information collection process, EPA is also developing
sector based emission reduction strategies. These sector based approaches will take a
comprehensive look at emissions characteristics across all sectors, many which contain
industrial, institutional, and commercial boilers.

Final Response Product:

Data inventory - March 2006
Analysis of collected data - June 2006

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2.2 Industrial Surface Coatings:

Recommendation: EPA should complete as soon as possible a review of the contributions from
this category and the technical and economic feasibility of further controls. EPA should then
initiate development of a regional or national emissions control regulation for the category, or
take alternative action consistent with the results of its analysis.

AQMWG Priority Level: Medium

Workgroup Participants:

Paula Hirtz, EPA/OAQPS/ESD, (919) 541-2618, hirtz.paula@epa.gov

Steven Rosenthal/R5/USEPA/US@EPA
Floyd Ledbetter/R4/U SEPA/US@EP A
Stanley Tong/R9/USEPA/US@EPA
Anne Arnold/Rl/USEPA/US@EPA
WilliamL Johnson/RTP/USEPA/US@EPA
Bruce Moore/RTP/USEPA/US@EPA
Dave Salman/RTP/USEPA/US@EPA
Elaine Manning/RTP/U SEPA/US@EP A
Barry Elman/DC/USEPA/US@EPA
Dennis Beauregard/RTP/USEPA/US@EPA
Bob B1 aszczak/RTP/USEP A/US@EPA
Elineth Torres/RTP/USEPA/US@EPA
Marc Houy oux/RTP/U SEP AAJ S@EP A
Roy Huntley/RTP/USEPA?US@EPA
Paula Hirtz/RTP/USEPA/US@EPA

Approach: The workgroup members agreed to conduct an analysis of the industrial surface
coatings category. The analysis would include review of non-attainment contributions from 25
Industrial Surface Coatings source categories, the existingl3 NSPS rules, 25 CTGs and existing
ACTs, the 11 outstanding categories listed for regulation under 183(e), and identification of new
categories, including but not limited to facility maintenance operations and surface coating of
miscellaneous wood products. The analysis will include an evaluation of further emission
reduction opportunities. In order to evaluate the CTGs, the workgroup anticipates an extensive
review of state and local limitations would be performed, followed by data collection to support
a feasibility study of adopting tighter state and local limits. The technical and economic
feasibility of using low VOC/low HAP coatings and further controls will also be evaluated by
the workgroup. Work will then proceed for those categories amenable to updated rules and/or
guidance.

Current Status: Members of the workgroup have met four times over the last 2 months. The
workgroup has essentially identified a 2 prong approach: 1) analyze the existing regulations and
identify gaps, and 2) utilize emission inventory data to identify sources of high VOC emissions.

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The work group is in the preliminary stage of identifying all in-house (federal and state)
regulatory information to provide a comprehensive overview of the industrial surface coating
rules and guidance. Thus far we have compiled a list of (over 43 completed and 20 outstanding)
federal rules related to industrial surface coating.

Members of the workgroup from EMAD are updating the current baseline (2002) and future
projected (2010) VOC emissions from the industrial surface coating source categories with 2002
emission inventory data. The new data will be used to rank sources of industrial surface coating
emissions in ozone non-attainment areas across the country. The new data should be ready for
the next meeting scheduled for Nov. 16.

Final Response Product: To be determined by results of analysis.

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2.3 Consumer Products (Non-Industrial Solvents):

Recommendation: EPA should initiate rulemaking efforts to establish minimum performance
standards (i.e., a national rule) for this category using the VOC content limitations contained in,
and regulating the products covered by, the model rule developed by the Ozone Transport
Commission.

AQMWG Priority Level: Medium
Workgroup Participants:

Bruce Moore (lead)

Melissa Payne
Elineth Torres
Bob Stallings (ozone)

Roy Smith (toxics)

(To be named) (Voluntary Programs)
Clive Davies (Design for Envir)
Pauline Johnston (indoor air)

Alison Kinn-Bennett (Envir Purch)
Laurie Saltzman

(To be named) (Envir Purchasing)
(To be named)

Anne Pope (lead)

Dennis Beauregard (inventory)
(To be named) (Website Design)
Roy Smith (toxics)

(919)541-5460

OAQPS/ESD
OAQPS/ITPID

OAQPS/ESD
OAQPS/AQSSD
OAQPS/ESD
OPEI

OPPTS/OPT/EETD
ORIA/IED
OPPTS/OPT/PPD

Consumer Product Safety Commission
General Services Administration
Federal Trade Commission
OAQPS/EMAD
OAQPS/EMAD
OAQPS/ITPID
OAQPS/ESD
OPPTS/OPT/EETD

Christina Cinalli (toxics)

Clive Davies (Design for Environment) OPPTS/OPT/EETD

David Sanders	OAQPS/AQSSD

David Solomon	OAQPS/AQSSD

John Silvasi	OAQPS/AQSSD

Geoff Wilcox	OGC

Doug Aburano	Region 5

Stanley Tong	Region 9

Amy Royden-Bloom	STAPPA/ALAPCO

(To be named)	LADCO/Midwest RPO

(919)
(919)
(919)
(919)

(202)
(202)
(202)

(919)
(919)

(919)
(202)
(202)
(919)
(919)
(919)
(202)
(312)
(415)
(202)

541-3609
541-4347
541-7649
541-5362

564-3821
343-9425
564-8859

541-5373
541-5512

541-5362
564-8542
564-3821
541-3356
541-5375
541-5666
564-5601
353-6960
947-4122
624-7864

Approach: Working on several possible approaches to respond to this recommendation. Will
be having discussions with several stakeholder groups and internally to determine what the best
approach is.

Estimated Date for Responding to Recommendations:

approach to be taken.

Will be determined based on

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2.4 Architectural Coatings

Recommendation: EPA should initiate rulemaking efforts to establish minimum performance
standards (ie., national rules) for this category using the VOC limitations contained in, and
regulating the products covered by, the model rule developed by the Ozone Transport
Commision (OTC).

AQMWG Priority Level: Medium

Workgroup Participants:

Bill Johnson, EPA/OAQPS/AQSSD, (919) 541-5245, i ohnson. williaml@epa. gov
Dennis Beauregard, EPA/OAQPS/EMAD, (919) 541-5512, beauregard.dennis@epa.gov
Barry Elman, EPA/OPEI, (202) 566-2958, elman.barry@epa.gov
Marc Houyoux, EPA/OAQPS/EMAD, (919) 541- 3649, houvoux.marc@epa.gov
Dave Salman, EPA/OAQPS/ESD, (919) 541-0859, salman.dave@epa.gov
Bob Stallings, EPA/OAQPS/ESD, (919) 541-7649, stallings.bob@epa.gov

Approach: EPA will begin working with stakeholders to determine key issues and ways to
address them.

Final Response Product: Dependent on discussions with stakeholders.

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2.5 Heavy-duty Diesel Engines:

Recommendation: EPA should reduce emissions from the existing fleet of heavy-duty (HD)
diesel engines by employing a multi-pronged approach.

AQMWG Priority Level: High.

Workgroup Participants:

Staffed by OTAQ. Coordinated with the Mobile Source Technical Review Subcommittee.

Lead: Jim Blubaugh.

Approach: EPA is continuing its existing efforts to employ a variety of strategies to monitor
and reduce emissions from the in-use HD fleet. Building on the successes of EPA's regulatory
and voluntary efforts to reduce emissions from diesel engines, EPA has created the National
Clean Diesel Campaign (NCDC).

First, EPA is committed to successful implementation of the 2007 Heavy-duty Highway Engine
Rule and the Clean Air Nonroad Diesel Rule. These rules will, by 2030, reduce PM by 250,000
tons per year.

Second, EPA is engaged in multiple compliance program strategies, such as continuing to work
with manufacturers to ensure compliance with existing and new emission standards, harmonized
nationwide OBD diagnostics for HD vehicles, and development of portable emissions
capabilities for diesel PM. Engine manufacturers will begin a new in-use testing compliance
program over the next two years.

Third, to address engines already in use today, the NCDC is promoting the reduction of
emissions, by up to 90 percent, through a variety of cost-effective and innovative strategies,
including switching to cleaner fuels, retrofitting, repairing, repowering, replacement, and idle
reduction, among others.

In conjunction with state and local governments, public interest groups, and industry partners,
EPA has established a goal of reducing emissions from the existing fleet of over 11 million
diesel engines by 2014. EPA determined the general sectors that provide the best opportunity to
obtain significant reductions are ports, construction, freight, and agriculture. The Agency's
SmartWay Transport Partnership program will promote emission reduction strategies in the
freight sector. The Agency also identified school buses as an area where diesel control can
greatly help a susceptible population. Each program provides technical and financial assistance
to stakeholders interested in reducing their fleets' emissions effectively and efficiently.

Over the last five years, EPA has brought forward a number of very successful voluntary
programs designed to reduce emissions from the diesel fleet. Retrofit programs are some of the
most cost-effective measures for PM control, and provide a health benefit to cost ratio of up to 13
to 1. Stakeholder support for these voluntary programs has been overwhelming, evidenced by

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our grant solicitations being met by demand ten times greater than available resources. Winning
grant programs have leveraged an average of two to four times additional resources. In support
of these programs, EPA has developed a number of tools stakeholders are using to support their
projects and partnerships. These tools range from technology verification programs to new
emissions model development to SIP guidance to facilitating outreach.

Given the clear signal about providing more opportunities for growing these voluntary programs,
EPA is working to expand them. Much of this growth will come from focused partnerships and
collaborative efforts at the state and local level. Thus, the NCDC will work to further energize
interested stakeholders through regional collaborative initiatives, such as the West Coast Diesel
Collaborative, the Northeast Diesel Collaborative, the Midwest Clean Diesel Initiative and the
Mid-Atlantic Diesel Collaborative.

Estimated Date for Responding to Recommendation: The compliance and voluntary program
strategies described above, such as the NCDC, are ongoing.

Final Response Product: Continued effective implementation of compliance programs and of
voluntary programs aimed at reducing emissions from in-use HD engines. NCDC sector goals,
to address the emissions of the 11 million engines in the existing fleet, include:

School Buses:

Ports:

Freight:

Construction:

Ag:

Reduce emissions of the entire fleet of school buses by 2010

Reduce emissions from all sources at sea ports

Eliminate unnecessary idling from trucks and locomotives and create
demand for lower emission freight services

Reduce emissions from major construction projects in non-attainment
areas, initially targeting public projects then the private sector

Promote biofuels/renewables and retrofit in farming communities in
non-attainment areas

Resource Needs to Address

Recommendation: Substantial resources are needed to provide funding assistance in the form
of grants or loans, for retrofit, replacement, and other emission reduction strategies. These funds
leverage external resources. EPA's FY06 budget includes $5 million for NCDC grants, and $7
million for school bus grants.

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2.6 Emissions from Ships, Locomotives, and Aircraft and Mobile Source Air Toxics:

Recommendation: EPA should address emissions from ships, locomotives, and aircraft, and
mobile source air toxics through national emission standards.

AQMWG Priority Level: High.

Workgroup Participants:

Staffed by OTAQ and EPA regulatory development workgroups.

Coordinated with the Mobile Source Technical Review Subcommittee.

Leads: Locomotives and ships - Bill Charmley, OTAQ. Aircraft - Glenn Passavant, OTAQ. Air
toxics - Kathryn Sargeant, OTAQ.

