1

 1 U.S. ENVIRONMENTAL PROTECTION AGENCY

 2 CLEAN AIR SCIENTIFIC ADVISORY COMMITTEE (CASAC)

 3 OXIDES OF NITROGEN AND SULFUR OXIDES

 4 SECONDARY REVIEW PANEL

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 6

 7

 8

 9

 10 - - -

 11 TRANSCRIPT OF PUBLIC MEETING

 12 - - -

 13

 14

 15

 16

 17 October 6, 2010

 18 8:30 a.m. - 5:25 p.m.

 19

 20 Marriott at Research Triangle Park

 4700 Guardian Drive

 21 Durham, North Carolina 28803

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 1 CASAC SECONDARY REVIEW PANEL MEMBERS PRESENT:

 2 Dr. Armistead (Ted) Russell

 3 Dr. Anthony Maciorowski

 4 Dr. Praveen Amar

 5 Dr. Charles T. Driscoll, Jr.

 6 Ms. Lauraine Chestnut

 7 Dr. Dale Johnson

 8 Dr. Myron Mitchell

 9 Dr. Andrzej Bytnerowicz

 10 Dr. H. Christopher Frey

 11 Dr. Ellis B. Cowling

 12 Mr. Richard L. Poirot

 13 Dr. Kathleen Weathers

 14 Dr. Rudolf Husar

 15 Dr. Naresh Kumar

 16 SCIENCE ADVISORY BOARD STAFF:

 17 Dr. Angela Nugent, Designated Federal Officer

 18 ENVIRONMENTAL PROTECTION AGENCY STAFF:

 19 Lydia Wegman, Esq.

 20 Dr. Bryan Hubbell

 21 Dr. Richard Scheffe

 22 Dr. Tara Greaver

 23 Karen Martin, Esq.

 24 Dr. Jason Lynch

 25 Mr. Randy Wade

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 1 ENVIRONMENTAL PROTECTION AGENCY STAFF CONTINUED:

 2 Leah Anderson, Esq.

 3 Ms. Ginger Tenet

 4 Mr. Travis Smith

 5 Mr. Adam West

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 1 DR. NUGENT: Good morning, everyone. It's

 2 time to start our meeting. And I am Angela Nugent,

 3 the designated federal officer for the CASAC Oxides

 4 of Nitrogen, Secondary NAAQS Panel. And this is a

 5 public meeting of that panel.

 6 CASAC is an independent federal advisory

 7 committed chartered under the federal authority.

 8 EPA policy require that the meetings of the panel

 9 be open to the public; that they be announced in

 10 the Federal Register; that there be opportunities

 11 for public comment; that deliberations of this

 12 panel happen in open session, where I, as the DFO,

 13 am present. And I am delighted to say we've met

 14 all those requirements for this panel. And we also

 15 have -- have succeeded in helping our members and

 16 having our members help us meet the requirements of

 17 the Federal Ethics in Government Act. So, for the

 18 record, everyone is in compliance with that.

 19 So my responsibilities here at the meeting

 20 involve taking minutes for the meeting. These

 21 minutes will be available to the public within 90

 22 days, with approval of the chair, within 90 days.

 23 And assisting the panel in its deliberations today,

 24 we have four oral commenters who were -- who have

 25 time on the agenda and they'll be introduced this

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 1 morning. We've had written comments provided by

 2 the public that we provided to the members of the

 3 panel.

 4 And I'd like to proceed with the agenda to

 5 introduce first Dr. Anthony Maciorowski for his

 6 welcoming remarks and Dr. Armistead Russell, who

 7 will carry out the agenda.

 8 Before I do that, I'd just like to make a few

 9 housekeeping remarks. We're on teleconference.

 10 There are several people participating by

 11 teleconference and we're always concerned with the

 12 audibility within the room and for people on the

 13 teleconference.

 14 So I think we have very good teleconference

 15 support here, but as the day progresses, I think it

 16 will be more and more important for us to remember

 17 the mikes, because the mikes are what link us to

 18 people listening on the phone, to make an effort to

 19 use those mikes. And then for people who are on

 20 the phone, I ask you please to put your phone on

 21 mute so that we don't capture your ambient noise in

 22 the room in the hotel; and also when you are

 23 speaking to use a handset and not your

 24 speakerphone.

 25 So if anyone has problems with audibility on

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 1 the phone, I ask them to send me an e-mail and I'll

 2 be monitoring e-mails during this teleconference

 3 and we'll see what we can do to improve your, you

 4 know, your ability to hear us in the room.

 5 So with that, I'd like to turn it over to

 6 Dr. Maciorowski.

 7 DR. MACIOROWSKI: Thanks, Angela. I'll be

 8 very brief. The CASAC, as you're aware, it's

 9 iterative. You all have met a number of times. My

 10 major role is to thank you all for participating,

 11 thank Dr. Russell for participating, and recognize

 12 the work of the OEQPS and the other folks that are

 13 in the room. So continue on. Thank you very much.

 14 DR. RUSSELL: Thank you, Tony and Angela. And

 15 first I'd like to welcome Angela as being DFO of

 16 this committee; and thank you, Kendall, I guess in

 17 absentia for getting us here.

 18 With that, also thank you very much to the

 19 panel for all the work they've done in the last I

 20 guess three weeks. And thanks for EPA for all the

 21 work that they did to get us here.

 22 I mean, I thought the amount -- the amount of

 23 revision done to the Policy Assessment was quite

 24 impressive and I still continue to really like the

 25 direction we've been going, though I think the

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 1 discussion here we'll see what more may need to be

 2 accomplished to get us to where we want to be.

 3 And with that, we have a whole agenda, if you

 4 look at it. And what I want to do is I'm going to

 5 pretty much have to ride the curve through some of

 6 it. Because I want to get to the point where we

 7 can have some fairly lively discussion on the

 8 overall thoughts on the documents, where it stands

 9 in terms of being able to advise the administrator

 10 and CASAC and this panel in terms of what -- what

 11 would be the elements of the standard, what we

 12 might choose as level, you know, essentially, as

 13 you go through the components or elements of the

 14 standard, how well informed we think we are.

 15 And I think there is, just by reading the

 16 individual member comments that we've gotten so

 17 far, there is quite a bit of -- there is a range of

 18 comments that I see there. So I think we're going

 19 to need some time to really discuss those and sort

 20 of get a view of what -- where we want to go from

 21 here and what sort of advice we can give EPA.

 22 So that was -- if I start sort of pushing

 23 onwards, don't be surprised. I want to make sure

 24 that we do have time to complete our task at hand.

 25 One other thing is how many people would be

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 1 interested on the panel in going out to dinner as a

 2 group this time? A couple of choices: One would

 3 be barbecue and one would be maybe something else.

 4 I realize barbecue may not be great for

 5 vegetarians. So think about that and at the break

 6 we'll sort of take a poll and decide what to do

 7 from there.

 8 If anyone knows of a great place, you know,

 9 Bullock's is one. I'm not sure if we did that with

 10 this committee or maybe it was another committee.

 11 It's a barbecue place, but I wanted someplace where

 12 we could go, actually, sort of relax, but also be

 13 fairly quick because I think by now you recognize

 14 that I try to give everybody a significant amount

 15 of writing assignments to do such that when we

 16 reconvene tomorrow morning we're fairly far along

 17 in our task and we can deliberate very efficiently

 18 tomorrow.

 19 So that is -- that is the plan. I guess the

 20 next thing, just most of us know each other, but

 21 also to make sure that the folks on the phone know

 22 who is here and just to reintroduce ourselves, I

 23 thought we can go around the table and again

 24 introduce ourselves, where we're from, et cetera,

 25 and end up with EPA and that will be time for EPA

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 1 to start off. Naresh.

 2 DR. KUMAR: Naresh Kumar, EPRI.

 3 DR. HUSAR: Rudolf Husar, Washington

 4 University in St. Louis.

 5 DR. WEATHERS: Kathleen Weathers, Cary

 6 Institute of Ecosystem Studies.

 7 MR. POIROT: Richard Poirot, Vermont

 8 Department of Environmental Conservation.

 9 DR. COWLING: Ellis Cowling, North Carolina

 10 State University.

 11 DR. FREY: Chris Frey, North Carolina State.

 12 DR. AMAR: Praveen Amar with NESCAUM.

 13 DR. DRISCOLL: Charles Driscoll, Syracuse

 14 University.

 15 MS. CHESTNUT: Lauri Chestnut, Stratus

 16 Consulting.

 17 DR. JOHNSON: Dale Johnson, University of

 18 Nevada, Reno.

 19 DR. MITCHELL: Myron Mitchell, SUNY SF,

 20 Syracuse.

 21 DR. BYTNEROWICZ: Andrzej Bytnerowicz, U.S.

 22 Forest Service, Pacific Southwest Research Station

 23 in Riverside, California.

 24 DR. RUSSELL: Thanks. And with that, Lydia,

 25 you want to take over, introduce your gang?

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 1 MS. WEGMAN: Sure. Ted, you didn't want to

 2 check who is on the phone?

 3 DR. RUSSELL: Sorry about that. Are there any

 4 committee members on the phone? Who else is on the

 5 phone?

 6 DR. NUGENT: We weren't expecting any members

 7 to participate by phone.

 8 MS. WEGMAN: Good morning, everyone. Thank

 9 you all very much for being here and for the work

 10 you did. We know we got the document to you a

 11 little later than we had intended to. And we know

 12 there was a lot to read in a short period of time;

 13 and we very much appreciate the effort that you all

 14 made in reviewing it and getting your comments to

 15 us in a timely way. Thank you very much, as

 16 always, for all the work you did. Thank you.

 17 We have a great team here who has been working

 18 on this and many of them will speak to you during

 19 the course of this meeting. The team has been led

 20 by Bryan Hubble, Richard Scheffe, Tara Greaver have

 21 been the main folks working on it. We've also had

 22 help from our Office of Atmospheric Program, Jason

 23 Lynch is in the back, back there. Randy Wade,

 24 Ginger Tenet, Karen Martin, Travis Smith is a new

 25 member of our group, and Adam West have all been

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 1 working on it; and there are several other folks

 2 here listed who are not actually here right now,

 3 but it's been a big team and we very much

 4 appreciate all the work that they have done.

 5 Okay. Let's see, thank you. I wanted to just

 6 remind some folks who may not be as familiar with

 7 the NAAQS process of how the NAAQS review process

 8 does work. Many of you have seen this slide

 9 before, probably most of you, but just to remind

 10 you how it works and where we are within it, we

 11 started out with a kickoff meeting and we developed

 12 an Integrated Review Plan, which leads to the

 13 Integrated Science Assessment, which you review.

 14 You actually also review the Integrated Review

 15 Plan.

 16 We've, of course, completed the Integrated

 17 Science Assessment. We also do Risk and Exposure

 18 Assessment, which you've also reviewed and that is

 19 completed. We are now on the far right at the

 20 Policy Assessment phase; and of course, you have

 21 now reviewed our second draft Policy Assessment.

 22 The next step in moving toward a standard,

 23 this is a court-ordered schedule that we have, is

 24 for us to issue a final Policy Assessment and once

 25 that final Policy Assessment is done, we will move

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 1 forward. We will be briefing our EPA management

 2 and developing a draft proposal which will go

 3 through interagency review and then we will issue

 4 it on the schedule I'll go through in a minute.

 5 That proposal will be out for public comment.

 6 And while it is not common, CASAC is welcome to

 7 provide public comment if it wishes to on the

 8 proposal. And then we will go through agency

 9 briefings, interagency review and issue a final

 10 standard.

 11 So we are a major portion of the way through

 12 this review now that we've reviewed the second

 13 draft Policy Assessment. And we're going to be

 14 moving on from here to the rulemaking phase. We

 15 have very little flexibility in timing because this

 16 is a court-ordered schedule. I think you are

 17 already aware that we have received one extension

 18 from the litigant in this case in part because of

 19 the comments you made earlier on during this review

 20 and we would not anticipate being able to get any

 21 further extensions at this point.

 22 So I just want you to be aware we are all on a

 23 tight time line and that we are now heading toward

 24 completion of the Policy Assessment and the

 25 rulemaking phase.

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 1 So just to go over the schedule and remind you

 2 where we are. So, as I said, we are in the process

 3 of right around the middle here of your review of

 4 the second draft Policy Assessment. We have the

 5 public review meeting today and the CASAC meeting

 6 and we plan to issue the final Policy Assessment

 7 document in December. So we want to give ourselves

 8 enough time to take your comments into account and

 9 to respond to them, but we plan to issue that

 10 document in December.

 11 Then between December and July, we will be

 12 going through the drafting process, first our

 13 agency management, then drafting the proposal, the

 14 interagency review. We've got to get the proposed

 15 rule out for signature by July 12th of next year.

 16 We'll have a 90-day public comment period.

 17 This is, obviously, a new approach to the

 18 secondary standard. We want to allow adequate time

 19 for public comment and then we plan to issue the

 20 final rule March 20th. So it's a very short time

 21 period between the proposed and final rule. So I

 22 just want everyone to be aware of the schedule

 23 we're on and how quickly we are moving forward from

 24 here.

 25 Then I wanted to talk for a moment about the

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 1 elements of the standard. Ted mentioned them, but

 2 just to remind everybody that we do have four

 3 elements to all the standards that we issue. This

 4 is true for both the primary and secondary

 5 standards. The indicator is the element of the

 6 standard that defines the chemical species or

 7 mixture that we measure in determining whether an

 8 area is meeting the standard. The averaging time

 9 defines the period of time over which the indicator

 10 is averaged.

 11 The form defines the air quality statistic

 12 that is to be compared to the level of the

 13 standard. And the level, of course, is the

 14 quantitative number that we offer as the maximum

 15 amount of the air quality statistic that is

 16 permitted under the standard. And these four

 17 elements work together.

 18 And in this case, we have complexities

 19 associated with each of these elements, but they

 20 all work together to determine how protective the

 21 standard will be, the degree of protection we are

 22 providing to the environment in this case or the

 23 public health in the case of the primary standards.

 24 And we appreciate there are complexities to

 25 each element of the standard and that it can be

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 1 challenging to think about how to make them work

 2 together to provide the degree of protection that

 3 is appropriate, but it is to you that we look for

 4 advice on how to think about these elements

 5 together and how we can think about them working

 6 together and determine what is a good range for the

 7 administrator to consider as far as the degree of

 8 protectiveness.

 9 You do not have to give us one number or one

 10 answer for each of these elements. We just need

 11 your advice on what the science can support as far

 12 as a range of standards and a range for each of

 13 these elements. So I don't want you to feel

 14 pressed into giving us specificity that you're not

 15 comfortable with, but we are very much looking for

 16 your advice on the ranges for these things, to the

 17 extent you can provide it to us. And overall this

 18 will determine the level of protection the standard

 19 achieves. And each of these elements of the

 20 standard will be defined by rulemaking when we go

 21 forward with the standard itself.

 22 Before I turn this over to Bryan to walk

 23 through the second draft overview, I want to note

 24 one other thing. This comes up quite frequently.

 25 In setting the standard we do not take into

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 1 account, we are not legally permitted to take into

 2 account cost or the feasibility of meeting the

 3 standard. Our job is to determine what standard is

 4 requisite to protect public welfare from known and

 5 adverse -- adverse effect -- from known and adverse

 6 effects, known and anticipated adverse effects, but

 7 cost and feasibility to implement the standard are

 8 not something that we consider. It's not something

 9 you should be considering either.

 10 So I just wanted to remind folks of that since

 11 that sometimes is lost in dealing with the

 12 complexity of a standard like this. So, again,

 13 thank you all.

 14 DR. RUSSELL: Before we go on, actually, do we

 15 have any questions for Lydia?

 16 MS. WEGMAN: I'm going to sit here for a

 17 minute while Bryan goes through the presentations.

 18 DR. RUSSELL: In terms of any legal issue, she

 19 is our resident lawyer.

 20 MS. WEGMAN: I will note we have someone from

 21 our Office of General Counsel. Leah Anderson is

 22 here to make sure I don't say anything wrong and to

 23 answer more difficult questions.

 24 DR. RUSSELL: Are there any questions from the

 25 panel on this point? I was just wondering how does

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 1 this work tie into the Clean Air Act with Title IV?

 2 You know, do you just want to sort of enlighten us

 3 on that?

 4 MS. WEGMAN: Sure. Title IV is the provisions

 5 that address acid rain. And Title IV contains very

 6 specific requirements and reductions that are

 7 needed. It sets up a, as I think you're all well

 8 aware, a Cap and Trade Program; and it does in

 9 fact, you know, reduce SO2 and NO2 emissions and it

 10 has been a quite successful program.

 11 This is a separate statutory requirement we

 12 have to set a National Ambient Air Quality Standard

 13 to protect public welfare and to set a standard

 14 that is requisite to protect public welfare. It is

 15 setting a level, an averaging time form, as we just

 16 discussed, to protect public welfare.

 17 The Acid Rain Program has made good progress

 18 certainly, but what we are finding is that there

 19 are still areas that are not in fact receiving

 20 protection that is requisite. And the standards

 21 job is to determine what that is. And it may mean

 22 that more will need to be done in order to meet the

 23 standard beyond what the acid rain provisions

 24 provide, as far as reductions in SO2 and NO2, and

 25 the Clean Air Act recognizes that.

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 1 And it's quite clear that the Acid Rain

 2 Program is not meant as a substitute for the

 3 standard for the NAAQS. That, in fact, the NAAQS

 4 continues to apply and even if that means going

 5 beyond what the Acid Rain Program provides.

 6 DR. RUSSELL: Any other questions. Lauri then

 7 Praveen.

 8 MS. CHESTNUT: Could you clarify the

 9 difference between the primary and the secondary

 10 standard in terms of what it -- what it triggers?

 11 I mean, I understand that the goal is to be set or

 12 the standard set without regard to the cost, but --

 13 MS. WEGMAN: Sure. So the primary standard of

 14 course is the health-based standard and there is a

 15 set of provisions. There are a set of provisions

 16 within the Clean Air Act as to what has to be done

 17 for both the primary and the secondary standards.

 18 And basically once we set a standard, it becomes

 19 the obligation of the state to implement the

 20 standard.

 21 And I should have noted that cost and

 22 feasibility are very much able to be taken into

 23 account by the states to develop the implementation

 24 plans that are needed to meet these standards.

 25 Once we set a standard, there is what's called

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 1 designations where areas are determined to meet or

 2 not meet the standard typically based on monitoring

 3 programs that are in place, but sometimes modeling

 4 can be used to help determine that.

 5 Once areas are designated as attainment or

 6 nonattainment there are different requirements that

 7 apply, but states have to develop plans to help

 8 bring areas that are not meeting the standard into

 9 attainment with the standard. There are also

 10 various what are called infrastructure elements of

 11 state plans that have to be submitted to us for

 12 any -- either a primary or secondary standard and

 13 all of these requirements apply.

 14 In the case of the primary standard, the Clean

 15 Air Act has some specific requirements that have to

 16 be met, reasonably available control technology;

 17 reasonably available control measures in the case

 18 of ozone; reductions of 15 percent of VOC, volatile

 19 organic compounds. There is an inspection and

 20 maintenance requirement for ozone. There are a

 21 whole lot of specific requirements related to the

 22 primary standards, particularly for ozone. For the

 23 secondary -- and there are very specific dates laid

 24 out by which the standards must be met.

 25 In the case of secondary standards, there are

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 1 no specific dates. The statute merely says that

 2 the standards must be met as expeditiously as

 3 practicable. And the statute does require the

 4 state to submit implementation plans for the

 5 secondary standards and those standards, just as

 6 primary standards, trigger a new source review

 7 requirements. And the states, you know, do develop

 8 these plans and EPA often issues rules to help

 9 states meet those plans consistent with our

 10 authorities under the Clean Air Act. Does that

 11 help answer your question?

 12 DR. RUSSELL: Praveen.

 13 DR. AMAR: Thank you. A quick question, the

 14 connection between Title IV and what you just said

 15 about the standard setting procedure, and you said

 16 Title IV wasn't providing requisite protection at

 17 this time, but I'm just thinking even if it were,

 18 this process still stands alone on its own?

 19 MS. WEGMAN: It does. And just to be clear, I

 20 mean, Title IV's job was not to provide requisite

 21 protection. Title IV set up the system to reduce

 22 acid rain and put in place caps and allocations and

 23 requirements for sources to meet those caps and

 24 reductions. It was not designed to provide

 25 requisite protection.

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 1 DR. AMAR: But hypothetical, suppose it were,

 2 that Title IV had done --

 3 MS. WEGMAN: You're right. We would still

 4 need to set --

 5 DR. AMAR: We would still be here, right?

 6 MS. WEGMAN: We would absolutely still be here

 7 setting a National Ambient Air Quality Standard.

 8 It's an independent requirement of the law.

 9 DR. RUSSELL: Ellis.

 10 DR. COWLING: Lydia, what are the additional

 11 Title IV requirements that must be -- I mean, the

 12 cap is the obvious one. Are there other provisions

 13 of Title IV that we all ought to have in our minds

 14 as we offer counsel and advice?

 15 MS. WEGMAN: I haven't read Title IV recently

 16 enough. Jason, do you want to speak to that?

 17 DR. LYNCH: Not right now.

 18 MS. WEGMAN: My best recollection is there is

 19 a cap. There are allocations for utilities that

 20 they have to meet to meet the cap. There are

 21 reporting requirements, but it's all designed to

 22 meet the cap in the acid rain provisions.

 23 DR. COWLING: And the continuous submission

 24 monitoring is a part of that?

 25 MS. WEGMAN: Uh-huh. Monitoring provisions,

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 1 monitoring and reporting provisions are part of the

 2 acid rain sections.

 3 DR. COWLING: Do you think we all ought to

 4 reread Title IV?

 5 MS. WEGMAN: You are more than welcome to read

 6 Title IV. It's like the Constitution. It's one of

 7 those things that's good to read every now and

 8 again.

 9 DR. COWLING: Are there -- I mean, if there

 10 are additional things we ought to have in mind as

 11 we --

 12 MS. WEGMAN: To be honest, Ellis, I don't

 13 think you need to read Title IV to do your job here

 14 today. There are separate statutory provisions

 15 related to the National Ambient Air Quality

 16 Standards and those are the provisions that we need

 17 to meet in setting the standard.

 18 My only point here is that there are separate

 19 acid rain provisions. They go down one track and

 20 we have to go the down the track of setting the

 21 ambient air quality standard.

 22 DR. COWLING: We have plenty to do today, as

 23 you said.

 24 DR. RUSSELL: Thank you very much. So, Bryan?

 25 DR. HUBBELL: One thing, just a follow up on

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 1 that, one way to think about it is the Acid Rain

 2 Program was about emissions. It was not about

 3 environment or environmental effects. It's about

 4 emissions. And the standards are about setting a

 5 benchmark for environmental effects.

 6 So moving on to the new Policy Assessment, I

 7 wanted to talk a little bit about the structure to

 8 remind you that while we have the same number of

 9 chapters as we did last time, it's a different

 10 structure. We've moved some of the chapters

 11 around, consolidated others and added a few.

 12 The first four chapters are the same as in the

 13 first draft, covering known or anticipated

 14 ecological effects in Chapter 2; considerations of

 15 adversity to the public welfare in Chapter 3,

 16 adequacy of the current standards in Chapter 4.

 17 Chapter 5 is now the combination of the previous

 18 drafts, Chapters 5 and 6. We consolidated those

 19 and tried to streamline that based on the comments.

 20 I'm not sure we were 100 percent successful, but

 21 we're on our way.

 22 Chapter 6 is now the co-protection chapter.

 23 Chapter 7 is the new chapter in response to your

 24 advice to include a chapter on uncertainty,

 25 variability and sensitivity. Chapter 8 is now an

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 1 ambient air monitoring chapter, which consolidates

 2 a lot of the monitoring discussions from the

 3 previous draft. And then Chapter 9 is again the

 4 concluding chapter.

 5 So overarching changes made in our second

 6 draft in response to your comments, we did try to

 7 improve consistency in the units used throughout

 8 the document; and we did add a definitions table, a

 9 master definitions table to Chapter 1.

 10 Again, there are still a remaining few things

 11 that we need to fix, but we're working towards it.

 12 It's remarkable how many different units are used

 13 in the various different types of studies. So

 14 trying to pull it all together and make sure

 15 everything has been consistent has been a

 16 challenge.

 17 We did combine Chapter 5 and 6 into an

 18 integrated chapter that really talks on the options

 19 for the elements of the standard. It focuses on

 20 aquatic acidification. That's our new synthesis

 21 point in Chapter 5. We added Chapter 7 integrating

 22 discussions of uncertainty and sensitivity

 23 analyses, again, related to how they have

 24 implications for the AAPI form of the standard

 25 rather than just a broad discussion of uncertainty.

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 1 We added Chapter 8 on monitoring issues. We

 2 did try to expand our discussions of the role of

 3 nitrogen deposition and N-limited systems in a

 4 number of places throughout the document. And,

 5 again, we're looking for your reactions to whether

 6 we've adequately covered that.

 7 And we've expanded discussions of the options

 8 for the individual elements of the AAPI form of the

 9 standard in an attempt to try to provide more

 10 specificity in how we're dealing with certain types

 11 of issues like aggregation, spatial aggregation,

 12 such as how we deal with reduced nitrogen and so

 13 forth.

 14 So Chapter 2 the primary differences there,

 15 we've streamlined the chapter somewhat and we

 16 added, per your advice, we added a new table that

 17 summarizes the assumptions and limitations of the

 18 various ecological effects models that we've used

 19 in our review.

 20 In Chapter 3 we have added now a discussion of

 21 decisions regarding protection of aquatic resources

 22 that have been made by communities and NGOs and

 23 states and also by the European Union when they

 24 were considering which critical loads to set for

 25 protection against aquatic acidification across the

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 1 European Union.

 2 We've modified a number of the figures, 3.4

 3 and 3.5 were the original figures that had the

 4 Class I areas and showed NOx and SOx deposition in

 5 Class I areas. Now we've expanded those to focus

 6 in on all the various types of natural resources,

 7 state and local parks and wilderness areas as well

 8 as Class I areas.

 9 We've clarified how economics might factor

 10 into determining adversity. And, as part of that,

 11 we've added an additional assessment, monetized

 12 value of acidification damages in the Adirondacks

 13 using a study by Banzhaf, et al. And, again, this

 14 is an attempt to match economics to looking at the

 15 changes in NOx and SOx that might be expected from

 16 moving from various different levels of ANC

 17 targets. So we've tried to add additional context

 18 by looking at the dollar values.

 19 We've also added a number of tables that

 20 summarize the evidence or information that's

 21 available on the values of ecosystem services that

 22 might be affected by NOx and SOx deposition. And

 23 we've also tried to include a broader context for

 24 ecosystem service values and, again, descriptions

 25 of the damages that might be due to NOx and SOx

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 1 specifically where we're able to do so. Again,

 2 there was still quite a bit of limitations of

 3 what's actually available, but we tried to

 4 summarize what was there better.

 5 Chapter 4 the primary things we did here was

 6 move things around. We've moved the assessment of

 7 the CMAQ performance discussion to Chapter 7 on

 8 uncertainty. We've moved the monitoring -- a lot

 9 of the monitoring discussions to Chapter 8. We

 10 have added some additional plots per your

 11 recommendations looking at sulfur and some

 12 additional nitrogen plots, comparing NOy and total

 13 nitrogen, for example. And we've added a

 14 discussion regarding nutrient enrichment effects in

 15 both managed and non-managed systems. Again, this

 16 is an attempt to try to more carefully discuss the

 17 nitrogen role.

 18 Chapter 5 is probably the -- it is the largest

 19 chapter in the document and the most complex and

 20 where we spent most of our effort. We did combine,

 21 again, Chapters 5 and 6 into this second draft

 22 Chapter 5. It now includes options for the

 23 atmospheric indicator, the averaging time, the

 24 form, and levels of components of the form; for

 25 example, the discussion of target ANC values and

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 1 looking at percentage of ecosystems to be covered.

 2 The focus of the chapter has now been really

 3 refined to focus almost entirely on aquatic

 4 acidification, with understanding the co-protection

 5 of other effects as presented in Chapter 6. We

 6 really have reduced our discussions of attempting

 7 to try to think through terrestrial acidification

 8 in this round of the standards.

 9 Our new content includes a more complete

 10 conceptual diagram outlining each step to develop

 11 the tradeoff curves and the AAPI. There is a large

 12 reliance now on critical load modeling, which,

 13 again, we're looking for your input on. We have a

 14 section that compares critical loads calculated

 15 using steady state versus dynamic modeling. We

 16 have a section that compares the SSWC-based

 17 critical loads using two different approaches for

 18 calculating the preindustrial base cation

 19 weathering. That's the F-factor versus direct

 20 MAGIC derived base cation weathering rates.

 21 We've expanded the critical loads dataset that

 22 we have. It now includes over 7,500 sites. And

 23 we've worked to try to develop some methods to

 24 exclude catchments in which acidification has

 25 resulted from either high organic acid content,

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 1 acid mine drainage or naturally low base cation

 2 weathering. And this is a test, again, to focus on

 3 those areas sensitive to acid deposition and also

 4 responsive or likely to be responsive to reductions

 5 or decreases in NOx and SOx concentrations.

 6 In addition, we've included a number of

 7 options for spatial aggregation of components of

 8 NOy and SOx to be able to develop a tradeoff curve

 9 in AAPI equations in a regionally aggregated way.

 10 I will say that we spent a lot of time on

 11 developing these types of options and options that

 12 we're going to talk about today are one subset of a

 13 much larger set that we've considered. Tara has

 14 got some additional information about why we ended

 15 up going in the directions we have gone. You know,

 16 this is probably the most challenging aspect of

 17 what we've been working on is how do you develop

 18 something that is nationally representative in

 19 scope to be a national standard, but allows for

 20 this understanding of the differences in

 21 sensitivity to different waterbodies.

 22 So we recognize that this is in some ways a

 23 very subjective part of the analysis, but it's also

 24 one we've tried to develop using the best available

 25 information that we had. So we understand the

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 1 challenges in trying to review this. We had a lot

 2 of challenges in developing it. We need

 3 conversation as to either are we on the right

 4 direction or do we need to continue to go back and

 5 look at this more?

 6 Some of the major options that we looked at

 7 were starting with a sort of strawman was to be

 8 able to just say, okay, what if we chose one

 9 standard for the whole country? We talked about

 10 that. That was, well, a strawman.

 11 We then said, well, is there something we can

 12 do that's better than that without getting too

 13 complex? And so we tried to divide the U.S. into

 14 acid-sensitive categories and then spatially

 15 aggregate population of critical loads. And that's

 16 the basis for selecting the targets that we worked

 17 with. Coming up with ways to spatially average the

 18 nitrogen uptake and retention term; and to be able

 19 to spatially and temporally average the reduced

 20 nitrogen terms because, again, all these have to

 21 match to form the standard.

 22 The notorious G-dot term, which no one really

 23 liked, has been removed from the first draft and

 24 has been disaggregated so that each component is

 25 represented in the AAPI equation separately for

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 1 clarity and completeness. And we also have new

 2 sections that are now covering the components of

 3 the AAPI equation, including specifically a

 4 discussion of justification for looking at various

 5 target levels of ANC; and also a section, which was

 6 mostly sent to you under separate cover, hopefully

 7 everybody received that additional set of

 8 materials, that was looking at the implications of

 9 selecting different percentages of waterbodies that

 10 we might identify to reach the target ANC levels.

 11 So hopefully everyone got that additional piece of

 12 information.

 13 Chapter 6, again, this is the chapter looking

 14 at co-protection for other effects if you have a

 15 standard that focuses on aquatic acidification.

 16 The main addition in this chapter was adding

 17 discussions of impacts of the aquatic acidification

 18 on nutrient enrichment for terrestrial nutrient

 19 enrichment and aquatic nutrient enrichment and we

 20 continued to have the section that talked about

 21 terrestrial acidification as well.

 22 Chapter 7 this is the new chapter you

 23 requested, which we agreed was a major improvement

 24 to pull all the uncertainty information together.

 25 We have sections that are focused on the major

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 1 areas of the standard, including the discussions of

 2 ecosystem effects, ecosystem services and benefits,

 3 CMAQ modeling, the different components of AAPI and

 4 the critical load and ANC modeling.

 5 Our focus is how uncertainty and variability

 6 might impact the standards. That was our intent in

 7 trying to focus that way. We did provide, again,

 8 under separate cover, we provided a summary table

 9 of key uncertainty elements to try to put them all

 10 into a readily accessible and comparable format.

 11 The basic conclusion that we generally feel

 12 that we have high confidence in the major

 13 components of the effects to indicators linkages,

 14 that's that overall diagram. However, there are

 15 relatively larger uncertainties in certain

 16 subcomponents that are related to where we have

 17 observational gaps. For example, we have no

 18 measurements of dry deposition. We have less

 19 information on base cation weathering rates and a

 20 number of other factors, including reduced

 21 nitrogen.

 22 So we recognize that some of those components

 23 are still highly uncertain. We need to either be

 24 able to improve the characterization through

 25 additional monitoring and other information as we

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 1 go through time, but we also need to continue doing

 2 evaluations for some of the modeling components

 3 that we're planning to do.