Approach:

Ships, locomotives, and aircraft. EPA will promulgate national standards under Clean Air Act
section 213 that will reduce air pollution emissions from diesel locomotives and from Category 1
and 2 diesel powered marine vessels (does not include ocean-going marine vessels). The
program will focus on:

The opportunity to apply advanced aftertreatment technologies being used for on-highway and
land-based nonroad diesel engines to diesel locomotives and diesel marine engines, to reduce PM
and NOx.

The potential for encouraging or requiring improvements to existing diesel locomotives and
diesel marine engines.

All seven major U.S. freight railroads joined EPA's voluntary SmartWay Transport Partnership
in May 2005. Each railroad will develop a plan to identify fuel savings and emission reduction
strategies. Strategies include reducing idling, improving aerodynamics, applying new fuel-
saving technologies, and installing emission control devices.

EPA will also be working on national and international standards for ocean-going vessels
(Category 3 diesel marine engines). EPA will pursue more stringent standards for PM and NOx,
both through the International Maritime Organization as well as an EPA-initiated rulemaking.

EPA is also exploring the possibility of designating one or more U.S. coastal regions as a Sulfur
Emission Control Area (SECA) under provisions specified by the International Maritime
Organization (IMO). A SECA designation could result in substantial reductions in SOx
emissions from ocean-going vessels when operated in designated U.S. waters.

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Mobile source air toxics. EPA will promulgate national standards under Clean Air Act section
202(1) that will reduce air toxic emissions from fuels, vehicles, and (under section 183(e))
portable fuel containers. This is known as the "MSAT rule."

Fuel control options will focus on gasoline.

Vehicle control options will consider both evaporative and exhaust emissions.

National standards for portable fuel containers will consider emissions from evaporation,
permeation, and spillage.

National standards to reduce hydrocarbons from small gasoline engines (including lawn and
garden and recreational marine) will also reduce air toxic emissions.

Estimated Date for Responding to Recommendation:

An advanced notice of proposed rulemaking on locomotives and category 1 and 2 marine
engines was published in June 2004. Notice of proposed rulemaking is currently being
developed. A proposal is expected in 2006.

EPA will work within the International Maritime Organization (IMO) over the next several years
for more stringent international standards for Category 3 marine engines and their fuels. EPA
will also work toward the development of a Federal rule for Category 3 marine engines during
2006.

EPA's work on a potential SEC A designation cannot begin in earnest until the U.S. has ratified
the IMO Annex VI treaty. We are hopeful ratification will occur during 2006.

A final rule adopting the existing International Civil Aviation Organization NOx standard for
aircraft engines is expected in 2005.

Proposed MSAT rule by February 28, 2006. Final rule by February 9, 2007.

Proposal for small gasoline engines is expected by Spring 2006; final rule by Spring 2007.

Final Response Product: Proposed and final rules.

Resource Needs to Address Recommendation: Existing efforts will continue.

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2.7 Evaluation of Additional Emissions Reduction Potential and Cost Effectiveness for
Cement Manufacturing, Petroleum Refining, and Pulp and Paper:

Recommendation: The cement manufacturing, petroleum refining, and pulp and paper industrial
source categories are already under substantial regulation, but continue to be significant sources
of pollutants and warrant further consideration by EPA. EPA should evaluate potential national
or regional emissions reduction strategies for criteria pollutants and air toxics in these categories.
This should include improving emissions inventories if necessary and assessing their impacts on
nonattainment areas or other sensitive areas. EPA should carefully consider the cost-
effectiveness of imposing additional controls as it determines whether additional emissions
reductions are justified and should take action consistent with the results of this analysis.

AQMWG Priority Level: Medium

Workgroup Participants:

Brenda Shine, EPA - OAQPS, ESD, (919) 541-3608.shine.brenda@epa. gov

Tim Smith, EPA - OAQPS, AQSSD, (919) 541-4718, smith.tim@epa.gov

Fox, Tyler, EPA - OAQPS, EMAD, (919) 541-0503, fox.tvler@epa.gov

Bill Neuffer, EPA-OAQPS, AQSSD, (919) 541-5435, neuffer.bill@epa.gov

Bob Lucas, EPA-OAQPS, ESD, (919) 541-0884, lucas.bob@epa.gov

Keith Barnett, EPA-OAQPS, ESD, (919) 541-5605, barnett.keith@epa.gov

Jeff Telander, EPA-OAQPS, ESD, (919) 541-5427, telander.ieff@epa.gov

Doug Solomon, EPA-OAQPS, ESD, (919) 541- 4132, solomon.douglas@epa.gov

Steve Marquardt, EPA-Region 5,ARD, (312) 353-3214, marquardt.steve@epa.gov

Margaret Sieffert, EPA- Region 5, ARD, (312) 353-1151, sieffert.margaret@epa.gov

Rae Trine, EPA-Region 5, ARD, (312) 353-9228, trine.rae@epa.gov

Rhea Hale, EPA/OPEI (202) 566- 2965 , hale.rhea@epa.gov

Carl Koch, EPA/OPEI (202) 566-2972 , koch.carl@epa.gov

Others, as appropriate

Approach: In response to the recommendation, a cross-divisional team within OAR, with
assistance from participants in Region 5, has taken the lead in evaluating the potential for
additional emissions reductions for these three industrial sectors. The approach for conducting
the evaluation of the three industries is outlined in the paragraphs below. Following the
evaluation, a decision will be made on what actions are appropriate to take.

The evaluation comprises 3 components that were also identified by the AQMWG: first,
refining the base and future year inventories, where appropriate; second, evaluating control
strategies and identifying measures that would provide greater or more optimal reductions in air
toxics and criteria pollutants than the current regulatory framework; third, conducting modeling
to assess the impacts of these sectors on risk, nonattainment and/or sensitive areas, and in
evaluating the effects of proposed compliance strategies. Each of these areas is discussed in

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greater detail below:

1.	Refining Base and Future Year Emissions Inventories - The approach entails reviewing our
current year inventories with additional data sources as available to refine our estimates; we have
not at this time conducted additional information collection activities but instead have relied on
our National Emissions Inventory, Toxics Release Inventory, and other available sources of
information to provide comprehensive estimates of all emitted pollutants; for example, the
National Council of the Paper Industry for Air and Stream Improvement (NCASI) has
documented on a routine basis, nationwide S02 and NOx emissions from U.S. pulp and paper
mills since 1980; likewise, we have been working with the petroleum industry to generate
emission estimates for refinery risk analyses. We also propose to evaluate our growth and
emissions projections for future years, and consider implementation of existing control measures
such as the NOx SIP call, BART, CAIR, NSPS and MACT regulations, or other case-specific
control measures; for example, a significant percentage of US refinery capacity will be
implementing additional controls as a result of settlements resulting from NSR enforcement
cases. We will quantify the effects of these actions on future emissions projections.

2.	Review and Identification of Optimal Control Strategies - We propose to review available and
emerging control technology information for various emission sources within these sectors to
determine their effects on all types of pollutants, and their costs; additionally, we propose to
identify and review any proposed national or regional measures for implementation of these
control technologies. Information resulting from this analysis will allow us to identify optimum
strategies, considering feasibility, costs, and benefits across all pollutant types.

3.	Conducting Modeling to Assess the Impacts of Sectors - Using emissions projections, we
propose to assess the contribution of these sectors to risk and on nonattainment or sensitive areas,
noting that some preliminary analyses have been initiated on these sectors as part of our residual
risk efforts; where appropriate, we will also model or estimate the effects of any proposed
control strategies.

Estimated Date for Responding to Recommendation: To date, emission inventories and
projections have been updated for all three sectors; modeling for screening level risk assessments
and for effects on the NAAQS for PM2.5 have been conducted for all three sectors; and
evaluation of emission reduction strategies is ongoing for all three sectors. We envision
completing the reviews for all three sectors in the summer 2006.

Final Response Product: Multipollutant Emission Reduction Strategy Reviews for all three
sectors.

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2.9 Guidance for Local Measures for Additional Key Sectors:

Recommendation: EPA, in conjunction with S/L/T and affected stakeholders, should prepare
guidance for local (urban-scale) control measures to support the upcoming round of ozone and
PM2.5 SIPs, and, if possible, optimize multipollutant control benefits and opportunities for
reducing criteria and toxic air pollutants.

AQMWG Priority Level: High

Workgroup Participants:

Tim Smith, EPA - OAQPS, AQSSD, (919) 541-4718, smith.tim@epa.gov
Tyler Fox, EPA - OAQPS, EMAD, (919) 541-0503, fox.tvler@epa.gov
Brenda Shine, EPA - OAQPS, ESD, (919) 541-3608, shine.brenda@epa.gov
Marc Houyoux, EPA- OAQPS, EMAD, (919) 541-3649, houvoux.marc@epa. gov
Michael Regan, EPA-OAQPS, EMAD, (919) 541-5294, regan.michael@epa.gov
Amy Vasu/RTP/USEPA/US@EPA, vasu.amy@epa.gov
Bill Neuffer/RTP/USEPA/US@EPA, neuffer.bill@epa. gov
Larry Sorrels/RTP/USEPA/US@EPA, sorrels.larry@epa.gov
Laura McKelvey/RTP/USEPA/US@EPA, McKelvev.laura@epa.gov
Ron Ryan/RTP/USEPA/US@EPA, ryan.ron@epa.gov
Scott Jenkins/RTP/USEPA/US@EPA, Jenkins.scott@epa.gov
Bill Johnson/RTP/USEPA/US@EPA, Johnson. williaml@epa. gov

Approach:

EPA has formed a workgroup to implement this recommendation. The group views this as a
two-fold problem:

(1)	Identification of any significantly-emitting source categories for PM2.5, and for PM2.5 and
ozone precursors in PM2.5 and ozone nonattainment areas, which are not addressed by other
CAAAC recommendations, and

(2)	Identification of the EPA actions and guidance which can address these source categories to
help with the SIP development process, and to address ways to optimize multipollutant concerns
where possible.

Regarding item (1) above, we have reviewed projected 2010 emissions for a 41 category
breakdown for 16 Eastern nonattainment areas which are projected to exceed the PM2.5 NAAQS
in 2010 after implementation of the CAIR rule. Many of these areas are also projected to
exceed the ozone standards in 2010. The results of this analysis appear to suggest that most
significant categories are already addressed by existing CAAAC recommendations. We have
identified a few categories, including industrial metals processing facilities, commercial cooking,
and a few others, which are not addressed by current CAAAC recommendations.

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Regarding item (2), we have already undertaken work for two of the categories. For metals
processing, we are funding a steel mill case study in cooperation with the State of Michigan and
EPA region 5. For commercial cooking, we are funding an innovations case study project to
assess the feasibility of voluntary programs for commercial charbroilers, for which control
technology is available. For some of the source categories, it appears that ample guidance may
already be available. For example, the WRAP has developed a comprehensive guidance
document for fugitive dust sources. Final, we have identified categories which will be
addressed by area source hazardous air pollutant emissions standards.

Estimated date for Responding to Recommendation: Actions being taken on two categories:
commercial cooking (evaluating feasibility of voluntary program) and steel mills (pilot project to
evaluate emissions and additional controls).

For the restaurant case study EPA/OAQPS working with regional offices and states to identify
city for pilot project. We expect selection of pilot project city in near future, and have written
contract work assignment to assist in outreach effort.