 4 Chapter 8 is an attempt to try to introduce

 5 important concepts related to ambient air

 6 monitoring. Again, we consolidated discussions

 7 from the first draft, Chapters 4, 5 and 6. This

 8 includes now discussions of the ambient air quality

 9 indicators; discussions of reactive nitrogen and

 10 sulfur species; measurements that are related to

 11 the AAPI form of the standard; complementary

 12 measurements, for example, measurements of reduced

 13 nitrogen; sampling frequency issues; and a

 14 discussion of monitoring methods, recognizing that

 15 there is going to be a separate AAMS meeting to be

 16 held in early 2011, which is a group that looks at

 17 monitoring issues for CASAC. So that will be a

 18 separate meeting that we're hoping to get scheduled

 19 sometime in January or February.

 20 And, finally, Chapter 9 is our initial

 21 conclusions. Again, this was expanded from the

 22 previous draft to try to include a discussion of

 23 staff conclusions regarding options for elements of

 24 the standard. This includes discussions of the

 25 indicators; the averaging times; the form; and

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 1 considerations that are relevant to selecting the

 2 levels and the overall options of the standards.

 3 We also added a table, again, sent under

 4 separate cover that summarizes those options, tries

 5 to talk about them relative to the issues of

 6 spatial aggregation and temporal aggregation. We

 7 have also included some discussion of how critical

 8 uncertainties might influence the AAPI.

 9 And this notes, and I'm hoping that we can

 10 clarify this and make sure that everyone

 11 understands, the differences between the target ANC

 12 and what the AAPI level would be. And, again, this

 13 is trying to highlight the importance of

 14 considering uncertainty and other factors, such as,

 15 for example, the times of recovery and those types

 16 of factors in determining the overall options for

 17 the standards; as opposed to the target ANC, which

 18 is one specific element that is used to inform a

 19 level of the standards.

 20 And, again, we need advice on all of the

 21 elements of the standard, including ranges of

 22 levels and combinations of elements of the

 23 standards, which is understandably a very difficult

 24 task. But, again, as Lydia said, what we're not

 25 necessarily looking for is specific values or

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 1 specific this is the right answer.

 2 What we're looking for is the ability to

 3 provide the Administrator with a reasonable range

 4 of options for her to make an informed judgment

 5 based on it. And that's what we're looking to you

 6 for is to help us develop those reasonable ranges

 7 for the various different elements of the standard

 8 and also for combinations and options for the

 9 overall form of the standard.

 10 That's it. Thank you.

 11 DR. RUSSELL: Thanks, Bryan. Questions from

 12 the panel for EPA at this point? Praveen.

 13 DR. AMAR: Thank you. You mentioned the AAMS

 14 meeting. What's the connection between that

 15 meeting and our work here?

 16 DR. HUBBELL: Rich?

 17 DR. SCHEFFE: It's the subcommittee of CASAC.

 18 And it's a specific committee to deal with

 19 monitoring issues that arise from a lot of the

 20 NAAQS reviews. And the first -- one of the first

 21 scheduled meetings for the upcoming calendar year

 22 is to discuss the monitoring issues that arise from

 23 this review. In other words, the issues that are

 24 laid out in Chapter 8 in terms of moving towards

 25 federal reference certification for NOy,

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 1 particularly sulfate and so forth. That will be

 2 discussed more in depth and we'll get an

 3 opportunity to get advice from experts in the

 4 measurement community to support, you know, the

 5 following rule development.

 6 DR. AMAR: I think I understand it, but I'm

 7 trying to figure out the connection of our output

 8 and their output and how they will be --

 9 DR. SCHEFFE: Ted could probably answer that.

 10 There is some overlap in certain committees. Ted

 11 is certainly on that committee, Rich Poirot. So

 12 you'll have overlap in that regard between the two

 13 committees.

 14 MS. WEGMAN: I think, Rich, the AAMS provides

 15 more technical advice, as Rich was saying, on the

 16 subject for the federal reference method; and we'll

 17 be folding that advice into the development of the

 18 proposal. That's why we're hoping to have the

 19 meeting in January or February because whatever

 20 advice we get from them we do want to take into

 21 account in the proposal.

 22 DR. HUBBELL: For example, what we're looking

 23 from you is, all right, if you comment that you

 24 believe the ambient indicators that we've

 25 identified are appropriate, then that information

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 1 can go to the AAMS and they can help us determine

 2 what the FNR methods might be appropriate to

 3 actually develop measurements for those particular

 4 indicators.

 5 DR. RUSSELL: Rich.

 6 MR. POIROT: Bryan, could you give me some

 7 sense of how the attainment/nonattainment test

 8 would work, the metrics by which an AQCR or a

 9 county would be determined to be in the attainment

 10 and how would we get out of non -- you know, what

 11 is actually the test?

 12 DR. HUBBELL: Well, the test in this case,

 13 this is, again -- the test is not the measure of

 14 the ANC. The test is to use the equation, the AAPI

 15 form and to plug in measured concentrations of NOy

 16 and SO2 plus SO4, and to plug those into the

 17 equation given the parameters that we specify as

 18 part of the rulemaking or the methods we specify,

 19 plug those in and then compare them against the

 20 level of the standard, which would be the level of

 21 the AAPI that we determine to be protective.

 22 So, for example, if we chose an AAPI level of

 23 50 just to say, you would take the levels of NOy

 24 and SOx in an appropriately monitored area, put

 25 them into the equation that's appropriate for that

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 1 area, and you would then calculate a value that

 2 would be compared against that level of the AAPI

 3 standard.

 4 MR. POIROT: So the degree or severity of

 5 nonattainment would be the extent to which that

 6 sort of combines SOx, NOx, exceeds the AAPI.

 7 DR. HUBBELL: That's right.

 8 MR. POIROT: It wouldn't be 11 percent of the

 9 links.

 10 DR. HUBBELL: No.

 11 MR. POIROT: That has nothing to do with it.

 12 DR. HUBBELL: No, that has nothing to do with

 13 it. The way that our system works here is that,

 14 again, that percentile, the percentage of the lakes

 15 that you're trying to protect, that goes into

 16 determining the NOx and SOx levels, NOy and SOx

 17 levels that need to be met over an area.

 18 Okay. That's why when we say it is still a

 19 national center, it's not focused on 11 percent of

 20 particular lakes in the area. It's saying for this

 21 region that we've set up these parameters for,

 22 given the NOx and SOx levels that you measure, are

 23 you getting to the critical load, essentially when

 24 you map it through the deposition, are you getting

 25 to the critical load that will protect 90 percent

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 1 or 85 percent of the lakes?

 2 So the determination of what percentile of

 3 lakes to protect is an up-front characterization of

 4 what your target critical load is going to be. So

 5 the two pieces that determine your critical load

 6 for a particular area that then gets translated

 7 into an atmospheric concentration are the

 8 percentile protection and the target ANC.

 9 Those two things together, along with other

 10 characteristics of your ecosystem area, those two

 11 things together determine what the critical load

 12 is. And that determines what your NOy and SOx and

 13 concentrations will be in the atmosphere. That's

 14 what those tradeoff curves are trying to get at.

 15 In fact, the tradeoff curves, again, are another

 16 way of expressing whether or not you attain the

 17 standard. If you actually plot your observed NOy

 18 and SOx levels on that tradeoff curve, if you're

 19 above the tradeoff curve, then you're out of

 20 attainment; if you're below, you're in the

 21 attainment.

 22 MR. POIROT: So each AQCR has its own tradeoff

 23 curve?

 24 DR. HUBBELL: That's right. That's right.

 25 MR. POIROT: Thank you.

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 1 DR. RUSSELL: Other questions? I'll ask, but

 2 there is just one tradeoff curve for each AQCR,

 3 right?

 4 DR. HUBBELL: That's correct. And it will be

 5 based on their estimate of reduced nitrogen that we

 6 determine for them or that is determined through

 7 their -- you know, we lay out a couple options of

 8 ways of thinking through that. We're still working

 9 through options for how to deal with reduced

 10 nitrogen. It's based on their reduced nitrogen

 11 characterization. And it's based on the critical

 12 loads that have been calculated for that overall

 13 region which they -- in which they rely.

 14 DR. RUSSELL: Any other questions?

 15 DR. AMAR: But, to be clear, you haven't

 16 defined AQCR in this report, have you?

 17 DR. HUBBELL: No. And Lydia can correct me if

 18 I'm wrong, we don't need to consider necessarily

 19 how the nonattainment area will look at this point.

 20 It's really something that can be determined

 21 through the implementation process.

 22 MS. WEGMAN: Yeah. That will be worked out as

 23 we start thinking about -- assuming we get the

 24 standards set, thinking about designations and how

 25 to define the appropriate size of the area which

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 1 should be designated nonattainment.

 2 DR. RUSSELL: And just like now those areas

 3 can go across state boundaries and everything.

 4 MS. WEGMAN: Yes. We do have areas now.

 5 DR. HUBBELL: In the case obviously when you

 6 look at our maps, the focus of the maps is not

 7 state boundaries or geopolitical boundaries because

 8 we're not talking about human populations. The

 9 focus is on ecosystems, which clearly cross a

 10 number of boundaries.

 11 MR. POIROT: Well, I guess we'll come to this

 12 discussion later, but this is kind of the question

 13 period. So understanding the implication of these

 14 various different ways that you have of picking

 15 percentages of waterbodies to be protected was very

 16 difficult for me to grasp. And, in addition, it

 17 seems like it's inherently and unavoidably a

 18 somewhat arbitrary kind of a process.

 19 I guess I was wondering since in effect what

 20 we're trying to do is create this quasi-artificial

 21 ANC, which ironically is something we could just go

 22 to the lake and measure, is there a way that that

 23 kind of a test could actually be applied sort of

 24 retrospectively? Let's say we pick a particular

 25 scheme of, you know, grouping in the lakes and

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 1 ecoregions together and so forth and come up with

 2 an answer that ends up putting an area out of

 3 attainment, could the state then go back and

 4 measure the ANC in the lakes and say, wait a

 5 minute, we got it wrong, actually, the real

 6 distribution is different than that that was

 7 projected by the approach that we used?

 8 I'm just wondering if there is a way to

 9 interject some reality on the ground or in the

 10 lakes in a way to make this arbitrary decision

 11 somewhat less critical than it would otherwise need

 12 to be?

 13 DR. HUBBELL: The standards are in our

 14 five-year review cycle. And obviously as new

 15 information becomes available between reviews that

 16 information gets included in the next review. So

 17 when we set our standards now, it's based on the

 18 currently available information and the best

 19 science available at that time.

 20 So while it is true that states can go out and

 21 measure and say, well, something is not right here,

 22 that can then be introduced in the next review

 23 cycle, five-year review cycle, which given we're

 24 talking about standards that are averaged over

 25 three to five years, it's a very reasonable interim

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 1 guide post to set, you know.

 2 The other thing to recognize is that one of

 3 the reasons why it wouldn't be appropriate to just

 4 say let's go out and measure ANC is that there are

 5 other factors that are changing that can affect ANC

 6 as well. What we're trying to do, in fact the way

 7 we've set up the forum, is to isolate, to

 8 understand how changes in NOx and SOx might affect

 9 or are anticipated to affect ANC levels. But

 10 because we can't control everything else, it would

 11 be inappropriate to just measure ANC because it's

 12 not the thing that we're truly targeting. We're

 13 truly targeting NOx and SOx concentrations to try

 14 to reduce or degrees -- I mean to increase the ANC

 15 levels.

 16 DR. SCHEFFE: One other thing too, Rich, that

 17 would be a great scenario if you could go out and

 18 measure ANC and you actually saw that you had a

 19 high level of ANC. That would be a great scenario,

 20 but in all likelihood you probably would have the

 21 other scenario where because the response time, the

 22 lag time in the system that you may be actually

 23 reducing your air quality, but the lag time is

 24 going to be so great to actually show a beneficial

 25 ANC result in the water too. So you have that

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 1 consideration as well.

 2 DR. HUBBELL: Within one to two years,

 3 obviously, as you go further through time, you'd be

 4 able to see this response. That's always been one

 5 of the problems with trying to look at ecosystem

 6 impacts in a direct way is that there is this lag

 7 time. And, again, what -- you know, by using the

 8 models and by using information we have, we can

 9 judge and say, well, based on our best information

 10 we expect that change in NOx and SOx will

 11 ultimately get us to our target critical load and

 12 our target ANC level.

 13 DR. RUSSELL: And last question, Dale, because

 14 then we'll have to go to a public comment, but

 15 we'll have a chance to ask questions later.

 16 DR. JOHNSON: As lag time, what is the

 17 mechanism for the lag time? Is the lag time in the

 18 actual emissions; is it a lag time in the soil

 19 recovery?

 20 DR. SCHEFFE: It's mostly a lag time in the

 21 biogeochemical system, you know, throughout the

 22 soils in the system.

 23 DR. HUBBELL: Soils are certainly one of the

 24 reasons --

 25 DR. JOHNSON: Well, I think that's an issue

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 1 because I think when soils acidify in these acidic

 2 environments --

 3 DR. RUSSELL: And, Dale, get closer to your

 4 mike if you could.

 5 DR. JOHNSON: Sorry. I think when soils

 6 acidify, either naturally or because of pollution,

 7 they don't deacidify. They are not going to come

 8 back unless you lime them. So this entire effect

 9 of bringing up this capacity intensity thing would

 10 really stop development. And so your lag time in

 11 that case where you have interlacid (phonetic)

 12 anions in an already acid soil, there is -- very

 13 short, there is no lag time, minutes. I don't

 14 think that's quite getting through.

 15 DR. HUBBELL: Jason, do you have a response to

 16 that?

 17 DR. LYNCH: Dale, I mean, I don't disagree

 18 with you in terms of your comment. If you take a

 19 case study and you model the response back and what

 20 you can find in many systems is that once you bring

 21 down the influx of acid anions, the soils that

 22 we're losing say base cations off of an

 23 exchangeable site, we'll begin to reacquire those

 24 over time. And then you can then have in a sense a

 25 lag between the benefit or reducing acid anion and

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 1 what actually results within the surface water

 2 condition.

 3 DR. JOHNSON: I'm not quite sure I follow.

 4 You're saying the base saturation will increase?

 5 DR. LYNCH: The base saturation, yeah, you

 6 know --

 7 DR. JOHNSON: Why would it? Maybe this is too

 8 technical for this particular point, but I don't

 9 see why it would.

 10 DR. LYNCH: In terms of improvement. I know

 11 when we look at and use some of the models to do it

 12 you begin to improve those conditions for sure.

 13 So, I mean, I'm happy to talk in more detail in

 14 terms of --

 15 DR. JOHNSON: Models may say that, but I don't

 16 think that's ever been seen in reality.

 17 DR. LYNCH: Okay.

 18 DR. RUSSELL: Okay. And I recognize there may

 19 be more questions, but it's 9:20 and just because

 20 we have people on the line who are expecting to go

 21 at about this time, we will scooch over to public

 22 comment. And the order is?

 23 DR. NUGENT: The first public speaker is

 24 Dr. Eladio Knipping from EPRI, and he has materials

 25 that are just being distributed to you now. I just

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 1 received before our meeting.

 2 DR. RUSSELL: And I'll be keeping time. So

 3 when the time comes, I'll start waving and cutting

 4 you off.

 5 DR. KNIPPING: Good morning, I'm Dr. Eladio

 6 Knipping. I'm in environment sector of the

 7 Electric Power Research Institute. EPRI is an

 8 independent nonprofit organization that conducts

 9 research relating to the generation, delivery and

 10 use of electricity for the benefit of the public.

 11 As the emphasis of the PAD is on the

 12 protection of sensitive surface waters, my comments

 13 today are focused on the science underlying the

 14 Atmospheric Acidification Potential Index and the

 15 result of an uncertainty analysis showing the

 16 impact on SOx and NOx concentrations required to

 17 show attainment.

 18 The primary concern is that the uncertainty

 19 associated with EPA's approach to estimating

 20 critical loads and mapping those to atmospheric

 21 concentrations is so large that its use in defining

 22 the requisite level of the standard is

 23 questionable. EPA cites this uncertainty as very

 24 small. Our computations show otherwise.

 25 Some of the key points contained in our

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 1 comments are as follows: Determination of the

 2 critical deposition load is highly dependent upon

 3 historical values of pre-industrial base cation

 4 concentration in 1850 through 1860. Those values

 5 were never measured. EPA proposes to estimate

 6 those values using hindcasting with the MAGIC model

 7 or using an F-factor approach. The latter method

 8 was developed for Scandinavian countries that have

 9 much less diverse bedrock and soils than in the

 10 United States.

 11 Testing of the MAGIC model going forward in

 12 time raises doubts about its ability to simulate

 13 from far back in the past. The EPA should consider

 14 that both deposition and surface water data are

 15 available for the last 20 to 30 years, a period

 16 with decreasing SOx and NOx deposition. This

 17 period must be simulated accurately to gain

 18 confidence in the models. Only then can one move

 19 forward in time with the models to develop approach

 20 for evaluating sensitivities to deposition rather

 21 than try to hindcast conditions from over 150 years

 22 ago that were not measured.

 23 Cation exchange is missing completely from the

 24 processes leading to the AAPI equation. Moreover,

 25 surface water pH is largely determined by the

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 1 fraction of precipitation that flows laterally

 2 through deeper soil horizons and cation exchange in

 3 these soils.

 4 In the Adirondacks, surface water sulfate

 5 concentrations have decreased with decreasing SOX

 6 deposition. Surface water nitrate concentrations

 7 have also decreased though to a lesser degree.

 8 Note the ANC increased only slightly. This is

 9 because the base cation concentration being largely

 10 induced by the strong acids also decreased. Thus

 11 the predicted increase in ANC by the MAGIC model

 12 did not materialize.

 13 Base cation weathering inputs play a critical

 14 role in SSWC applications, but are likely to be

 15 highly uncertain due to the use of hindcasting and

 16 the underconstrained nature of the weathering

 17 formulations used in the MAGIC model.

 18 VSOx and VNOy are atmospheric transfer

 19 functions calculated from model simulations. The

 20 atmospheric model and the model configuration, such

 21 as grid resolution can make a large difference in

 22 the calculated VSOx and VNOy parameters.

 23 With respect to the difference of atmospheric

 24 model there is a large difference between CMAQ and

 25 CAMAX. I would remind everyone that CAMAX is the

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 1 model that EPA OAQPS has used in developing the

 2 currently proposed transport rule. This introduces

 3 uncertainty and the definition of a secondary NAAQS

 4 using EPA's approach.

 5 A full discussion on these topics and other

 6 concerns are described in our full comments and

 7 will be covered in the forthcoming report to be

 8 submitted before the filing deadline.

 9 At this moment I would like to illustrate the

 10 combined impact of all these issues on the levels

 11 of a proposed standard.

 12 We have conducted uncertainty analysis using

 13 EPA's equations and models by applying the Monte

 14 Carlo technique as well as other methods with the

 15 combination of our and EPA's estimates of

 16 uncertainty in the individual terms for an example

 17 in the Adirondacks. Note that the values plotted

 18 are within 1.5 standard deviations from the mode of

 19 the probability distribution, representing an

 20 87 percent confidence interval.

 21 These results do not include the LNHx term and

 22 its associated uncertainties. The results are for

 23 a single lake. Multiple lakes results and results

 24 in other regions with less available data will have

 25 wider variance and confidence limits.

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 1 By the way, I did not include the uncertainty

 2 in the LNHx term because this distribution would

 3 become so wide that it would require more than the

 4 time I have allotted to actually walk you through

 5 the steps so that you can see why that distribution

 6 becomes so much wider.

 7 In every case we found large overall

 8 uncertainties that compromised practical usefulness

 9 of the equations and models in helping define the

 10 requisite level of any standard.

 11 In the proposed approach, whatever standard is

 12 established will be based on highly uncertain

 13 methods, including under-constrained estimates of

 14 preindustrial conditions. However, the best

 15 available information regarding how surface waters

 16 will respond to changes in acidity deposition is

 17 the change measured in response to decreased

 18 deposition over the past two decades.

 19 Only mechanistic models that can accurately

 20 represent this observed response can build

 21 confidence in the ability to predict responses to

 22 future changes in deposition. Establishment of a

 23 standard requires a technically rigorous basis and

 24 must not ignore high-quality research regarding the

 25 response of surface waters to changes in

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 1 deposition.

 2 I'd be happy to explain this more in detail if

 3 you folks would like.

 4 DR. RUSSELL: Thank you. Any questions for

 5 Eladio at this time? Chris.

 6 DR. FREY: The question on the inputs for this

 7 analysis, are the distributions of variability or

 8 uncertainty use based on three-year or five-year

 9 averages?

 10 DR. KNIPPING: That is covered in the report.

 11 Right now I don't have that information with me,

 12 but these are -- I will note that these

 13 uncertainties are within the parameters that EPA

 14 used in its own uncertainty analysis.

 15 So we're not making it any broader. We're

 16 using parameters that are within EPA's uncertainty

 17 analysis. And, again, this does not cover the LNHx

 18 term. That would make this distribution so broad

 19 that I would really want to have more time to

 20 explain how each individual parameter affects the

 21 distribution.

 22 DR. RUSSELL: Praveen.

 23 DR. AMAR: I'm in the last statement you made

 24 about not ignoring high-quality research. I know

 25 you said lots of things. What do you have in mind

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 1 there, or maybe you already mentioned it?

 2 DR. KNIPPING: It's all in the full report

 3 comments. I think that we need to look at the

 4 variability of the air quality models. We need to

 5 include information regarding ecosystems impacts.

 6 There was mention of lag time, but we also need to

 7 consider cation exchange and how that affects the

 8 response of ecosystems to changes in deposition. I

 9 think that these things have not been addressed

 10 with the level of rigor that I believe is necessary

 11 to inform the process.

 12 DR. AMAR: Are there certain publications or

 13 reports or otherwise that you want us to look at?

 14 DR. KNIPPING: Right now you have a report

 15 that summarizes all that information, including

 16 citations and the results of the current analysis

 17 that we are performing.

 18 DR. RUSSELL: And by that report it's the one

 19 that's seen right here?

 20 DR. KNIPPING: These are -- this is a

 21 preliminary version of our full report. Our full

 22 report will be submitted before the November 12th

 23 deadline.

 24 DR. RUSSELL: Thank you. Aaron Flynn. Aaron.

 25 MR. FLYNN: Good morning. My name is Aaron

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 1 Flynn. I'm an attorney with Hunton & Williams. I

 2 represent the Utility Air Regulatory Group or UR.

 3 We have a significant number of concerns with the

 4 procedural, legal, scientific and policy choices

 5 that EPA appears to be pursuing based on the

 6 information contained in the current draft of the

 7 Policy Assessment Document.

 8 And I will only address a few of those

 9 concerns in the comments here. The regulatory

 10 comments that EPA is considering during this review

 11 represent significant departures from established

 12 practices under the NAAQS program; and accordingly

 13 it is essential that the agency provide the public

 14 with adequate time to review and comment on the

 15 various draft documents that will inform this

 16 review of the secondary NAAQS for NOx and SOx.

 17 The secondary Draft Policy Assessment was made

 18 available only 19 days before this meeting and

 19 additional significant material was released on

 20 September 23rd. This has prevented UR from fully

 21 developing comments for presentation to CASAC and

 22 we hope the panel has had more time to work with

 23 the document than we have, but we anticipate

 24 submitting more extensive comments to EPA by

 25 November 12th, the deadline for comments to the

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 1 agency.

 2 At each stage of this review EPA has

 3 introduced new concepts fleshing out some of the

 4 policy positions under development as part of this

 5 review. Even at this relatively late stage of the

 6 NAAQS review process, however, there remain

 7 significant issues that have not been addressed in

 8 the second draft of the Policy Assessment.

 9 The document itself notes that a number of

 10 additional analyses and policies issues will likely

 11 be included in the final draft, although what they

 12 might entail or what they might conclude is not

 13 clear at this point. Moreover, despite new

 14 additions to this draft of the document, it remains

 15 difficult to envision precisely how the

 16 Administrator is to piece together and jointly

 17 assess the various potential components of the

 18 standard that EPA staff describes.

 19 In addition, how the staff's recommended

 20 standard will be implemented and the various policy

 21 questions that must be resolved to allow for

 22 implementation remain exceptionally vague. The

 23 Policy Assessment notes, for instance, that the

 24 nation's monitoring networks are largely inadequate

 25 to fulfill implementation needs for a NAAQS, such

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 1 as the one EPA staff recommends. Similarly, the

 2 document notes that FRM and FEM designations remain

 3 a substantial stumbling block, as we have discussed

 4 already this morning.

 5 It remains entirely unclear how the

 6 designation of attainment and nonattainment areas

 7 will take place or how the spatial extent of the

 8 nonattainment will be determined; and, despite some

 9 of the conversation we've had this morning, how

 10 states will determine what steps to take to provide

 11 for attainment and how to demonstrate that it will

 12 be achieved remains an open question. Nor is it

 13 clear how states are to establish in the future

 14 whether the NAAQS has been attained.

 15 These crucial matters should not continue to

 16 be a mystery at this phase of the review. UR

 17 believes that these matters must be fully assessed

 18 and presented by EPA in this document and that they

 19 merit CASAC review and input to the Agency. UR,

 20 therefore, urges CASAC to request that the Agency

 21 provide a Draft Policy Assessment that completely

 22 analyzes the relevant issues for CASAC review and

 23 comment.

 24 Finally, UR remains highly skeptical of the

 25 legality of EPA staff's recommended secondary NOx

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 1 and SOx NAAQS and acidification-based standard will

 2 likely conflict with the Title IV Acid Rain Program

 3 in our opinion. And, further, UR is concerned that

 4 the AAPI conflicts with the Clean Air Act's

 5 requirement that a NAAQS prescribe a single,

 6 nationally uniform level of acceptable atmospheric

 7 concentrations of a particular criteria pollutant.

 8 The AAPI is designed to do just the opposite.

 9 Whatever the scientific merit of the staff's

 10 approach, it must be consistent with the Act.

 11 In sum, the current draft of the Policy

 12 Assessment continues to suffer from what UR

 13 believes are real and very considerable

 14 deficiencies. The document still does not address

 15 issues that are crucial to state regulators and EPA

 16 itself. UR hopes the CASAC panel will take these

 17 concerns into account and request revisions to the

 18 Policy Assessment.

 19 Thank you very much for your consideration.

 20 If you have any questions, I'd be happy to attempt

 21 to address them.

 22 DR. RUSSELL: Thank you, Aaron. Questions?

 23 Seeing none. Thanks. Ellis?

 24 DR. COWLING: I read the statement that is

 25 under your heading, procedures, Procedural

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 1 Concerns: "The regulatory options EPA is

 2 considering during this review represent

 3 significant departures from established practices

 4 under the NAAQS program." I agree. But this EPA

 5 committee or this EPA group, including the

 6 developing ISA and IEA, are doing exactly what the

 7 National Research Council recommended in its report

 8 in 2004 recommending changes in the NAAQS review

 9 processes in order to achieve more significant

 10 multi-pollutant approaches in air quality

 11 management. I presume that you're appreciative of

 12 the documentation that the National Research

 13 Council report contains that drives them to

 14 conclude that exactly what you said must be done.

 15 MR. FLYNN: Our point really is that given the

 16 significant changes and the fact that the Act

 17 itself has not been significantly changed, we do

 18 require as members of the public a period to

 19 comment on and to adequately review what the agency

 20 is doing and how these changes may or may not be

 21 consistent with the Act.

 22 DR. RUSSELL: Any questions? Thank you.

 23 Chris.

 24 DR. FREY: I just wonder on the legal point

 25 raised, and as to whether the standard has to be

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 1 nationally uniform and whether the standard is

 2 heading in a direction that's not nationally

 3 uniform, is that a legal issue from the perspective

 4 of the EPA general counsel who may still be in the

 5 room or is that an issue we can address and move on

 6 with?

 7 DR. MACIOROWSKI: The role of CASAC is to

 8 comment on scientific and technical issues.

 9 Certainly as the agency proceeds back through

 10 rulemaking there are a number of available options

 11 that the agency has and is to consider broader

 12 public comments, economics, legalities and so on.

 13 CASAC is a scientific advisory committee and its

 14 focus should be on the underlying science that's

 15 going on.

 16 So in terms of the legalities we have no

 17 lawyers on this panel. We have certain lawyers in

 18 the room who sort of nurture these processes for

 19 the agency. We have public who are very concerned

 20 about legal issues and all those things are

 21 ultimately relevant to the final decision making

 22 process. However, CASAC's role is fundamentally

 23 focused on science and it's a science advisory

 24 committee.

 25 DR. FREY: I understand that, but if there is

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 1 a constraint, I mean, we're looking at a Policy

 2 Assessment Document that's looking at policy

 3 options and I think it is reasonable to ask a

 4 question about what, if any, constraints we may

 5 have.

 6 DR. HUBBELL: I'm sure that Leah will jump in

 7 here if she needs to, but, to be clear, our

 8 supposition going into this is that we are in fact

 9 establishing a national standard. The form of that

 10 standard is such that you're combining NOx and SOx

 11 to compare against a national level, which is

 12 determined based on a target ANC value. The target

 13 ANC value is a national standard.

 14 The way that we meet it through different

 15 combinations of NOx and SOx that vary throughout

 16 the country, but the metric that we are comparing

 17 against is a national standard. It is not a

 18 regional standard. It is a national standard.

 19 MS. WEGMAN: If I could just note quickly, we

 20 think what we are doing and what we are considering

 21 is consistent with the Clean Air Act, which isn't

 22 to say it will be agreed with by all parties. That

 23 is our view, that the approach we are taking is one

 24 that we believe is consistent with the Clean Air

 25 Act.

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 1 MR. FLYNN: I'll just add that I certainly

 2 appreciate that you're operating under the

 3 supposition that it's a legal approach. We would

 4 really like to see -- and I agree with you that it

 5 would be nice to see in the Policy Assessment

 6 Document a fuller legal explanation.

 7 DR. RUSSELL: Thank you. John Jansen. Go

 8 ahead.

 9 MR. JANSEN: Good morning. My name is John

 10 Jansen, principal scientist for Southern Company.

 11 Southern Company has serious concerns about the

 12 staff's recommendation on the secondary SOx --

 13 secondary NAAQS for NOx and SOx. In short, the

 14 recommended NAAQS is problematic for various legal

 15 and scientific reasons and reflects fundamental,

 16 practical incompatibilities between the NAAQS

 17 program and the welfare effects that EPA is seeking

 18 to address.

 19 The staff's efforts to link ambient

 20 concentrations of SOx and NOx to the ecological

 21 indicator ANC through use of the AAPI is fraught

 22 with uncertainties that EPA staff greatly

 23 under-represent, an unsupported and grossly

 24 simplified assumption. Further, important

 25 parameters, such as base cation deposition as well

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 1 as base cation exchange, are ignored.

 2 EPA staff acknowledges the need for a national

 3 uniform standard, but has designed a standard

 4 that's anything but nationally uniform. It is not

 5 a uniform level of ambient NOx and SOx. A uniform

 6 level of AAPI or, in reality, ANC is not a

 7 pollutant in the ambient air. A uniform level of

 8 ANC can be overly protective in some areas of the

 9 country. For example, Florida lakes having

 10 thriving fisheries despite low pH, low DOC and low

 11 ANC, they have those thriving fisheries because of

 12 low aluminum and so it would be overprotective.

 13 Moreover, many of the agency staff's

 14 assumptions are invalid. Depositions to NOx and

 15 SOx concentration ratios are not constant as the

 16 agency continues to brush aside complications in

 17 pursuit of the standard. For example, by using

 18 extensive spatial and temporal averaging to

 19 minimize the inherent variability of the ratio, it

 20 is necessarily becoming increasingly divorced from

 21 reality and incompatible with critical -- other

 22 critical aspects of the standard.

 23 For example, the definition of area over which

 24 the percentage of lakes meeting the acceptable ANC

 25 can easily conflict with this averaging offense,

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 1 and I'm assuming area is now AQCR, but maybe not --

 2 maybe that's not the case.

 3 While we understand the reason that EPA has

 4 decided essentially to exclude reduced nitrogen

 5 from the AAPI, doing so places the entire burden on

 6 attaining the NAAQS on SOx and NOx. This is

 7 another reason why the NAAQS program is ill suited

 8 for this task.

 9 EPA is evaluating different bases for

 10 determining the area over which the percentage of

 11 waterbodies meeting the ANC limit is assessed

 12 ranging from one population of the entire United

 13 States to using sensitivity classes, ecoregions or

 14 clusters. It remains unclear precisely how the

 15 various areas will be defined and how relevant

 16 ecosystem characteristics within them will be

 17 identified.

 18 It is unclear how these various areas will

 19 relate to the designation of attainment and

 20 nonattainment areas. Further, how will these areas

 21 relating to the deposition-to-concentration ratios?

 22 The size of the area has serious implications for

 23 how large and how seriously various uncertainties

 24 are as well as for implementation issues.

 25 What will be the role of the states in all of

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 1 this complexity? There are also considerable

 2 shortcomings in the databases EPA is relying on.