Steel mill case study in Detroit is underway to assess sources and potential controls.
EPA/OAQPS has funded contract study and is working closely with the State of Michigan and
EPA Region 5 staff in conducting this technical evaluation. Results of this contract report are
expected in January 2006.

In addition to these two case studies, EPA is providing considerable technical input to
STAPPA/ALAPCO "menu of options" document which is expected to be completed in the near
future.

Final Response Product: Guidance documents or other approaches for categories identified.

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2.10 Residential Wood Smoke Reduction Initiative:

Recommendation: EPA should further develop the Residential Wood Smoke initiative that
includes working with S/L/T, industry, non-governmental organizations and others to support
and facilitate the changeout of dirty, inefficient "conventional" (pre-New Source Performance
Standard or NSPS) woodstoves with new, cleaner and more efficient heating appliances (e.g.,
EPA certified woodstoves and gas appliances). Concurrent with the development and
implementation of changeout programs, EPA should commence efforts to revise the NSPS.

AQMWG Priority Level: High

Workgroup Participants:

Karen Blanchard, EPA - OAQPS, (919) 541-5503 blanchard.karen@epa.gov

Larry Brockman, EPA - OAQPS, (919) 541-5398 brockman.larry@epa.gov

Gary Blais, EPA-OAQPS, (919) 541-5515 blais.gary@epa.gov

Rick Colyer, EPA-OAQPS, (919) 541-5262 colver.rick@epa.gov

Eric Crump, EPA-OAQPS,(919-541-4719) crump.eric@epa.gob

Jim Eddinger, EPA-OAQPS, (919-541-5426) eddinger.iim@epa.gob

Tim Smith, EPA - OAQPS, (919) 541-4718 smith.tim@epa. gov

Mike Toney, EPA-OAQPS, (919) 541-5247 tonev.mike@epa.gov

Gil Wood, EPA- OAQPS, (919) 541-5272 wood.gil@epa.gov

J Stephen Hartsfield - National Tribal Air Association, 505-242-2175 x 106

shartsfield@ntec.org

John Crouch - Hearth, Patio and Barbecue Association, 916-536-2390,
i ohn. crouch. hpb a @ sb cgl ob al. net

Approach:

Woodstove Changeout Pilots - "Great American Woodstove Changeout"

Building on the momentum from the Libby, MT woodstove changeout kick-off event in June,
EPA, working with the Southwest Pennsylvania Air Quality Partnership (SPAQP), the hearth
industry, Allegheny County Health Department and other partners, kicked off an 11 county
woodstove changeout campaign on Sept. 29 in Pittsburgh. The timing for this event could not
have been any better given the rising energy prices and interest from the public in using more
affordable fuels like wood to heat their homes.

The EPA awarded a $100,000 grant to the SPAQP for funding low-income households that
changeout their old, dirty inefficient woodstoves with a clean burning, more efficient hearth
appliances (e.g., gas, pellet or EPA-Certified woodstove). Allegheny County contributed
$80,000 toward the low-income households. The hearth industry provided rebates (-10%) for
any person that changeout their old stove with a clean burning technology. If the 40.000
woodstoves in the Pittsburgh area could be replaced, this would yield about $470 million in
health benefits in 2008. In addition to the pilots, EPA is providing technical support to the
greater Dayton, Ohio area's Regional Air Pollution Control Agency in implementing their

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planned woodstove changeout. There are another 10 or so areas throughout the country EPA is
in communications with about implementing their own woodstove changeouts over the next
year.

We plan to support additional woodstove changeouts in FY 06 and beyond and hope to grow the
initiative similar to the diesel retrofit program. Finally, we will likely continue to target our
efforts in PM2.5 nonattainment areas, locations where there are short term PM2.5 spikes due to
wood burning, and in community-based air toxics program locations.

Guidance for Quantifying and Using Wood Stove Changeout Emission Reductions in State
Implementation Plans - This document is intended to provide agencies with guidance on
quantifying emission reductions for replacing or "changing out" dirty, inefficient pre- NSPS
woodstoves with cleaner burning technologies (e.g., gas, pellet or EPA-Certified stoves). EPA
expects that air quality officials may wish to use the emission reductions resulting from
implementing a wood stove changeout campaign to help meet the goal of attaining the PM2.5
NAAQS. EPA plans to have a final of this guidance document available by November 2005.

New "How To" Guide on Fireplace/Wood Stove Website (www.epa.gov/woodstoves) - By the
end of November EPA plans to have a user-friendly, comprehensive "How To" guide for
implementing a woodstove changeout campaign available on our website. This guide, along with
the current information on the website is intended to provide air pollution control officials with
the necessary tools to more easily implement their own changeout campaigns and otherwise
address residential wood smoke.

Fireplaces

EPA continues to work with the HPBA, individual fireplace and wood stoves manufacturers,
NSPS-accredited wood stoves testing laboratories, and others by participating in an ASTM
(American Society for Testing and Materials) committee to develop a consensus test method for
testing fireplace emissions. This effort was requested by the HPBA. Significant progress is
being made towards a consensus test method. EPA foresees that this effort would allow the
potential development of a consensus emission standard and/or a National building code for
fireplaces within the next 3 years.

Outdoor Wood-fired Hydronic Heaters (OWHH) - EPA has initiated a review of the recently
received petition from northeastern states to regulate outdoor wood-fired hydronic heaters and
we expect to make on decision by next spring on how to address this source category.

Woodstove NSPS - EPA is working with Hearth Industry to gather data on the percentage of
stoves that meet the more stringent Washington State standard. Review of this data will help
determine priority of NSPS.

Estimated Date for Responding to Recommendation:

• Final woodstove changeout SIP guidance: November 2005

• Final woodstove changeout "How To" Guide: November 2005

• Determine priority for reviewing woodstove NSPS: December 2005

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• Determine outdoor wood boiler federal strategy : Spring 2006

Final Response Product: We will continue implementation of the initiative and develop
associated products as needed.

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2.11 Open Burning:

Recommendation: EPA should work with S/L/T to encourage more vigorous control of
open burning, especially in, and adjacent to, counties with Class I areas and counties
classified as nonattainment for fine particles or ozone.

AQMWG Priority Level: Medium

Workgroup Participants:

Tribal:

John Cox - Confederate Tribes
Tamera Dawes - ITCA

Patricia Mariella - Gila River Indian Community
State/Local

Tom Atkinson - Georgia
Tammy Medlen - Tennessee
Bob Habeck - Montana
Debra Wolfe - Montana
Corky Martinkovic - Arizona
John Lyons - Kentucky
Rick Boddicker - South Dakota
Coleen Campbell - Colorado
Tina Suarez-Murias - California
Mike Ziolko - Oregon

Troy Perry - Jefferson County Dept. of Health (Alabama)

Mel Cummings - Hillsborough County Env. Protection Commission

John Hornback - Metro 4/Vistas

Rita Truillo - NM

Adele Malone - Nevada

Brad Musick - NM

FLM

Brian Mitchell - National Park Service
Lisa Bye - BLM

EPA

Bill Beal - OAQPS
Larry Elmore- OAQPS
Julie McClintock - OAQPS
Kenneth Fradkin - Region 2
Raymond Forde - Region 2
Steve Scofield - Region 4
Joe Kordzi - Region 6
Susan Klein - Region 7

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Amy Algoe-Eakin - Region 7
Alan Ban wart - Region 7

Laurel Dygowski - Region 8

Libby Faulk - Region 8
A1 Petersen - Region 9
Anne Dalrymple - Region 10
Steve Body - Region 10

Approach: In response to the recommendation, the open burning workgroup participants will
take the lead in developing ways to encourage more stringent controls on open burning where it
affects Class I and nonattainment areas and work towards educating stakeholders about the
effects of open burning on air quality. The first step in this process was to decide on the types of
open burning the workgroup would concentrate on. After coordination and consensus between
stakeholders to ensure everyone's concerns are met, the workgroup developed a list of the types
of open burning they are addressing. The initiation of this workgroup has provided an additional
benefit of being a forum for discussion between stakeholders on issues they are facing
concerning open burning.

The next step in the process was to gather existing information on open burning emissions,
controls, and emission reduction techniques in each state, as well as existing informational and
educational materials. The workgroup would take advantage of existing information and data
that has been collected on open burning by States, Tribes, Locals, and RPOs. Once existing data
is collected, the workgroup and EPA would work cooperatively with stakeholders to update and
gap-fill the information as necessary. From initial conversations within the workgroup, it
appeared that this task will be quite formidable, as many states have very little if any information
that has been collected on open burning emissions or emission reduction techniques. The
outcome of this was that it was determined that states involved in the workgroup represent many
states across the country and they have very little information on open burning emission
inventories or reduction techniques.

Further research by the workgroup revealed that EPA has very recently done some extensive
work on updating and expanding open burning emission quantification factors and emission
inventory information. The EPA data was presented to the workgroup and members' feedback
determined that this was the type of information that we needed for open burning emission
inventories and emission factors to determine quantification for emission reduction techniques.
In addition, it was discovered that EPA's MSW office has a backyard burning website that
already contains a centralized location for each state's open burning control information. The
workgroup will look at updating the website information and also at a way to centralize the
emission inventory and emission quantification information. In addition, the next step will be to
gather pertinent and updated outreach materials for stakeholders to use and place in a centralized
location with the emission inventory and emission quantification information.

In order to make it easier for States, Tribes, and Locals to take advantage of benefits from stricter
open burning controls, the workgroup will develop outreach SIP guidance and a model rule. The

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workgroup will apply data collected on emission reduction strategies to developing SIP guidance
that provides procedures and calculation methodologies to facilitate the determination of
emission reduction credits. Information collected on existing open burning controls will form the
basis for the development of a model open burning rule to be used by States, Locals, and Tribes.
In addition to SIP guidance and a model open burning rule, the workgroup will utilize input from
workgroup members and stakeholders to determine what other things would encourage States,
Locals, and Tribes to adopt more stringent controls on open burning. The SIP guidance, model
rule and informational materials will be gathered into a website that is easy to use. In order to
make stakeholders aware of these products, the workgroup will coordinate with outreach staff
from different agencies.

Based on an assessment of the data pertaining to emissions and control measures, and the impact
of open burning on nonattainment areas, the workgroup will determine whether open burning
strategies should be a component of nonattainment SIPs. If open burning only has an impact on
a few nonattainment areas, it may be determined that specific control measures at a more local
level are more effective. The workgroup has also been tasked with working with EPA's Office
of Solid Waste to determine whether a national open burning rule is worthwhile. Based on the
data collected, input from EPA's Office of Solid Waste, and input from stakeholders, the
workgroup will determine whether a national open burning rule would be useful and effective.

Because of the correlation with Class I and nonattainment areas, the workgroup will coordinate
with any projects or measures that are being developed to address the requirements in 40 CFR
51.308 and 51.309 (Regional Haze SIPs), or nonattainment area SIPs.

Estimated Date for Responding to Recommendation: May 2006. If it is determined that a
national open burning rule would be beneficial, the response to this portion of the
recommendation would be May 2007 or later to allow for development and implementation of
such rule.

Final Response Product: The final response product will be a SIP guidance document, a model
rule, and informational and outreach materials. A national rule pertaining to open burning is also
a possible product.

Resource Needs to Address Recommendation: Region 8, Region 4, other EPA Regional
Offices, Headquarters, Tribal staff time, State staff time, and Federal Land Manager Staff time.

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2.12 High-emitting Gasoline Vehicles:

Recommendation: EPA and States/Locals/Tribes should reduce emissions from high-emitting
gasoline vehicles that are believed to contribute a high fraction of mobile source emissions.

AQMWG Priority Level: Variable (depends on the impact of high-emitters on a particular

inventory).

Workgroup Participants: Staffed by OTAQ. Coordinated with the Mobile Source Technical

Review Subcommittee. Lead: Gene Tierney.

Approach: EPA is working on an ongoing basis to reduce emissions from high-emitting light-
duty gasoline vehicles through implementation of on-board diagnostic (OBD) requirements,
vehicle inspection and maintenance (I/M) programs, and federal compliance programs. In
addition, EPA continues to investigate emissions from light-duty vehicles through various test
programs and through analysis of data generated by I/M programs, remote sensing, and other
laboratory tests. EPA plans to continue acquiring and assessing new data to evaluate the
effectiveness of vehicle controls including OBD, enhanced evaporative systems, and new
emission standards.

In 2005 and 2006, EPA will analyze and report on new data collected for the now-complete
Kansas City Study. This study collected, for the first time, a random, representative, stratified
sample of the entire light-duty gasoline fleet and measured all criteria pollutants, along with PM
and toxics. Criteria pollutants were measured both in the lab and on the road using portable
emission measurement systems (PEMS), providing comprehensive real world data on vehicle
performance under a wide array of operating conditions. The statistical approach in this study
will allow us to characterize the distribution of all emitters and, in particular, high emitters.

In 2005 and 2006, EPA will complete an interim report on the current OBD high mileage study
and analyze that data with respect to high emitters. This effort will then be expanded to include
high mileage Tier 2 vehicles, and employ PEMS to characterize real world emissions of these
vehicles.

EPA is currently in the process of acquiring state I/M modal (second-by-second) data and remote
sensing data for use in MOVES (Motor Vehicle Emissions Simulator) to characterize the impact
of high emitters on the emission inventory. We are also updating information on the national
fleet and its activity patterns to better characterize the nation's fleet. Data from all sources,
including the California Air Resources Board, are being sought and used.

EPA also implements a strong compliance program to ensure that vehicles continue to meet
emission standards as they age. In January 2006, EPA will have the first complete set of data
from the manufacturer-run In-use Verification Program (IUVP). This will include both low
mileage data (one year old, and 10,000 miles and higher) and high mileage data (four years old,
and 50,000 miles and higher). EPA will analyze and evaluate this data for use in determining the
impact of high emitters.

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In 2006, EPA plans to conduct a study of high-emitting light-duty vehicles using PEMS. The
purpose of this study is to better understand the emission patterns from high emitters under real
world driving conditions. Such patterns are known to be highly variable and better
characterization of this behavior will improve both inventory modeling and our ability to detect
and repair such problems. High emitters will be identified in I/M lanes and equipped with PEMS
for 1-3 days of owner operation.

At this time, EPA is discussing with the Coordinating Research Council a new test program to
evaluate the effectiveness of enhanced evaporative systems. These systems are now as much as
nine years old, and data are needed to understand evaporative emissions from these vehicles and
the occurrence of high emitters. It is hoped that a cooperative program can be launched in 2006
to look at these questions.

Estimated Date for Responding to Recommendation: EPA implements or oversees programs
to address high emitters on an ongoing basis through state I/M programs, emission factor testing,
and compliance programs.

We will continue to improve our understanding of the contribution of high-emitting vehicles in
the vehicle fleet through analysis of recently collected data from Kansas City and the high
mileage program, through on-going programs to collect data such as our compliance programs,
and through special studies like the upcoming Tier 2 high mileage OBD study and the I/M high
emitter study. The results of these data collection and analysis efforts will culminate in
populating the emission factors in MOVES2006.

In the longer term, EPA plans to continue collecting emission factor data, compliance data, I/M
data, and remote sensing data, and using that data to continuously improve our inventories and
assessment of the impact of high emitters on air quality.

Final Response Product: Characterization of the impact of high emitters on today's mobile
source vehicle inventory. MOVES2006. Recommendations for program changes to further
reduce emissions from high emitting vehicles.

Resource Needs to Address Recommendations: Existing resources are being used for work
already underway.

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2.13 Conformity:

Recommendation: Conformity should be retained as part of the nation's AQM system.

AQMWG Priority Level: Low. Priority is low because there is an effective program in place.

Workgroup Participants: Staffed by OTAQ. Coordinated with the Mobile Source Technical

Review Subcommittee.

Lead: Lee Cook.

Approach: Transportation conformity requires that air pollution levels from motor vehicles in a
Metropolitan area, including emissions from planned transportation projects, be consistent with
levels necessary to assure timely attainment and maintenance of NAAQSs. The workgroup
recommended that conformity's 20 year transportation planning horizon, and the requirement to
revise transportation conformity analyses every three years, be maintained.

Estimated Date for Responding to Recommendation: SAFETEA-LU: On August 10, 2005
SAFETEA-LU was signed into law. SAFETEA-LU made the following changes to the existing
conformity program:

• changing the minimum frequency for conformity determinations from 3 years to 4
years;

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•	allowing areas to shorten the time period covered by conformity determinations after
consultation with the air agency and public comment

•	providing 24 months instead of the current 18 months to determine conformity after
new budgets become available;

•	adding a 1-year grace period for conformity lapses;

•	streamlining requirements for conformity SIPs; and

•	providing a mechanism to allow all areas to change or add transportation control
measures to approved SIPs without a full SIP revision.

EPA plans to issue interim guidance by the end of the year. We will then work as expeditiously
as possible to incorporate these changes into the conformity regulations by SAFETEA-LU's
deadline of August 2007.

Conformity Rulemakings: EPA is currently working on a rulemaking that will address "hot-
spot" requirements for transportation projects in areas that do not meet the National Ambient Air
Quality Standards for PM2.5 and PMi0. Hot-spots are localized pollutant concentrations that
exceed the federal emission standards.

On December 13, 2004, EPA issued a supplemental proposal that detailed additional options for
addressing PM2.5 and PM10 hot-spot requirements (69 FR 72140). The supplemental proposal
included the original options proposed by EPA in November 2003 (68 FR 62690), as well as new
options. EPA is currently reviewing the comments received on the supplemental proposal and
plans to finalize PM2.5 hotspot requirements for projects by March 2006.

Final Response Product: Retention of the transportation conformity program. Changes to the
20-year conformity horizon and 3-year minimum frequency requirement resulted from the
legislation.

Resource Needs to Address Recommendations: Implementing changes to the program that
result from SAFETEA-LU can be accomplished with existing resources.

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3.1 Align SIP Submittal Dates:

Recommendation: Because ozone, PM2.5, and regional haze SIPs have similar elements and
are likely to contain similar control strategies, EPA, S/L/T and other stakeholders should strive to
align the submittal dates of the three SIPs. This recommendation is not intended to suggest
changes to any deadlines for attainment or implementation of control strategies, or to imply that
a single SIP should be required for ozone, PM2.5, and regional haze. It is further recommended
that, in the future, EPA should align designation dates as appropriate to promote multipollutant
SIP development

AQMWG Priority Level: High

Workgroup Participants:

Barbara Driscoll, EPA - OAQPS, AQSSD, (919) 541-1051, driscoll.barbara@epa.gov

Kay Prince, EPA - Region 4, (404) 562-9026, prince.kav@epa.gov

Todd Hawes, EPA- OAQPS, AQSSD (919) 541-5591, hawes.todd@epa.gov

Amy Vasu, EPA - OAQPS, AQSSD (919) 541-0107, vasu.amy@epa.gov

John Silvasi, EPA- OAQPS, AQSSD (919) 541-5666, silvasi .i ohn@epa.gov

Sharon Reinders, EPA- OAQPS, AQSSD (919) 541-5284, reinders.sharon@epa.gov

Doug Grano, EPA- OAQPS, AQSSD (919) 541-3292, grano.doug@epa.gov

Approach: The workgroup first acknowledged that in order to officially align the SIP submittal
dates the Clean Air Act would need to be changed. Current timing requirements including those
caused by litigation, court ordered deadlines, etc make it difficult to align submittal dates. In
addition, most states are already developing their ozone SIPS for 2007 which makes timing
critical to affect the next round of SIPs. On-going activities to address this issue are to continue
to encourage States to integrate ozone, PM2.5 and regional haze planning through language in
Ozone and PM Implementation Rulemaking. Work with team, and stakeholders to determine
what incentives might be available to encourage States to submit their PM SIPs early.

Estimated Date for Responding to Recommendation: PM rule proposed in September 2005;
Ozone Phase 2 Rule final possibly by end of December 2005; PM incentives by Jan 30, 2005 if
determined feasible.

Final Response Product: Language in on-going rulemaking encouraging integration of SIP
work and submittals. Incentives for States to provide PM SIPs early if determined feasible.

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3.2 Protocol For SIP Development:

Recommendation: Each State should work with the appropriate EPA Regional Office to
develop and implement a protocol for SIP development and processing that would lay out
responsibilities, expectations, and timelines for all parties. While a model protocol should be
developed, the EPA Regional Office and each State should have the flexibility to design a
protocol tailored to their specific needs.

AQMWG Priority Level: High

Workgroup Participants:

Steve Rosenthal, EPA - Region 5, ARD, (312) 886-6052, rosenthal.steven@epa.gov
Kathy Watson, Indiana Department of Environmental Management, (317) 233-5694,
KWATSON@idem.in.gov,

Pat Troth, Indiana Department of Environmental Management, (317) 233-5681,
PTROTH@idem.in.gov

Approach: Region 5 will work with Indiana to develop a protocol for SIP development and
processing that could serve as an example protocol for use by other states. The most important
part of this protocol is fostering the development of effective communication between EPA and
the State to avoid late hits in the rule adoption process. Informing EPA at an early stage is
important so that the State can be made aware of all relevant and up to date EPA guidance and
any important precedents. This will allow needed changes to a draft rule or the requirement for
additional technical support to be identified as early as possible in the SIP process. In addition
to communication on specific SIP actions, there should be periodic, e.g. monthly,
communication between EPA and the State that provides an overview of all pending SIP actions.
This will enable the proper allocation of resources.

This protocol will detail the necessary communication between Indiana and EPA Region 5 from
the time that a draft SIP revision is first envisioned until final rulemaking. Indiana will provide
Region 5 with sufficient time to comment during its comment period and identify the appropriate
State contacts. The time required for EPA's review as well as the EPA staff performing the
review will be identified. All reasonable efforts will be made by EPA to identify significant
issues in draft SIP revisions. EPA and Indiana will consider developing a spreadsheet that
identifies each proposed SIP revision, the expected time (for both Indiana and EPA) for each step
and the status of each step in the review. This is needed to flag any potential bottlenecks before
they can cause a delay.

Indiana's SIP/Rules tracking and monthly calls should greatly facilitate development of this
protocol. Also, the monthly calls are a convenient time to discuss any issues that come to light.

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By the end of July we will have discussed the project background and general approach.
By the end of August we should have all the elements of the SIP Protocol worked out,
including specific timing and tracking issues.

By mid-November we should have a draft protocol prepared for review by OAR, ORC
and OGC.

By mid-December we should have a final SIP Protocol document prepared for signature
by Commissioner Easterly and the Regional Administrator.