 3 While EPA has relied on CMAQ to produce some of the

 4 these databases, the performance of CMAQ and

 5 reliability of its deposition calculations, as

 6 coupled in the NAAQS approach, cannot be evaluated

 7 without adequate data.

 8 There are similar uncertainties in existence

 9 and representativeness of the other databases, such

 10 as the deposition of reduced nitrogen, the various

 11 geological, soil and vegetative cover datasets, the

 12 water quality, quantity and biotic resources.

 13 There is also a question in my mind as to the

 14 rationale for the 5,280 waterbodies that are used

 15 to represent the thousands of lakes, rivers and

 16 streams in the United States.

 17 The considerable gaps in the nation's air

 18 monitoring networks renders existing network

 19 inadequate for assessing compliance with the

 20 secondary NOx and SOx NAAQS. Indeed a substantial

 21 amount of work is required on FRM issues, which has

 22 been identified. Further, a standard taking a AAPI

 23 form will also likely require the calculations

 24 necessary to determine compliance to be included in

 25 whatever FRM is approved -- is developed.

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 1 These examples illustrate the NAAQS program is

 2 not an appropriate mechanism for regulating

 3 ecosystem acidification. The AAPI strains the

 4 parameters of the NAAQS program and a more

 5 reasonable alternative approaches should be

 6 investigated. Thank you.

 7 DR. RUSSELL: Thank you, John. Questions for

 8 John? Ellis, I see you.

 9 DR. COWLING: John, when I read this statement

 10 this morning that is in the next to the last

 11 paragraph of your statement: "The substantial

 12 amount of work will be required before adequate

 13 federal reference methods and equivalent methods

 14 can be established." And I couldn't help but

 15 remember when we were working together in the

 16 Southern Oxidants Program, you were very much

 17 concerned about measurement methods and you made a

 18 huge investment, you and the Southern Company, you

 19 together with the other cooperatives made a huge

 20 investment in developing the Search Program.

 21 I wonder if you could comment on your

 22 eagerness to join with EPA in fulfilling your hope

 23 that this additional work would be accomplished by

 24 making investments of the sort that you did in

 25 developing Search?

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 1 MR. JANSEN: Well, certainly we would want to

 2 make sure that all the work we have invested in is

 3 utilized in this process, there is no doubt. The

 4 NOy techniques that we have used in deploying the

 5 Search certainly are a form that could be

 6 considered in establishing an FRM. But we think we

 7 know how to do that, but I've also seen quite a bit

 8 of debates about those kinds of methods in the

 9 past.

 10 So yes, you know, we certainly will bring our

 11 expertise to the -- to the table, but it's more

 12 than just SO2 and sulfate and NOy. It's the

 13 equation itself. I think there is a serious

 14 consideration has to be given to what portions or

 15 if not the entire equation itself needs to go

 16 through this process.

 17 The analogy I would cite is the improve

 18 equation. We're talking about a secondary standard

 19 for PM, talking about using an equation. Well, the

 20 way that equation is being used in the actual

 21 setting of the standard I would suggest serious

 22 consideration needs to be given to that being part

 23 of the FRM. And if it is in the process to vet

 24 that equation or this equation, the AAPI is going

 25 to be a process that's going to take some time.

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 1 DR. RUSSELL: Praveen.

 2 DR. AMAR: Quick question about your last

 3 statement about AAPI stretching the NAAQS program

 4 too much and one should look at alternative

 5 approaches, reasonable. What are you thinking?

 6 MR. JANSEN: Well, within the constraints of

 7 the Clean Air Act, I don't know exactly what I'm

 8 thinking. We do have Acid Rain Title IV as a

 9 separate response to this issue a couple decades

 10 ago. Is that an appropriate thing? Of course,

 11 that requires Congressional action.

 12 We do have serious emissions reductions that

 13 are occurring under other portions of the Act and

 14 the question is, is that adequate? Is setting a

 15 standard equivalent to the primary standard

 16 adequate to long-term improvement in the

 17 environment?

 18 I'm not a lawyer. I'm going to rely on UR to

 19 make those arguments, but I think there are other

 20 alternatives that ought to be considered. And what

 21 I say you can't put a square peg in a round hole.

 22 And that's sort of the way I think about what we're

 23 trying to do here. We're striving too hard to make

 24 something fit that doesn't fit.

 25 DR. RUSSELL: Thank you. John Heuss, are you

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 1 on the phone?

 2 MR. HEUSS: Yes, I am.

 3 DR. RUSSELL: You may begin.

 4 MR. HEUSS: Thank you. I am with AIR,

 5 Incorporated. Of course, I will be providing

 6 written comments to the agency for the Alliance of

 7 Automobile Manufacturers.

 8 The PA revisits the appropriateness and

 9 feasibility of setting secondary NAAQS to address

 10 effects resulting from deposition. Previous

 11 reviews EPA decided that secondary standards were

 12 not an appropriate approach to address deposition

 13 effects. As we discussed earlier, both EPA and

 14 Congress regulated deposition through Title IV.

 15 Nothing has changed to alter the fundamental

 16 limitations that led to those decisions. As the

 17 previous speakers noted, the -- that deposition is

 18 a regional, not national, concern. A national

 19 uniform standard is not appropriate.

 20 Ecological indicators the EPA recommends is a

 21 measure of water quality and can't substitute for

 22 uniform national standards. The criteria for NOx

 23 and SOx cover a portion of the sulfur and nitrogen

 24 compounds that cause deposition-related effects.

 25 In particular, reduced nitrogen is important, but

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 1 not subject to regulation.

 2 The air quality includes both regulated and

 3 unregulated compounds. Importantly, we think that

 4 there is no unique link between ground-level NOx

 5 and SOx species and the deposition that may lead to

 6 effects. The assumption that surface-based

 7 measurements of these species at any site are

 8 indicative of the surface-based deposition has not

 9 been demonstrated and is likely flawed. Total

 10 deposition at most sites is dominated by wet

 11 deposition and the chemical composition of the

 12 precipitation is determined largely by in-cloud

 13 reaction. Thus wet deposition of the species will

 14 be a function of the gas and particle

 15 concentrations at cloud level, not at surface

 16 level.

 17 Another concern we raise is even as CMAQ

 18 provided reasonable estimates of total deposition

 19 of some of these species, it appears to do it for

 20 the wrong reasons and we provide examples.

 21 Consequently, the reliance on CMAQs being proposed

 22 by EPA appears to be flawed.

 23 Another important issue is the beneficial

 24 effects of nitrogen deposition need to be weighed

 25 along with any adverse impacts in the

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 1 Administrator's decision on the National Ambient

 2 Air Quality Standard.

 3 The written material we provided to CMAQ

 4 raises issues of implementation. Importantly,

 5 there is no fundamental acidifying potential for

 6 the NOy. Individual components of NOy will

 7 determine the dry deposition of those components.

 8 Ground level concentrations of NOy are not a

 9 satisfactory link to wet deposition and are not

 10 even a satisfactory link to the dry deposition

 11 since a different mix of NOy components will result

 12 in a different amount of nitrogen deposition as

 13 deposition velocities for the NOy component species

 14 vary widely.

 15 The PA is incomplete in many ways, as has been

 16 noted, with regard to the ecoregions, how many,

 17 what actual measurements would need to be made in

 18 each, how attainment would be determined, how

 19 control areas and tips would be developed.

 20 If an AAPI standard were set, new monitoring

 21 networks would need to be put in place. That's

 22 already been mentioned. Since EPA recommends three

 23 to five years of monitoring, any designations would

 24 not occur for the foreseeable future. This would

 25 delay any additional controls under the present

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 1 standard until well after the next five-year review

 2 is completed.

 3 In the meantime, NOx and SOx emissions will

 4 continue downward under various existing and

 5 planned proposed programs. For example, the

 6 on-road motor vehicle control program will reduce

 7 NOx emissions by about 50 percent over current

 8 levels.

 9 In addition, EPA's Transport Rule calls for a

 10 70 percent reduction in annual power plant SO2

 11 emissions and a 50 percent reduction in annual NOx

 12 emissions. That's in 2014 compared to 2005

 13 baseline. That's for a 28-state area.

 14 The PA doesn't address the important question

 15 of whether all these programs are sufficient to

 16 adequately protect the public health. It should.

 17 The question of whether current levels are adverse

 18 is not enough. You really have to look at whether

 19 or not the future levels that we know will be there

 20 will be adverse.

 21 So, finally, based on AIR's review, the

 22 proposed approach is a regional deposition standard

 23 using the critical loads approach dressed up and

 24 sold as a National Ambient Air Quality Standard.

 25 The approach is incompatible with the NAAQS

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 1 provision of the Clean Air Act.

 2 We think EPA should take the information in

 3 the PA, turn it into a report to Congress as an

 4 update to the 1995 report on the feasibility of

 5 acid deposition standards under Title IV.

 6 In addition, there really isn't anything

 7 keeping states from working together now using

 8 regional agreements to address any remaining acid

 9 deposition concerns.

 10 Thank you for your attention. And if there

 11 are any questions, I'll try to answer them.

 12 DR. RUSSELL: Thank you, John. Questions for

 13 John?

 14 Okay. In that case we can move on to the

 15 schedule. We are already just a wee bit behind.

 16 As I said, I will try to push us forward so we can

 17 have sort of a number of discussions later on in

 18 terms of some of the bigger picture issues.

 19 Starting first, charge question one. Laurie.

 20 MS. CHESTNUT: So charge question one is

 21 focused on Chapter 3. The definitions of

 22 adversity, are they appropriate to consider in

 23 determining what constitutes adversity to public

 24 welfare relative to the NOx and SOx secondary

 25 standards?

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 1 As a first remark, I just want to say,

 2 acknowledge that this chapter is much improved from

 3 the first draft and very responsive to the comments

 4 that were made on that. I think there is still

 5 some -- some details that I'm probably repeating

 6 from the last round of comments on it, but on the

 7 whole it's much more clear and the context is much

 8 better established for the quantitative results

 9 that are presented.

 10 I think it's quite clear there is a well

 11 documented link between the level of ecosystem

 12 services with the indicator ANC and welfare effects

 13 that the numbers are focusing on the recreational

 14 fishing, but the addition of the results for total

 15 value are very, very helpful there.

 16 I think I, and I saw on some of the other

 17 comments too, had questions about the presentation

 18 of the results in tables I think it's 3-2 and 3-3,

 19 just -- I was confused of whether these are

 20 additive or incremental and the text needs more

 21 explanation about the different -- how the numbers

 22 relate to the categories of the ANC changes that

 23 are considered there, which kind of comes back to

 24 how is that helping form the welfare implications

 25 of the target of 20, 50 versus a hundred ANC. So

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 1 that's important that that's clarified.

 2 And I think the rest of the comments that I

 3 have on this come back to, well, two categories.

 4 Whenever there is still this tendency to talk about

 5 the numbers that can be talked about, and

 6 forgetting to repeat the big picture of -- people

 7 care about the preservation of ecosystems in their

 8 natural state and at a quality that supports the

 9 species, the fauna, the flora, the stuff that

 10 should be there.

 11 So they don't just care about being able to

 12 catch the fish. They care that the lake is in a

 13 condition that supports the species that you'd

 14 expect to be there if there wasn't human pollution.

 15 So this kind of gets in a little parenthesis of

 16 nonuse value, but I think it needs to come forward

 17 even stronger that that is a big part of what

 18 people care about.

 19 We see it, there is evidence from the actions

 20 of communities and the statutes and in the

 21 willingness to pay for studies when those questions

 22 are asked, the values. So it's all there. It's

 23 just keep the story, you know, comprehensive. And

 24 it gets a little lost in the -- I think it's

 25 better -- it's better in the aquatic section where

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 1 the emphasis is now.

 2 But, along the same lines, while these

 3 ecosystem services clearly have value, the

 4 characterization of how they're being harmed or

 5 diminished by the deposition at current levels

 6 could be improved. I know we can't get to a bottom

 7 line dollars on it, but over what geographic area

 8 is there dieback of the red spruce and the maple

 9 trees? What percentage of these forests are, you

 10 know, what's the mortality rate or how can -- can

 11 information that was in the previous documents be

 12 brought forward here to describe the extent, the

 13 magnitude, even though it's in qualitative terms,

 14 of what the impact of the deposition is, not just

 15 these are important resources? I think that's

 16 clear. These are important resources. How are

 17 they being hurt?

 18 DR. RUSSELL: Okay. And before going on, just

 19 remember I will want to lead discussion --

 20 discussants to take charge of writing up the

 21 response. So just keep that in mind.

 22 So if you're a lead discussant, as the

 23 discussion goes on, just jot notes as to what other

 24 people have said, since this evening you can write

 25 up the -- the group responses to the charge

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 1 question. Keep that in mind. Praveen.

 2 DR. AMAR: I agree with all the things Lauri

 3 said, but a few other comments too. One with

 4 respect to public welfare and Chesapeake Bay. I

 5 thought it would be useful if the adversity concept

 6 was more clearly discussed and separately allocated

 7 to NHX, that is, not just the NOy. The document

 8 does talk about it's only interested in NOy.

 9 That's one major comment.

 10 The comment before I say more things, I think

 11 sections 3.3.2 and 3.3.3 are an economics framework

 12 in adversity. We don't say things, you know, I

 13 mean, I enjoyed reading those two pages and

 14 explaining to me what that meant. That's a

 15 compliment to the writers.

 16 And Figure 3.6 it's good that we have the

 17 nitrogen and sulphur deposition to different maps,

 18 one for the east and one for the west. But one for

 19 the west has the scale, if you look, has the

 20 highest scale. It goes all the way from 300 to

 21 1,300 equivalent factors per year. And I think we

 22 should split it. I mean, I wasn't sure where the

 23 maximum deposition nitrogen sulfur was in the west.

 24 That scale is just too large, 300 to 1,300, all in

 25 one color. So if it's possible to show where the

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 1 highest levels are.

 2 And one more comment about the -- I guess it's

 3 the revealed preferences. We do talk about NGOs

 4 and state governments and other efforts to address

 5 it. I thought we all looked one thing, as a

 6 country, we had a real preference through Title IV.

 7 We did manage the 10-million-ton reduction of SO2;

 8 and to the extent that's about $5 billion worth of

 9 benefit, I think it should include not just the

 10 states and NGOs and communities but this country as

 11 a whole. That's it. Otherwise, it's a very good

 12 chapter.

 13 DR. RUSSELL: Thank you. Panel? Dale.

 14 DR. JOHNSON: I had three things there. One

 15 was page 3.7, somewhere in there the Department of

 16 Energy was not mentioned. They funded a lot of

 17 environmental research. Having worked at the

 18 National Lab for a few years, I would say you ought

 19 to consider that, including some air pollution

 20 work.

 21 Table 3.1 is incomplete. You don't

 22 acknowledge that soils are filters for good water

 23 quality. On the other hand, soils can be

 24 pollutants themselves. And climate in that table

 25 is interesting, talk about regulating climate and

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 1 so forth? I didn't know we were able to do that.

 2 I think what's implied here is carbon

 3 sequestration, which is summarily dismissed and is

 4 irrelevant; and yet there is three full pages of

 5 discussion of growth increase and negative effects

 6 on fire systems in the southwest, which is

 7 completely true, I lived in those systems, but

 8 that's exactly the same phenomenon that causes

 9 carbon sequestration in other systems.

 10 So not -- once again, the same thing, it lacks

 11 balance. You need to have some consideration,

 12 growth increase might be desirable here, it's

 13 undesirable there, but let's talk about the whole

 14 picture.

 15 DR. RUSSELL: Other comments. Naresh?

 16 DR. KUMAR: This is just a general comment.

 17 This is one of the chapters that I would like to

 18 review, but I couldn't find the time. And I just

 19 wanted Angela and Ted to know that two and a half

 20 weeks was just not enough for me, but anyway, to

 21 read all the chapters and I would really like more

 22 time for this review. With other things happening,

 23 it's hard to find the time under those constraints.

 24 DR. MACIOROWSKI: That's why there is a

 25 committee.

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 1 DR. RUSSELL: Other? Other comments? Andre.

 2 DR. BYTNEROWICZ: I have just a technical

 3 comment related to Figure 3-2, which isn't mind

 4 earthing, but I think it should be corrected. It's

 5 the European data on eutrophication. And you're

 6 saying that on the right-hand side you have

 7 acidification. Actually, this is effect of sulfur

 8 deposition itself, not acidification as a part of

 9 concentration. So that should be corrected.

 10 DR. RUSSELL: Thanks, Andre. Moving on.

 11 Ellis, question two and three.

 12 DR. COWLING: Two and three, let me just read

 13 the question and then I'll offer my own.

 14 DR. RUSSELL: I wouldn't worry about reading

 15 it, just for expedience.

 16 DR. COWLING: I'll try to be concise, but

 17 okay. In the light of -- I think it's important we

 18 focus on what the question is in the light of the

 19 panel's views on the appropriate definitions of

 20 adversity that Lauraine just talked about. Do you

 21 agree that the current levels of NOy and SOx are

 22 adverse? And my quick answer is yes. And the

 23 question -- I think Chapter 3 makes a very nice

 24 presentation of certain facts about the Clean Air

 25 Act. It gives a long list of effects on

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 1 ecosystems, but it doesn't give a guidance about

 2 what is an adverse effect. And I thought what EPA

 3 has done is created a working definition; and I

 4 think the working definition which talks about

 5 disruption in ecosystem structure and function were

 6 a good definition.

 7 It wasn't in the Clean Air Act, but that's the

 8 one that has been working pretty well so far. And

 9 I must say I'm delighted that you're taking

 10 seriously ecosystem effects. So thanks for what

 11 you're doing.

 12 And this significant disruption is presented

 13 and I thought the quotation that you took from the

 14 ISA, just one of those, the scientific evidence is

 15 sufficient to infer a causal relationship between

 16 acidifying disposition and effects on

 17 biogeochemical and biota and aquatic ecosystems.

 18 That's the kind of firm statement that gives

 19 conviction to the recommendations that you're

 20 asking for CASAC to respond to.

 21 The third question: Has staff appropriately

 22 applied this approach in reviewing the adequacy of

 23 the current standards and potential alternative

 24 standards? And, once again, I say yes. I believe

 25 that EPA staff has very appropriately taken up

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 1 these matters. And the very short-term present NOx

 2 and SOx standards simply don't apply to long-term

 3 acidification effects.

 4 So the present standards are designed to give

 5 a degree of protection against fuller injury and

 6 that's not what a full realization of what

 7 protection of ecosystems ought to involve.

 8 Acidification and nutrient enrichment are very,

 9 very important. And I think that the indicators

 10 that have been suggested are appropriate.

 11 So I look forward to looking at all the

 12 different -- all of the different parts of the

 13 standard, the indicator, the averaging time, the

 14 level and the static method of calculation. So I'm

 15 looking forward to protecting aquatic ecosystems to

 16 start with and going from there to all the other

 17 kinds of ecosystem effects that are mentioned,

 18 particularly in Chapter 6. That's enough for me.

 19 DR. RUSSELL: Thank you, Ellis. Dale.

 20 DR. JOHNSON: Mine will be the same theme as

 21 before and that is that certainly the -- by

 22 limiting it to the aquatic effects or largely

 23 limiting it to aquatic effects, you're not looking

 24 to -- I don't know of any benefit to aquatic system

 25 or other side of the story, acidifying is negative.

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 1 When the terrestrial effects are considered,

 2 again, there needs to be more balance. I'm not

 3 against your idea of trying to increase -- trying

 4 to tighten regulations, that's not the point. The

 5 point is balance. And it's just not there.

 6 I spent over a decade working with elevated

 7 CO2 at community and all, and the whole thing was

 8 about forest growth is going to increase with

 9 elevated CO2 unless we have a nitrogen limitation.

 10 There was no -- hardly any thought at all about

 11 changing nitrogen deposition. So here we are all

 12 about nitrogen deposition, not considering elevated

 13 CO2 and the growth interaction of that. And so to

 14 me there is a huge disconnect here. There needs to

 15 be some expansion of unintended consequences let's

 16 call them. That's my point. That's my main point.

 17 DR. RUSSELL: Thank you, Dale. Panel? Very

 18 good. Which does move us to question four and,

 19 Dale, you're still on tap.

 20 DR. JOHNSON: Well, I don't know if there is

 21 anything much more to add to what I've already

 22 said. I've got a long dissertation there about it

 23 in my write-up that you can see.

 24 The question is: Is this document -- I'm

 25 starting to ask myself does this document and is

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 1 this whole effort a mission to increase standards

 2 or is it supposed to be -- and I assume that my

 3 role is supposed to be -- if so, my role is

 4 supposed to be the scientific critic. As a

 5 scientific critic, I'll say it's too narrow. It

 6 doesn't consider the unintended consequences;

 7 whether you want to call them beneficial or

 8 negative, I don't care.

 9 There is great debate in the literature at

 10 this point about nitrogen deposition, carbon,

 11 climate change and so forth. And I can't fathom

 12 that this would go forward without that coming up

 13 again in some fashion. To summarily dismiss it now

 14 makes no sense to me whatsoever.

 15 So it's the same thing I've been saying for a

 16 couple years now and it's all written out. So I'll

 17 just leave it at that.

 18 DR. RUSSELL: Thank you, Dale. Lauri.

 19 MS. CHESTNUT: I don't have much to add on

 20 this. I think we can see in the document there is

 21 more attempt to acknowledge that there is potential

 22 upside or downside implications, but that that's

 23 not the focus. I think the issues that Dale is

 24 raising about the carbon it's going to keep coming

 25 up.

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 1 DR. RUSSELL: Okay. Kathy.

 2 DR. WEATHERS: It occurs to me now, Dale, as

 3 you're talking, buried in the Neco term is nitrogen

 4 uptake by biosystem. So, in essence, buried in

 5 that term is stimulation of growth, the extent that

 6 nitrogen stays within the system, stays in the

 7 biomass and doesn't go out. I wonder if it's

 8 possible to identify that as a process that is

 9 recognized, that's utilizing nitrogen for what

 10 you're calling, you know, a positive?

 11 DR. JOHNSON: Yeah. And similarly the

 12 discussion on fire, you know, the negative effects

 13 of increased growth on fire, that's the same

 14 phenomenon. It's just the question of how you look

 15 at it. And I don't think -- I think that there

 16 is -- I think if you had the people from the

 17 elevated CO2 committee, for example, in here then

 18 they might say, well, you know, what's this

 19 nitrogen deposition going to interact with CO2 in

 20 the future? What's it going to do to carbon

 21 sequestration?

 22 I don't argue that this is going to offset the

 23 negative effects on water. That's not the point.

 24 I just don't think it's a complete assessment. You

 25 can never come up with all of the unintended

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 1 consequences, of course. But this is one that, to

 2 me, having worked on this stuff, is glaring.

 3 DR. RUSSELL: Other panel members? Thank you.

 4 Praveen, question five.

 5 DR. AMAR: So the big Chapter 5 and we have

 6 question five simply asking what they think about

 7 the revised conceptual framework for this AAPI

 8 standard we are talking about; and do we agree with

 9 the structure; and does it do a good job of various

 10 linkages? I guess in many ways conceptual

 11 framework is what we had seen in the first draft.

 12 So I think it does a good job. In fact, I

 13 thought it was very well thought out. That's what

 14 I said last time.

 15 And I think I still have one point which I

 16 made before, which has to do with maybe the

 17 opportunity to address ammonium or chlorine

 18 explicitly and not taking into account, which is

 19 the language we use now. I think it takes the

 20 opportunity down the road for actual reductions in

 21 ammonia.

 22 So when this thing gets implemented, ammonia

 23 needs to be taken into account. Maybe there would

 24 have been a transfer like we have for SOx and NOx

 25 and treat ammonia as a pollutant, which I still

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 1 think 4 to 5 million-tons per year. Unlike SOx and

 2 NOx, it's not going down, it's going up. And still

 3 there is no procedure here to address ammonia.

 4 That's my major comment. It was the one I had

 5 made before. Otherwise, I think, not discounting

 6 that, I think it does a good job of what you're

 7 trying to accomplish.

 8 DR. RUSSELL: Myron.

 9 DR. MITCHELL: Because there is a couple of

 10 major issues I'd like to bring up that were

 11 discussed in other gatherings of this group, and

 12 that is clearly CMAQ is an important central focal

 13 point of these activities. And I think that's

 14 obviously appropriate based upon the amount of

 15 emphasis and effort put into CMAQ.

 16 However, I think within its present form,

 17 there is not an adequate analysis of and

 18 verification of CMAQ results. It's almost curious

 19 that CMAQ is used for dry deposition, which is very

 20 difficult to validate, but then to go to wet

 21 deposition, you go to NADP. But actually CMAQ

 22 actually does calculate a wet deposition component.

 23 Why not do that comparison to see how good that is?

 24 I also recognize CMAQ now is calculating

 25 meteorological conditions is now using measured

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 1 meteorological information. Do I have that

 2 correct?

 3 DR. SCHEFFE: Well, a couple things. We

 4 actually do use CMAQ for both wet and dry. And I

 5 think what you're seeing is we're in a transition

 6 period where we start off using a lot of the NADP

 7 for wet and dry and we're transitioning toward

 8 using a lot more CMAQ for both wet and dry.

 9 The other part of this, because of the

 10 tychastic nature of precipitation and the

 11 difficulty in terms of pairing in time and space

 12 observations and modeled estimates, we've gone to

 13 doing some adjustments of the precipitation field

 14 with measured observations of precipitation to do a

 15 prism adjustment approach and using the chemistry

 16 that's developed by CMAQ. And that has led to much

 17 greater pairing, much greater pairing in time and

 18 space between the observations and the predictions.

 19 DR. MITCHELL: I got a little confused. I

 20 thought from reading in the document for wet

 21 deposition NADP data was going to be used and CMAQ

 22 for dry.

 23 DR. SCHEFFE: It has to do with the

 24 deposition. Some parts of the analysis, I think

 25 even in Chapter 3 you may have seen there is a map

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 1 there that talks about CMAQ, dry deposition and EDP

 2 wet deposition. Some of the early analyses that

 3 went into both the ISA and RIA went into that.

 4 That has gradually been changing over time.

 5 DR. MITCHELL: My major point it seemed like

 6 there was a major opportunity importance to

 7 actually include this validation clearly within the

 8 document. It's going to come up again and again

 9 how well does this model validate.

 10 DR. SCHEFFE: Excellent point. We agree

 11 completely with that.

 12 DR. MITCHELL: I guess my other point had to

 13 do with some of the formulations of the AAPI index.

 14 And I have a concern about some of the components,

 15 particularly on the overall assumption that sulfur

 16 goes in and sulfur goes out. There is pretty good

 17 evidence that that is not the case for a number of

 18 different systems. And we also have systems we

 19 know that have had previous sulfur loadings that

 20 the amount of sulfur coming out is fairly high.

 21 So I think not accounting for an important

 22 component like that, which could actually cut one

 23 half of the AMQs and ANC will actually result in

 24 under-protecting systems because they are leaching

 25 out the mobile sulfate ion, which will result in

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 1 acidification over time.

 2 There is a couple specific things within the

 3 document. There is a statement to the effect about

 4 nitrate coming out of the snowpack and that's

 5 associated with the episodic snowbelt

 6 acidification. All kinds of studies have shown

 7 that that nitrate associated with snowmelt does not

 8 come from the snowpack; 95 percent of it comes from

 9 either the forest or the middle soil. That's a

 10 mistake that needs to be corrected.

 11 DR. HUBBELL: Just so I understand, so is it

 12 when the snow melts it's washing through the soil?

 13 DR. MITCHELL: Exactly. The nitrate is not

 14 coming from the snow. It's coming from nitrogen,

 15 ammonia mineralite, and nitrate base within the

 16 soil.

 17 DR. RUSSELL: Thank you, Myron. Rich.

 18 MR. POIROT: I don't have a lot to add. I

 19 noted I think it was Ted's comments, written

 20 comments that indicated this is by far the most

 21 complicated NAAQS review that we've seen in recent

 22 years; and I certainly want to second that, but to

 23 also kind of go back and think about, you know, the

 24 whole concept of a secondary standard to protect

 25 against welfare effects. This is kind of exactly

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 1 the kind of effect that could we develop secondary

 2 standards to protect against, we should. I think

 3 it's a very appropriate and albeit complicated

 4 approach, but it's necessarily complicated.

 5 Ecosystems are complicated.

 6 And so, anyway, I really wanted to express my

 7 appreciation and admiration for the way in which

 8 you've taken the limitations and constraints of the

 9 Act and developed what I think is a fairly coherent

 10 framework that would allow us to go from

 11 measurements of certain sulfur nitrogen species in

 12 the air in a way that would be protective against

 13 ecosystems. So I really appreciate that.

 14 And Praveen had mentioned the failure to

 15 include reduced nitrate and reduced nitrogen as a

 16 component, but I was very pleased to note the

 17 change from the last PA in which now reduced

 18 nitrogen is viewed as a varying aspect rather than

 19 a fixed constant, such that if I assume then if

 20 ammonia deposition were -- reduced is the wrong

 21 word --

 22 DR. AMAR: Lowered.

 23 MR. POIROT: -- brought down, then the

 24 required reductions in the others would be less and

 25 vice versa. So I thought that was an excellent

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 1 revision and very responsive to the comments.

 2 That's all I have.

 3 DR. RUSSELL: Thank you. So I took it that

 4 those are primarily responsive to question five.

 5 So at this point we have a break at 10:30. So

 6 we're still before that painfully enough. So back

 7 to Praveen.

 8 DR. AMAR: Question six.

 9 DR. RUSSELL: The all-important one.

 10 DR. AMAR: Which is not for me to answer.

 11 DR. RUSSELL: Sorry about that. Are there

 12 other panel comments on question five? Dale.

 13 DR. JOHNSON: I think this is in question

 14 five, the steady state model, I think it was page

 15 516 probably discussed that more, but that appears

 16 to assume that base cation output from a system

 17 equals weathering, correct?

 18 DR. LYNCH: No.

 19 DR. JOHNSON: No?

 20 DR. LYNCH: No.

 21 DR. JOHNSON: Then I need clarification on

 22 that.

 23 DR. LYNCH: Is it okay to do it now?

 24 DR. RUSSELL: Uh-huh. Please speak to the

 25 mike a little closer.

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 1 DR. LYNCH: So the weather, it's supply at

 2 that point within the waterbody and so the surface

 3 water is going to integrate all the components. So

 4 the base cation weathering from the soil and the

 5 rocks are going to contribute to that. Deposition

 6 from the atmosphere is going to contribute to that.

 7 And it's going to go into the system that then is

 8 going to be releasing it in terms of the stream.

 9 So it's integrative of the ecosystem, not just

 10 what's coming out in terms of the weathering

 11 process per se.

 12 DR. JOHNSON: Okay. I had the impression

 13 preindustrial calculations assumed that the base,

 14 however we got base, cation export was equal to

 15 weathering; the system was steady state, in other

 16 words?

 17 DR. LYNCH: Uh-huh.

 18 DR. JOHNSON: If it is a steady state that

 19 means soils never acidify. That can't true. They

 20 do always acidify unless you're in the desert.

 21 Something is not clicking here. Maybe you and I

 22 can sort that out.

 23 DR. LYNCH: Right. I understand -- I sort of

 24 understand what you're saying in terms of that, in

 25 terms of your point of view. Yeah, and what's --

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 1 if we could talk off line, that would be awesome.

 2 DR. JOHNSON: Something is not -- I'm missing.

 3 I want to second Myron's comment on sulfate

 4 because I think the Coweta and the Shenandoah

 5 watershed is about 80 percent of the incoming

 6 sulfate retained. Even if the sulfate emissions

 7 are down 40 percent, therefore, they're still going

 8 to break through some day and sulfate is going to

 9 go higher.

 10 DR. LYNCH: And that is correct, but in terms

 11 of the steady state model, it's saying that

 12 retention we're going to let that go through it.

 13 Now, the question is are we under or overestimating

 14 within the specific question could be -- could be a

 15 reality.

 16 DR. MITCHELL: It could be both. Someplace

 17 you're going to go over, depending where things are

 18 at with regards to the sulfur status of that soil

 19 and the soil properties.

 20 DR. LYNCH: Right, or it may not break

 21 through.

 22 DR. MITCHELL: Not some places. It would just

 23 absorb even more.

 24 DR. LYNCH: Yeah. And that absorption may be

 25 in terms of that process. And, you know, I was

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 1 talking with Jack Cosby with the University of

 2 Virginia and they both have sites where they tried

 3 to find that sulfur that has been there for 30

 4 years and they can't find it, but it's not coming

 5 from through the system.

 6 DR. MITCHELL: I guess the point, Jason, I did

 7 some quick calculations and looked at some of the

 8 figures, and fairly modest estimates of sulfur

 9 input would be half of those kind of ANC changes

 10 you're predicting.

 11 DR. LYNCH: Okay.

 12 DR. MITCHELL: You get two for one for sulfur.

 13 DR. LYNCH: That's right, you do.

 14 DR. RUSSELL: Naresh.

 15 DR. KUMAR: I think from a theoretical

 16 standpoint, the framework looks fine, but its

 17 practical usefulness can only be determined showing

 18 its robustness. I don't believe that has been

 19 fully evaluated by EPA.

 20 And, as Myron said, a lot of the confidence of

 21 the framework depend on the models, are using data,

 22 which is very sparse. And unless a full content of

 23 the analysis -- I realize we will discuss that

 24 later on, but unless that can be done and fully

 25 evaluate the robustness of this framework, just the

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 1 theoretical framework and I think I have doubt on

 2 its effect and usefulness.

 3 DR. MITCHELL: I guess what my point is, it's

 4 been a tremendous amount of effort in CMAQ in the

 5 development. And I guess I'm suggesting that EPA

 6 should recognize, obviously, time and money

 7 available. I suggest that greater emphasis on the

 8 validation that's already present versus more

 9 refinement of a more and more detailed model would

 10 be better in terms of what we're trying to do here.

 11 DR. RUSSELL: Thank you. Tell you what, it is

 12 10:30. And I think we can probably break at this

 13 point and then come back for question six.

 14 So let's do that. We'll stand adjourned until

 15 10:45.

 16 (Brief recess.)

 17 DR. NUGENT: This is the time of the meeting

 18 where we actually increase the deluge for everyone,

 19 more paper. I just want to let you know we will be

 20 distributing right now Chris Frey's written

 21 comments. In your packet on the left side, we have

 22 a compilation of members' comments we received by

 23 noon yesterday, but we've added to the back of that

 24 packet Dr. Weathers' comments and Hanson's --

 25 Husar's, Rudy Husar's and Hanson. I'll be

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 1 developing other compilations of comments and send

 2 them around so you can have electronic copies of

 3 everybody's comments in case that's useful as

 4 discussants prepare their summaries. So you'll

 5 actually have the electronic text and we'll post

 6 that on the website too so you'll have access to

 7 it.

 8 DR. RUSSELL: Thank you, Angela.

 9 So now we jump in probably one of the big

 10 questions, questions six. So stick with Praveen.

 11 DR. WEATHERS: Can I comment? One of the last

 12 things Myron said is the time spent on talking

 13 about validation or verification would be time well

 14 spent. And I agree with that completely. I think

 15 it's an overarching theme. I don't know if you

 16 have an answer to that, but I think we as a group

 17 need to talk about what that would look like.

 18 Maybe now is not the time to talk about it.

 19 Maybe it's in the overarching questions to talk

 20 about, but I think it's a really, really important

 21 point and something we should discuss, what would

 22 verification of this whole thing look like.

 23 DR. RUSSELL: I think that might come under

 24 when we talk about Chapter 7 'cause that's the

 25 chapter on evaluation of uncertainty and

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 1 variability and essentially all the components

 2 thereof.

 3 DR. WEATHERS: I just wanted to flag that.

 4 DR. RUSSELL: Praveen.

 5 DR. AMAR: Question six, I have a question I

 6 want to ask, but, quickly, question six talks about

 7 what we think about the appropriateness of

 8 considering single national population of

 9 waterbodies in establishing standards and what do

 10 we think about alternative subdivisions in the U.S.

 11 to identify the spatial boundaries of populations

 12 of waterbodies in acid-sensitivity categories. And

 13 specific questions A, B, C, the use of Ecoregion

 14 III, Roman numeral three, areas to aggregate

 15 waterbodies; ANC to further aggregate Ecoregion

 16 III; and finally the relative appropriateness of

 17 various methods going from one country, one nation

 18 and yes, no binary sensitive/less-sensitive

 19 classes, cluster analysis based on sensitivity

 20 classes, and finally individual ecoregions.

 21 And my answer is I did try and I tried to read

 22 that part of the Chapter 5. I don't think I got it

 23 completely, but I can see these. The option one,

 24 which says the whole country as one unit and

 25 providing for a single deposition. Somehow I think

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 1 it's too easy, simple and also its weaknesses, I

 2 think, are too many to really think this is the

 3 preferred approach; that is, overprotection for

 4 least sensitive waterbodies and underprotection for

 5 areas that are most sensitive.

 6 Then there is difficulty in the three

 7 sub-options under second option, 2-A, 2-B, and 2-C.

 8 They're based on the concept of level III

 9 ecoregions. I know somebody understands what that

 10 means more than I do. I think it's not well

 11 written, it's not well explained to a person like

 12 me. I didn't get it. And I wasn't sure how this

 13 divides the country into 120-plus acid-sensitive

 14 categories. Reference is made to the work by

 15 Omernik. Is that the way it is said?

 16 There are profound words. I didn't get

 17 exactly why that approach was chosen and other

 18 words -- other references too. Maybe as a group we

 19 can figure that out. And between options 2-A, 2-B

 20 and 2-C the approach based on cluster analysis,

 21 which is option 2-B, at least gets me -- you know,

 22 I think it seems to be the right balance. Maybe

 23 I'm just having a level of comfort based on other

 24 work I've seen on cluster analysis, at least based

 25 on five clusters.

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 1 And, again, I don't know whether that's the

 2 right approach or not, but definitely going all the

 3 way where you divide 120-plus ecoregions may be too

 4 detailed. So those are my responses. I don't

 5 think they're the best answers, but that's what I

 6 got out of reading that part of the chapter.

 7 DR. RUSSELL: Thank you. Myron?

 8 DR. MITCHELL: I'll pass for right now.

 9 DR. RUSSELL: You're going to take a pass for

 10 now. Rich?

 11 MR. POIROT: I had kind of the same experience

 12 as Praveen related in terms of I tried really hard

 13 and I just couldn't get it. I just didn't quite

 14 understand the distinction between the different

 15 options that you were proposing. And I just didn't

 16 own them, you know, in a way that I felt I could

 17 really contrast one to the other even to understand

 18 what -- what's the gain? What are we trying to

 19 narrow down or improve upon?

 20 So none of them seemed inappropriate to me.

 21 As I read through them, every one seemed kind of a

 22 logical progression, but then when I got done with

 23 them, I didn't really feel like I had a good basis

 24 personally to feel like one was better than

 25 another. And I feel like that's something that the

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 1 Administrator is going to need some better

 2 explanation, clearer explanation -- or at least I

 3 am -- to really get it.

 4 You know, on the one hand it seems like the

 5 single population suffers from this

 6 oversimplification concept and overprotection and

 7 underprotection. But then how do you -- and there

 8 is one point where there is a very eloquent

 9 sentence in there it talks about the goal is, you

 10 know, sort of the balance of efficacy and

 11 complexity and hitting just the right point. And

 12 from that perspective somehow the five clustered

 13 approach seemed to make sense to me.

 14 First of all, the clustering scientifically

 15 appeals to me. The beginning starting point with

 16 the ecoregions appeals to me very much in the sense

 17 that it's very consistent with the sort of

 18 environment first perspective. The whole idea that

 19 we're going to start with the characteristics of

 20 the environment, that's our beginning place really.

 21 So I really like that even though I don't know

 22 Omernik or whoever he is, but it makes sense. And

 23 then the clustering, according to similar values,

 24 makes sense. That kind of an approach is I think

 25 scientifically quite valid and seems appropriate

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 1 here.

 2 So other than that, you know, it's hard for me

 3 to really say I like one approach. Just the way

 4 that you were showing them comparatively, it didn't

 5 work for me or, you know, I was kind of pining back

 6 for the days of the staff papers and almost hoping

 7 that you might pick an option or a couple of them

 8 and advocate, tell us what's good about this one

 9 versus the other one, what's the advantages and

 10 disadvantages. It's almost like there was this

 11 missing kind of "and staff recommends." So it's

 12 kind of like putting that back on us. And I don't

 13 know, but I have a strong sense of that.

 14 Earlier when Bryan was talking about --

 15 talking about the area of nonattainment or whatever

 16 and I think you said something about we haven't

 17 necessarily determined how the spatial extent of

 18 nonattainment would be divided because it occurred

 19 to me disaggregating ecoregions into the

 20 traditional county could get very complicated.

 21 DR. HUBBELL: Again, we're not -- at this

 22 point we're not required to determine how we would

 23 establish nonattainment. You know, what we're

 24 trying to figure out is what's an appropriately

 25 protective level of the standard and then you have

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 1 to figure out how you would actually implement that

 2 through an establishment of a nonattainment area.

 3 It's pretty clear to us it's not going to look

 4 like a county or anything else. It's going to look

 5 like something else. The question is: Is it a

 6 nonattainment area around a lake or over an entire

 7 ecoregion? That's the kind of discussion that

 8 needs to take place in terms of implementation.

 9 What we're trying to establish within these

 10 regions, regions or broader, is what is population

 11 of lakes that you evaluate to determine the

 12 appropriate critical load matching a target ANC

 13 value? That's what we're trying to determine.

 14 MR. POIROT: So that's off our table even

 15 worrying about how a region of nonattainment would

 16 be --

 17 DR. HUBBELL: Right. But it is very much on

 18 your table to help us figure out what's an

 19 appropriate spatial scale for the population of

 20 lakes we should consider when we're determining

 21 what a critical load should be to cover or protect

 22 that particular population of lakes and streams.

 23 That's very appropriate and very helpful.

 24 MR. POIROT: Just as an example, there was one

 25 place in which you talked about one of the options

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 1 and included a mention that when it was applied to

 2 the Adirondack case study area that it appeared to

 3 correctly separate between and distinguish between

 4 those lakes that did have low ANCs and those that

 5 were less sensitive, that's good. More of that

 6 kind of a clear basis for distinguishing among the

 7 options I think would be helpful for the panel

 8 decision process. I think that's all I have.

 9 DR. RUSSELL: Myron.

 10 DR. MITCHELL: So I -- my thoughts on this I

 11 already indicated having, obviously, a single kind

 12 of standard makes it simple in terms of presenting

 13 it, but I think in terms of scientific defense of

 14 this, it would throw out all of the past work

 15 associated with the known major causes of

 16 variability of the deposition and nutrient level

 17 effect.

 18 So I think having those ecoregions, especially

 19 having some of those ecoregions which correspond to

 20 regions used in the past to designate different

 21 waterbodies bodies and classifying them makes the

 22 most sense in terms of moving this forward. I

 23 think otherwise this would be scientifically very

 24 difficult to defend.

 25 I think the real challenge would be some of

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 1 the areas which have not had a high amount of

 2 investigation, what to do with those areas. Maybe

 3 those areas have already been indicated not to be

 4 ones that are sensitive anyway. So it may not be

 5 that much of a problem.

 6 So I'm supportive of coming up with ecoregions

 7 and coming up with metrics based upon past analysis

 8 that can be used for defining these in a meaningful

 9 sense.

 10 DR. HUBBELL: If I might just say for one

 11 moment trying to clarify this, when we talked about

 12 the rationales for going with different approaches,

 13 there were really two things that were critical to

 14 us in considering this, and perhaps this didn't

 15 come through in the document. One was does going

 16 to a more defined spatial characterization, does

 17 that allow you to more carefully address the

 18 differences in sensitivity? In other words, does

 19 it show up in a different critical load? That's a

 20 clear way to measure that. You have a different

 21 critical load between different areas. In some

 22 cases, you know, when you went to sensitive versus

 23 nonsensitive, there was a big difference between

 24 those two areas.

 25 When you went to the full range of all the

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 1 ecoregions some of those were different and some of

 2 them weren't. The question is could we build it up

 3 again? That's where the cluster analysis idea came

 4 in.

 5 The second issue is that when you go to a

 6 smaller spatial scale because of the fact that

 7 we're using observed water chemistry data to try to

 8 develop critical loads, you have some areas that

 9 have relatively sparse data and because those data

 10 are not based on a random sampling of all the

 11 waterbodies within those ecoregions, when you have

 12 a sparse set of data, we're not clear whether

 13 you're getting -- what part of the distribution

 14 you're getting when you look at that set of

 15 critical loads. It may actually represent the

 16 upper percentile of sensitivity within that

 17 ecoregion or it might represent the full

 18 distribution.

 19 So the tradeoff when you go to a smaller

 20 ecoregion is that you have less confidence in the

 21 ability to characterize critical load values. As

 22 you scale up, you're hopefully getting a better

 23 overall estimate of the distribution across all the

 24 ecoregions included in that cluster.

 25 That's the tradeoff is data availability and

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 1 data sparseness and the ability to characterize the

 2 distribution with the ability to actually get more

 3 specific critical load information for subregions.

 4 That's the tradeoffs we're trying to characterize.

 5 Again, some of graphics were intended to show that

 6 and perhaps they weren't as clear in terms of

 7 getting that, but that was the principle we were

 8 trying to come up with.

 9 DR. RUSSELL: Rudy.

 10 DR. HUSAR: It seems that one of the reasons

 11 that it is difficult to assess the difference

 12 between possible options that's in uniform national

 13 and regionalized is that it is not -- in your

 14 presentations you do represent the characteristics

 15 spatial and otherwise of the individual component

 16 of this AAPI piece, but unless one actually goes

 17 through the entire sequence, in other words, what

 18 does AAPI really look like out there? Okay. What

 19 is the nature of that pattern? Does it actually

 20 pass the does-it-make-sense test, you know, as a

 21 thing? Therefore, not only that one doesn't -- you

 22 can't see that, sense making, but also you cannot

 23 make -- you definitely cannot value or judge the

 24 difference between one uniform approach and the

 25 other one.

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 1 DR. HUBBELL: So, in other words, instead of

 2 just going through the critical loads take it all

 3 the way through?

 4 DR. HUSAR: Carry all those calculations all

 5 the way through so you have a feel for that. Don't

 6 set the standard. Don't set the AAPI levels. It

 7 is just to see what is the 10, 20, 50, 100 of what

 8 that index look like so that you can actually see

 9 what are the what I would call the quality

 10 consequences of all of those many, many opaque,

 11 somewhat opaque factors that are embedded in that.

 12 DR. GREAVER: I guess the idea behind sort of

 13 separating what was happening at the sites where we

 14 had critical loads versus what was happening with

 15 some of the air characteristics was we really

 16 wanted to focus in and figure out how do we define

 17 what is an acid sensitive area.

 18 So at the last CASAC meeting on the first

 19 Draft PA we thought that we would use bedrock

 20 geology to do this. And we were going to use a

 21 method that was published by Sullivan, et al. in

 22 2007 and did these -- correlations between acid

 23 sensitivity and lithology. Well, we then tried

 24 to -- I should note those correlations were

 25 developed for the Shenandoahs.

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 1 We then tried to do them in areas that were

 2 glaciated in the Adirondacks, all the relationships

 3 fell apart. So we knew that bedrock geology was no

 4 longer what we could use to classify acid

 5 sensitivity.

 6 We then spent months looking at different

 7 datasets, different end points. There were two

 8 questions: Does it tell us about acid sensitivity

 9 and do we have national coverage? After looking at

 10 lots of different approaches, soil base cation

 11 weathering as it was monitored by McNulty in 2008

 12 I believe, we looked at that. We looked at DOC in

 13 the water. We looked at alkalinity. We looked at

 14 ANC. We looked at trying to cluster those criteria

 15 together and using four of them and then see if

 16 that would work, what that would tell us. And we

 17 decided that ANC was the best ecological indicator

 18 that told us something about acid sensitivity.

 19 At that point we had a couple options. We had

 20 Omernik's 1984 alkalinity map. We could draw a

 21 circle around the areas that showed low alkalinity.

 22 Those could be our sensitive areas; or is there

 23 another way to spatially define ecosystems. As

 24 ecologists we know the definition of an ecosystem

 25 doesn't have a spatial component. We know that

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 1 critical loads modeling happens at the watershed

 2 level. Watersheds there are too many of them,

 3 thousands of them within the U.S. for us to look at

 4 each one of those.

 5 So the ecoregion concept was developed

 6 starting in 1987 by Omernik. And it was developed

 7 to look at water quality, actually, not

 8 specifically acidification, but it was a tool for

 9 policy makers to aggregate and define spatial areas

 10 that were similar ecologically.

 11 And throughout the past, you know, 23 years

 12 they've developed better approaches to defining

 13 those ecoregions and there are three levels: One

 14 is the broadest. There are 15 ecoregions level

 15 ones in the U.S. Ecoregion level three that we

 16 selected as 87 different areas defined.

 17 So at that point we said, okay, knowing that

 18 ecoregion is a pretty well accepted way to define

 19 spatial areas in addition to the fact that ANC is

 20 our best indicator of acidification, let's use the

 21 two together to try to determine where the

 22 sensitive areas are. And from that point we then

 23 said okay what are the critical load -- what are

 24 the sites that we have calculated critical loads

 25 for in each of those ecoregions. For nine of those

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 1 ecoregions in the level three spatial definition,

 2 we have zero critical load data for. For some of

 3 them we have 700 critical load calculator sites

 4 where we can calculate critical loads. So that's

 5 what Bryan was referring to earlier in that some of

 6 these ecoregions are really well represented and

 7 data rich; some of them not so much.

 8 So, because of that, we then went into the

 9 clustering technique and we have clusters which

 10 we're trying to make five categories of sensitivity

 11 using the ecoregion spatial scale. So that's sort

 12 of a history of our thinking and some of the steps

 13 that we've gone through. Hopefully that can help

 14 as we continue the discussion.

 15 DR. RUSSELL: Actually, Kathy and then Andre.

 16 DR. WEATHERS: Part of the process, it's very

 17 helpful, both Bryan's and your descriptions are

 18 very helpful and they absolutely need to be

 19 captured in this document. The way I was thinking

 20 about it is, well, there is one option which is to

 21 spatially aggregate by -- limited by the data that

 22 you have. You just explained why that doesn't work

 23 so well, the base cation weathering or geology.

 24 The other is to think about process level

 25 data. So I like the ecoregion characterization

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 1 because it takes into account ecological variables

 2 that will influence both deposition and processing.

 3 So I'd like to encourage you to explain more

 4 clearly in the document what it is you just

 5 explained here. It will help us advise.

 6 DR. RUSSELL: Andre.

 7 DR. BYTNEROWICZ: Along those lines, living in

 8 the southwest, I'd like to ask you how confident

 9 you feel that you're doing a good job with this

 10 part of the country? Especially from the point of

 11 view that acidification effects are not so

 12 important, nutritional effects of nitrogen

 13 deposition are a key factor. So could you indicate

 14 to me a little bit more how you feel about

 15 acidification effect for the aquatic ecosystems and

 16 the next --

 17 DR. HUBBELL: I can tell you we don't feel

 18 good about the nutrient enrichment part of it.

 19 Obviously the assessment we did for co-benefits

 20 will suffer from the sparseness of data that's

 21 available. Maybe Jason can talk about coverage

 22 that we feel like we have in the southwest.

 23 DR. LYNCH: Sure. In terms of the data

 24 sources that went into calculating the critical

 25 loads, we really focused on the national surveys

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 1 that EPA has done over 30, 40 years. So they date

 2 back to the 1980s. And then heavily used data as

 3 part of the EMAP program both in the northeast and

 4 in the west.

 5 And one key point to emphasize about those

 6 datasets are that they really focus on sensitive

 7 areas within the U.S. in terms of the acidification

 8 and so the majority of the water quality

 9 measurements were in regions that were soon to be

 10 sensitive to acidification. It doesn't necessarily

 11 mean that they are showing effects.

 12 And so out west deposition may have been such

 13 that you don't have large effects within for

 14 acidification, but the potential to be too

 15 acidified was there. And so they did do a fairly

 16 sophisticated survey of western sites and we used

 17 that data.

 18 Having said that, most of that, the area that

 19 they focused on is kind of the northern part of the

 20 western. So the southwest, to the most part, is

 21 under-represented.

 22 We then moved into some newer datasets. There

 23 is the Weightable Stream Survey that was done. It

 24 concluded in 2007. So I refer to that date. Most

 25 of the data was collected early 2000s. That does

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 1 provide some coverage. It is national coverage

 2 there.

 3 We also looked at the 2010 lake survey that

 4 was completed to give some filling in, in terms of

 5 those coverage. Having said that, yes, there are

 6 definitely regions where we're data limited at this

 7 time. For this analysis so that we could keep a

 8 lot of the data sources consistent, we really chose

 9 to use the EPA-sponsored water quality data. There

 10 are state data out there that could be rolled into

 11 this analysis, just that we didn't use that at this

 12 time.

 13 DR. RUSSELL: Dale.

 14 DR. JOHNSON: Yeah, as long as you bring up

 15 the southwest, I'll bring up Lake Tahoe where there

 16 is a lot of research going on about atmospheric

 17 deposition and pollution because the watershed is

 18 about two-thirds water. The terrestrial buffering

 19 for all of that is zero. So it's straight into the

 20 lake and atmospheric input. So extremely

 21 important.

 22 DR. RUSSELL: Rudy.

 23 DR. HUSAR: Now, I recognize that there are

 24 all the effort that went into identifying the

 25 sensitivity, but I was thinking more of the

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 1 combination of atmospheric concentration,

 2 deposition and then the sensitivity together so

 3 that we see what is the nature of that pattern that

 4 actually arises from the combination of those.

 5 Because that to me, as far as I'm concerned, that's

 6 what your proposal is. The essence of the proposal

 7 there is this index that is meant to be measured to

 8 be used as the quote standard.

 9 DR. HUBBELL: Yeah, I agree.

 10 DR. RUSSELL: Ladies first. Lauri.

 11 MS. CHESTNUT: Thank you. I just have a

 12 question that's come up while you're talking about

 13 it in terms of these categories. Are all the

 14 parameters that go into that, do they have to be

 15 the same for the category, like the ammonia

 16 deposition or the transformation from ambient to

 17 deposition? So is that -- are those, you know, for

 18 any given category are those parameters all the

 19 same? So do we have to think about what division

 20 there needs to be so the function is specified

 21 right?

 22 DR. HUBBELL: Well, I mean, within the

 23 calculation of the critical loads those are

 24 calculated based on the individual lakes that we

 25 have information on, the water chemistry, the

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 1 streams and lakes, waterbodies bodies, the lakes

 2 and streams. The information we have on the

 3 individual waterbodies, but it's a total critical

 4 load for sulfur plus nitrogen -- actually, yeah,

 5 sulfur and then adjusted with nitrogen with the

 6 Neco terms.

 7 MS. CHESTNUT: So it's kind of an average

 8 across?

 9 DR. HUBBELL: No, that's individual lakes

 10 within an area. Then you calculate critical load

 11 and you take the distribution of critical loads.

 12 Where the question about spatial aggregate comes in

 13 is when you introduce reduced nitrogen and try to

 14 figure out how to adjust for reduced nitrogen.

 15 DR. GREAVER: Well, spatial aggregation for

 16 the critical loads question on it because you have

 17 to define which sites in your population are in

 18 your critical loads. And that then affects the

 19 distribution and how you select which percentage of

 20 those waterbodies.

 21 DR. HUBBELL: That's not averaging as much as

 22 it is -- you're still calculating for each

 23 individual lake. It's just a question of which

 24 ones get included in that distribution. That's

 25 what is determined by your spatial extent for

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 1 selecting lakes and streams.

 2 There is also a separate step of, we have to

 3 figure out what reduced nitrogen to subtract out of

 4 the available nitrogen that you have to work with

 5 to get your NOx-related critical loads. And that's

 6 another question -- that's why we propose a couple

 7 different ways that you could deal with it. One is

 8 you can average it over the entire region, which

 9 would be, you know, might be appropriate and we're

 10 still thinking through this. It might be

 11 appropriate to make sure you're covering the entire

 12 ecoregion if you're thinking of one monitor for the

 13 entire region. You might want to have an average

 14 that represents that entire region or you might

 15 want to have a different percentile of the

 16 distribution of reduced nitrogen values within that

 17 region.

 18 The other option is to match the reduced

 19 nitrogen to the area you're going to intend to

 20 represent with your monitoring. Within an overall

 21 ecoregion you want to make sure that you monitor

 22 the lakes and streams that are most important

 23 within that region. You might want to have a

 24 monitor in place to represent a particular portion

 25 of that ecoregion. And you might want to make your

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 1 reduced nitrogen match that particular area that

 2 you're monitoring for.

 3 So there are still options for dealing with

 4 that. And we're still playing through how that --

 5 what the implications would be for overall

 6 protection within the ecoregion. So we may be

 7 trying several different ways of looking at reduced

 8 nitrogen and seeing does it result in the specific

 9 level of protection that we anticipate, in terms of

 10 the percent of what waterbodies that are actually

 11 protected when you see a particular level of NOx

 12 and SOx.

 13 So those are the things we're playing through

 14 the system to see how it would impact the overall

 15 level of protection at a particular target ANC

 16 value. We haven't completed all those calculations

 17 yet. But, again, I do think that in the end you're

 18 going to have some aggregation of ammonia and

 19 you're going to have some aggregation of the

 20 transfer ratios that convert NOx to deposition.

 21 And they may not match the exact averaging --

 22 spatial averaging -- or, excuse me, spatial unit

 23 that you use to determine your population of lakes

 24 and streams. Is that clear at all?

 25 MS. CHESTNUT: Yeah, I think so. I guess what

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 1 I'm trying to get at in terms of grappling with

 2 this question is I think we start off with

 3 sensitive and not sensitive because we know we at

 4 least need the two categories. And every -- every

 5 division into more groups adds administrative work,

 6 data work, you know, it adds difficulty and

 7 therefore cost and complications, and what's gained

 8 with each.

 9 DR. HUBBELL: Right.

 10 MS. CHESTNUT: So where is the tradeoff and

 11 what's the right balance? One of the things this

 12 whole thing is about is allowing -- is this

 13 requisite, you know, finding a standard that's

 14 requisite to protect the sensitive areas and not

 15 overconstrain areas that aren't sensitive. And

 16 that's one of the things I kept trying to see if I

 17 could understand here. And I was having trouble

 18 seeing is -- yeah, you mentioned the difference

 19 between the critical loads for the two groups which

 20 gives you a sense of, okay, these areas are not

 21 sensitive are not as constrained. And -- but how

 22 does moving to more disaggregation, does it -- does

 23 it allow more flexibility for the less sensitive

 24 areas? Does it make them bigger in a way? Is

 25 there a bigger way that we're not going to be so

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 1 worried about it --

 2 DR. HUBBELL: It's more like when you cluster

 3 those ecoregions, what it does is bring more

 4 populations together. So when you take the

 5 distribution of those values and you say, okay,

 6 here is a critical load distribution and we select

 7 90 percent say, for example, you're trying to

 8 protect 90 percent, if you take 90 percent of the

 9 overall combined distribution and then apply that

 10 critical load to all the ecoregions within that

 11 cluster, okay, then you may be overprotecting some

 12 and underprotecting some.

 13 So the question is if you then disaggregate

 14 those clusters, do you get a substantial difference

 15 in the critical loads that have to be met for

 16 different ecoregions or are they largely the same?

 17 It all depends on how much similarity there are in

 18 those distributions.

 19 One of the things we're trying to do with the

 20 clustering is bring together those groups that are

 21 not likely to have big differences in their

 22 critical loads. So that you can reduce that

 23 burden, that complexity without giving up much in

 24 terms of the flexibility of changing the critical

 25 loads that each region might have to achieve.

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 1 The real question in looking between these is

 2 how much difference do you get in the critical

 3 loads; and is that worth the extra complexity?

 4 When you think worth, what does that mean? It

 5 means do you give them more close to their true

 6 requisite protection level or do you not? And if

 7 they're very close to each other, given the

 8 uncertainties and various other things we've got in

 9 this, is it worth taking the other step?

 10 Fundamentally it's going to end up being a

 11 policy call as to whether that's worth it. What

 12 we're looking for guidance on is, is the types of

 13 options we've laid out, does that capture the types

 14 of things you can think of that are representative

 15 of sensitivity differences that might be

 16 appropriate to consider when you decide whether or

 17 not it's a real difference in the critical load?

 18 And, you know, one of the things that we tried

 19 to point out through this in all these methods in

 20 every ecoregion or every group of ecoregions there

 21 are some more sensitive and some less sensitive

 22 lakes and streams included. There are almost no

 23 places in the country where it's all sensitive

 24 lakes or it's all nonsensitive lakes and streams.

 25 So there is always going to be that

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 1 distribution in each of those ecoregions. The

 2 question is really what's going on in the tails of

 3 the distributions and are they similar enough that

 4 we can combine them and feel that we're giving an

 5 overall level of protection?

 6 There is going to be a policy call that's

 7 required, but it should be informed by which

 8 differences are real versus which differences are

 9 simply implied by methodologies. We want to get at

 10 real differences in sensitivities so that we can

 11 try to adjust the critical loads.

 12 I don't know if that was helpful at all or

 13 not, but it is a difficult choice. And one thing

 14 we can certainly try to work on more is here's the

 15 chart, if you go to Figure 5-12. Are you at 5-12?

 16 Page 5-44, sorry. In this particular figure, what

 17 we're trying to demonstrate is the differences

 18 between the different options that might be

 19 available. And so we have option one, which was

 20 the one nation using all the lakes and streams. We

 21 had option two, which was splitting it into option

 22 2-A, which was splitting the country into sensitive

 23 and nonsensitive, and then option 2-B, which is

 24 using five clusters. We don't show the results for

 25 all the individual ecoregions.

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 1 What this shows in fact if you look at the

 2 deposition load to cover 90 percent of the lakes in

 3 a particular population, if you look just between

 4 the one nation and the sensitive and less

 5 sensitive, you see that the critical load for

 6 sensitive regions is very similar to the critical

 7 load for the nation when you just use the one

 8 nation. It's 26 versus 27. This is the critical

 9 load for both nitrogen plus sulfur.

 10 When you look at the critical load for the

 11 less sensitive area, it's twice as big. So you can

 12 say, well, that's a pretty significant difference

 13 if you allow for nonsensitive lakes to have a

 14 separate critical load. It means in those areas

 15 they're going to have to do less to be able to meet

 16 the standard. It makes sense given that

 17 flexibility and the fluctuation in sensitivity of

 18 the lakes.

 19 When you go to the clusters, you can see,

 20 well, three of the clusters are actually close to

 21 each other, looking, again, at the 90 percent

 22 deposition load. You see that the cluster one,

 23 cluster two and cluster four are all around, you

 24 know, 25 to 30. But clusters three and five are

 25 quite a bit different, they're 48 and 72.

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 1 In that case you can say there is still

 2 benefit in going to five clusters rather than going

 3 to two. You might say, well, maybe we should

 4 combine clusters one, two and four. Maybe they're

 5 all similar enough that we can combine them. There

 6 is still some tweaking that can be done.

 7 The idea is to try to find that balance of

 8 where you're gaining in terms of ability to have

 9 flexibility versus where you're losing in terms of

 10 complexity. This is sort of what we're trying to

 11 use for metrics for comparison.

 12 DR. RUSSELL: Bryan, thanks. Actually, I will

 13 point out to the committee one of the things you

 14 said is you're still working through a lot of

 15 issues associated with that. I think that's

 16 something -- I realize you can't give it to us

 17 right now, but that's the sort of thing I think we

 18 almost need to really fully advise you on, you

 19 know, some of the parts of the standard.

 20 DR. HUBBELL: Certainly, we understand that.

 21 What we're hoping is to get your -- again, this is

 22 the first time you've seen any of this.

 23 DR. RUSSELL: Right.

 24 DR. HUBBELL: What we want is reaction to this

 25 as well. It doesn't seem like a good thing to do.

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 1 It doesn't seem like reasonable metrics to be able

 2 to compare. Again, we went through way more

 3 methods than I want to try to lay out in this

 4 document, but it's not an easy task to come up with

 5 a way to divide the country up in a way that allows

 6 flexibility. This has not been done before.

 7 DR. RUSSELL: We appreciate it's not an easy

 8 task.

 9 DR. HUBBELL: The question is are we bringing

 10 the scientific information, the critical load

 11 information, the sensitivity information, are we

 12 bringing it together in a way that makes sense for

 13 you scientifically as you consider it and its

 14 usefulness for policy? That's what we're looking

 15 for.

 16 DR. RUSSELL: Charlie.

 17 DR. DRISCOLL: So I guess I agree with a lot

 18 of comments that have been said, particularly

 19 Rudy's comments to try to work through some of

 20 these issues, particularly given where the

 21 emissions are; and do the clusters make sense given

 22 the distribution of emissions across the country,

 23 the importance of sulfur in the east versus the

 24 importance of nitrogen in the west.

 25 I have the sense that one is too few and,

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 1 whatever it is, 87 is too many. So I think, you

 2 know, five makes sense if you look at a map, a

 3 figure, I think it's 5-11, to me that sort of looks

 4 about right given the levels of bins of ANC and

 5 what we're talking about as sensitivity. I think

 6 like that is in the ball -- ball game. But I

 7 worry -- I like the cluster approach. It makes

 8 sense, but I worry about as you move forward with

 9 this, you're going to presumably, if you go

 10 forward, you would probably add on other

 11 considerations like we've talked about, nutrient,

 12 nitrogen and other considerations. And there are

 13 efforts that are coming down the pipe. There is

 14 this big Forest Service initiative to try to

 15 develop empirical loads for nitrogen that are based

 16 on the ecoregion approach. So if you use a cluster

 17 approach, does that cause problems with broadening

 18 this to include these other issues that are on the

 19 back burner?