Estimated Date for Responding to Recommendation: December 2005

Final Response Product: A SIP Protocol developed with Indiana that will establish guidelines
to improve communication between EPA and the State and result in expedited and high quality
SIP revisions. This SIP Protocol will be intended to serve as an example for use by other states.

Resource Needs to Address Recommendation: Region 5, Headquarters and Indiana staff time.

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3.4 Streamline Minor SIP Revisions:

Recommendation: For the SIP approval/disapproval phase of the air quality management
process, EPA should establish a de minimis level for SIP revisions and streamline the processing
of these revisions by the use of "letter approvals" or similar expedited procedures signed by the
Regional Administrator. EPA should, in consultation with S/L/T and other stakeholders, develop
a listing of the types of SIP actions that are eligible for streamlined processing.

AQMWG Priority Level: High

Workgroup Participants:

Jerry Stubberfield, EPA - OAQPS, 919 541 0876, stubberfield.ierry@epa.gov
Donald Cooke, EPA-Region 1, 617 918 1668, cooke.donald@epa.gov
Sharon Reinders, EPA - OAQPS, 919 541 5284, reinders.sharon@epa.gov
Barbara Driscoll, EPA-OAQPS, 919 541 1051, driscoll.barbara@epa.gov

Approach:

Currently the Agency's On-line SIP Processing Manual contains the following information
regarding use of Letter Notices:

"Letter Notice Actions

Under the letter notice procedure, EPA sends a letter to the affected states and parties rather than
a notice-and-comment rulemaking to approve truly insignificant SIP actions. No notice will be
published in the Federal Register prior to sending final letter notice approvals to the state and
affected parties. The letter to the state will be EPA's final action approving such minor SIP
revisions. The Agency will periodically publish a summary list of all letter notice actions in the
Federal Register to keep the general public informed of SIP matters. The effective date of the
letter notice approvals will be the date of the letter to the state, not the date of the subsequent
summary Federal Register notice. Letter notices approvals will, however, remain subject to the
potential judicial review until sixty days after the date of the summary Federal Register notice.

Categories of SIP action appropriate for letter notice include: recodification involving no
substantive changes; minor technical amendments; typographical corrections; address changes;
and similar non-substantive matters. However, the decision to use Letter Notice actions as a
rulemaking tool is up to each individual Regional Office."

Members of the Letter Notice work group participated in a conference call with OGC and the
RC's on March 31, 2005. The consensus from that meeting was that the use of letter notice
should not be expanded. That it should be only used for minimal actions that had already been
defined (see below). We plan to upgrade the On-line SIP manual making some minor
corrections in the letter notice section but no further actions beyond that are planned. Requested
that EPA Regional Offices to survey their States as to need for expanding this approach.
Response to the survey indicated that no new additions to the list of eligible SIP actions qualify
for "letter notice approval".

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The members of the National SIP Processing Work Group which consists of all the Regional SIP
contacts will be advised of this action and a discussion of this conclusion discussed during one of
their upcoming monthly conference calls.

Identified List of SIP Actions That Could Use Letter Notices :

Typographic corrections

Address changes

Minor wording changes

Recodifications (no substantive changes)

Renumbering previously approved regulations

Minor SIP Actions

Minor or merely technical amendment
Technical amendments

SIP actions little interest to general public (public will have no interest in commenting)
SIP actions that are not substantive or do not have general applicability

Estimated Date for Responding to Recommendation: Follow-up discussions with Regions
and States have resulted in no new additions to list of eligible SIP actions which qualify for
"letter notice approvals". Response to recommendation determined to be completed.

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3.5 Timely EPA Guidance:

Recommendation: EPA guidance should be issued in sufficient time for States to meet their SIP
development deadlines. EPA should involve S/L/T and other appropriate parties in its guidance
development process. In cases where guidance is delayed, EPA should take into consideration
States efforts to meet deadlines without the benefit of the appropriate policy guidance.

AQMWG Priority Level: High

Workgroup Participants:

Barbara Driscoll, EPA - OAQPS, AQSSD, (919) 541-1051, driscoll.barbara@epa.gov
David Solomon, EPA - OAQPS, AQSSD, (919) 541-5375, solomon.david@epa.gov
Joe Paisie, EPA - OAQPS, AQSSD, (919) 541-5556, paisie.ioe@epa.gov
John Silvasi, EPA - OAQPS, AQSSD, (919) 541-5666, silvasi .i ohn@epa.gov
Larry Sorrels, EPA - OAQPS, AQSSD, (919) 541-5041, sorrels.larry@epa.gov
Rich Damberg, EPA - OAQPS, AQSSD, (919) 541-5592, damberg.rich@epa.gov
Denise Gerth, EPA - OAQPS, AQSSD, (919) 541-5550, gerth.denise@epa.gov

Approach: We are evaluating the process for guidance and implementation rules for ozone and
PM2.5 to be approved. We are looking at the current process, time it takes for review by
different offices in order to determine why the delays in issuing these rules have occurred and
what can be done to expedite the process in the future.

Estimated Date for Responding to Recommendation: Evaluate ozone and PM
implementation rules by December 2005. Develop list of recommendations for improving the
process based on the evaluations by end of January 2006.

Final Response Product: An evaluation of the actual guidance development process and
recommendations on how to improve the process.

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3.6 Avoid Unnecessary Public Hearings:

Recommendation: EPA should work with States and Tribes to develop a model regulation that
would require a public hearing for SIP revisions only if one is requested after public notice. This
recommendation is not to restrict public comment in any way, it is meant only to eliminate those
hearings that no one attends.

AQMWG Priority Level: High

Workgroup Participants:

Doug Aburano, EPA - Region 5, ARD, (312) 353-6960, aburano.douglas@epa.gov

Frank Acevedo, EPA - Region 5, ARD, (312) 886-6061, acevedo.francisco@epa.gov

Stuart Arkley, Minnesota Pollution Control Agency, (651) 796-7774, stuart.arklev@state.mn.us

Andre Daugievites, EPA - Region 5, ORC, daugavietis.andre@epa.gov

John Seltz, Minnesota Pollution Control Agency, (651) 296-7801. i ohn.seltz@state.mn.us

Jan Tierney, EPA - OGC, (202) 564-5598, tiernev.ian@epa.gov

Bill Wagner, EPA- Region 5, ORC, (312) 886-4684, wagner.william@epa.gov

Approach: In response to the recommendation, Region 5, with assistance from other workgroup
participants, will take the lead in developing an alternative public hearing process allowed for
under 40 CFR 51.102(g) [i.e., a public hearing for State Implementation Plan (SIP) revisions
only if one is requested after public notice]. Under 40 CFR 51.102(g) EPA has the authority to
approve State procedures for public hearings as long as certain criteria are met. To meet the
criteria described in 40 CFR 51.102(g), EPA and Minnesota would identify specific types of SIP
revisions where, historically, public interest has been very low and allow these SIP revisions to
proceed after opportunity for public hearing. Specifically, the State would publish a notification
of the public comment period and note that a hearing would be held if requested. If no hearing is
requested, the notice would be considered adequate for SIP purposes. Region 5 plans to pilot
this project with the State of Minnesota. Region 5 will prepare a rulemaking in the Federal
Register for this alternative process.

Based on the experience with the Minnesota pilot project, EPA will determine whether a national
rule change should be pursued. A national rule change could alter the need for an automatic
public hearing by amending 40 CFR 51.102 and could offer more global changes to EPA's
requirements. It should be clear that the Minnesota pilot project will be conducted under existing
provisions found in 40 CFR 51.102(g) that allow for limited alternatives to required public
hearings.

A national rule change to 40 CFR 51.102 and what EPA is pursuing with Minnesota are two very
different approaches towards addressing the same issue. If Region 5 is successful in addressing
Minnesota's concerns over holding unnecessary public hearings by identifying various types of
noncontroversial SIP revisions, agreeing that these SIP revisions should not be required to have
automatic public hearings, and establishing a model process under 40 CFR 51.102(g) for other
States to follow, then it may obviate the need for a national rule change to 40 CFR 51.102.

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Estimated Date for Responding to Recommendation: December 2005

Final Response Product: A project piloted with the State of Minnesota to reduce the number of
unnecessary public hearings held in that State.

Resource Needs to Address Recommendation: Region 5, Headquarters and Minnesota staff
time.

October 2005 Update: Region 5 and the Minnesota Pollution Control Agency have had
numerous phone calls and have examined various types of SIP revisions. We have identified a
limited number of SIP revisions that we believe to be noncontroversial and have historically
generated little or no public interest. Examples of these include: purely administrative changes
(e.g. fixing typos), 10-year maintenance plan updates with no substantive changes, and unit/plant
permanent shutdowns where SIP requirements are obsolete. We believe that these types of SIP
revisions are ideal candidates for allowing the public the opportunity to request a public hearing
rather than automatically having one. Under this scenario if anyone requested a public hearing,
one would be held.

To establish this alternative process, we believe a SIP revision request will have to be made.

This will not require a rule change at the State level but it will require the State to hold a public
hearing on the adoption of this alternative process.

We are still on track to complete this process by December 2005. In order for this to occur,
Region 5 will parallel process this request.

•	Early October 2005 - MPCA will send final draft to EPA; EPA will begin parallel
process.

Mid to late October 2005 - MPCA will hold public comment period and public hearing
for SIP revision; EPA will propose approval of alternative public hearing process

•	December 2005 - MPCA will make final submittal to EPA; EPA will issue final approval
of alternative process

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3.7 Facilitate Redesignation Process for Certain Areas:

Recommendation: For those areas that have not pursued and been granted redesignation when
initially eligible, and have continued to demonstrate violation-free ambient air quality for several
years, EPA should expedite the redesignation process. EPA should ensure that all Regions and
Sates are aware of the simplified procedures. This recommendation is not intended to change the
requirements for redesignation under the CAA.

AQMWG Priority Level: Low

Workgroup Participants:

Kay Prince, EPA - Region 4, APB, (404) 562-9026, prince.kav@epa.gov
Dick Schutt, EPA - Region 4 APB, (404) 562-9033, schutt.dick@epa.gov
Annie Nikbahkt, EPA - OAQPS, (919) 541-5246, nikbahkt.annie@epa.gov
Sharon Reinders EPA - OAQPS, (919) 541-5284, reinders.sharon@epa.gov
Larry Wallace, EPA - OAQPS, (919) 541-0906, wallace.larry@epa.gov
Barbara Driscoll, EPA - OAQPS (919) 541-1051, driscoll.barbara@epa.gov
Sara Schneeberg, EPA - OGC, (202) 564-5592, schneeberg.sara@epa.gov
Kendra Sagoff, EPA - OGC, (202) 564-5591, sagoffkendra@epa.gov
Rich Burkhart, EPA- Region 1, (617) 918-1664, burkhart.richard@epa. gov
Laurie Ostrand, EPA- Region 8, (303) 312-6437, ostrand.laurie@epa.gov
Jonah Staller, EPA - Region 8, (303) 312-6437, staller.ionah@epa.gov

Approach: The workgroup will work to compile existing guidance which would include but
may not be limited to:

September 4, 1992 redesignation guidance memo;

May 10, 1995 Clean Data Policy (for ozone);

December 14, 2004 Clean Data Policy for PM2.5;

Limited Maintenance Plan options for PM10 (October 18, 1999), 1-hour ozone
(November 16, 1994), and CO (October 6, 1995);

April 16, 1992 Proposed General Preamble;

October 28, 1992 memo regarding SIP actions in response to CAA deadlines;
September 17, 1993 memo regarding SIP requirements for ozone and CO
redesignation requests on or after November 15, 1992; and
October 18, 2000 S02 redesignation guidance memo.

Work with OAQPS to determine the appropriate website where existing and additional guidance
documents with respect to redesignation issues would be housed, including any policies
developed for the 8-hour ozone and PM2.5 NAAQS.

Region 4 will work with OGC and OAQPS to complete materials to be provided to Regional
Offices to assist in their actions on redesignation requests.

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Regional Offices will disseminate information to their states that includes a list of the available
guidance documents and the website where they can be found as soon as the list is complete and
the website location has been determined. Regions will provide assistance to states to help
facilitate the redesignation process so that the action on a redesignation request can be completed
in an expeditious manner..

Estimated Date for Responding to Recommendation: November 2005

Final Response Product: A website address that provides states and regions a complete list of
all available guidance documents. Materials for Regional Offices to use in acting on
redesignation requests.

Resource Needs to Address Recommendation: Existing resources at Regional Offices,

OAQPS and OGC.

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3.9 Co-Benefits of Innovative Measures:

Recommendation: EPA and S/L/T should work collectively to communicate the co-benefits
associated with innovative measures.

AQMWG Priority Level: High

David Solomon, EPA - OAQPS, AQSSD (919)-541-5375, solomon.david@epa.gov
OAQPS Innovations Team (David Cole team lead), (919)-541- 5565, cole.david@epa.gov
Jim Yarbrough, EPA - Region 6, (214)-665-7232, varbough.iames@epa.gov
Alan Powell, EPA - Region 4, (404)-562-9045, powell.alan@epa.gov
Roman Kramarchuk, EPA - OAP, CAMD, (202) -343-9089, kramarchuk.roman@epa.gov

Approach: In response to this recommendation, OAQPS, with assistance from other workgroup
participants, will work with States, locals and tribes to define and communicate how proposed
strategies and innovations to improve air quality would also improve quality of life in general.
EPA plans to use two different pathways to identify and communicate (both directly and
collectively the States, local and tribes) the non-air quality benefits, such as improving public
health, increasing economic and other societal benefits, to be derived from innovative and
voluntary approaches to meeting air quality goals. One is to use the upcoming 2005 Air
Innovations Conference as a forum to have State, local and tribal participants highlight and
discuss co-benefits, in addition to the air quality impacts of innovative approaches. The other is
to acknowledge and recognize non-air quality benefits in the context of EPA policy and guidance
documents and materials developed for States, locals and tribes to use in support of innovative
and voluntary air quality measures. For example, EPA plans in its forthcoming guidance on
bundled SIP measures (see recommendation #3.11) to include a discussion on the importance of
providing the public with information on broader, non-air quality benefits, associated with
innovative air quality solutions as well as providing some specific examples of co-benefits
associated with certain innovative and voluntary measures.

Estimated Date for Responding to Recommendation: August 2005.

Final Response Product: The August 2005 Air Innovations Conference will highlight the
benefits of new and innovative air quality projects going on around the United States and
encourage dialogue among stakeholders. EPA policy and guidance on innovative and voluntary
approaches will include a discussion of the associated co-benefits and the importance of
informing the public of how such approaches improve their quality of life beyond reductions in
air pollution. Final response product was completed on schedule.

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3.10 Innovative and Voluntary Measures:

Recommendation: EPA should encourage States' and Tribes' efforts to implement innovative
measures by providing enhanced flexibility, SIP/TIP credit guidance, technical support, and
funding for innovative and voluntary programs.

AQMWG Priority Level: High

David Solomon, EPA - OAQPS, AQSSD (919)-541-5375, solomon.david@epa.gov
OAQPS Innovations Team (David Cole team lead), (919-541- 5565), cole.david@epa.gov
Tim Smith, EPA-OAQPS, AQSSD, (919)-541-4718, smith.tim@epa.gov
Andy Steckel, EPA-Region 9, (415)-947-4115, steckel.andrew@epa.gov
Alan Powell, EPA- Region 4, (404)-562-9045, powell.alan@epa.gov
Meghan McGuinness, EPA - OAP, CAMD, (202)-343-9133, mcguiness.meghan@epa.gov
Laurel Dygowski, EPA - Region 8, (303)-312-6144, dygowski.laurel@epa.gov
Paul Bubbosh, EPA - OTAQ, TRPD, (202)-343-9322, bubbosh.paul@epa.gov

Approach: In response to this recommendation EPA plans to:

1)	Issue additional enabling policy and guidance on how States and Tribes may gain
SIP/TIP credit for innovative measures, including guidance on:

(A)	SIP credit for voluntary mobile diesel retrofits (OTAQ lead),

(B)	SIP credits for voluntary stationary diesel retrofits (OAQPS lead),

(C)	SIP credit for voluntary woodstove retrofit programs (OAQPS lead), and

(D)	SIP credit for bundled measures (OAQPS lead).

Each lead office, with input from the other Headquarters Offices and the EPA regions,
will be responsible to develop and issue a final guidance document. During the guidance
development process a draft of the guidance will be provided to the states and a select
group of stakeholders for feedback.

2)	Create an interactive Air Innovations web site which will act as a clearinghouse for
information on new technologies, innovative approaches, mentoring resources, and "off-
the-shelf' measures, pilot projects, and quantification techniques. OAQPS will have the
lead in developing the web site and will coordinate its design and contents with the other
Headquarter Offices, Regional Offices and the States.

3)	Develop sector-based guidance that would synthesize and clarify innovative
technological approaches to reducing pollution in the key sectors. The implementation of
this item is covered under the AQM recommendations which target specific sources, for
example recommendation 2.1-2.4 for stationary source categories and 2.5 and 2.6 for
mobile source categories.

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4) Continue to target funding to promote innovation. Specifically, as part of the 2005 Air
Innovations Conference, OAQPS plans to make two $50,000 grants available to State and
local agencies and tribes to support innovative and voluntary approaches to improving air
quality. In addition OAQPS has reserved $295,000 in EPA contract funds to support
innovative projects at Headquarters and the Regional Offices.

Estimated Date for Responding to Recommendation: August 2005 for the listed guidances,
the Air Innovations web site and Air Innovations Conference; May/June 2005 for awarding of
EPA's contract funds for innovative projects; and October 2005 for awarding of the two 50 K
state and local grants.

Final Response Product: (1) Listed guidance documents issued, (2) Air Innovations web site
online, (3) 2005 Air Innovations conference held, (4) two EPA $50,000 State and local grants
awarded to innovative projects and, (5) $295,000 in FY 2005 EPA contract funds awarded to
projects supporting innovation. Final response products (1), (2), (3) and (5) were complete.
Two 50k State and local grants expected to be awarded during the first calendar quarter of 2006.

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3.11 SIP Credits for Bundled Innovative Measures:

Recommendation: EPA should incentivize innovative pollution control strategies by
offering SIP/TIP credit for "bundled" and discounted measures.

AQMWG Priority Level: High

David Solomon, EPA - OAQPS, AQSSD (919)-541-5375, solomon.david@epa.gov
David Cole, EPA - OAQPS, AQSSD, (919-541- 5565), cole.david@epa.gov
Barbara Driscoll, EPA - OAQPS, AQSSD, (919)-541-1051, driscoll.barbara@epa.gov
Rebecca White, EPA - OTAQ, OD, (202)-564-5949, white.rebecca@epa.gov
Marilyn Powers, EPA - Region 3, (215)-814-2308, powers.marilyn@epa.gov
Steve Rosenthal, EPA - Region 5, (312)-886-6052, rosenthal.steven@epa.gov
Andy Steckel, EPA-Region 9, (415)-947-4115, steckel.andrew@epa.gov
Meghan McGuinness, EPA - OAP, CAMD, (202)-343-9133,
mcguiness.meghan@epa. gov

Alan Powell, EPA - Region 4, (404)-562-9045, powell.alan@epa.gov

Approach: In response to this recommendation OAQPS, with assistance from other
workgroup members, will develop and issue a guidance document on how States and
tribes can get SIP/TIP credit upfront for a bundle of small, innovative measures and
evaluate the measures in the aggregate by looking at air quality improvements after
implementation. The guidance will point out that an appropriate discount factor should
be applied to the credit, considering the amount of credit claimed and the level of
uncertainty associated with quantifying the actual air quality benefits of the bundled
measures. During the guidance development process a draft of the guidance will be
provided to the States and a select group of stakeholders for comment.

Estimated Date for Responding to Recommendation: Final product is expected by
August 2005

Final Response Product: Guidance document on SIP credit for bundled measures. Final
response product was completed on schedule. Final guidance on SIP credit for bundled
measures was issued on August 15, 2005.

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3.12 Regional Approaches to SIP Planning:

Recommendation: For many areas, planning for new SIPs or major revisions to existing
SIPs for two or more separate nonattainment areas that are both part of the same regional-
scale air quality problem should be coordinated. If requested by a State, EPA should
work with the different nonattainment areas, Tribes and combinations of multistate
organizations and other stakeholders, as appropriate, to assist in the development of
regional approaches to planning. This could include technical assistance such as
modeling, national or regional control strategies, model SIPs, and model rules as
templates for S/L/T adoption.

AQMWG Priority Level: High

Workgroup Participants:

Bill Beal, EPA/OAQPS, (919) 541-5667, beal.bill@epa.gov

Marcia Spink, EPA/Region 3, (215) 814-2104, spink.marcia@epa.gov

Bill Baker, EPA/Region 2, (212) 637-3733, baker.william@epa.gov

Meghan McGuiness, EPA/HQ, (202) 343-9133, mcguinness.meghan@epa.gov

John Silvasi, EPA/OAQPS, (919) 541-5666, silvasi,iohn@epa.gov

Robin Langdon, EPA/OAQPS, (919) 541-4048, langdon.robin@epa.gov

Todd Hawes, EPA/OAQPS, (919) 541-5591, hawes.todd@epa.gov

Rich Damberg, EPA/OAQPS, (919) 541-5592, damberg.rich@epa.gov

Tad Aburn, Maryland, (410) 537-3245, gaburn@mde.state.md.us

Mike Koerber, LADCO/Midwest RPO, (847) 296-2181, koerber@ladco.org

Brock Nicholson, North Carolina, (919) 715-0587, brock.nicholson@ncmail.net

Sheila Holman, North Carolina, (919) 715-0971, sheila.holman@ncmail.net

Tom Webb, EPA Region 9, (415) 947-4139, webb.thomas@epa.gov

John Hornback, VISTAS, (404) 361-4000, hornback@metro4-sesarm.org

Jerry Stubberfield, EPA/RTP, (919) 541-0876, stubberfield.jerry@epa.gov

Anna Garcia, MANE-VU/OTC, (202) 508-3842, agarcia@otcair.org

Chuck Layman, CENRAP, (405) 378-7377, clavman@censara.org

Bob Gruenig, NTEC/WRAP, (505) 242-2175, bgruenig@ntec.org

Pat Cummins, WRAP, (970) 884-4770, pcummins@westgov.org

Cynthia Stahl, EPA/Region 3, (215) 814-2180, stahl.cynthia@epa.gov

Approach: The group has had several conference calls, most recently on October 25.
Discussion topics have included the development and use of model rules and templates
by Regional Planning Organizations (RPOs) and Multijurisdictional Organizations
(MJOs); the experience of the WRAP (Western Regional Air Partnership) which used
model rules for the states which elected to submit early regional haze SIPs under section
309; the development of regional technical tools and technical support documents; the
OAQPS/EPA grant process; and possible work by the RPOs beyond regional haze.
Tighter budgets also frame this subject so the extent to which RPOs or other regional
efforts can make better use of resources has been discussed.