 20 So I think that that's an important

 21 consideration. It would be some -- it would be

 22 nice if you could use ultimately, you know, however

 23 many years down the road use the same basic

 24 approach for acidification, nutrient, nitrogen and

 25 so on and so forth, so that this approach is

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 1 consistent for these different effects. So I'm not

 2 answering the question very well. I'm just

 3 throwing out a few thoughts.

 4 DR. GREAVER: Could I respond to that? One of

 5 the things I like about using the clustering

 6 approach is we're clustering ecoregions. If I

 7 remember correctly, that Forest report on empirical

 8 nitrogen approach uses the ecoregion concept to

 9 assign those loads. I think they're compatible in

 10 that sense. Maybe the clusters would be

 11 disaggregated a little bit if we then did a

 12 nutrient or just an empirical nitrogen critical

 13 load.

 14 DR. DRISCOLL: I would agree if you can do

 15 that and retain the cluster approach if that's how

 16 we're going forward with nitrogen. It seems like

 17 this is a huge effort to pull all this nitrogen

 18 information together. It could be improved

 19 certainly, but you think it's a potential resource

 20 to take it to the next step and address these

 21 nitrogen issues in the west.

 22 DR. RUSSELL: Naresh.

 23 DR. KUMAR: I think I go back to Lauraine's

 24 question that if you have to aggregate LNHx terms

 25 and NOy terms having five clusters is too few

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 1 because LHNx is going to vary so much across the

 2 regions. So I just don't understand what is the

 3 difficulty in having the 77 ecoregions? Other than

 4 if some of the regions don't have enough data,

 5 could those regions be combined together and maybe

 6 they could have a data from all the other regions

 7 taking an average. At least the ecoregions, if you

 8 have it there, I think individual --

 9 DR. HUBBELL: To be clear, I mean, these

 10 sensitivity regions, they're not the end in terms

 11 of you come up with the distribution of critical

 12 loads and pick the critical load that represents

 13 the 90 percent protection over that entire class of

 14 sensitivity, but you can then further refine the

 15 tradeoff curves, the critical loads for NOx and SOx

 16 based on more spatially refined estimates of

 17 ammonia. And you can also, again, to develop the

 18 concentration-based critical loads you can use more

 19 spatially refined estimates of VNOy and SOx. It's

 20 not that you have to then average over that entire

 21 cluster for that particular part of the variable.

 22 It's just used to establish the basic critical load

 23 for acidity that's used.

 24 DR. RUSSELL: Rich.

 25 MR. POIROT: I wonder if we could go back and

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 1 look at that Figure 5-12 for a minute. That's

 2 actually one of the places where I lost you. And

 3 maybe I could find it, you can explain it to me.

 4 But I guess I was -- I had been following along

 5 with this proposed cluster approach thinking that

 6 the Cluster 5 was the most sensitive and had the

 7 lowest mean ANC and so forth. And I guess I must

 8 have gotten that wrong; or if that's true, then why

 9 does it have the highest deposition of all of the

 10 clusters to protect the 90 percent level? I guess

 11 I expected to see some more logical pattern of

 12 clusters in that figure and I don't understand why

 13 it's not there.

 14 DR. GREAVER: So probably Figure 5-12, we have

 15 it in Figure 5-5, we noted in Figure 5-12

 16 parenthetically what the mean ANC level value was

 17 for the five clusters. Cluster 5 actually has the

 18 highest ANC value. It's 167, so that corresponds

 19 quite well to the highest.

 20 But your point is a good one because when you

 21 see Cluster 3 and 4, Cluster 3 has a lower ANC

 22 value, yet a higher what we're defining deposition

 23 metric. So Clusters 3 and 4 there is a little bit

 24 of inconsistency between that mean ANC level and

 25 the 90th percentile critical load.

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 1 DR. HUBBELL: Part of that is the difference

 2 between the mean and looking at the more sensitive.

 3 When we're looking at 90th percentile critical load

 4 that protects the 90th percentile lake, it may not

 5 be all matched with what the mean ANC value for the

 6 overall distribution is. If the distribution has a

 7 very long tail, it could end up having a very big

 8 difference between the mean ANC and what the 90th

 9 percentile critical load values end up being

 10 protecting 90 percent of the lakes and streams

 11 within that cluster.

 12 And that actually is the case and we probably

 13 should put the median in as well as the mean ANC so

 14 you can get an idea of the overall shape of the

 15 distribution a little better. That's probably

 16 what's causing some of the confusion.

 17 DR. RUSSELL: Other questions from the panel?

 18 Thank you.

 19 DR. HUSAR: Just a quick question, maybe

 20 suggestion regarding the Figure 5 all summarizing

 21 the outcome of many of these options. Would it be

 22 possible to take that same information that went

 23 into producing this kind of comparison to expose

 24 more of the underlying parts of that, such as would

 25 making the same thing spatially and doing more than

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 1 just in Figure 5-12 or 5-13, which illustrates some

 2 aspects of what the nature of the spatial

 3 consequence is of those assumptions? In other

 4 words, the reason seems to be where I get confused

 5 it's kind of opaque as to what goes into these

 6 summaries. So if they are broken down and exposed

 7 as pieces, maybe it would be more easier to

 8 understand.

 9 DR. HUBBELL: We can certainly try. It's a

 10 little hard because a lot of inputs -- these

 11 critical loads derived from the SSWC model which

 12 integrates everything up to that point. So it's a

 13 little difficult to then tease out sort of

 14 individual parts.

 15 So we can take it from this point and go

 16 forward in terms of saying what happens when you

 17 combine that with reduced nitrogen and the other

 18 parts of the AAPI equation. But the first parts of

 19 the AAPI equation are really determined by the

 20 critical load modeling. It's hard to disaggregate

 21 them unless you're saying in terms of doing more

 22 maps we can. If you're saying doing more maps, we

 23 can certainly do that.

 24 DR. HUSAR: Doing more maps to separate the

 25 deposition part from the sensitivity part.

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 1 DR. HUBBELL: We can do more maps, for sure.

 2 DR. GREAVER: We have some. I'd like to

 3 highlight two maps. They might be helpful. In

 4 Figure 5-10, what we have there -- and that's on

 5 page 5-37, what we have there is a map of the U.S.

 6 with the ecoregions at Level III outlined. And

 7 those that are colored red we considered sensitive

 8 using our ANC criteria. Those that have no color

 9 or color, I guess it's white, would not be

 10 sensitive.

 11 So for this example what we did is divided our

 12 population of 7,500 critical loads into two

 13 categories, sensitive and not sensitive, and looked

 14 at the distribution. And in Table 5-4, it talks

 15 about the sample size and the associated Neco

 16 values that go with that. Then on Figure 5-11,

 17 that shows the different categories or which

 18 ecoregions are considered in which of the five

 19 clusters based on the mean ANC value. And then we

 20 give more of the statistics that go along with the

 21 critical load populations or I should say sites for

 22 the critical loads to be calculated. Those

 23 populations has been outlined further in Table 5-5.

 24 In this case there are 7,500 -- population of

 25 7,500 sites is then divided into these five

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 1 categories and the sample size ranges from 216 to

 2 2,500. We have big populations for each of these

 3 clusters. Then when we finally get to our single

 4 ecoregion approach, we don't provide a map there.

 5 We provide a map of the ecoregion, each of them

 6 individually earlier on. And Table 5-6 goes

 7 through each and every one of them, each of those

 8 87, and it gives you the mean and eco-value, the

 9 number of critical loads that we had calculated for

 10 that ecoregion, the mean value for that, the

 11 standard error; and then once we looked at the

 12 distribution, the 90th percentile, 75th percentile

 13 and 50th percentile. So we tried to present these

 14 statistics.

 15 DR. HUBBELL: We can potentially map out more

 16 of those. We could look at these tables and turn

 17 them into maps. Maybe that would be helpful.

 18 DR. HUSAR: Yeah. When there are exposed

 19 companion maps of both the sensitivity that Tara

 20 has been explaining how those are arising from, at

 21 the same time to see also what is the nature of the

 22 deposition maps so that you have at least some

 23 feeling as to why is it that the certain cluster,

 24 let's say, whatever are up there, why are they

 25 sensitive? Is it primarily due to the high

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 1 deposition that is driving that or because of their

 2 surveyed high sensitivity?

 3 DR. GREAVER: That's a good point. ANC, our

 4 ANC indicator integrates those two things because

 5 ANC is a consequence of both natural sensitivity

 6 and your loading. So that's why we chose ANC to

 7 base the sensitivity on.

 8 DR. RUSSELL: Rich.

 9 MR. POIROT: So you sent us as an attachment,

 10 this series of maps that show waterbodies that

 11 would show critical load of 50 and 20

 12 microequivalents per liter. I guess I was

 13 wondering is there another kind of question -- like

 14 isn't part of this categorization process really

 15 aimed at avoiding under and overprotection?

 16 So is there a companion map to these that

 17 rather than showing -- or at the same time you're

 18 showing us the different ANC levels, is there a way

 19 to show graphically under and overprotection?

 20 DR. HUBBELL: Possibly.

 21 DR. GREAVER: We played with that. We tried

 22 to do a bar graph, bar graphs, like we did in

 23 Figure 5-12 for all the ecoregions; but, as you can

 24 imagine, with the 87 different ecoregions it's a

 25 really, really large graph, but it does give you

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 1 visually, you know, some idea of who is being

 2 underprotected and who is being overprotected.

 3 What we ended up doing is we produced Figure

 4 5-14. What this is, is for these 87 ecoregions, we

 5 plotted out what's the 90th percentile deposition

 6 metric for each of those and so -- and then

 7 percentage of the ecoregions protected. So if you

 8 protect 100 percent of your ecoregions at the 90th

 9 percentile value, your deposition metric is 13.

 10 Then we also give the values for 90, 75, 25, et

 11 cetera.

 12 So this is a way that we tried to compress all

 13 87 of those into one figure and give you some idea

 14 of the relative sensitivity and the amount of

 15 underprotection and overprotection for a given

 16 deposition metric.

 17 DR. HUBBELL: I think, again, we can certainly

 18 continue exploring ways of trying to map out for

 19 individual ecoregions and particular sets of

 20 waterbodies what the level of over or

 21 underprotection is. We can continue to work

 22 through that and try to come up with better ways to

 23 present that information certainly.

 24 DR. RUSSELL: Praveen.

 25 DR. AMAR: I'm looking at Figure 5-9, the

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 1 ecoregions and you have A.B.C, 8.2.3, what is that,

 2 the .2 and .3?

 3 DR. GREAVER: That's a naming mechanism they

 4 use.

 5 DR. AMAR: Subcategories?

 6 DR. GREAVER: It is actually. At the Level

 7 III ecoregions you have the three numbers, 8.3.1.

 8 Level II would be 8.3. Level I would be ecoregion

 9 8. Level I you have far less ecoregions in the

 10 U.S., I think it's about 15. At Level II those

 11 become subdivided; at Level III those become

 12 subdivided further.

 13 DR. HUBBELL: Our apologies too, we had

 14 originally had -- we had a definitions table along

 15 with these numbers that says exactly which each one

 16 is, what their descriptive title is. I don't know

 17 what happened to that. It may have gotten somehow

 18 cut out. But there is -- there is a distinct

 19 mapping, specific word descriptions of each of

 20 these ecoregions that exist. So we'll make sure

 21 that we get that out.

 22 DR. RUSSELL: Thank you. Unless there is

 23 something burning, we probably should move on.

 24 So question 7, Andre.

 25 DR. BYTNEROWICZ: So generally I think the

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 1 concept of critical loads of course is, according

 2 to my understanding, logical and appropriate for

 3 the development of secondary standards. And this

 4 approach links concentrations of oxidized forms of

 5 nitrogen and sulfur with nitrogen and sulfur

 6 deposition and their acidifying effects on aquatic

 7 ecosystems.

 8 And what's important this approach also takes

 9 into consideration reduced form of nitrogen as a

 10 contributor to acidification of lakes and streams.

 11 In my previous remarks I mentioned that it's

 12 important to have in mind how it links to the

 13 effects on terrestrial consistence and nutritional

 14 effects of nitrogen deposition, but we've already

 15 discussed that.

 16 In regards to Part A of this question I have

 17 trouble with understanding that. Maybe it's the

 18 reason that I'm not a specialist in this area, but

 19 I think a portion of the document should be better

 20 or clearer origin. And I think I would probably

 21 try to modify a question because the question for

 22 me was confusing and what is the appropriateness of

 23 generalizing the factor. For me, it would be more

 24 logical, at least for me, if I wanted to discuss

 25 that would be is the proposed methodology for

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 1 obtaining BCo values adequately described and what

 2 the panel opinion is on extrapolating the exchange

 3 for the Adirondack lakes and southern Appalachian

 4 streams to the rest of the U.S. I think that kind

 5 of understanding of the problem would help us, not

 6 being so specific about the F approach.

 7 And Part B what are the views of the panel on

 8 filtering criteria, I think it's a reasonable

 9 approach in regard to application of the first

 10 screen, those ANC values below the target ANC

 11 values I think is logical, clearly described.

 12 Use of the second screen the removal of all

 13 the BCo values below 10 microequivalents per liters

 14 per year, I had problems understanding why this

 15 particular value is used. Maybe it's somewhere in

 16 the text, maybe I missed it. I have to admit I

 17 like to have a little bit more time to read the

 18 document. So maybe I have missed something because

 19 of the lack of time.

 20 In regard to the first screen for acid mine

 21 drainage and the organic acidity, I have no

 22 problems with understanding them and I think they

 23 are good. That's what I have.

 24 DR. RUSSELL: Thank you, Andre. Kathy.

 25 DR. WEATHERS: I don't have too much to add to

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 1 that, I agree. Although based on a conversation

 2 that Charlie and I had this morning, I thought the

 3 filtering approach was a good idea. But one

 4 question is why take out the naturally acidified

 5 lakes? Why not leave them in and see how it comes

 6 out in your analysis? Leave them in and adjust the

 7 percentage of lakes that are protected.

 8 So I know it was responsive to our questions

 9 and comments last time around that you did the

 10 filter.

 11 DR. HUBBELL: We did consider leaving them in

 12 and adjust the percentage or take them out. We

 13 determined if we took them out when we selected the

 14 percentage and went forward with that, those lakes

 15 would still receive some protection. We just

 16 wouldn't be targeting them because they're already

 17 below the amount of ANC that we could possibly hope

 18 to achieve.

 19 So the idea was that, you know, that you base

 20 your critical load distribution and your target

 21 critical load on those that are both sensitive and

 22 likely to be responsive and then you accept that

 23 you'll get additional protection for those that are

 24 not responsive to atmospheric deposition.

 25 DR. WEATHERS: You might reconsider taking

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 1 that class of lakes out up front, filtering the

 2 acid mine drainage, yes, you might reconsider.

 3 Charlie, I don't know if you wanted to add to that.

 4 DR. RUSSELL: Charlie, you're up.

 5 DR. DRISCOLL: So I agree with what Kathy

 6 says. I feel, I think fairly strongly, that it's a

 7 mistake to remove high DOC lakes and the very

 8 acid-sensitive lakes.

 9 I agree, acid mine drainage, that's fine, that

 10 makes good sense to eliminate those from

 11 consideration because you're filtering on the front

 12 end and then you're filtering on the back end to

 13 protect some level of lakes, 90 percent,

 14 70 percent, whatever the value is that's

 15 determined. You can always flag those systems and

 16 indicate that those systems never had an ANC above

 17 50 and maybe that's criteria for, you know, why

 18 they wouldn't achieve protection. It seems to me

 19 if you include them, these lakes, it's a more

 20 transparent part of the process.

 21 The other thing is your values are, at least

 22 for DOC, are arbitrary. You're selecting 10

 23 milligrams per liter. That's a very high value,

 24 but there are lakes or surface waters in very

 25 sensitive areas that can be -- that organic acids

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 1 can influence the acid-based chemistry at

 2 relatively low concentrations.

 3 So I think a value of 10, you know, indicating

 4 that those are naturally acidic organic acids is

 5 arbitrary. And those systems that have high levels

 6 of DOC and naturally occurring organic acids can

 7 also show effects of acidic deposition. They can

 8 show elevated sulfate. They can show elevated, you

 9 know, inorganic aluminum. Why not include them and

 10 just flag them as part of the analysis?

 11 I know New York would be very upset if you got

 12 rid of some of those systems because there is a lot

 13 of lakes in the Adirondacks that fall into those

 14 categories that you're throwing out on the front

 15 end.

 16 In terms of the other questions about the

 17 critical loads approach, I think that makes sense.

 18 I endorse that. It's widely used throughout the

 19 world and it made sense that we use something like

 20 that.

 21 And then the other question was the F-factor

 22 approach. And I agree that using a steady state

 23 approach like the F-factor approach might be a good

 24 initial analysis, but I think, as I said

 25 previously, ultimately we need to know the time

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 1 scale of recovery. And so I think parallel efforts

 2 for applying dynamic models need to be done.

 3 That's going on in a number of case studies now.

 4 DR. RUSSELL: Kathy.

 5 DR. WEATHERS: Just a question on the F-factor

 6 approach since all of us seem to be fairly confused

 7 what the question was. What question did you want

 8 answered?

 9 DR. HUBBELL: What we wanted was an answer to

 10 what Andre was saying, which is have we

 11 appropriately evaluated the available information

 12 to characterize base cation weathering and is this

 13 a reasonable approach given the available data we

 14 have?

 15 DR. LYNCH: What Bryan said, that's what we're

 16 trying to get at. Is this a reasonable approach

 17 given the availability of data and where we are on

 18 the science today?

 19 DR. WEATHERS: But you're also using not just

 20 the F-factor approach to get at base cation supply

 21 weathering, right? Is that what I understood

 22 from --

 23 DR. LYNCH: Yeah. Well, okay, just to

 24 clarify, I mean, the idea behind the base -- the

 25 F-factor is this idea if you have acid anions on

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 1 the soil, they're going to cause some level of

 2 leaching. And so we want to remove that out of the

 3 calculation in terms of estimating the critical

 4 load.

 5 And so where you have sensitive systems that

 6 becomes very important because then you can be

 7 using the water quality data depending on where you

 8 took it. In terms of its history, you can be

 9 overestimating what the base cations flux to that

 10 system would be. And so the F-factor is saying,

 11 well, it's probably something lower than -- lower

 12 than that.

 13 When you have systems with a lot of base

 14 cations, you know, in a sense the value becomes one

 15 and it's less important. And so that's where

 16 that's coming in. It's trying to get us a way to

 17 correct for that value.

 18 And so what we're trying to get at is it's

 19 not -- I mean you can do dynamic modeling and

 20 compare and there is two graphs and two case

 21 studies in there in the Adirondacks and the

 22 southern Appalachians. And we're going to do even

 23 more comparisons there. That shows that if you use

 24 those two methods that if you're generally on the

 25 low end, so 80 microequivalents or less of ANC, you

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 1 know, you get pretty good comparisons. Where it

 2 begins to fall apart in the Adirondacks is when you

 3 get higher values. And in general it's more

 4 scattered in stream systems in terms of that.

 5 And so, you know, is it approach -- do we want

 6 to refine that approach? Definitely. But what

 7 we're looking for is this a way -- is it okay to

 8 move forward with this or is there better

 9 approaches that we should be thinking about that,

 10 you know, we can be looking to be modeling, et

 11 cetera?

 12 DR. HUBBELL: One of the critical things Jason

 13 said if it performs well, where we're most

 14 interested in the range of minus 50 to a hundred of

 15 ANC, you know. We're not as concerned about the

 16 really high ANC values because they're not likely

 17 to be affected by these standards, those areas,

 18 because they're going to have such high critical

 19 loads that they'll allow for a regular deposition.

 20 DR. SCHEFFE: I think for consistency the

 21 F-factor approach was used in all the critical load

 22 calculations nationally.

 23 DR. LYNCH: It's easy to do it. Can I go back

 24 and ask Charlie a question, based on a comment?

 25 DR. RUSSELL: Sure.

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 1 DR. LYNCH: The concern, Charlie, for why we

 2 added in the DOC criteria was the case of say

 3 Florida. And an example there is you wouldn't

 4 necessarily want to constrain or, you know,

 5 overregulate in Florida. And so that's, you know,

 6 Pacific and midwest the acidity may be driven more

 7 naturally. We don't want to overprotect in that

 8 system. We're trying to create a balance.

 9 DR. HUBBELL: The issue is if we leave them in

 10 there when we do our percentages, you can say,

 11 well, you can adjust the percentages; but the

 12 percentage of targeted lakes might have to vary

 13 quite a bit between the different types of systems.

 14 If we're looking for a consistent percent of

 15 waterbodies to protect across the country, better

 16 to take out things we don't want to protect first

 17 so we can say consistently we're trying to protect

 18 90 percent.

 19 If you leave those in, you might say, well, in

 20 Florida we only want 70 percent because 25 percent

 21 are naturally acidic lakes. It made it more

 22 complicated to think about how to set a single

 23 parameter as a target percentage throughout the

 24 country.

 25 DR. DRISCOLL: It's been a long time since

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 1 I've looked at data in Florida. And I know that

 2 they are -- they're interesting systems. And they

 3 do, some of them, have high DOC, but they also have

 4 very high chloride as I recall. And you could have

 5 conditions where chloride could impart natural

 6 acidification if the sodium is retained on the

 7 exchanger.

 8 I understand, you know, the problems with

 9 Florida; but, you know, I think that there are also

 10 issues, as I indicate, in areas like the

 11 Adirondacks or the upper midwest where there are

 12 high DOC systems where there are impacts as well.

 13 So I'll have to think about Florida more, but I

 14 think these other systems are relevant as well.

 15 DR. HUBBELL: If there is another criteria

 16 that can be used to screen out Florida than just

 17 saying Florida lakes are out, if we can come up

 18 with another criteria, obviously, that's something

 19 we could use. It's trying to find what are the

 20 criteria that are most useful for screening out

 21 lakes that would be responsive to and sensitive to

 22 deposition.

 23 DR. DRISCOLL: I'd have to go back and look at

 24 the Florida systems. Like I said, it's been a long

 25 time since I did. I'd have to try to refresh my

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 1 memory.

 2 DR. RUSSELL: Any other questions, comments?

 3 DR. SCHEFFE: Just one more part.

 4 DR. RUSSELL: Rich.

 5 DR. SCHEFFE: Let's assume, you know, we use

 6 this 10 cut off of 10 microequivalents for DOC,

 7 what's in the Adirondack lakes that most of those

 8 lakes were not screened out, wouldn't that

 9 alleviate some of the concerns you have? Because,

 10 again, the concern about some of these naturally

 11 heavily organic waters, I mean, I think Bryan's

 12 point is really something we are real concerned

 13 with in terms of some consistency in terms of

 14 population of protecting waterbodies.

 15 So how would you respond to that if, you know,

 16 in essence when we look at this, most of those

 17 sensitive waterbodies in the Adirondacks are

 18 actually included in the compilation?

 19 DR. DRISCOLL: That's fine. I understand that

 20 there will be some, you know, that there will be a

 21 lot of lakes in the Adirondacks, but there will

 22 also be a lot of lakes that have background ANC

 23 values below 50, and there will also be a fair

 24 amount of lakes with DOC values that are high.

 25 So I'm not saying that at the end of the day

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 1 you wouldn't filter those out. I'm just saying

 2 when you come up with your targets, you can flag

 3 those values so that that's, you know, part of the

 4 decision making process in terms of justifying the

 5 target value of 90, 95, 80, whatever -- whatever is

 6 come up with. It's just an alternate approach to

 7 do this.

 8 I think rather than having two screens, one on

 9 the front end, one on the back end, why don't you,

 10 to the extent you could, have one screen and

 11 everybody understands that?

 12 DR. RUSSELL: Thank you. Andre, you're still

 13 up.

 14 DR. BYTNEROWICZ: I guess question eight, yes.

 15 DR. RUSSELL: Question eight, yes.

 16 DR. BYTNEROWICZ: Well, I think the proposed

 17 approach makes sense and utilizes the best

 18 available knowledge on levels of distribution of

 19 reduced nitrogen. And in terms of not having a

 20 separate sample for ammonia I think is the way to

 21 go.

 22 I have a remark regarding distribution of

 23 concentrations on the spatial scale and due to high

 24 ammonia deposition velocity and possibly the steep

 25 concentration gradients ammonia source areas, I

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 1 think that should be taken into account. And,

 2 therefore, averaging reduced nitrogen concentration

 3 over large areas may lead to missing smaller areas

 4 where ammonia concentrations may be seriously

 5 elevated with potential high geopolitical and

 6 ecological effects. Therefore, option two, I think

 7 I would vote for that because it allows for a

 8 conditional spatial refinement of sensitive areas

 9 to reflect the heterogeneity of NHx deposition.

 10 And following that, as we discussed in our

 11 previous meetings, and you did discuss in your

 12 previous documents a much better understanding of

 13 spatial and temporal distribution of reduced

 14 nitrogen, especially among the U.S., is critical.

 15 And efforts should be continued to assure that we

 16 can accomplish this goal at the national scale.

 17 That's what I have to say.

 18 DR. RUSSELL: Thank you. Kathy.

 19 DR. WEATHERS: Yeah. Are there any other

 20 options? I agree that including this is really

 21 important, but are there any other options for

 22 spatial refinement, which is I think what we're

 23 talking about here, it would be desirable to not

 24 only have ammonia and ammonium deposition, but have

 25 better spatial refinement than we get with the CMAQ

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 1 model.

 2 DR. HUBBELL: If you look at page 9-8, there

 3 is an interpolated ammonia map that is based on

 4 current CMAQ modeling. Clearly, you could go into

 5 the individual grid cell and use that value, but is

 6 that appropriate and representative of the area

 7 you're trying to cover with understanding of the

 8 NOx and SOx concentrations that are going to be

 9 then combined with that to determine the overall

 10 loading. So that's what we're trying to get,

 11 again, that balance.

 12 Our current thinking on this, again, you could

 13 go with the ecoregion size and do an average over

 14 that. You can try to come up with some smaller

 15 groupings similar to polygons based on the credence

 16 values. You can come up with some polygons that

 17 represented areas of more relatively uniform

 18 ammonia deposition that could be then bend

 19 together; or you could simply say, you know what,

 20 we're representing area of 12 kilometers with our

 21 monitor and we're going to use a 12-kilometer grid

 22 cell to match that. Those are the options we could

 23 go to.

 24 It's not clear to me what is the most

 25 appropriate overlap between those two, between the

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 1 NOx and SOx, ambient concentrations and the

 2 deposition of ammonia. Advice on that would be

 3 very welcome. It's not a hundred percent clear to

 4 me what is appropriate to match those two together.

 5 It's clear we want to do that.

 6 DR. WEATHERS: That is a challenge. It seems

 7 to me, my gut call is they've got to be matched to

 8 the scale that CMAQ is modeling right now. In part

 9 that's because it would also be desirable to have

 10 better spatial resolution for the NOx and SOx

 11 deposition, which concentrations may be more

 12 uniform over that area, but deposition is not and

 13 it's based on vegetation of subsurface and that

 14 sort of thing or dry deposition.

 15 So this is that devil in the details of the

 16 spatial scales, matching spatial scales, scaling up

 17 and scaling down the various factors in the AAPI

 18 and for the deposition. So my call would have that

 19 be the same as the CMAQ.

 20 DR. HUBBELL: Yeah. One of the things we're

 21 looking at too is the deposition transference

 22 ratio, averaging them over that same spatial scale

 23 that we're interested in because it is, again,

 24 because of these issues that the concentrations are

 25 not going to match the deposition at a very fine

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 1 scale, but over a broader scale they may match much

 2 better. That's one of the things that we'll

 3 continue to explore as well is how does the spatial

 4 scale affect the relationship between the

 5 concentrations and the deposition.

 6 DR. WEATHERS: Yeah. And the links back to

 7 one of the appeals of the ecoregions, because, in

 8 fact, it's the vegetation type that will influence

 9 this deposition if that's clustered together.

 10 DR. HUBBELL: Yeah, okay. Thank you.

 11 DR. RUSSELL: Charlie.

 12 DR. DRISCOLL: So last time we met I had a

 13 comment about the effects of nitrate deposition

 14 versus ammonia deposition on whether or not they

 15 would have an equivalent effect. So I went back

 16 and did a little work on this.

 17 So we actually did some -- a number of

 18 simulations looking at the tradeoffs between

 19 nitrate and ammonia. And I thought that there

 20 would be some effect, but the effect, at least from

 21 our model calculations, is relatively minor, only

 22 one or two microequivalents per liter relatively.

 23 We did it for a number of systems, some that

 24 show fairly high nitrogen leaching and some that

 25 show relatively low nitrogen leaching. From that

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 1 standpoint, which I brought up last time, that does

 2 not seem to be a consideration.

 3 DR. RUSSELL: Panel?

 4 DR. BYTNEROWICZ: If I could.

 5 DR. RUSSELL: You certainly may.

 6 DR. BYTNEROWICZ: I forgot to mention when I

 7 had my time, there is a new paper by Robin Dennis,

 8 Science Atmospheric Pollution Research. It's a new

 9 journal just published. He's talking about

 10 distribution of ammonia and changing basically the

 11 common knowledge that ammonia can be transferred

 12 over a long distance. I think it's a very valuable

 13 new piece of information.

 14 DR. SCHEFFE: That's in Chapter 7, actually.

 15 I used that very liberally in Chapter 7 in terms of

 16 talking about some of the improvements in CMAQ,

 17 especially in characterizing ammonia.

 18 DR. HUBBELL: And that is, again, another

 19 reason to potentially consider broader spatial

 20 averaging rather than just refined because there

 21 are other gradients, you can see from the

 22 deposition map, there is some pretty fine gradients

 23 around major source areas and it's probably a good

 24 idea to really again -- these are the things we can

 25 look at as we think about implementation issues as

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 1 well, but defining that spatial area that's

 2 represented by this particular input to the

 3 modeling I think is very important. Again, we're

 4 going to continue to try to develop those

 5 relationships and form that before we get to the

 6 rule.

 7 DR. BYTNEROWICZ: Just to respond to that, but

 8 it has to be done cautiously because our data from

 9 Sierra Nevada shows that over a distance of

 10 70 kilometers, running from California central

 11 valley into eastern Sierra, you can reduce on the

 12 average ammonia concentration from about four or

 13 five micrograms per cubic meter to around one or

 14 two. So it's not a very steep gradient, you know.

 15 DR. HUBBELL: Sure.

 16 DR. SCHEFFE: Obviously, it's going to vary

 17 quite a bit for terrain and vegetation features

 18 that go along those transects.

 19 DR. BYTNEROWICZ: What's interesting when we

 20 compared the transect with what we saw 20 years

 21 ago, the gradient at that time was much stronger

 22 because we were going down to about one microgram

 23 per cubic meter or below. So it looks like with

 24 the change of gasoline formulation and higher

 25 emissions of ammonia we are having larger, stronger

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 1 effect over a larger scale.

 2 DR. RUSSELL: Kathleen.

 3 DR. WEATHERS: Question: Actually, Charlie,

 4 your simulations what I think you just said

 5 translating into the terms that are being used here

 6 is that ammonia deposition would actually go into

 7 the Neco term. Is that right? It doesn't come out

 8 as nitrate if you add more ammonium? It would

 9 functionally go into the tradeoff curve as a bigger

 10 Neco term over time?

 11 DR. DRISCOLL: Possibly. What I did was I

 12 took for a series of watersheds in the Adirondacks,

 13 I looked at a range of hypothetical nitrate ammonia

 14 deposition. And I was thinking since ammonium is

 15 cation, if you altered it, you would have a

 16 different response than nitrate, which is an anion.

 17 There were differences in the way I thought

 18 they would go, but they were relatively subtle. I

 19 think for 20 sites we looked at maybe one or

 20 two microequivalents per liter variation. Because

 21 ammonium is more acidifying, there was a little bit

 22 greater effect with ammonia than nitrate. Nitrate

 23 is more alkalizing, but it was fairly subtle.

 24 DR. WEATHERS: Yeah. The reason I'm asking is

 25 I'm thinking about the way you've conceptualized

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 1 the tradeoff curves and where ammonium deposition

 2 and Neco sit and whether in terms of process that's

 3 something you can or would like to take into

 4 account? Does it actually translate into a bigger

 5 Neco term?

 6 DR. SCHEFFE: So what we do with the Neco

 7 term, we consider both nitrate and reduced nitrogen

 8 to be exactly equivalent in terms of its effects on

 9 the ecosystem. So Charlie had raised the question,

 10 well, that might not necessarily be true in terms

 11 of how it goes. So what we're hearing from Charlie

 12 is the assumptions we're using for Neco, we would

 13 keep it pretty much the same the way we represent

 14 it in the equation form.

 15 So in concept, the Neco term it can be looked

 16 at it's going to be acting on any form of nitrogen

 17 that deposits. We do separate out and we do have a

 18 relationship between Neco and reduced nitrogen to

 19 kind of account for, you know, hypothetically how

 20 much reduced nitrogen can be taken up, you know, by

 21 the whole system and we look at it in those terms

 22 as well.

 23 DR. RUSSELL: Any other questions? Looking at

 24 the time, I think we'll break for lunch. If you

 25 look at -- well, we actually have about ten more

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 1 minutes. I'll keep it here for ten more minutes.

 2 With that, Naresh.

 3 DR. KUMAR: Question nine.

 4 DR. RUSSELL: Question nine.

 5 DR. KUMAR: That's the deposition transference

 6 ratios TNOy, TSOx. I didn't see any other changes

 7 in these. I don't know whether I missed anything

 8 or not.

 9 DR. HUBBELL: We changed the name.

 10 DR. KUMAR: Yeah. Major concerns means these

 11 are very predictable things between aggregate

 12 concentration and deposition and devising a model

 13 that can't be evaluated because of a lack of data.

 14 So you looked at some of the variability using

 15 a model, variability in concentrations. Some

 16 equations can be large, but I was wondering why not

 17 also look at the variability from different models

 18 because, you know, CMAQ and other models are being

 19 used by different agencies than EPA. Just trying

 20 to see how stable the issue is using different

 21 models. Also something which is not completely

 22 looking at different mechanisms, I think that needs

 23 to be done.

 24 DR. SCHEFFE: Yeah. If I could respond, those

 25 are good points. And so yeah, we would want to

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 1 look at the differences related to interannual

 2 variability in meteorology. We would want to look

 3 at differences with regard to emissions and we'd

 4 want to look at differences with regard to

 5 different chemical mechanisms and treatments there.

 6 So we do have some examples of variability,

 7 some spatial variability as well, as well as some

 8 response to different emission scenarios that we're

 9 really, you know, those -- we're very optimistic

 10 about the results of those. When we look at the

 11 difference between the base case in 2005 and moving

 12 into the future in 2030 where we see approximately

 13 50 percent reduction in NOx and 40 percent

 14 reduction in SOx, and we see quite a bit of

 15 stability retained in those ratios, which is very

 16 important.

 17 We do have to do those other analyses and we

 18 have those planned. And it's a matter of trying to

 19 find -- what we really want to do is have the

 20 analyses of isolating the chemical mechanism using

 21 the same meteorology and the same emissions

 22 scenario so we can kind of look at what is the

 23 effect of different chemical mechanism treatments

 24 on that. And so that's one of the things that we

 25 really intend on having done before this document

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 1 becomes final.

 2 DR. HUBBELL: That's also true for the model.

 3 One of the problems we ran into is finding

 4 something that's the same in terms of inventories

 5 and everything as the CMAQ run is not easy.

 6 Because we also often have to try to find existing

 7 modeling runs that have been done because there is

 8 a huge demand for modeling in EPA and not a lot of

 9 resources. We've been trying to take advantage of

 10 existing runs. Unfortunately, there wasn't a

 11 matching exact one for CMX and CMAQ.

 12 DR. KUMAR: Just looking at that, and seeing

 13 how variable it is, is useful.

 14 DR. SCHEFFE: I agree. Even though it's

 15 mixing all those different processes together, it

 16 is useful. It's something we're trying to kind of

 17 nail down as well.

 18 DR. RUSSELL: In fact, I wouldn't see there is

 19 much need to look at exact matches for something

 20 like this.

 21 DR. HUBBELL: You inflate the two things.

 22 Although we've established emissions aren't

 23 important in terms of it's not introducing

 24 variability, it won't be as big a deal. But if

 25 you're using a different emissions inventory with

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 1 KMx than you are with CMAQ, then you're getting

 2 both the emissions and modeling differences that

 3 might be impacting.

 4 DR. SCHEFFE: It would important if you have

 5 big differences you'd want to kind of have some

 6 insight in terms of what perhaps is causing those

 7 differences.

 8 DR. RUSSELL: Right. But my view is if this

 9 is going to work that well, there better not be

 10 that big of a difference.

 11 DR. HUBBELL: You have to be stable with

 12 everything.

 13 DR. SCHEFFE: That's a good point.

 14 DR. HUBBELL: It's diagnosing what you would

 15 do with it.

 16 DR. RUSSELL: Right. The first thing I would

 17 do is say is this a hard stop?

 18 DR. HUBBELL: Fair enough.

 19 DR. KUMAR: Also, the variability I assume is

 20 being driven by wet deposition patterns from year

 21 to year. But maybe you can also verify, is it --

 22 does the wet deposition ratio change or even the

 23 dry deposition ratio change when you go from one

 24 unit to another?

 25 DR. HUBBELL: That could be looked at as well.

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 1 DR. KUMAR: That's all I have.

 2 DR. RUSSELL: Rudy.

 3 DR. HUSAR: Not much new to add here. It

 4 still seems natural and meaningful to use the CMAQ

 5 for making those estimations of the deposition,

 6 different parts of the deposition. The aggregation

 7 procedure also makes sense lumping them in

 8 deposition.

 9 The word -- the statement here that, well, if

 10 indeed those estimates let's say on the deposition

 11 do indeed match the observation, but this is now --

 12 the problem is that the model estimation of the dry

 13 deposition in particular in one of your tables is

 14 off, a 40 percent difference in the sulfur dioxide

 15 simulation. That simply indicates that something

 16 about the deposition particularly outside is not

 17 quite right. If the model overpredicts by

 18 40 percent that means it is not removing

 19 adequately. So the estimate of the dry deposition,

 20 which is one of the biggest, probably biggest,

 21 terms in your overall deposition is going to be

 22 off, substantially off, okay.

 23 Now, and that's the part that later on in

 24 Chapter 7, you know, is not dealt with because you

 25 don't necessarily have enough data, et cetera, to

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 1 see neither the magnitude, nor the variability, nor

 2 for that matter where the spatial is for that

 3 region.

 4 So that's still a hang up, you know, issue

 5 with those, fixing, making sure that that overall

 6 mass balance within the model does actually come

 7 out right.

 8 DR. SCHEFFE: Yeah. Those are really good

 9 points. And I think one of the things -- what's

 10 come to light when we look at things because we've

 11 been using these models for air applications so

 12 often and so familiar, and different questions and

 13 different challenges arise when we look at it from

 14 a deposition perspective. And having that split

 15 between sulfur dioxide in particular to sulfate,

 16 you know, is increasingly more important in these

 17 applications. You know, the 40 percent is not --

 18 that's not what I would say is a generalizable

 19 number in terms of the ratio between CMAQ and

 20 sulfur dioxide, but nevertheless there is a trend

 21 for CMAQ to be overpredicting sulfur dioxide.

 22 There is also some concerns with regard to the

 23 very limited amount of observations that we have in

 24 the CASTNET network for sulfur dioxide as well and

 25 how accurate those measurements are.

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 1 So there is a lot of work as we move forward.

 2 I think Myron was making those points. We really

 3 have to be looking at that more and more carefully.

 4 I agree with you. It's very important; that sulfur

 5 mass balance is very, very important for this

 6 process.

 7 DR. HUSAR: Yeah. And just to highlight the

 8 emphasis that you could now contribute to that

 9 whole fixing, including the CMAQ, would in fact be

 10 on the sulfur dioxide dry deposition because so

 11 much in the past was about the sulfate.

 12 DR. SCHEFFE: Sure.

 13 DR. HUSAR: Now, the thing is this is about

 14 the other part, which actually is the bulk of

 15 the --

 16 DR. SCHEFFE: I agree, emphasis now.

 17 DR. HUSAR: This is just a routine procedural

 18 kind of a point over here, I still have some

 19 concern about the reading of this thing callid

 20 transfer something or another.

 21 DR. SCHEFFE: Transference.

 22 DR. HUSAR: Transference ratio. It's the same

 23 as I stated before. Deposition velocity is not a

 24 physical entity. It happened to arise from the

 25 ratio of deposition to concentration. So,

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 1 therefore, there is no reason to invent a new term

 2 for deposition velocity that may be either dry

 3 deposition velocity or wet deposition velocity in

 4 the ratio of deposition or total deposition

 5 velocity. In that case, you would avoid, among

 6 other things, the confusion that it causes, the

 7 issue within your own document. If it's named five

 8 different ways in different sections of the

 9 document, ambient concentration, deposition,

 10 transformation ratio quite a big difference.

 11 DR. SCHEFFE: It's supposed to be X'd out.

 12 DR. HUBBELL: We tried to catch that.

 13 DR. HUSAR: And things like that. It's just

 14 my favorite expression on that when you have enough

 15 natural complexity in the system there is no need

 16 for artificial complexity introduced.

 17 DR. RUSSELL: I think we are the ones that

 18 suggested a different name was advisable because it

 19 isn't either a dry deposition philosophy or wet

 20 deposition philosophy. So I think we're the ones

 21 who requested that.

 22 DR. SCHEFFE: Rudy, we've gotten as much of

 23 the other kind of comments as to how dare you call

 24 this thing a deposition philosophy or deposition

 25 ratio because deposition only, only corresponds to

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 1 individual species. So when you aggregate things

 2 there were a lot of people that were set off that

 3 we were calling it a deposition philosophy.

 4 DR. RUSSELL: CASAC has changed its mind on

 5 things before.

 6 DR. HUBBELL: We're happy to call it whatever

 7 you want to call it.

 8 DR. HUSAR: Maybe I would like to have a

 9 conversation with the person who --

 10 DR. RUSSELL: I don't recall who actually

 11 first did that. Praveen.

 12 DR. SCHEFFE: Yeah, it was Praveen.

 13 DR. RUSSELL: Talk to Praveen.

 14 DR. AMAR: I used to be the deposition person

 15 too. But I think transference too, how do you say

 16 it, transference ration, yeah, I think it makes

 17 sense because it's simply a modeled number. You're

 18 dividing all your deposition to all your

 19 concentrations on a wet basis.

 20 So, anyway, my comment in addition to what

 21 Naresh had to say, I think you mentioned on page 56

 22 about that some of the sulfate is found in coarser

 23 fractions and CMAQ does not address coarse

 24 fractions of PM and then you notice something to

 25 the effect that you are going to address that in a

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 1 monitoring chapter, which I have not read

 2 thoroughly. Have you addressed that issue?

 3 DR. SCHEFFE: I think there was probably some

 4 carryover from earlier versions. Current versions

 5 of CMAQ do incorporate coarse particle treatment in

 6 there, okay.

 7 DR. AMAR: So that's not an issue then.

 8 DR. SCHEFFE: It's always -- characterization,

 9 of course, particles in general is an issue, but

 10 one of the points that we were trying to make and,

 11 to be honest, it ends up being in the noise

 12 probably, but what happens is when you look at --

 13 forget about models or mantras when you consider

 14 all the distributions of particles in the air, we

 15 know, you know, from the various studies that the

 16 vast majority, 80, 90 percent or more, of particles

 17 are in the fine fraction, less than two and a half

 18 microns, okay.

 19 And initially we were just under the

 20 assumption, all right, we could basically not worry

 21 too much about the coarse fraction because so much

 22 of it is in fine fraction. But because of the

 23 different deposition velocities, where you start

 24 getting into direct gravitional effects with large

 25 particles, that small tail that's in that larger

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 1 size fraction can have consequences in terms of

 2 contributing a lot to the actual deposition of

 3 sulfate. But, having said that, sulfate deposition

 4 is relatively small compared to total sulfate

 5 deposition.

 6 DR. RUSSELL: Though, being specific, I

 7 thought CMAQ coarse fraction you do not have

 8 sulfate growing into -- growing into the soil.

 9 DR. SCHEFFE: I think we need to check on the

 10 specifics of that, but the newer versions of CMAQ

 11 have started to incorporate coarse particle

 12 treatment.

 13 DR. AMAR: To be clear then, the document says

 14 it might be a big issue. What I'm hearing from you

 15 that it may not be and, therefore, we don't need to

 16 address it?

 17 DR. SCHEFFE: Well, but, anyway, with regard

 18 to CMAQ, regardless of how that treatment is,

 19 whatever particle sulfate mass is there, it will be

 20 incorporated into a mass balance context,

 21 regardless of, you know, what part and size

 22 distribution. That's all being included there,

 23 okay.

 24 From a monitoring perspective this has other

 25 implications where we are recommending that we have

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 1 an open inlet to capture all the particle sizes.

 2 DR. RUSSELL: It has the ability to calculate

 3 the transference ratio and the uncertainties

 4 therein? True?

 5 DR. SCHEFFE: I've got to think about that

 6 because the way it's all kind of embodied in the

 7 model -- so that would --

 8 DR. HUBBELL: I think --

 9 DR. RUSSELL: What I'm saying is since you're

 10 using CMAQ you can't calculate a transference

 11 ratio, but CMAQ doesn't really capture the sulfate

 12 in the large -- in the coarse particle, the 2, 5,

 13 10, but then you're measuring what's happening in

 14 the two, five to ten and applying a CMAQ

 15 transference ratio that's really only based on the

 16 up to PM 2.5. There is a little bit of sloppiness

 17 there.

 18 DR. SCHEFFE: Yeah, there is. There is some

 19 what I would call inconsistency there.

 20 DR. RUSSELL: Much better word. Thank you.

 21 Other panel questions or comments? Myron.

 22 DR. MITCHELL: I guess it's kind of based upon

 23 some other comments about the CMAQ application,

 24 looking at the chapters, my understanding that

 25 looking at these transference ratios was done from

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 1 CMAQ runs from 2002 to 2005, which would probably

 2 capture a fair amount of meteorological variation

 3 but very little in terms of emission variation. It

 4 seems a little presumptuous to me to indicate there

 5 is low variation. I'm looking at changes in

 6 emissions over time and attributing that and saying

 7 this is capturing that. I think that needs to

 8 be --

 9 DR. SCHEFFE: It's a good point, but we did

 10 have a 2030 emission scenario in which there were

 11 30 percent reduction in NOx and 40 percent in

 12 reduction in SOx in that domain. That's what we're

 13 talking about in terms of its ability and

 14 variability in emission changes.

 15 DR. MITCHELL: Looking at some of these

 16 changes like wet and dry deposition ration, looking

 17 at long-term actual like CASTNET, I'm concerned

 18 that you're basically looking at what is already in

 19 the model and calculating out the model and saying

 20 the model works. That's not a very valid -- that's

 21 not a very firm foundation.

 22 DR. HUBBELL: Sure. Sure. There is some ORD

 23 data, some folks at ORD who are thinking about this

 24 and we're trying to get that analysis done.

 25 They're looking at the co-located sites where you

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 1 have both the concentration measurements and the

 2 deposition measurements.

 3 DR. MITCHELL: Then I get -- I look at Figure

 4 5-20 on page 558, I look at these ratios between

 5 deposition and concentration, particularly I was

 6 curious about the sulfa form. I have a hard time

 7 figuring out what in the heck would cause -- what

 8 do you do with marine sulfate and how does -- what

 9 is driving that pattern? It doesn't make any sense

 10 what I could think about what would drive sulfur

 11 deposition in concentrations? What goes on in the

 12 coast?

 13 DR. HUSAR: Because by that time it's mostly

 14 wet deposition, all the gas is gone and -- and

 15 therefore --

 16 DR. MITCHELL: That part I know. It's like

 17 marine aerosols would be gigantic, like

 18 50 kilometers.

 19 DR. HUSAR: It's kind of the artifact of the

 20 inversion --

 21 DR. MITCHELL: This seemed curious to me.

 22 DR. HUBBELL: What it's showing is that when

 23 you get off the coast, the concentrations are very

 24 low. So the deposition-to-concentration ratio --

 25 the deposition is mainly wet deposition and not as

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 1 related or deposition --

 2 DR. MITCHELL: Concentrations of marine

 3 sulfate.

 4 DR. HUBBELL: You're not getting that --

 5 DR. MITCHELL: How is that covered? It's a

 6 question?

 7 DR. SCHEFFE: No. What we need to do actually

 8 there is a few things going on. There is the

 9 intermixing of a lot of the marine kind of

 10 processes that are markedly different than what's

 11 going on land. And then you also have some

 12 boundary effects that come into play as well. And

 13 so we need to have a better -- we need to have a

 14 better description of what's going on.

 15 We see that with a lot of things. You can

 16 look at almost any kind of a model output. These

 17 might be transformation ratios. We can look at

 18 concentration patterns for many, many different

 19 species and we see incredible gradients. We can

 20 get a better description of that for you.

 21 DR. HUBBELL: To be fair to the model, most of

 22 the valuations were focused on what's over --

 23 DR. MITCHELL: I understand. I know the

 24 Oceanic Department is looking at critical loads and

 25 looking at the sensitivity areas, and I was

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 1 wondering how the modeling is working then.

 2 DR. RUSSELL: Not to cut us off, we're going

 3 to have a cold lunch if we don't break. We have a

 4 hot lunch. So let's get back at about 1:10.

 5 (Lunch recess.)

 6 DR. RUSSELL: Correct me if I'm wrong, I think

 7 we're up to question 10.

 8 MR. POIROT: I have that.

 9 DR. RUSSELL: Yes.

 10 MR. POIROT: Before we leave the last

 11 question.

 12 DR. RUSSELL: Yes.

 13 MR. POIROT: Regarding these transference

 14 questions, I ended up having a confidence crisis

 15 over the weekend in terms of how much I worried

 16 about the NOy, TNOy function. I thought I was

 17 comfortable with it the last time around, but we

 18 hadn't really been able to see the details of it.

 19 I wish the EPA people were here.

 20 DR. RUSSELL: Shall we table that one? I

 21 think we can get through number ten pretty quickly.

 22 MR. POIROT: Okay.

 23 DR. RUSSELL: And we can go back to number

 24 nine because yes, it wouldn't be bad if EPA were

 25 here to finish those other ones up. Question 10

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 1 is --

 2 DR. COWLING: Are they not coming up?

 3 DR. RUSSELL: They are, but they don't get

 4 lunch served to them. Sometimes it's not as quick

 5 for them to turn around.

 6 And keep in mind this is good timing, we can

 7 discuss things. If we need to ask EPA questions,

 8 we can wait for them to return.

 9 DR. KUMAR: A number of them are on the

 10 averaging time of three to five years. Is that

 11 appropriate given the AAPI standard? So I don't

 12 see any change in that. I will stick with that.

 13 I'll agree that's an appropriate time.

 14 DR. RUSSELL: Praveen, I thought ten would be

 15 quick.

 16 (Dial tone heard over the speaker.)

 17 MR. McNAMARA: I didn't do anything. The

 18 system must have disconnected itself. I'll re-call

 19 it.

 20 DR. RUSSELL: Any other -- the things

 21 discussed on question nine that we don't need EPA's

 22 input on? If you would like to get the feel of the

 23 panel, I guess make some statements to the panel

 24 about questions.

 25 DR. KUMAR: One question I have EPA has done

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 1 -- looked at these issues for 12-kilometer

 2 resolution, and we know things can change if we one

 3 resolution to another. Is there a need to also

 4 look at these resolution -- these ratios with a

 5 different resolution? Everything else is still the

 6 same, but the resolution changes. Would that have

 7 an effect and speak to the stability of this issue?

 8 DR. HUBBELL: We might have some runs where we

 9 have 36 kilometer and 12 kilometer and we could

 10 look at that as well. And we were also talking

 11 about doing some comparisons if you do, you know, a

 12 12-kilometer grid cell by itself compare NOy to

 13 total deposition and expand out to a grid square,

 14 keep going out that way and see how they change.

 15 That's another way to look at it.

 16 DR. RUSSELL: Is that something you all are

 17 doing right now?

 18 DR. HUBBELL: No. I think it's very doable.

 19 We have the data to do that. I made a note to

 20 myself to do that.

 21 DR. RUSSELL: Rich, back to you.

 22 MR. POIROT: I was thinking, you know, that

 23 these ratios are sort of critically important, and

 24 yet we can't touch them and explore them. It would

 25 be nice if we could see them in more detail, I

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 1 mean, different ways.

 2 I found, you know, just for example, there are

 3 some figures on page 728, Figure 7-12 that show

 4 these box whisker plots of the variability or the

 5 coefficient of variations of these ratios over

 6 time, as you model, I think this is over the longer

 7 term change in emissions. So that idea of having a

 8 metric, however it works, that remains stable over

 9 time as emissions are changed is really important;

 10 and these figures gave me better confidence than I

 11 otherwise would have had.

 12 But I guess I'm wondering are there other ways

 13 you can show this information since I just don't

 14 know what these kind of box whisker plots are

 15 supposed to look like? That they're close to zero

 16 in terms of the change over the period that feels

 17 good to me. But maybe -- is there a better way

 18 that you could display that information? Because

 19 to me that's a very compelling kind of an argument.

 20 Just before that you had these other plots showing

 21 the change over the -- over the recent years or I

 22 assume it's just the meteorology that's changed

 23 mostly.

 24 I noticed you inverted those. It's an inverse

 25 of the ratio. I'm sure you had a good reason for

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 1 doing that. Since I don't know what it is, I'm

 2 tempted to ask if we could see those the other way

 3 around. Because wouldn't it be sort of the gross

 4 overpredictions that we would want to be

 5 emphasizing rather than the large underpredictions

 6 in terms of the where -- how the outliers fall?

 7 But, again, the stability across time gives me

 8 confidence.

 9 On the other hand, then I went back and looked

 10 at the scatter plot in Chapter 4, I don't know if I

 11 can find these. On page 437, if I read it

 12 correctly, we're seeing total oxidized nitrogen

 13 deposition versus NO2, NOy and nitric acid limited

 14 to the Adirondacks region. And there is almost no

 15 correlation at all between the NOy and deposition.

 16 And that made me start to wonder is NOy really the

 17 right indicator? I kind of think it is, but I

 18 don't know if there is something wrong with this.

 19 Am I misinterpreting it in a way that --

 20 DR. SCHEFFE: When do you want me to respond?

 21 MR. POIROT: Jump in any time.

 22 DR. SCHEFFE: So one of the CASAC members

 23 requested that draft. I think it was Rich Poirot.

 24 And it was a good idea. I think it was in the

 25 context of the argument that was being made that,

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 1 you know, NO2 isn't a particularly good indicator

 2 for what we're trying to accomplish here.

 3 So in addition to the maps you have showing

 4 that the NO2 concentration are not as significant

 5 let's say in rural areas compared to urban areas,

 6 why not regress in a line with deposition. So I

 7 took a shot at that. It was in that context and

 8 yeah, I was not pleased with that. I was tempted

 9 not to include it, but I figured, well, wait a

 10 minute, I was asked to do that and it's what's the

 11 results show. It represents some of the challenges

 12 here.

 13 Now, I will say a few things. It is not

 14 surprising to me to see poor correlations between

 15 NOy and total nitrogen deposition for a number of

 16 reasons. And some of those reasons have been

 17 pointed out by some of the comments that there are

 18 different things going way above in the higher

 19 levels of the atmosphere than what's going on at

 20 the surface, particularly wet deposition.

 21 But in the other parts of that too is this was

 22 done on an individual grid cell basis, these

 23 regressions. And I know we've had a lot of

 24 discussions today about spatial aggregation and we

 25 really need to come back with a much more clearer

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 1 explanation about what our intention is in terms of

 2 how we're going to base critical loads and then

 3 ultimately how we're going to base the calculations

 4 on spatially aggregated areas and what the basis

 5 for that will be. But we are never -- I shouldn't

 6 say never. We are unlikely to ever apply these at

 7 12-kilometer grid base.

 8 A more representative regression would have

 9 looked at the Adirondacks aggregated spatially as a

 10 whole and take time slices and then look at those

 11 regressions. Because what's happening is as much

 12 as there is an interference going on, a noise

 13 that's being introduced by nitrogen dioxide.

 14 Because nitrogen dioxide doesn't deposit, for all

 15 intents and purposes, because of the soil

 16 deposition velocity, there are a number of grid

 17 cells that are in proximity to urban areas with

 18 relatively high nitrogen dioxide concentrations

 19 throughout the Adirondacks. So that's what is

 20 creating a lot of the scatter you see. You don't

 21 see that of course with something like nitric acid.

 22 It's much, much tighter.

 23 It does raise the obvious question. Part of

 24 the response to all of that is that in trying to,

 25 you know, explain some of the thinking that's going

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 1 on here, in trying to have an ambient indicator, we

 2 wanted an ambient indicator that does a lot of

 3 things.

 4 We want an ambient indicator that's

 5 representative of NOx, you know, by virtue of the

 6 Clean Air Act standards, by Clean Air Act language

 7 that's out there. NOy is certainly compatible with

 8 that.

 9 We are also concerned with if we just looked

 10 at one individual species, let's say, like nitric

 11 acid or perhaps total nitrate or something, then

 12 you have to be concerned with, well, what about the

 13 total reservoir of acidifying potential that's

 14 offered by nitrogen in the air? And if we were to

 15 eliminate NO2, for instance, we would be missing

 16 some of that potential. And you get into a lot of

 17 issues in terms of how do you account for wet

 18 deposition? You want to tie wet deposition to this

 19 process.

 20 There are other things that can be done. We

 21 could kind of look at different ways of that AAPI

 22 equation where we would separate out some of these

 23 individual species and some of those terms. But

 24 what it comes down to eventually is when we start

 25 looking at reductions over time in emissions, those

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 1 reductions in emissions are going to be reducing,

 2 you know, those NOy concentrations. Those

 3 reductions are also going to introduce reductions

 4 in deposition as well. And I think some of the

 5 relationships we have to look at in a better

 6 fashion, we did a little bit of that with

 7 transference ratios, is looking at what happens

 8 when we change the emissions of nitrogen; and what

 9 happens then to the relationship of that to

 10 concentrations in the air and to deposition. And

 11 that would be maybe another way of looking a that.

 12 But it is -- it is very challenging. And

 13 right now the way of the form equation is, it does

 14 in a mass balance and in an adequate mass balance

 15 manner tie together a lot of features that are

 16 going on in wet and dry deposition with ambient

 17 concentrations. And there are, as has been pointed

 18 out, there are a number of issues where there are

 19 incommensurabilities with the relationship between

 20 an ambient indicator and other processes that are

 21 going in the atmosphere. That's what we're living

 22 with. That's part of the reason why we feel

 23 strongly that we have to use a model that captures

 24 those processes in all the different dimensions.

 25 DR. HUBBELL: I'll point out in the risk and

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 1 exposure assessment we looked at changing NOx and

 2 then the resulting changes in deposition and

 3 concentrations. And if you recall, I'm recalling,

 4 if I'm remembering myself correctly, you saw a

 5 commensurate reduction in each one. You saw a

 6 proportionately the same kind of reductions in NOy

 7 or it might have been NOx at that time and the

 8 deposition of nitrogen.

 9 So it was clear that reducing or decreasing

 10 NOx emissions affected both the ambient indicator

 11 and the deposition measure in a proportional way.

 12 Which is another reason why we felt the indicator,

 13 the changes were correlated with each other was a

 14 good indicator for looking at standards 'cause the

 15 changes are correlated with each other.

 16 MR. POIROT: And I agree with that. I guess

 17 one of the reasons actually I was wondering about

 18 that a little bit was just to see if it would be

 19 possible to make an alternative calculation of

 20 transfer function that was based on nitric acid and

 21 nitrate. The reason and only reason -- well,

 22 several, the indicators themselves inherently are

 23 more directly associated with deposition, but,

 24 number two, having something that's kind of already

 25 measured or is measurable by, let's say,

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 1 CASTNET-type methods. Because -- we're getting

 2 ahead of ourselves on the topic. I don't want to

 3 go there too far, but, you know, in the event that

 4 we're not able to rule out a big new national

 5 continuous NO2 network, is there something else

 6 that we can approximate that with reasonably well

 7 supplementing that occasionally?

 8 So that's kind of why I was interested in

 9 that. What would the answer to that -- you could

 10 do the same thing in the model, just the ratio of

 11 those two things.

 12 DR. SCHEFFE: Yeah. And I actually have gone

 13 through that. I actually have split up and

 14 reformulated that AAPI equation to separate out

 15 nitrate kind of -- actually, a lot of it came out

 16 of discussions with Monford community about we do

 17 have the availability of doing it through CASTNET

 18 to measure total nitrate. And the total nitrate

 19 measurement in CASTNET is a fairly well regarded

 20 measurement, not the individual components, nitric

 21 acid and particle nitrate; but when you combine

 22 them, that is a fairly well regarded measurement.

 23 So that certainly could be done.

 24 It then raises some other questions though

 25 that, as I said, you are missing a very important

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 1 potential reservoir of other species because it's

 2 all the species that contribute. There are a lot

 3 of unknowns. As we move forward we've had a lot of

 4 the internal discussions. It's like, well, there

 5 is a debate in the community about how important

 6 NO2 deposition is. The Canadians believe it is a

 7 lot more important than what's currently believed

 8 in terms of the way we treat it here in the States.

 9 So there is a lot of issues in terms of moving

 10 forward, in terms of getting better

 11 characterization of deposition of all the species

 12 of nitrogen. And to leave some of them out, you

 13 know, it goes against the grain as well. It's a

 14 challenge.

 15 But to answer your question, yes, that

 16 mechanically is not that difficult to do with

 17 regards to CASTNET.

 18 DR. RUSSELL: Kathleen.

 19 DR. WEATHERS: Yeah, I'd like to underscore

 20 that request. I think it speaks to the fact that

 21 there are uncertainties everywhere in all of these

 22 calculations and it's one way to look at

 23 comparisons of CMAQ to CASTNET and also look at

 24 deposition. Despite the fact that it's modeled, it

 25 gives us some balance for understanding where CMAQ

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 1 sits relative to other measures of deposition we

 2 have. I think it's really important to calculate a

 3 speed for nitrate and compare the concentration

 4 deposition in CASTNET.

 5 DR. RUSSELL: Other panel questions, comments,

 6 discussions? Ellis.

 7 DR. COWLING: Rich, as you were talking about

 8 all the forms of reactive nitrogen, the INC

 9 committee offered the advice that NOy was the best

 10 way to deal with the oxidized forms of nitrogen.

 11 There are other chemically reduced forms of

 12 nitrogen. And then there are the organic forms of

 13 nitrogen about which we are still in the great

 14 uncertainty. But it appears that there are, if you

 15 collect precipitation, there is a fraction of the

 16 nitrogen which is not -- not inorganic, either

 17 oxidized nor reduced; and, therefore, and at least

 18 according to Hans Spurrow's measurements, that is

 19 some times.

 20 I'm just introducing the assurance that NOy

 21 was a good choice because not only did a CASAC

 22 member recommend it, but the INC committee also

 23 urged that you consider NOy as the choice so far as

 24 the oxidized forms are concerned. But there are

 25 the organic forms, those are mentioned in Chapter

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 1 7, as is appropriate of course. And maybe there

 2 are some -- we're trying to approximate total

 3 reactive nitrogen deposition and its acidifying,

 4 and essentially the nutrient enrichment kinds of

 5 effects. But the more use that we make of the

 6 phrase "total nitrogen," the more likely we are to

 7 have our minds affixed around what is really

 8 important in ecosystem response.

 9 DR. SCHEFFE: Thank you. Other -- you didn't

 10 want a response to that? Did you? Just a comment.

 11 DR. RUSSELL: Other panel discussions? Thank

 12 you. Question 11, Charlie.

 13 DR. DRISCOLL: Okay. It seems like I was

 14 assigned many multipart questions. I'm not sure if

 15 there was some message that's being sent to me, but

 16 I'll try to muddle through them.

 17 Anyway, so there was a fair amount of

 18 discussion in the report on the aspects of

 19 selecting an ANC and the implications of that. So

 20 I think that there were a number of values

 21 considered. I think the ones that were probably

 22 considered given the most attention was probably

 23 20, 50 and 100 microequivalents per liter. And I

 24 think one of the challenges here is that the

 25 response, the biological response is not really

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 1 fixed by a level of ANC, but really it's a

 2 continuum with relatively clear facts that lower

 3 ANCs and diminishing as you get to higher and

 4 higher ANCs.

 5 So I think that, you know, the treatment that

 6 was presented in the document was -- was

 7 reasonable. There is a lot of uncertainty

 8 associated with this. But it seems like, you know,

 9 what was presented was fine.

 10 I mean, at the end of the day you have to pick

 11 a value, right? And if I read between the lines,

 12 it looks like 50 is the value that you would, you

 13 know, if you had to pick a value, that's what it

 14 would appear that you're endorsing. And I think

 15 that that's a defensible position. It's certainly

 16 moderate. If you take a hundred, you'd be very

 17 conservative and 20 is probably -- there are pretty

 18 clear effects at 20. So I think 50 is a nice round

 19 number and it's probably somewhat defensible. It

 20 considers the impacts of episodic acidification.

 21 So I feel, you know, I feel fairly comfortable with

 22 that value. I think it's probably fairly

 23 defensible.

 24 DR. HUBBELL: To be clear on this, because I

 25 don't want to be misunderstood, what we're looking

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 1 for is really just, again, a range of potential

 2 options that are able to be considered by the

 3 Administrator in making a judgment about what's

 4 adverse or not adverse and what target ANC would be

 5 likely to lead to protection of public welfare. So

 6 it's more looking for a range.

 7 So what we were trying to lay out is what

 8 happened at different -- what we see is happening

 9 at different levels of ANC that would then form a

 10 potential range.

 11 DR. DRISCOLL: Would you make a recommendation

 12 for a value that might be considered?

 13 DR. HUBBELL: We recommend -- we're not making

 14 a recommendation. We'll draw some conclusions

 15 about what range might be supported by the science.