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The group's next step is to begin drafting discussion of these issues and possible
recommendations. This document will be refined in upcoming calls.

Estimated Date for Responding to Recommendation: December 2005

Final Response Product: Short document and briefing(s).

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3.14 Weight-of-Evidence Demonstrations:

Recommendation: In order to move beyond the current approach of relying on air
quality modeling, EPA, in conjunction with S/L/T and affected stakeholders, should
modify its guidance to promote weight-of-evidence (WOE) demonstrations for both
planning and implementation efforts. In particular, these demonstrations should reduce
reliance on modeling data as the centerpiece for SIP planning, and should increase use of
monitoring data (and analyses of monitoring data) especially for tracking progress.

AQMWG Priority Level: High

Workgroup Participants:

Tyler Fox, Air Quality Modeling, OAQPS (919) 541-5562

James Hemby, Air Quality Data Analysis Group, OAQPS (919) 541-5459

Lula Melton, Emissions Inventory, OAQPS (919) 541-2910

Shao-Hang Chu, Integrated Policies and Strategies, OAQPS (919) 541-5382

Todd Hawes, Integrated Strategies Group, OAPQS (919) 541-5591

Doug Grano Ozone Policies and Strategies Group (919) 541-3292

Approach: In an initial effort to incorporate a WOE approach in planning efforts to
provide the most technically defensible basis for a control plan and to satisfy any
statutory requirement for a demonstration of attainment - EPA (Air Quality Modeling
Group) has released a draft final guidance for 8-hour 03 SIP demonstrations and will
release final version in April 2005 with the 03 implementation rule. This guidance
includes modeling and other technical analyses for state demonstrations. AQMG will
also release a draft final guidance for PM2.5 SIP demonstrations this Spring / Summer
with the upcoming PM2.5 implementation rule.

The Air Quality Modeling Group also plans to develop an integrated guidance document
that will merge 03 and PM2.5/Regional Haze documents and coordinate the development
of a process and mechanism to make air quality modeling available to States for use as
part of their WOE demonstration. This will require coordination across EMAD
especially with AQDAG concerning ambient data analysis for the air quality
characterization part of demonstrations to strengthen States abilities to understand air
quality and the nature of their problem, and coordination with EIG to incorporate the
appropriate emissions inventory guidance and possibly expand sections on emissions
modeling.

EMAD will also assess the current SIP-related guidance we provide across technical
areas of emissions, modeling, monitoring, and ambient data analysis to better understand
how to integrate where appropriate to focus areas on identification and solutions to their
air quality problems (respecting interactions across pollutants, if appropriate) and where
to also account for uncertainty analyses.

Estimated Date for Responding to Recommendation: 2005 - 2006

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Final Product:

Final guidance for 8-hour Ozone SIPs -October 2005

Draft guidance for PM 2.5 / Regional Haze SIP demonstrations - End of year 2005
Final guidance for PM2.5/Regional Haze SIP demonstrations - Spring 2006 (integrated
document with Ozone also)

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3,15 Periodic Assessments to Track Progress:

Recommendation: S/L/T and EPA should conduct periodic assessments to ensure that
areas are on track to meet NAAQS, HAP, and visibility goals, and make mid-course
adjustments, as necessary.

AQMWG Priority Level: High

Workgroup Participants:

James Hemby, Air Quality Data Analysis Group, OAQPS (919) 541-5459
Tyler Fox, Air Quality Modeling, OAQPS (919) 541-5562
Todd Hawes, Integrated Strategies Group, OAPQS (919) 541-5591
Doug Grano Ozone Policies and Strategies Group (919) 541-3292
Tom Rosendahl, Integrated Policies and Strategies, OAQPS (919) 541-5314
Barry Gilbert, Ozone Policy and Strategies, OAQPS, (919) 541- 5238
Dave Sanders, Ozone Policy and Strategies, OAQPS, (919) 541-3356
Gabrielle Stevens, Clean Air Markets Division, OAP, (202) 343-9252

Approach:

In an effort to lay a foundation for a performance oriented approach, and help build a
stronger framework for accountability, EPA is currently assessing the effects of regional
NOx reductions (particularly the NOx SIP call) on ambient ozone levels. This effort will
provide important insights into periodic assessment of program progress. Expansion and
enhancement of the NOx assessment requires planning / discussion, as well as
coordination and collaboration within OAQPS.

Estimated Date for Responding to Recommendation: FY 06

Final Response Product:

NOx Assessment - COMPLETED
Multi-pollutant accountability report - FY06/FY07
Shared products from Recommendation 1.5

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3.16 Evaluation of Averaging, Banking, and Trading in Gasoline Sulfur Program:.

Recommendation: EPA should evaluate the averaging, banking, and trading (ABT)
provisions included in the Tier II gasoline sulfur regulation to see if they are effective.

AQMWG Priority Level: Low.

Workgroup Participants:

Staffed by OTAQ. Coordinated with the Mobile Source Technical Review

Subcommittee.

Lead: John Holley.

Approach: NAS recommended that the effectiveness of ABT provisions for fuel
programs be evaluated. ABT provisions have not been used in fuel programs since the
lead phase-down. The evaluation will be phased to include annual analysis of available
information and a complete report when the program has been fully implemented and
patterns of credit usage are well-established.

Estimated Date for Responding to Recommendation: Some aspects of the evaluation
can be addressed in annual analyses beginning in late 2005. The more complete report on
this effort cannot be developed until late 2007 at the earliest, the first time data on a fully-
implemented program will be available.

EPA has issued a work assignment to a contractor to examine the information that will
become available through reporting data and develop a detailed plan for carrying out this
evaluation using these data and other information that will have to be developed. We are
expecting the contractor to issue a detailed work plan for this effort soon. As the
program matures and patterns of credit generation, trading, and usage become
established, it is possible that the contractor will be asked to carry out some of the
information gathering from sources other than quantitative reporting data in order to
implement the plan. In addition to the contracted effort specific to this evaluation, some
effort by program database administration contractors will be required to carry out
quantitative analyses.

Final Response Product: Report evaluating ABT in the gasoline sulfur program.

Resource Needs to Address Recommendations: The evaluation will require less than
one FTE for each report. Some contractor time will be required to program certain
analyses.

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4.1 SIPs to Address Multipollutant Impacts:

Recommendation: For the SIPs States are required to submit over the next several
years, EPA and S/L/Ts should promote the consideration of multipollutant impacts,
including the impacts of air toxics, and where there is discretion, select regulatory
approaches that maximize benefits from controlling key air toxics, as well as ozone,
PM2.5, and regional haze.

AQMWG Priority Level: High

Work Group Participants:

Amy Vasu, EPA - OAQPS, AQSSD (919) 541-0107, vasu.amy@epa.gov
Barbara Driscoll, EPA - OAQPS, AQSSD, (919) 541-1051, driscoll.barbara@epa.gov
Tim Smith, EPA - OAQPS, AQSSD, (919) 541-4718, smith.tim@epa.gov
Larry Sorrels, EPA - OAQPS, AQSSD, (919) 541-5041, sorrels.larry@epa.gov
Ted Palma, EPA - OAQPS, ESD (919) 541-5470, palma.ted@epa.gov
Brenda Shine, EPA - OAQPS, ESD (919) 541-3608, shine.brenda@epa.gov
Madeleine Strum, EPA - OAQPS, EMAD (919) 541-2383, madeleine.strum@epa.gov
John Silvasi, EPA - OAQPS, AQSSD (919) 541-5666, silvasi,iohn@epa.gov
Doug Grano, EPA - OAQPS, AQSSD (919) 541- 3292, grano.douglas@epa.gov
Yvonne Johnson, EPA - OAQPS, ESD (919) 541 -3921. iohnson.vvonnew@epa.gov
Doug Solomon, EPA - OAQPS, EMAD (919) 541- 4132, solomon.douglas@epa.gov
Norm Possiel, EPA - OAQPS, EMAD (919) 541- 5692, possiel.norm@epa.gov
Doug Aburano, EPA - Region 5, ARD, (312) 353-6960, aburano.douglas@epa.gov
Marypat Tyson, EPA- Region 5, ARD, (312) 886-3006, tvson.marypat@epa.gov
Carl Nash, EPA - Region 5, ARD, (312) 886-6030, nash.carlton@epa.gov
Margaret Sieffert, EPA - Region 5, ARD (312) 353-1151, sieffert.margaret@epa.gov
Jackie Nwia, EPA - Region 5, ARD (312) 886-6081, nwia.iacqueline@epa.gov
Kathryn Sargeant, EPA - OTAQ, ASD (734) 214-4441, sargeant.kathryn@epa.gov
Mark Simons, EPA - OTAQ, TRPD, (734) 214-4420, simons.mark@epa.gov
Meg Patulski, EPA - OTAQ , TRPD (734) 214-4842, patulski.meg@epa.gov
Sikander Khan, EPA - OAP, CAMD, (202) 343-9781, khan.sikander@epa.gov
Jeneva Craig, EPA- OAA, OPAR, (202) 564-1674, craig.ieneva@epa.gov

Approach: The work group evaluated the recommendation and decided, based on the
timing of current SIP development, with most States currently developing their revised
ozone SIPs, to pursue the following actions in the order shown below:

1)	Develop a 3-page summary of information which could be provided to States that
includes:

a) a working definition of "multipollutant control strategy"; b) an initial list of key air
toxic pollutants to consider in developing a multipollutant control strategy; and, c) a
summary description of an approach that an area could use to develop its own list of toxic
air pollutants of concern to consider in control strategy development.

2)	Send a memo to ADDs, with 3-page summary as attachment, with the following
purposes:

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a) request that the ADDs contact the States in their Region and encourage them to start
moving toward a multipollutant approach in developing control strategies for their state
implementation plans (SIPs); b) inform ADDs about current efforts to support the
development of multipollutant control strategies; and, c) ask ADDs for their thoughts,
and those of their States, about the tools/guidance that are needed to support development
of multipollutant control strategies.

3)	Perform a pilot study in Detroit, in coordination with Region 5 and Michigan DEP, to
evaluate multipollutant control strategy development within the ozone and PM2.5 SIPs.

4)	Develop guidance on multipollutant control strategy development.

Estimated Date for Responding to Recommendation: Memo and 3-page attachment
have been developed and were sent to Regional ADDs August 10, 2005. Detroit pilot
study, as well as guidance development, will take place through Fall 2006.

Final Response Product: Draft guidance for developing multipollutant control
strategies. Guidance will be informed by findings from Detroit pilot study. Tools and
resources needed for multipollutant control strategy development will be described and
cited.

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4.2 Multipollutant Benefits and Disbenefits in Standards Setting:

Recommendation: EPA should explicitly outline and quantify multipollutant benefits
and disbenefits when setting emissions standards.

AQMWG Priority Level: High

Workgroup Participants:

Brenda Shine, EPA - OAQPS, ESD, (919) 541-3608, shine.brenda@epa.gov
Tim Smith, EPA - OAQPS, AQSSD, (919) 541-4718, smith.tim@epa.gov

Others, to be determined.