 16 DR. DRISCOLL: I think the values that are

 17 laid out and the literature associated with that I

 18 think is appropriate. I think it's fine.

 19 DR. RUSSELL: Andre.

 20 DR. BYTNEROWICZ: I cannot add too much to

 21 that. I basically agree that considering ranges

 22 from minus 50 to plus 50 equivalents per liter

 23 makes sense. And the standard of 50 seems to be

 24 reasonable. And it looks like it's based on what

 25 you have provided, the analysis you have provided

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 1 and based on what the Europeans and some of the

 2 U.S. states are doing.

 3 In regard to Part A, 11 Part A of this

 4 question is that probably a better discussion

 5 should be provided for how those proposed values of

 6 20, 50 and 100 would mean to the surrounding

 7 terrestrial because it speaks in various eco-zones.

 8 I think more specific information could be provided

 9 and not only -- there is I think it's Chapter 6 you

 10 have a graph showing various levels of deposition

 11 related to sensitive indicators for terrestrial

 12 ecosystems. It's a good graph, but I think more

 13 text would be needed to explain what you are trying

 14 to do, I mean, linkage between aquatic and

 15 terrestrial. I'd like to see it and it may be

 16 between Chapter 5 and 6.

 17 DR. HUBBELL: So are you suggesting that we

 18 give explicit weight to those co-benefits and

 19 picking a level of ANC?

 20 DR. BYTNEROWICZ: Yes, 20, 50 versus 100, what

 21 it means to the terrestrial. So for the east coast

 22 it may be sugar maple and spruce.

 23 DR. RUSSELL: Dale.

 24 DR. JOHNSON: I don't have any issue with the

 25 ANC targets picked, but there is again -- seems to

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 1 be an underlying assumption or model prediction or

 2 something that these delays that we're delaying

 3 with response and then a delay with recovery. And

 4 I think underlying that we've already discussed it

 5 a little bit during the break, but is the idea that

 6 the soils are somehow going to recover to a less

 7 acidic condition when deposition is reduced.

 8 I don't think there is any evidence -- I'm not

 9 aware of any study ever done that shows that that

 10 would occur. Models might predict it, but I don't

 11 think it's supportable.

 12 So the soils might remain acid. You remove

 13 the mobile anion and the soil solution and the

 14 streams and lakes become less acid, but not the

 15 soil. I think that's a scenario you should take a

 16 close look at.

 17 DR. RUSSELL: Thank you. Panel? Questions,

 18 comments on this? Lauri.

 19 MS. CHESTNUT: In terms of the broadest

 20 question, I think it makes sense the range of ANC

 21 that you are looking at here, but the way that this

 22 document is kind of summarizing in language some of

 23 the benefit of going from, you know, higher than 50

 24 confuses me. And the example is the last bullet in

 25 the executive summary where it says that target

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 1 levels above 50 may provide additional protection;

 2 however, overall health of aquatic communities may

 3 not be impacted. And that seems to contradict to

 4 me what it says in, for example, Table 2-1 where it

 5 says that between 50 and 100 fish species' richness

 6 begins to decline. Are there still some sensitive

 7 species that are not going to return unless you get

 8 above 50? I'm not clear on this.

 9 I think if -- and even if the populations are

 10 there, but they're not as healthy or not as robust,

 11 it seems like there is still -- it seems like the

 12 benefit, the potential benefit of going beyond 50

 13 is being underplayed in this language versus what

 14 we've seen in the evidence. I don't know.

 15 DR. HUBBELL: We'll work on that one. There

 16 is agreement.

 17 DR. RUSSELL: Other panel members? Very good.

 18 Moving on. Charlie, you're still in charge.

 19 DR. DRISCOLL: Part A. Part A.

 20 DR. RUSSELL: No.

 21 DR. DRISCOLL: 11-A.

 22 DR. RUSSELL: I think most of the people

 23 included 11-A in their comments.

 24 DR. DRISCOLL: Okay. We can move on to 12.

 25 DR. RUSSELL: Yeah.

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 1 DR. DRISCOLL: Okay. I think that the -- I

 2 think that the approaches that were considered for

 3 assessing these alternative percentages to protect

 4 is appropriate. One of the challenges here is a

 5 lot of information, the biological information are

 6 based on spatial surveys. So you have a range of

 7 water quality conditions and you see organisms

 8 responding to those range of conditions and you

 9 infer a relationship. And you infer that

 10 relationship is going to work through time. And

 11 there is not a lot of very good temporal biological

 12 information. There is a little bit of information

 13 though and it suggests that the organisms don't

 14 necessarily respond to the same -- in the same way

 15 across those chemical changes.

 16 So I guess my only comment is that there is

 17 some uncertainty associated with biological -- the

 18 temporal biological response is going to be in the

 19 same patterns that they are spatially. And it

 20 might be useful to have a little bit of text

 21 associated with that, if you can understand what

 22 I'm saying.

 23 DR. HUBBELL: So just to repeat to make sure I

 24 did get it, so what you're saying is that the

 25 current effects in relationship between effects and

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 1 ANC or pH levels or whatever that we're observing

 2 now if we're attempting to protect 90 percent by

 3 picking a critical load of the current distribution

 4 that if we change the NOx and SOx levels in the

 5 deposition that response may not be proportional to

 6 that 90 percent. In fact, you may not end up with

 7 the same percent protection because some are going

 8 to respond more than others in ways we are not able

 9 to tell from our existing scientific literature.

 10 Is that correct?

 11 DR. DRISCOLL: Yeah. I guess what I'm trying

 12 to say is that we have spatial patterns and we're

 13 assuming that those spatial patterns will hold

 14 through time for a given site. We don't -- I mean,

 15 there are not a lot of data to, you know, support

 16 or refute that. And so probably would be good to

 17 clarify that that's an assumption that's, you know,

 18 made here and response will really depend on, you

 19 know, how these organisms respond, you know, to

 20 these changes over time.

 21 DR. RUSSELL: Andre.

 22 DR. BYTNEROWICZ: For me a question came to an

 23 issue of toxicity, which is damaging individual

 24 species versus biodiversity changes. And what

 25 should be more important or are we looking for some

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 1 kind of common denominator? So that's something

 2 which I didn't see discussed and I thought I'd like

 3 to see discussed more.

 4 DR. HUBBELL: So -- so -- so relevant to an

 5 entire ecoregion, for example, we're talking about

 6 protecting 90 percent of the lakes from, you know,

 7 an ANC of 50 or 20. What you're suggesting is we

 8 should evaluate it based on not only individual

 9 responses, but whether that will preserve

 10 biodiversity across a broader set of waterbodies?

 11 DR. BYTNEROWICZ: Yes. That's basically what

 12 I would like to see because more protection -- the

 13 most protection you can provide would also provide

 14 better protection for biodiversity, if I recall,

 15 from what you were saying versus toxicity. So I

 16 don't know what would be kind of a silver bullet

 17 for what we're trying to accomplish.

 18 DR. HUBBELL: Well, I mean, just to clarify

 19 that, I mean, the way we were discussing

 20 biodiversity wasn't whether you chose 20, 50 or 100

 21 as your ANC target. When we're talking about the

 22 percent of lakes, it's a question of if you protect

 23 90 percent of lakes from an ANC of 50, one of the

 24 pieces of information we provided was do you also

 25 protect the remaining percentage of the lakes from

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 1 going below say 20, which is, you know, where

 2 really bad things start happening.

 3 So you could balance that by saying, okay,

 4 well, if we covered 95 percent of lakes, would

 5 that -- would the remaining 5 percent, would they

 6 then be protected? In other words, are you gaining

 7 at least some minimal level of protection for the

 8 lakes that you are not targeting for the highest

 9 levels of ANC? That's really what the analysis was

 10 trying to look at. Not so much within the

 11 individual lakes are we protecting against subtle

 12 damages to biodiversity versus loss of fish

 13 species.

 14 So I'm not sure exactly how to consider the

 15 biodiversity question regarding across lakes.

 16 Maybe it makes sense within a region maybe to think

 17 about do we have some lakes that have some species

 18 and some lakes that have other species. I'm not

 19 sure exactly how you quantify that.

 20 DR. BYTNEROWICZ: Well, I'm not either.

 21 That's why I was questioning it.

 22 DR. HUBBELL: Maybe just qualitatively

 23 discussing.

 24 DR. RUSSELL: Dale.

 25 DR. JOHNSON: Not much to add. I was confused

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 1 by the DL factor. And I see components in it, but

 2 how it ended up being the merit levels, I'm not

 3 sure. I don't know if I missed something or

 4 getting feeble minded or what?

 5 DR. HUBBELL: No. We have a lot of terms

 6 dealing with deposition. The DL is the deposition

 7 load that is equivalent to the critical load that

 8 we will protect a particular percentage of the

 9 lakes from -- at a target ANC value. So we say DL

 10 percent 90, it's saying for an ANC of 50, that's

 11 the critical load that will protect 90 percent of

 12 the lakes in that particular region.

 13 DR. JOHNSON: But numerically somehow was it a

 14 model output?

 15 DR. HUBBELL: It's based on we take the

 16 critical loads from the SSWC modeling for all the

 17 lakes and streams within that particular spatial

 18 area and we arrange them in a distribution and you

 19 find the critical load that will protect

 20 90 percent.

 21 DR. RUSSELL: Panel? All right. That takes

 22 us to 13 and Chapter 6, Lauri, that's you.

 23 MS. CHESTNUT: Okay. So Chapter 6 is the

 24 co-matters. I think this is a really helpful

 25 analysis. You know, we can talk about it. You can

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 1 do a lot of other things. I'm not sure given all

 2 the challenges here what the utility is of doing

 3 more, but I think there are some interpretations

 4 maybe that could be pushed a little more with what

 5 you've already done.

 6 One of the questions that came to mind for me

 7 in, for example, the terrestrial. So we know by

 8 just focusing on the aquatic we're not necessarily

 9 setting levels that are going to protect against

 10 the terrestrial acidification for the nutrient

 11 enrichment issues. And this is a nice little

 12 analysis that looks at how close you might get, but

 13 the question I was left with was one of the

 14 conclusions here is that for sensitive aquatic

 15 systems, the sensitive terrestrial ones close by

 16 would get, in most cases, sufficient protection. I

 17 don't have a clear understanding of how co-located

 18 those things are on a national scale. So is

 19 that -- are they mostly usually in the same place

 20 or are they spread out?

 21 DR. HUBBELL: Within the same watershed

 22 generally the way the analysis was done.

 23 MS. CHESTNUT: So there is a little more that

 24 could be said here about the implications that this

 25 is going to protect a lot -- a big share of the

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 1 terrestrial systems.

 2 DR. HUBBELL: What it does not address -- this

 3 is an area we need to develop more in the write-up.

 4 It does not address to a great extent what is the

 5 implications for areas that are not co-located with

 6 a waterbody or a sensitive watershed, because

 7 clearly regional reduction in NOx is probably going

 8 to have some impacts, but it's very difficult to

 9 determine how that's going to affect.

 10 MS. CHESTNUT: Right. And my question is how

 11 many, you know, what share of the sensitive

 12 terrestrial ecosystems are not co-located with

 13 sensitive aquatic? I mean, not that you can -- I

 14 don't know how precise you can get, but.

 15 DR. HUBBELL: We can look into that.

 16 MS. CHESTNUT: Something -- are you getting

 17 most of it or are you getting 10 percent of it?

 18 DR. HUBBELL: I think we can try to look into

 19 that.

 20 MS. CHESTNUT: Okay. And I think with the

 21 nutrient, you know, it was a clever thing to look

 22 at the Chesapeake and the TMDLs; and while it looks

 23 like the deposition change wouldn't necessarily get

 24 you all the way, I didn't -- to what might be a

 25 target from that share, I didn't have a sense of

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 1 where we're starting from.

 2 So, again, yeah, it doesn't get you all the

 3 way, but does it get you halfway? Does it get you

 4 90 percent? Is it getting 10 ten percent? Get

 5 some context for that to get a sense of -- 'cause I

 6 think it kind of feeds into the uncertainty issues

 7 overall of, okay, we're not quite sure we're

 8 getting these numbers quite right, but if we know

 9 the benefits are really -- include a lot of other

 10 things and we're getting a good share toward them,

 11 then maybe you're more comfortable with some of the

 12 other uncertainties. So I think it's important in

 13 a whole picture.

 14 And the other thing I want to -- I don't

 15 expect that this chapter and this document is going

 16 to get into this, but I would like to see a list of

 17 all the other co-benefits that -- of reducing these

 18 emissions from -- to fine particulate, human

 19 health, ozone, crops, visibility any of the effects

 20 where there is no specific threshold. If there is

 21 a gradient, then any reduction in these emissions

 22 is going to mean that there is a whole list of

 23 other co-benefits.

 24 So it's a critical issue whether, again, there

 25 is a threshold you have to get to before you get

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 1 any benefit or if you're looking at an effect where

 2 there is a gradient. I mean, then each -- then

 3 there is going to be some benefit and I think it's

 4 worth mentioning even if it's just a list here that

 5 there would be other benefits of reducing these

 6 blues.

 7 DR. RUSSELL: Ellis.

 8 DR. COWLING: Instructions, he says getting to

 9 question number 24 was the most important thing to

 10 do. So I'm going to be very short in my answer to

 11 this question and I'll support what Lauri just

 12 said. If we choose to try to decrease the harm

 13 that is occurring in aquatic ecosystems, there will

 14 be substantial benefits also in other ecosystems.

 15 And, therefore, whether we can easily quantify them

 16 or not, we ought to go for it. End of statement.

 17 DR. RUSSELL: Panel? Very good.

 18 MS. CHESTNUT: Don't hesitate.

 19 DR. RUSSELL: Yeah, charge question 14, Rudy.

 20 DR. HUSAR: Uncertainty, variability,

 21 sensitivity, the new chapter -- the new chapter is

 22 good. It really brings together those issues that

 23 have been raised throughout in a single chapter and

 24 the individual uncertainties. Those uncertainties

 25 that can't be dealt with, not even not necessarily

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 1 quantified, but can't be dealt with are being dealt

 2 with, but there are the lingering questions about

 3 the other uncertainties that are not easy either to

 4 quantify or explain their causes, okay.

 5 Well, I would just start with the surprise

 6 CMAQ, okay, in that the SO2 overestimation,

 7 substantial overestimation, 40 percent is a large

 8 number, is an uncertainty that wouldn't need to be

 9 discussed and dealt with more in terms of the

 10 consequences of that; that is, that that is the

 11 place where much of the deposition actually of

 12 these so-called acidifying agents are happening and

 13 that's the one that's unknown.

 14 So while it is useful to keep showing how well

 15 the sulfate deposition matched by the model, the

 16 fact is that the same CASTNET dataset could

 17 actually be used to show how the SO2 variation, for

 18 instance, throughout the five-year simulation has

 19 been changing, in spite of the fact that we

 20 understand that the data are weaker there. So

 21 that's one that the -- that's one concern on the

 22 thesis of the sensitivity -- on the uncertainty

 23 analysis.

 24 Another aspect is more of the general approach

 25 as to what do we -- what does the sensitivity

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 1 analysis incorporate? In other words, is it really

 2 looking at the overall system kind of sensitivity,

 3 particularly the propagation of errors all the way

 4 from the beginning, unless of course we think of it

 5 in terms of the flow of these materials from the

 6 source, transport transformation, removal and then

 7 through the deposition into the body.

 8 Seeing how the propagation goes all the way

 9 through, one would get an idea as to, now, what is

 10 the importance of the fact that let's say the

 11 deposition has such an uncertainty? In what way --

 12 which part of that curve on the other side, on the

 13 effects side, where are you on the curve? Are you

 14 on the steep part of the curve or not? So,

 15 therefore, that sensitivity of the overall system

 16 might help. Now, so that was the second comment.

 17 The third one is coming back to the general

 18 comment that it would really be helpful to know as

 19 to what are the major houses. Essentially have a

 20 better understanding of why things are the way

 21 these pictures are showing the way they are. In

 22 other words, if you look at the systems, there

 23 are -- there are stressors and there are stressees.

 24 Now, the stressors are the inputs, the drivers

 25 on the front end, fine. Then there are the

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 1 stressees, the sensitivity of these species. In

 2 these analysis it would really be helpful to know

 3 as to where is the stressee. The stressor is the

 4 driver for the behavior of the system; and where is

 5 the stressee, the sensitivity or the weakness let's

 6 say of the ANC. And that kind of a large-scale

 7 analysis or quantification of explanation would

 8 really be helpful.

 9 DR. RUSSELL: Thank you, Rudy. Naresh.

 10 DR. KUMAR: I agree that discussion of

 11 uncertainty and sensitivity analysis is improved

 12 from the last version, but I think a complete

 13 quantity analysis has not been done and I don't

 14 understand why it has not been done because it can

 15 be done. In a case I had actually recommended an

 16 approach last time. We mentioned the word

 17 propagation. I'll talk more about that. So that's

 18 something to, again, go back and see how that can

 19 be done.

 20 So the uncertainty, the way it has been

 21 evaluated was the quality of the data. There is

 22 some quantitative uncertainty and some confidence.

 23 Overall what the panel had requested last time has

 24 not been done. So going back to that, I think what

 25 we asked last time was to maybe look at the

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 1 uncertainty.

 2 DR. HUBBELL: The last time, to be clear,

 3 because we tried to pay attention to this, it was

 4 determined that the propagation of uncertainty was

 5 unlikely to be possible. That we could look at the

 6 individual sensitivities, which we did, through

 7 constructing elasticities and trying to look at the

 8 covariants of the approaches, but the panel -- in

 9 the letter that the panel sent out said that it was

 10 probably unlikely that we could fully propagate

 11 uncertainties and come up with a full quantitative

 12 treatment in the consensus letter.

 13 There were some individual responses, but,

 14 again, it was understood that there is really not

 15 any -- one thing, we don't have quantitative

 16 uncertainties for most of the elements.

 17 DR. KUMAR: I think even in the letter the

 18 panel had recommended that EPA conduct a

 19 sensitivity study to correctly answer this

 20 associated with the different components and

 21 propagate every step to arrive at ensemble of sorts

 22 and NOy response to meet a given standard because

 23 that range that would give us a confidence

 24 interval.

 25 DR. HUBBELL: In the consensus letter, we had

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 1 this back and forth through the letter, we felt

 2 it's not something we can do at this point. We can

 3 and we did try to come up with individual

 4 uncertainties and look at individual sensitivities,

 5 but because we don't have probability distributions

 6 for most of the components, we didn't feel it was

 7 possible to do a full Monte Carlo-type simulation.

 8 I thought at least in our discussions that that was

 9 something that the panel as a whole agreed with,

 10 that it was not feasible to do that at this point.

 11 Again, if you want to change that, that's fine.

 12 But we took it from the consensus letter that that

 13 was not something we were being asked to do.

 14 DR. KUMAR: The letter on September 15th

 15 stated that the panel recommended. I assume this

 16 was a consensus recommendation last time in the

 17 letter.

 18 DR. HUBBELL: I don't have the letter in front

 19 of me.

 20 DR. RUSSELL: We have to look at the April

 21 letter.

 22 DR. KUMAR: I'm reading from this one, the

 23 charge questions.

 24 DR. HUBBELL: There were two different issues,

 25 one in the front letter and one in the specific

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 1 charge question. There was conflicting

 2 information. I remember the conversation. I just

 3 know there was no way we could actually do a

 4 propagated uncertainty through everything.

 5 DR. KUMAR: 'Cause I believe you do have some

 6 understanding of the dangers of different

 7 components, yes, maybe?

 8 DR. HUBBELL: Some. We did try to do the --

 9 DR. KUMAR: You could propagate those limits

 10 of those dangers toward every step and either do

 11 that through propagation or do a Monte Carlo. So,

 12 again, example that I guess -- could be done.

 13 DR. HUBBELL: We'll consider it. Again, I

 14 don't think it was something that was very feasible

 15 for us to try to do.

 16 DR. RUSSELL: I think our comment probably had

 17 more to do with we fully understand you do not have

 18 a quantitative estimate of all the pieces that go

 19 into an AAPI. So you would have had to then --

 20 DR. HUBBELL: Make up stuff.

 21 DR. RUSSELL: -- making up some uncertainties.

 22 DR. HUBBELL: We were not comfortable doing

 23 that.

 24 DR. RUSSELL: I'm sure we would have told you

 25 that we couldn't agree with the made up

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 1 uncertainties.

 2 DR. KUMAR: You don't have -- you could be

 3 very careful and have a bit of uncertainty and have

 4 a known answer. Still I can see how the other

 5 uncertainties play into all a range of NOy as far

 6 as substance. That's what's critical to figure out

 7 the range on that. That would give us some

 8 confidence interval in this approach.

 9 DR. RUSSELL: Rudy, you raised your hand

 10 again.

 11 DR. KUMAR: I was not done.

 12 DR. RUSSELL: Sorry about that. You breathed.

 13 DR. KUMAR: There is an A, B and C. I don't

 14 know if you want us to go on to all of those

 15 together or not.

 16 DR. RUSSELL: Yes.

 17 DR. KUMAR: So number two is on the model

 18 CMAQ, the performance I think, again, the

 19 performance on CMAQ model is still incomplete even

 20 after the request by the panel. Last time we had

 21 recommended the model propose NO, NO2, nitric

 22 oxide, NOy from different networks where you had

 23 routine measurements be included -- including the

 24 network, for which we had like ten years of data on

 25 those components, and still there is no mention of

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 1 why that was not done.

 2 And also the Table 7-1 shows performance

 3 statistics for a species. I think I had mentioned

 4 it last time also that using a normalized mean

 5 statistics is misleading for annual average

 6 quantities. I can go over, if we have time, why

 7 that's misleading.

 8 Normally when I do papers, I publish it

 9 showing that normal statistics. They have to show

 10 mean normal. And there is a difference. If the

 11 panel wants, I can explain that, but I think we

 12 should be showing a mean normal statistic when

 13 we're using annual average quantity.

 14 So I will go to Part D. Part D was discussed

 15 in a previous charge question on the TSOx and TNOy

 16 how we look at the variability in that in different

 17 means.

 18 DR. NUGENT: I'd ask you to ask the -- you

 19 provide comments next.

 20 DR. HUSAR: About not being able to examine

 21 propagation efforts. Well, first of all, there are

 22 certain differences between systematic errors that

 23 seem to be existing in the CMAQ; that is, if on the

 24 average CMAQ overestimates approximately

 25 40 percent, well, that's a different kind of an

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 1 error than let's say some kind of a random error

 2 for which you may not know the distribution

 3 function.

 4 So if indeed, let's say, sulfur dioxide is

 5 overestimated 40 percent, there should be no

 6 ambiguity or conceptual or numerical difficulty

 7 propagating that, saying what happens if you would

 8 then remove that 40 percent and then you see what

 9 is the consequence on the outcome on the curve. So

 10 at least systematic errors could be actually

 11 examined.

 12 DR. HUBBELL: We could do that with the

 13 elasticities that we provided. That's simply

 14 measuring for a one percent change what's the

 15 expected impact on the AAPI. So it would be

 16 relatively straightforward. If you have a

 17 40 percent error in SO2, we could propagate that

 18 through. So that's doable. That's not the same

 19 thing as doing multiple sources of errors and

 20 propagating them through.

 21 I want to make sure we're clear on this, what

 22 the letter said, it acknowledges a probabilistic

 23 listing assessment of uncertainty at this time.

 24 It's not likely to be practical within the range of

 25 this review of the secondary standards. So that

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 1 was the, you know, front page of the consensus

 2 letter, which is why we didn't focus on that as an

 3 activity.

 4 DR. HUSAR: So the propagation is not

 5 necessarily doable because of the distribution

 6 functions, but should definitely be possible.

 7 DR. HUBBELL: Which we agree with in terms of

 8 -- and, again, we can focus on what we identify as

 9 the critical quantitative known -- not known, but

 10 estimates of uncertainties in initial parameters.

 11 It's fairly straightforward to multiply that by the

 12 elasticity.

 13 DR. RUSSELL: Panel? Myron and then Dale.

 14 DR. MITCHELL: I guess I just want to -- I

 15 guess we're on the same page here with what Rudy

 16 just said is for these uncertainty analysis to

 17 focus on anything that actually could be

 18 reformulated in some of these basic relationships

 19 and use that for uncertainty. And also if there is

 20 something which has not been included in the

 21 current index, like what happens if you actually

 22 add reduced nitrogen, how is that going to affect

 23 the overall relationships across some of these

 24 sites.

 25 I would say there are some major processes

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 1 that aren't included. That kind of conceptual

 2 model level of air also should be -- this is not a

 3 statistical analysis, but it's also just looking at

 4 some major -- some of the major features in the

 5 model may change, but would be the outcome of that

 6 output.

 7 DR. RUSSELL: Dale.

 8 DR. JOHNSON: First of all, back to the table

 9 of Myron and Ellis, I think it should include also

 10 the reduced benefits of reducing sulfur deposition,

 11 whether quantifiable or not. And for uncertainty,

 12 I don't know what you do about this, but there are

 13 uncertainties that are hard wired into some of

 14 these models. The premises have a bit model on A-5

 15 and examined premises for that, the assumptions for

 16 that model; and out of the five, four of them are

 17 demonstrably false.

 18 So what would happen if you started including

 19 changing these things? I don't know how you

 20 quantify that, but that's a real significant source

 21 of uncertainty.

 22 DR. RUSSELL: Kathy.

 23 DR. WEATHERS: I thought the elasticity

 24 analysis was a real useful thing. And underscoring

 25 what someone said, I think changing those terms to

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 1 maybe a 40 percent difference, the depositions, the

 2 key term and maybe base cations, whatever the terms

 3 are that were like -- you're likely to be off by a

 4 huge percentage, go ahead and make that change.

 5 Again, I'm not arguing because we're plus or

 6 minus 40 percent, 50 percent, 100 percent

 7 understanding that means that this should all down

 8 the tubes, but I think being realistic about making

 9 those changes much bigger percentage than just

 10 one percent.

 11 DR. HUBBELL: Again, the one percent is simply

 12 a scalable uncertainty. Elasticities are not an

 13 uncertainty calculation at all. It's a sensitivity

 14 calculation that can be applied to sensitivity

 15 factors.

 16 DR. WEATHERS: Right. But it's telling us

 17 something about the model, the AAPI model, how it

 18 responds to big differences in the input terms,

 19 right?

 20 DR. HUBBELL: Sure.

 21 DR. WEATHERS: So there are some places where

 22 real uncertainties are huge and changing those to

 23 reflect that I think would be useful.

 24 DR. SCHEFFE: Could I add a couple

 25 clarifications?

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 1 DR. RUSSELL: Short, yeah.

 2 DR. SCHEFFE: So in terms of, just to be

 3 clear, the model itself is not used as the

 4 indicator in nonattainment, attainment kind of

 5 setting. And the way -- and we do acknowledge, you

 6 know, there is some work to be done with getting,

 7 you know, the sulfur calculation correct. That is

 8 a concern that we have, but that manifests itself

 9 in terms of uncertainty in terms of how that's

 10 translated to the transference ratio. That's kind

 11 of how we would have to look at that.

 12 So a 40 percent -- being off 40 percent in an

 13 important component like SO2 doesn't necessarily

 14 translate in being off 40 percent in a parameter

 15 that goes in the AAPI. They are much different

 16 things. That's how we would have to look at that.

 17 DR. WEATHERS: I was kind of lumping that,

 18 thinking about, well, it could easily be off for a

 19 particular area, a particular lake or watershed

 20 40 percent in actual deposition.

 21 DR. RUSSELL: And I will actually make a

 22 comment, this is something I had done over the

 23 weekend with the spreadsheet you had sent me was

 24 actually turn it around and do my

 25 back-of-the-envelope uncertainty assessment on the

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 1 concentrations that would be estimated to go along

 2 with a certain AAPI. So if you sort of turn that

 3 AAPI equation around instead of looking at the

 4 elasticities of the AAPI to the inputs to look at

 5 the elasticity or the uncertainty of, you know, the

 6 thing that's actually going to be represented --

 7 going to be what's monitored to the various inputs.

 8 Because, you know, the AAPI, that's a hard and fast

 9 number, you're going to set that.

 10 So if you turn that around, one thing at least

 11 I found, and you may have done this as well, is

 12 that the uncertainty of those concentrations --

 13 yeah, the uncertainty of the associated

 14 concentration is quite sensitive to that

 15 transference ratio, even though the elasticity

 16 suggests that the AAPI is not that sensitive to

 17 that. You can turn that around. That doesn't come

 18 through in the current document.

 19 And the other thing is that you need to take

 20 account of covariants because as your covariants --

 21 covariants matrix shows, you know, the R squared

 22 between TSOx and TNOx is about 80 -- .8.

 23 So, you know, they're, not surprisingly, very

 24 highly correlated. So looking at those two

 25 separately would underestimate the uncertainty. I

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 1 think you have probably done that and sort of seen

 2 what that means.

 3 DR. HUBBELL: We have been looking at this

 4 question of the NOx and SOx and how sensitive they

 5 are to these and thinking about covariants a little

 6 bit. Of course, the issue with the NOx and SOx

 7 it's a tradeoff curve, so there are multiple

 8 quantities. You can make some assumptions and say,

 9 well, what would the maximum SOx be if you had NOx

 10 being zero and vice versa? I'm curious how you set

 11 that up.

 12 DR. RUSSELL: I said what would be the

 13 necessary -- so I had to simplify it because yes,

 14 it is a necessarily complex thing. I just said

 15 what is the necessary reduction in the sum of this,

 16 if we sort of treat them having the same ratio of

 17 the transference ratio.

 18 DR. HUBBELL: Which isn't quite right, but

 19 close.

 20 DR. RUSSELL: It's not quite right, but if you

 21 look at the concentrations, it's not tremendously

 22 far off. That's just how I came up with it. I

 23 think that's very important to recognize what

 24 the -- you know, how that actually impacts this

 25 thing you're measuring in terms of really the

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 1 percent or fraction of lakes that you will

 2 ultimately be protecting at a specific level, is

 3 that that level of uncertainty could really impact

 4 that being overprotective or underprotective.

 5 DR. HUBBELL: Yeah.

 6 DR. RUSSELL: Charlie.

 7 DR. DRISCOLL: So I think this uncertainty

 8 analysis is very important and we'd recommended

 9 that you work on it last time. You've done this.

 10 But, you know, as I go through this and I read, you

 11 know, what you've done I worry a little bit because

 12 the uncertainties can be very high in some of these

 13 components. And I think it's important not to lose

 14 sight that we have a tremendous amount of empirical

 15 data over a long period of time where we measure

 16 surface waters and we see how they respond to

 17 changes in deposition. And there are very clear

 18 mass and chart balance constraints.

 19 So I think that there is much more confidence

 20 in understanding and quantifying how systems would

 21 respond moving forward given the past information

 22 that we have on soils and surface waters than comes

 23 through in this document. And I'm not really sure

 24 how to put that in terms of uncertainty analysis,

 25 but I think, you know, we know how these things

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 1 have responded over the last 20, 30 years; and I

 2 think we have a pretty good idea how they're going

 3 to respond over the next 10, 20 years just because

 4 of mass and charge balance constraints. And I

 5 think it's important that we don't lose sight of

 6 that because it provides important information to

 7 put the uncertainties in context.

 8 DR. RUSSELL: Rudy.

 9 DR. HUSAR: Yes. One thing material that is

 10 already in a well-defined, balanceable media indeed

 11 such consistency checking is doable.

 12 But on the driver's side, on the input side

 13 there are still these major uncertainties as to

 14 what is it that actually causes and what is

 15 actually the magnitude of the actual depositions

 16 themselves.

 17 And so a methodological suggestion here, this

 18 is both for the group and to the EPA, is indeed the

 19 recommendation that one should at least for the

 20 next decade when these same topics will be coming

 21 up that an ensemble or a set of these models to be

 22 used just the same way as in Europe, those ensemble

 23 multi-model exercises give you a feel as to what is

 24 the nature and the range of uncertainty by virtue

 25 of the fact that you use different instruments,

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 1 quote, unquote measuring or quantifying this stuff.

 2 So this will be a recommendation to write up

 3 this part of the section. You might see this

 4 tomorrow as a suggestion.

 5 DR. RUSSELL: Other comments on this one?

 6 Moving on, did you have --

 7 DR. WEATHERS: I want to agree with Charlie.

 8 I think that having the big picture up there front

 9 and center is really important. And I guess that's

 10 why I like the sensitivity analysis because it

 11 collapses some of the big pieces and you can look

 12 at what a huge percentage change might mean to the

 13 sensitivity of the entire AAPI. So I think your

 14 point is really important, Charlie, and I think

 15 sensitivity analysis is one way to look at the big

 16 picture.

 17 DR. RUSSELL: Thank you. So we are 15. And

 18 that again is Rudy.

 19 DR. HUSAR: What is me?

 20 DR. RUSSELL: Fifteen are the panel's views on

 21 the insights provided by the AAPI, maybe you

 22 included this, sensitivity analysis and actually we

 23 did discuss it, the evaluation.