Approach: The response to this recommendation will be an ongoing effort to
systematically include multipollutant analyses in standards setting processes throughout
OAQPS. Besides the obvious benefit of informing our decision-making processes
relative to control strategy recommendations, this explicit consideration will also enable
us to develop more robust emission projections and will therefore inform planning
decisions for future program efforts. In past rulemakings, we have provided some limited
assessment of multipollutant benefits and disbenefits. However, these assessments have
not been comprehensive and have often occurred on an ad-hoc basis. In response to this
recommendation, we propose to develop a protocol for conducting multipollutant
analyses in our standard setting process. This protocol should provide us with a
framework for making consistent decisions and for recording the results of our analyses
for consideration in future efforts.

Final Response Product: Multipollutant Analysis Protocol. Draft for internal EPA
review by end of October 2005. Completion of protocol by December 2005 and updated
as needed.

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5.1 Program Review to Evaluate and Improve Ecosystem Protection:

Recommendation: EPA should, in parallel with recommended scientific and technical
work, begin now to examine current and alternative clean air related policies and
programs to develop approaches that would advance the protection of ecosystems from
the adverse effects of air pollution. Alternatives that should be evaluated include a
regional cap-and-trade program, protection of ecosystems based on critical loads, and a
State-wide planning program for protecting and enhancing air quality in areas that attain
the NAAQS (including National Parks and Wilderness Areas).

AQMWG Priority Level: High

Workgroup Participants:

Lead: Rick Haeuber, EPA - OAR, OAP/CAMD
Rona Birnbaum, EPA - OAR, OAP/CAMD
Kent Helmer, EPA - OAR, OTAQ/ASD
Brian Hill, EPA - ORD, NHEERL/MCED
John R. Kelly, EPA - ORD, NHEERL/MCED
Kathy Kaufman, EPA - OAR, OAQPS/ITPID
Julie McClintock, EPA - OAR, OAQPS/AQSSD
Melissa McCullough, EPA - OAR, OAQPS/ITPID
Steve Paulsen, EPA - ORD, NHEERL/WED
Barbara Roberts, EPA- OAR
Bill Russo, EPA - ORD, NHEERL/RPCS
Tamara Saltman, EPA - OAR, OAP/CAMD
Vicki Sandiford, EPA - OAR, OAQPS/AQSSD
David Schmeltz, EPA - OAR, OAP/CAMD
Randy Waite, EPA - OAR, OAQPS/ESD
Suzanne Young, EPA - OAR, OAP/CAMD

Approach: In response to this recommendation, the workgroup will work with staff
from other agencies (e.g., USGS, US Forest Service, National Park Service), members of
the non-federal scientific research community, and other interested stakeholders to: A)
assess current Clean Air Act authorities to determine their effectiveness and feasibility in
protecting ecosystems from the adverse effects of air pollution; B) review the state of the
science and facilitate development of ecosystem analysis tools for conducting integrated
assessments and policy comparisons; and C) evaluate innovative uses of current
authorities, as well as potential alternative programs, for their ability to enhance
ecosystem protection.

A. Assess Current Programs and Policies for Ecosystem Protection

As an initial step, the working group will undertake a comprehensive review of
ecosystem protection successes and limitations under current Clean Air Act authorities.
This review will provide material for considering innovative uses of current

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policies/programs and potential alternative approaches to advance ecosystem protection
under existing authorities. Policy evaluation will involve understanding the geographic
scope of the sources and receptors of key environmental concerns, examination of the
reliance on monitoring and modeling associated with various Clean Act Authorities,
program integration implications, and other related matters. Specifically, the review of
current programs will examine aspects such as statutory authority and mandates; program
goals, objectives, and details; pollutants controlled, control mechanisms, and
spatial/temporal scale; program monitoring and assessment (interface with Goal 1.5
workgroup); and program needs to enhance ecosystem protection. The review will be
shared with other Federal Agency staff and stakeholders as material to simulate
evaluation of policies and programs to enhance ecosystem protection (see Section C
below).

Current Projects and Products

• Comprehensive review of ecosystem protection successes and limitations under
current authorities - joint workgroup project
o Draft report - March 2006

B. Ecosystem Assessment Tools - review and development for policy evaluation

A state-of-the-science review of ecological assessment tools will support efforts to
evaluate current and alternative policies and programs from an ecosystem protection
perspective. Over the past five years, EPA has worked to enhance its ecosystem
assessment tools through cooperative relationships with academic research groups. These
relationships have supported development of new dynamic ecological process models
(e.g., Pnet-BGC, DayCent-Chem) that may better assess both aquatic and terrestrial
ecosystem response to sulfur and nitrogen emissions/deposition. In evaluating critical
loads for ecosystem protection, for example, ecological process models (e.g., the Steady
State Mass Balance Model, Very Simple Dynamic Model) have been used in the
northeastern U.S., Canada, and Europe to understand ecosystem impacts of pollutant
emissions and deposition. It is important to compare and evaluate a suite of ecological
process models as tools to assess critical loads as a viable ecosystem protection approach
in the U.S., as well as examining other policy/program approaches at broad regional
scales.

Other models, such as TRIM.FaTE and TRIM.Risk, are being developed under the
auspices of the Residual Risk program to assess the fate and transport of emissions and
the ensuing risk to ecosystems. In addition, atmospheric transport and deposition models
(e.g., CMAQ) and a toxics monitoring strategy are also currently underway, which will
eventually supply valuable data and estimates to feed ecosystem models.

Current activities will provide the tools to assess environmental policies and programs in
a comprehensive manner:

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Current Projects and Products

•	EPA-USGS Interagency Agreement - currently supports a project entitled
"Ecological and Biogeochemical Responses to Changing Atmospheric Nitrogen
and Sulfur Deposition in Diverse US Ecosystems: a cross-site modeling
proposal." This effort involves collaboration among scientists at several sites to
project ecosystem and biogeochemical response to changing atmospheric
deposition of S and N compounds using the DayCent-Chem model and other
models. DayCent-Chem has been developed for assessing western ecosystem
response to air pollution. This effort supports further development of DayCent-
Chem as an assessment tool, including its use in developing critical loads and its
application to other regions of the country.

o Science workshop - January 2006
o Deposition scenario model runs - June 2006
o Manuscripts to scientific journals - December 2006

•	EPA-US Forest Service Interagency Agreement - currently supports a model
comparison project that applies major steady-state and dynamic models to
Adirondack Mountain watersheds and compares models as tools for assessing
ecosystem response to emissions/deposition changes and developing critical
loads.

o Model comparison workshop - 2006 (date to be determined)

•	Multi-media Risk Assessment - The TRIM.FaTE module predicts pollutant
concentrations in multiple environmental media and in biota and pollutant intakes
for biota, all of which provide both temporal and spatial exposure estimates for
ecological receptors (i.e., plants and animals). TRIM.Risk, the risk
characterization module, is used to integrate the information on exposure received
from TRIM.FaTE for ecological receptors with that on dose-response or hazard
assessment and to provide quantitative descriptions of risk or hazard and some of
the attendant uncertainties.

o Ecological Risk/Multimedia Workshop - Fall 2005/Winter 2006

C. Assess innovations and alternative policy approaches

EPA has much experience in evaluating current policies and programs in relation to
ecosystem protection concerns, such as its yearly publication of the Acid Rain Progress
Report. EPA also has experience with prospective policy/program analysis, including
assessments of various legislative proposals since the mid 1990s, numerous analyses of
regulatory proposals, and Reports to Congress.

Past policy/program evaluation experience provides a solid foundation for the analyzing
innovative and alternative policies and programs. In previous analyses, policy proposals
were evaluated using an integrated combination of tools — the Integrated Planning Model
provided an emissions inventory, air quality models (REMSAD/CMAQ) provided
regional to national deposition levels, and ecological models (e.g., MAGIC) determined
the projected ecosystem response. As described above, current activities will provide
additional ecological assessment tools for use in future integrated assessments of

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ecological response to changes in sulfur and nitrogen emissions and deposition. In
addition, working group members utilizing the ecological risk and multimedia models
(see multi-media workshop description above) will explore ways to assess ecosystem
effects from air toxics, especially those that are persistent and bioaccumulative.

The working group, in collaboration with other stakeholders, will be responsible for
developing and selecting policy/program approaches to be examined qualitatively and
quantitatively, including integrated assessment. In cooperation with the Goal 1.5
working group, the policy/program approaches also may be examined in terms of
available indicators and monitoring/measurement tools.

To examine whether and how to develop and apply critical loads, in particular, EPA
should recognize and build on current efforts in evaluating critical loads (focusing on
sulfur and nitrogen deposition, and ozone levels) as a tool for designing and evaluating
ecosystem protection policies. The federal land management agencies (e.g., US Forest
Service, National Park Service) have current efforts underway focused on defining
critical deposition loads for Class I areas, particularly in western states. Similarly, a
research group convened under the auspices of the New England Governors-Eastern
Canadian Premiers has undertaken a critical deposition loads analysis for northeastern
North America. EPA can support and augment these efforts:

Current Projects and Products

•	Collaborate with the federal land managers in their critical loads efforts. Both of
the interagency agreements described above include significant collaboration (and
co-funding) with federal land managers from the U.S. Forest Service and National
Park Service. In particular, federal land managers and other stakeholders will be
involved in workshops evaluating the state of the science regarding ecological
process models (dynamic and steady state models) as tools for developing critical
loads at local to regional scales. Subsequent efforts (including workshops) will
apply models to areas of the US where data exist to drive both dynamic and
steady state models.

o Workshops planned under auspices of EPA interagency agreements with
USGS and U.S. Forest Service (see Section B above)

1

•	Inter-agency technical workshop, including academic research community and
stakeholders, to examine technical and scientific issues involved in using critical
loads in the context of policy/program assessment and development.

o Workshop - Spring 2006

•	EPA-US Forest Service Interagency Agreement - to further explore and
understand one approach, EPA currently supports development of a critical loads
map for Maine using both steady-state and dynamic models in support of the New
England Governors-Eastern Canadian Premiers critical loads mapping project

o Draft critical loads map for Maine - January 2006

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Estimated Date for Responding to Recommendation: 2006-2008
Final Response Products:

•	Review of Clean Air Act authorities with ecosystem protection component.

(2006)

•	Refined ecological process models to support ecosystem assessment in all policy
considerations — descriptions of the models and their applications will appear in
peer-reviewed journal articles. (2007-2008)

•	Critical loads mapping and analysis

~	Complete set of critical loads maps (based on S, N deposition) for the
northeastern US (using steady state models) to facility evaluation of their
utility in the US. (June 2006)

~	Critical load estimates for select test sites in regions throughout US using
dynamic models, including sensitive areas in western and northeastern US.
(Winter 2007)

•	Inter-agency critical loads technical workshop. (Spring 2006)

•	Evaluations of dynamic models for use in developing regional critical loads and
characterizing broad regional impacts.(Winter 2007)

•	Integrated assessment reports for alternative approaches identified by working
group and stakeholders. (Fall 2008)

Resource Needs to Address Recommendation: Substantial resources have already
been committed to support air-ecosystem policy assessments and work is proceeding in
many areas. Additional resources are needed to complete any new comparative analyses
and syntheses of analytical policy results. In addition several focused workshops will be
held to provide opportunities for other federal agencies, tribes, states, industry,
environmental groups, and academics to participate.

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