 24 DR. HUSAR: Nothing new.

 25 DR. RUSSELL: I think we actually got into it.

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 1 DR. HUSAR: It's the same. I can tell that I

 2 would not know the -- other than the fact that with

 3 regard to the elasticity, well, the question is

 4 what is the nature of those assumptions by which

 5 you are performing, that you are including the

 6 preservation of? The one percent kind of

 7 preservations are okay, of course, you know, if you

 8 just look at the -- just the smaller changes, but

 9 what if you take those irregularities that happen

 10 on the front and back end and all of a sudden that

 11 40 percent may -- you said, well, it may not be a

 12 40 percent change in something or another on the

 13 back end. What if a 40 percent data result in

 14 80 percent change in the back end simply because of

 15 the inherent measurements.

 16 DR. HUBBELL: I think that's fair. I tried to

 17 get some of that by looking at various points on

 18 the curve and doing marginal changes along those

 19 different segments of the response. But, as I

 20 think I mentioned in the write-up, some of the

 21 variables even switches signs. Q, for example,

 22 which is the runoff, switches signs at one point.

 23 At one point it causes the AAPI to increase.

 24 In some points it causes the decrease. Knowing

 25 where that inflection point is and if you cross it

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 1 by some large change is fair enough. So we can

 2 certainly look at that and characterize for

 3 large-scale change what is the potential for

 4 percent response.

 5 DR. RUSSELL: Thank you. Any other -- I think

 6 we already got -- no, Naresh wants more on 15.

 7 DR. KUMAR: Fifteen, right? Just short, I

 8 agree, the variation of the elasticity response is

 9 a good way to adjust the sensitivity for the

 10 different components. I would recommend that the

 11 same be done for turning around the source and NOy,

 12 that's the end result and we can guarantee the

 13 sensitivity of those quantities of different

 14 components of the AAPI.

 15 DR. HUBBELL: Yes, we agree.

 16 DR. RUSSELL: Question 16, Charlie.

 17 DR. DRISCOLL: Okay. I didn't really have

 18 much to comment on, on the specific question

 19 concerning the uncertainty for MAGIC and the SSWC.

 20 There was some discussion in there that more needs

 21 to be done. It's been only done to a limited

 22 extent. You folks did a fair amount as part of

 23 this analysis for the REA. So I think that I guess

 24 I would agree that it would be useful to continue

 25 to do these uncertainty analysis.

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 1 I think though, as Rudy said, I think there

 2 are other aspects to evaluate these tools that

 3 should be considered going forward. Probably don't

 4 have time to do it, you know, between now and

 5 December, but things about comparing different

 6 types of approaches, different types of models and,

 7 you know, either structural differences in these

 8 models that would be important to understand and to

 9 try to evaluate the components of the models, for

 10 example, improve the Neco term, which I think is

 11 pretty soft. It's pretty hard to evaluate that.

 12 Might be other tools to do that.

 13 Another area that it seems to me in need of

 14 attention is to look at the role of organic acids.

 15 We talked about basically throwing out the high DOC

 16 waters, but there may be ways of simulating DOC

 17 that could be considered in future efforts. So I

 18 think that there are -- uncertainty issues are

 19 important, but I think there are also some, you

 20 know, looking at structural components of the

 21 models would be helpful going forward.

 22 DR. RUSSELL: Chris.

 23 DR. FREY: I don't really have a lot of

 24 comments on MAGIC or SSWC because those go beyond

 25 my own expertise. I thought the write-up was

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 1 readable for someone who is not an expert in those

 2 models.

 3 Maybe I'll just -- I have some maybe more

 4 general comments about Chapter 7. One is that I

 5 don't think there is a very clear framework

 6 throughout the chapter. I think this applies to

 7 these two models as well on the spatial and the

 8 temporal scope of the quantities for which variable

 9 and uncertainty are being characterized. And

 10 because variability and uncertainty both are

 11 sensitive to geographic averaging and temporal

 12 averaging, without that context, it's not clear the

 13 meaning of many of the characterizations, including

 14 the summary Table 7-1.

 15 And then some of the analyses presented in the

 16 chapter, you know, they don't seem consistent with

 17 later in Chapter 9 with the spatial scales or the

 18 temporal scales, probably more so the temporal

 19 scales. You know, if the standard might ultimately

 20 be based on a three to five-year averaging period,

 21 then any assessment of uncertainty should be based

 22 on a three to five-year averaging period. And that

 23 should be discussed in Chapter 7.

 24 So there is an unavoidable linkage between

 25 Chapter 7 and Chapter 9 as far as where are things

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 1 going with the Policy Assessment. If the goal is

 2 to assess uncertainty, to inform the choice of

 3 alternative, you know, levels and forms and so on,

 4 then it ought to be on a consistent time and

 5 spatial scale. So that's one general comment I

 6 have.

 7 Another is maybe it's not critical to this

 8 document, but there isn't really a framework given

 9 for -- I mean, there is some framework given for

 10 the uncertainties, but since ultimately it becomes

 11 a qualitative analysis, I think perhaps in the REA

 12 there is more detail and a method for that. But

 13 giving the reader a little bit of an idea that this

 14 isn't -- well, that there is some structure to it

 15 and it's not completely an ad hoc process might be

 16 helpful.

 17 And then there is always I guess questions

 18 about the tier of assessment, like this is a

 19 qualitative assessment. It didn't go to a

 20 quantitative assessment. Those issues can be

 21 discussed in the context of a tier approach in

 22 dealing with uncertainty and why the analysis

 23 mostly stops at a sort of tier one or tier zero,

 24 maybe sometimes go to a quantitative sensitivity

 25 analysis. That could be more clear to the reader.

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 1 And then just the comment maybe not related to

 2 charge question 16, but on these extrapolating a

 3 elasticity to 40 percent error, obviously, that

 4 works if it's a linear response. If the response

 5 is not linear, then that would not be a good idea.

 6 DR. HUBBELL: I wasn't suggesting we'd

 7 multiply it. We actually run a system.

 8 DR. FREY: Thanks.

 9 DR. RUSSELL: Panel? Question 17, Charlie,

 10 you're up again.

 11 DR. DRISCOLL: This is probably even more

 12 dangerous than to ask me multipart questions,

 13 asking me what are, you know, research and

 14 monitoring. I mean, we could go on for days I

 15 think on a monologue for this.

 16 So I think there are a number of things that

 17 were identified in the report that were appropriate

 18 in terms of particularly looking at some of the

 19 aspects of deposition, you know, uncertainty in

 20 terms of ammonia; and the, you know, actually what

 21 are the values of a deposition that are occurring;

 22 what are the sort of sub-grid scale effects and how

 23 those link to watershed models.

 24 I mentioned previously issues about response

 25 of organic acids and also better datasets to track,

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 1 you know, the recovery of soils and vegetation and

 2 surface waters and aquatic biota, so those are just

 3 a few, but there are many more. I'm sure a lot of

 4 other folks here could add in a lot more,

 5 particularly on the atmospheric side.

 6 DR. RUSSELL: I think that is referring people

 7 to individual comment goes a long way because there

 8 are just so many things that we really need to have

 9 research on here. So, you know, if there is

 10 something that is burning, I'd bring it up now or

 11 up for discussion, but I like Charlie's approach to

 12 that. So, Chris.

 13 DR. FREY: Yeah, on charge question 17, I

 14 guess at first I couldn't figure out what part of

 15 the chapter this referred to, then I figured out it

 16 was the modeling gaps and the data. I didn't go

 17 back and check other Policy Assessments for the

 18 other criteria. So I don't remember if that

 19 subheading is the one that's used elsewhere, but I

 20 think if it's really the goal is to focus on

 21 research and data collection needs, maybe the

 22 heading could clearly say that. And then if there

 23 were an introductory paragraph that would help me

 24 with that section.

 25 So I think -- I tried to figure out what were

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 1 the research needs, and this won't take very long,

 2 but it just seemed to me that the chapter or that

 3 section focused on things like occult deposition

 4 from clouds and fog, lightning-generated NOx, the

 5 role of organic bound nitrogen, better soil and

 6 agricultural emissions of -- it wasn't clear -- it

 7 sort of implied NOx, but I think it must have meant

 8 ammonia and NOy and not NOx. And then more data

 9 for sensitive ecosystem areas and sort of general

 10 areas of need. You know, those all seemed

 11 reasonable to me. I'm not an expert in those

 12 topics, but it made sense.

 13 I think what was missing though was there was

 14 not a reflection of the Table 7-1, which gives, you

 15 know, a long list of uncertainties and whether

 16 they're low, medium and high ranges or biased or

 17 the state of knowledge. And it seems like from

 18 that table one can infer some additional research

 19 needs, just some examples -- I tried to find which

 20 of those uncertainties were high in some way.

 21 So, for example, the preindustrial based

 22 cation concentrations listed as having high

 23 magnitude of uncertainty and a high knowledge base

 24 uncertainty. So one might think, oh, that should

 25 be a priority for future data collection or model

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 1 development. So I was surprised that wasn't in the

 2 discussion.

 3 Dry deposition generically for both nitrogen

 4 and sulfur was listed as having a medium magnitude

 5 of uncertainty and a medium high knowledge based

 6 uncertainty. It seems like that might merit some

 7 discussion in terms of future research. And also

 8 the ecological indicator regarding ecosystem

 9 services seemed to have both a medium high

 10 magnitude of uncertainty and also a negative bias.

 11 I think that needs more discussion.

 12 And then there were issues that were brought

 13 up early in the Policy Assessment that are

 14 basically set aside because there is not enough

 15 information to address them now. So examples are

 16 the terrestrial acidification and aquatic system

 17 nutrients enrichment.

 18 So what are the research needs for those so

 19 that they could be part of the next assessment?

 20 And then I think we've heard also comments about

 21 addressing unintended consequences, which might be

 22 appropriate.

 23 In the recent CASAC PM panel review on the

 24 second Draft Policy Assessment for PM, there was

 25 some discussion about developing a follow-on

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 1 workshop to focus on research needs to inform the

 2 next revision of the NAAQS. And if the research

 3 agenda is big enough or significant enough, maybe

 4 something similar might be considered for this set

 5 of pollutants and effects as well.

 6 DR. RUSSELL: Panel? Andre.

 7 DR. BYTNEROWICZ: On page 7-11 you're

 8 discussing ammonia and see it's dealing with this

 9 particular pollutant. In the end you said you were

 10 considering I think it's according to Dennis's

 11 paper 2011, using the sensitivity analysis for two

 12 sources probably in North Carolina. My suggestion

 13 would be these are probably big stationary sources.

 14 It would be nice to do something similar also

 15 somewhere else in the country looking at multiple

 16 sources of ammonia because that would be a key

 17 thing.

 18 DR. SCHEFFE: Sure. Just for clarification,

 19 that was probably the only empirical data that that

 20 study was based on, but then of course the

 21 parameterization from that is brought in too and

 22 applied nationally. That's a very good point to

 23 make.

 24 DR. BYTNEROWICZ: I mentioned that because

 25 we're having new things on ammonia in the west,

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 1 which could be used probably.

 2 DR. RUSSELL: Others?

 3 DR. AMAR: Back to ammonia again, I think one

 4 reason would be, I think that's probably an

 5 extension of that, with the local nature or

 6 regional nature or in between nature of ammonia I

 7 don't think is clear in this document. There is

 8 some evidence it's not as local, but maybe do a

 9 more systematic analysis of ammonia and its nature.

 10 DR. RUSSELL: Rich.

 11 MR. POIROT: I just wanted to add that I

 12 thought the whole chapter was rather well done.

 13 And this kind of sets a new bar for subsequent

 14 NAAQS. They should all include a Chapter 7 like

 15 this. And I additionally like the coupling of the

 16 identification of the research needs with the

 17 delineation of the uncertainty, very appropriate.

 18 I just wanted to say nice job. Now, do it next

 19 time.

 20 DR. RUSSELL: And fill in the blanks with

 21 numbers.

 22 DR. SCHEFFE: That's the hard part.

 23 DR. RUSSELL: Yes, it is. Okay. So moving on

 24 to monitoring, Rich, you get to go through all

 25 three questions. You don't even have any help on

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 1 it.

 2 MR. POIROT: No. I noticed Paul Hanson

 3 couldn't give any comments. Well, the chapter

 4 before we get to the charge questions, right away

 5 the chapter starts out with what I thought was a

 6 nice listing of the different multiple objectives

 7 that might be addressed by monitoring. Almost

 8 always we get hung up on monitoring this for

 9 compliance determination, period. And to a certain

 10 extent it absolutely has to be and meet that

 11 objective.

 12 And, you know, when we have our research hats

 13 on, our science hats on, of course we can think of

 14 all kinds of other things that will help us add to

 15 the list, but in this case I think it's especially

 16 relevant, these additional objectives really fit

 17 here very well. Yeah, maybe we can get by with the

 18 modeled calculation of reduced nitrogen, but not

 19 for long, you know. Plus, it's within our grasp.

 20 It's something that actually can be done.

 21 And so the idea of providing some of that kind

 22 of information rather than needing to rely on the

 23 model, you know, would be really helpful. Of

 24 course, we want to improve the model and the

 25 process, our understanding of the processes and

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 1 subsequent NAAQS reviews is I think actually pretty

 2 important and the whole idea of accountability,

 3 which really was the whole basis of the CASTNET

 4 network in the first place.

 5 So in this particular case I think the

 6 secondary objectives are very important. And I

 7 might add as well that until this morning's

 8 presentation I wasn't aware the agency plans to go

 9 to the AMS committee for some additional feedback

 10 on measurement issues because I was kind of writing

 11 my pre-meeting comments with the anticipation that

 12 this might be the last shot at it. So I might have

 13 been overly arching in some cases.

 14 At any rate, the first charge question asked

 15 about our opinions of using an open inlet to

 16 capture all particle sizes for sulfate in

 17 particular. And sort of the follow-up questions is

 18 our opinion on using the CASTNET filter packs as a

 19 future reference method for sulfate. Again, I

 20 think this would be a good topic for the AMS

 21 committee to address in more detail.

 22 I had taken a few counterpoints, made a few

 23 counterpoints to the need for an open-face

 24 collector and so forth. One of the most important

 25 of which is yes, we believe that larger particles

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 1 with a much larger deposition velocity, gravitional

 2 settling component can contribute a lot more to

 3 total sulfur deposition; and, for that matter, to

 4 total nitrogen deposition especially if we're

 5 concerned about coastal estuaries and places where

 6 it's not just acidification that's the issue, but

 7 as we get into the marine environment, for example,

 8 we would expect to see some coarse particle

 9 nitrogen deposition, could be potentially

 10 important.

 11 But the issue though is that simply by letting

 12 those bigger particles into our collector gives us

 13 no information about what fraction of the total is

 14 from those larger particles. So we're really not

 15 very much more ahead of where we would be if we had

 16 to rely on fine particle measurements plus a fudge

 17 factor. We still have to have a fudge factor

 18 either way. So I don't oppose it. I actually like

 19 the idea of using that kind of an open-faced

 20 approach for deposition relevant measurements and

 21 so forth.

 22 So even though I am picky at it, I actually

 23 support it. And, further, I would support

 24 consideration of something like that for nitrogen,

 25 particles of nitrogen deposition as well because I

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 1 don't think that the monitoring approach should

 2 necessarily be exclusively limited to the

 3 acidification issue if one of the objectives is to

 4 support future evolution of this.

 5 I -- the next charge -- should I stop there?

 6 DR. RUSSELL: Go through them all.

 7 MR. POIROT: Asks about our views on requiring

 8 measurements of ammonia and ammonium to assist in

 9 implementation of the standard. Certainly I think

 10 that those measurements would be very helpful,

 11 especially for ammonia.

 12 I think ammonium is measured reasonably well

 13 in our collective networks, but what's missing I

 14 think is the gas phase ammonia measurements. There

 15 is a small component of NADP that's beginning to

 16 make some measurements using passive samples. It's

 17 really just not right what a shoestring budget

 18 that's being cropped together with this. It's a

 19 pretty important thing and maybe this would be our

 20 opportunity to advocate those kinds of measurements

 21 in a more formal way because they are important.

 22 So I certainly am a supporter of that aspect of the

 23 proposal.

 24 And then, finally, the last charge question 20

 25 gets into our views on having a subset of sites

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 1 that would make measurements of some of the perhaps

 2 even continuous measurements of some of the other

 3 NOy species, nitric acid, true NO2, NO and so

 4 forth, particularly nitrate. Again, you know, the

 5 science side of me says this would be great. This

 6 would be excellent. I get a little concerned

 7 though about our ability to actually go out and

 8 roll out a new rural detailed set of new NOy and

 9 continuous SO2 sites that for the most part don't

 10 exist.

 11 Perhaps we're not supposed to consider those

 12 implementation phase difficulties, but sooner or

 13 later we'll have to deal with them. And so that

 14 gets back to one of the reasons why I was wondering

 15 before about whether a calculation of the nitrogen

 16 deposition couldn't be derived from the kinds of

 17 measurements that are collected already by CASTNET

 18 methods; that is, specifically the particulate and

 19 nitric acid measurements that are routinely made

 20 with CASTNET. Could we use those as a way of

 21 estimating total nitrogen deposition using the same

 22 kind of ratio -- model ratio as you're now using

 23 for total NOy?

 24 The reason being that if we could, that would

 25 allow an expansion of this basic CASTNET network

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 1 maybe to cover the broader spatial area with many

 2 sites. And then we could enhance that with a

 3 smaller number of sites, making the continuous NOy

 4 and continuous SO2 and some of these other things

 5 rather than saying we can't get started unless we

 6 had continuous NOy and SO2 as our base network.

 7 So that was the one kind of a twist I wanted

 8 to suggest considering, you know, maybe there are

 9 certain aspects of the CASTNET program itself that

 10 would be healthy to put to some scrutiny and get a

 11 little bit of review there.

 12 You know, another thing I wanted to mention

 13 though is if this would be a situation where if the

 14 CASTNET-type measurements were used, we would have

 15 a network operated by EPA and its contractors,

 16 funded by money that's taken out of the state

 17 monitoring pot and then you would come and let us

 18 know whether we were in compliance or not. Some of

 19 my colleagues, my boss, for example, might not look

 20 kindly on that.

 21 I, actually, don't oppose it and think it

 22 would be interesting to actually meld some of these

 23 together rather than considering -- insisting that

 24 our turfs are all different, we really should be on

 25 the same side here. Along those lines, there are

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 1 some, as Rich knows, rural end-course sites. And

 2 bringing in some CASTNET measurements at some of

 3 those sites and maybe along with some, you know,

 4 true NO2, all of a sudden we could start to answer

 5 a lot of these questions a lot better.

 6 So somewhere I think there is room for some

 7 compromises and combinations of different

 8 approaches. So those were my comments.

 9 DR. RUSSELL: Panel? Myron.

 10 DR. MITCHELL: I guess I just want to kind of

 11 amplify on some of Rich's comments. It seems like

 12 there is an opportunity in this chapter to look at

 13 some of the previous findings, including

 14 uncertainty where some of the major problems are;

 15 where the concerns are; where the data needs are;

 16 and use this in terms of examining where the

 17 monitoring community needs to go. Whether that's

 18 actually having less CASTNET sites where they're

 19 doing more things or looking at integration across

 20 the different monitoring networks, there is a good

 21 opportunity here to take -- to give some useful

 22 recommendations to the community.

 23 DR. RUSSELL: Thank you. Any other comments

 24 from the panel?

 25 DR. AMAR: One point, thank you. I'd like to

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 1 add on to what Rich was saying, and we had this

 2 discussion last night. If CASTNET, and I'm not a

 3 monitoring expert, but if CASTNET, an existing

 4 network, can address what we're trying to do here

 5 later on in the implementation of AAPI versus some

 6 extensive monitoring network locations, measurement

 7 methods, frequency, the cost and, again, from a

 8 state's perspective, we do -- we do worry about

 9 those things, whether, you know, a good standard

 10 proposed here could actually be implemented based

 11 on a huge network which required quite a bit of

 12 investment which wasn't forthcoming.

 13 DR. RUSSELL: Ellis.

 14 DR. COWLING: I'd like to mention the results

 15 of conversations that I had in preparation for this

 16 meeting with John Walker and with Robin Dennis and

 17 learning about how many collaborative endeavors are

 18 ongoing right now within EPA dealing with Canada

 19 and their perspectives on the various challenges of

 20 measuring all the NOy species and the chemically

 21 reduced forms and the organic forms. And the Dutch

 22 have instrumentation, which is proven quite

 23 effective at least in the Dutch environment and

 24 maybe in other parts of Europe as well.

 25 So I don't know if it's appropriate for a PA

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 1 to include the little writing on what's going on

 2 inside EPA right now, but I was impressed. If it's

 3 appropriate, I would certainly recommend that some

 4 mention be made of these ongoing collaborative

 5 efforts that are going on in which there are

 6 scientific progress that's being achieved in other

 7 parts of the world and by instrumentation, which is

 8 also being tested collaboratively in this country

 9 and in other parts of the world where there may be

 10 some bright ideas and methodologies and ways of

 11 dealing with uncertainties and errors and so on

 12 that maybe we haven't thoughtfully evaluated as

 13 yet.

 14 DR. RUSSELL: Rest of the panel? I think --

 15 MR. POIROT: Just one thing I meant to say but

 16 forgot was that as much as I like these secondary

 17 objectives that are listed here, in some ways I

 18 don't know if they can be fully justified in terms

 19 of this NAAQS alone; at the same time I don't think

 20 they really need to be. This opens the door I

 21 think to a lot of things that relate to improving

 22 and evaluating the model performance that have we

 23 might say co-benefits to many other pollutants.

 24 So that's just one point that I'd like to

 25 maybe try to raise that in our letter thinking what

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 1 our collective comments would be here. Some of

 2 these are very well justified not from a secondary

 3 SOx, NOx perspective alone.

 4 DR. RUSSELL: Thank you. And with that, it is

 5 2:45 and time for the break. We're right on

 6 schedule.

 7 (Brief recess.)

 8 DR. RUSSELL: Committee, first important

 9 question so we can get some of this done. I think

 10 we have -- we paired it down to two choices really

 11 for restaurants tonight. One is Lebanese, that's

 12 supposed to be very good. And the other one is

 13 Indian, which is also supposed to be very good.

 14 Lebanese one runs, what, 20 bucks a head?

 15 DR. FREY: Ten bucks a head.

 16 DR. RUSSELL: Indian is more expensive.

 17 DR. WEATHERS: How far away?

 18 DR. RUSSELL: Five for the Indian. It's in

 19 Morrisville, which isn't too far.

 20 DR. AMAR: Indian is in Morrisville, the same

 21 distance. Do you have it down?

 22 MR. POIROT: No. I remembered that Lebanese

 23 came up. So hands for Lebanese? Okay. Indian?

 24 Lebanese it is.

 25 So the next question how many people want to

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 1 go tonight to the Lebanese? Make it ten; 6:30 or

 2 6:00? Why don't we shoot for 6:00. The earlier

 3 the better. We may actually leave earlier

 4 depending on how quickly we can get done here.

 5 DR. JOHNSON: Leave here at 6:00?

 6 DR. RUSSELL: Leave here at 6:00. That should

 7 give everybody time to make a first draft of

 8 their --

 9 DR. BYTNEROWICZ: Very optimistic.

 10 DR. RUSSELL: -- or at least talk to your

 11 co-supporters in drafting it and then we can go out

 12 to dinner. The lobby at 6:00.

 13 So with that, we're getting to the conclusion

 14 chapter; and in some ways actually these last four

 15 questions sort of bring up things that we've

 16 already discussed.

 17 What I want to do is start thinking of the

 18 bigger picture at this point too; and that is, what

 19 should we actually be recommending, you know, EPA

 20 and I put 24-D, as being a very important question,

 21 it asked us what would we look at as being the

 22 components of the standard. That's the advice they

 23 want. And typically, actually, in a CASAC meeting,

 24 the last one, the panel starts giving advice

 25 specifically as to the standard. That's what they

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 1 asked us.

 2 Typically at this point we would be evaluating

 3 the staff's recommendations as to the standard as

 4 well and their reasoning for that. So in this case

 5 we're doing it a little bit more free form, if you

 6 will. So we want to start thinking about how we

 7 can answer that big question, what is really

 8 missing from this report to be able to adequately

 9 inform both us as well as the Administrator in

 10 terms of what is important, what she might decide

 11 as the appropriate level of the standard.

 12 So what's really missing and where we think we

 13 should go from here in that is this document really

 14 ready to go on? Are we comfortable with it? Where

 15 do we want to proceed on making recommendations

 16 about the standard itself? So to get into the big

 17 questions, I think what we talked about so far

 18 today in the discussion gets us a long ways in

 19 terms of sort of laying the foundation for that

 20 discussion. And then I think we have to have that

 21 discussion before we finish up this process.

 22 So, with that, we'll still go through the

 23 questions, but when we get to the end of 24-D, I

 24 think that's -- we want to start having the broad

 25 discussion about where we are, where we think this

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 1 document sits in terms of going forward. So, with

 2 that, 21 is Chris.

 3 DR. FREY: Okay. I struggled with this

 4 question because I wasn't really sure if there was

 5 something behind it that I was missing. And maybe

 6 just a general context maybe in the flavor of Ted's

 7 introduction is, you know, all the NAAQS are

 8 subject to some uncertainty in terms of the

 9 science. And so I think sort of the bottom line

 10 question is, is there strong enough, high enough

 11 degree of confidence in the science as we currently

 12 understand it that, you know, a standard setting

 13 process is needed that goes beyond the current

 14 secondary standard?

 15 And so when we talk about the overall

 16 characterization of uncertainty as it relates to

 17 the determination of an ecologically relevant

 18 multi-pollutant standard for NOx and SOx, I think

 19 ultimately that becomes a qualitative or

 20 dichotomous question, yes or no. There is a basis

 21 for a standard and the more quantitative aspect of

 22 how exactly do we set the standard.

 23 It seems that I think the document does a good

 24 job of explaining that the current standard is not

 25 adequately protective of aquatic acidification and

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 1 the associated adverse effects; and that there

 2 seems to be a high degree of confidence that, you

 3 know, therefore, a more stringent standard of some

 4 kind is needed. And so I think that's an important

 5 point and, you know, as we get into the details of,

 6 you know, what ANC level and what AAPI number to

 7 use, and how to do the tradeoff between NOy and

 8 SOx, I think the key question is, well, is there

 9 fundamentally enough evidence, you know, as

 10 imperfect as it is that that's the direction to go?

 11 As far as answering the charge question

 12 specifically, you know, I felt that Chapter 7

 13 covered a lot of issues and we brought up a lot

 14 more comments related to that that I don't see a

 15 need to repeat right now. I guess though a

 16 challenge might be in Chapter 9 maybe to either say

 17 more or say why we don't need to do this, but it

 18 seems like in each of the steps of coming up with

 19 particularly the level of the standard, you know,

 20 there is a starting point within ANC, and then that

 21 informs an AAPI, and then that informs a NOx, SOx

 22 tradeoff. And are there uncertainties that would

 23 lead to biases in those steps? And do those biases

 24 need to be corrected? And if so, can they be

 25 quantified.

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 1 Maybe that's in my view one of the kind of

 2 bottom line questions. And I don't -- this is not

 3 my area of domain expertise. I can't really answer

 4 that question, but I hope that the panel can. So I

 5 think that's all I'm going to say on question 21.

 6 You want to discuss 21 before we go to 22?

 7 DR. RUSSELL: We can do 21 and 22 at the same

 8 time.

 9 DR. FREY: All right. Twenty-two is an A, B

 10 and C with lower case Roman numeral subsections.

 11 So you may regret that we went on to that.

 12 DR. RUSSELL: Actually, maybe I will. Thank

 13 you. So let me move on, Charlie.

 14 DR. DRISCOLL: In the interest of time I

 15 really don't -- we've talked about uncertainty

 16 before. I don't really have anything else to add

 17 beyond what I've already said.

 18 DR. RUSSELL: And Myron.

 19 DR. MITCHELL: I guess I just want to indicate

 20 I think EPA did a good job showing the prudence of

 21 a multi-pollutant standard. I think you should be

 22 commended for that. I think it will be important

 23 to doing some modification changes, updates. We

 24 talked about some better -- improved validation of

 25 CMAQ and also making sure that within the

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 1 considerations of the aquatic side that DOC is

 2 included and on the terrestrial side it includes

 3 some other alternative sources for mobile add-ons,

 4 such as sulfur.

 5 DR. RUSSELL: Panel? Naresh.

 6 DR. KUMAR: Just one more thing in addition to

 7 what I mentioned earlier on into a lack of complete

 8 analysis or uncertainty. As I think about this,

 9 I'm struggling with one thing. Chris mentioned

 10 when he said framing the NAAQS standard, let's take

 11 an example, we have a high deal of confidence that

 12 once you remove, you know, NOx, SOx, SO2 that

 13 you're going to get a reduction in sulfate, very

 14 high degree of confidence. Models may not give you

 15 exactly what's observed, but you know that if you

 16 review SO2, you're going to get a reduction in

 17 sulfate.

 18 And I'm struggling here having shown that if

 19 you reduce SOx and NOx ambient concentrations that

 20 you are going to see an improvement in ANC and how

 21 much of that will be linear as the AAPI question

 22 shows or not. The MAGIC model has really shown

 23 what has been observed in the last 20 or 30 years.

 24 I'd like the panel's views on that because I'm not

 25 an expert on that.

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 1 DR. RUSSELL: So, Charlie.

 2 DR. DRISCOLL: Well, that's what I was trying

 3 to indicate earlier, that there is a lot of data --

 4 well, at least for some regions, you know,

 5 acid-sensitive regions, New York, New England,

 6 Pennsylvania, southeast, certainly less so in the

 7 west that there are fairly good records of how

 8 sulfate and nitrate have decreased over time and

 9 what the response of ANC is. And they're fairly

 10 consistent with the frameworks within the models.

 11 And they're constrained by charge balance

 12 relationships.

 13 We have a pretty good idea of how much ANC is

 14 going to change in response to the change of

 15 sulfate and nitrate. So I think there is a lot of

 16 information to basically bolster the uncertainty

 17 analysis and constrain it rather than just looking

 18 at it from a statistical perspective.

 19 So I think that will be very useful to come

 20 forward. I think maybe it's in some of the earlier

 21 documents, the ISA, but it doesn't really come

 22 through with me here. So I think that that's

 23 useful information to put uncertainty analysis in

 24 context.

 25 DR. RUSSELL: You seem like you had something

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 1 else to say.

 2 DR. KUMAR: I will ask Angela if we have the

 3 letter, are you going to show it?

 4 DR. NUGENT: Would you like to show it?

 5 DR. KUMAR: I would like to show the target

 6 from last time. There was some confusion as to

 7 what the panel had asked. We're talking

 8 uncertainty. I think it would be good to show

 9 that.

 10 DR. RUSSELL: So, as we're doing that, I'd

 11 like to ask, Chris, Charlie -- Myron, I guess

 12 you're still up, then I'll ask a question. Myron.

 13 DR. MITCHELL: For 22?

 14 DR. RUSSELL: Twenty-one, actually, I

 15 forgot --

 16 DR. MITCHELL: I already gave my comments.

 17 DR. RUSSELL: You did? Do you think the

 18 characterization -- I'll ask Chris -- the

 19 characterization in Chapter 9 was appropriate?

 20 DR. FREY: The characterization of

 21 uncertainty? No, actually, I put this under charge

 22 question 22, but one of the things I noticed is in

 23 Chapter 7 there was a nice -- or at least a

 24 relevant paragraph that it might better go in

 25 Chapter 9. This was on page 737 near the bottom

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 1 that talks about kind of the bottom line and it

 2 said there is no apparent directional bias in the

 3 uncertainty regarding the biological, chemical and

 4 physical processes incorporated in the AAPI, and it

 5 goes on.

 6 And it seems like that kind of discussion

 7 really needs to be in Chapter 9 because Chapter

 8 9 should either convince the reader that there is a

 9 high degree of confidence in each of these metrics

 10 used as the basis of the possible secondary

 11 standard; or that if there are uncertainties that

 12 we understand if there is a directional bias in

 13 them, and we have some idea of confidence bounds so

 14 that either we could choose to do a bias correction

 15 or consider a confidence bound in selecting a

 16 level, you know, for example.

 17 So that particular text I think either could

 18 be repeated or could be moved to Chapter 9 and

 19 maybe elaborated in terms of, you know, given an

 20 ANC, what does that apply to our knowledge of the

 21 AAPI? What does that imply for the tradeoff curve

 22 for NOx and SOx? How well do we know that? And

 23 should we be correcting any biases that might

 24 exist?

 25 So I think to that extent Chapter 9 could

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 1 have, I don't know, not a repeat of Chapter 7, but

 2 at least touch on the key inferences from Chapter

 3 7 that inform the standard set.

 4 DR. RUSSELL: Okay. I will actually say that

 5 when I read the paragraph and the conclusions on

 6 the uncertainty, it still didn't really inform me

 7 about the uncertainty in the resulting

 8 concentration that would be derived from all the

 9 uncertainties and all the pieces of the AAPI.

 10 Again, the AAPI, you know, you set a number for

 11 that.

 12 So in some ways, the elasticities you

 13 calculate of the AAPI to the individual components

 14 is not as important as the sense -- or the

 15 sensitivity of the concentrations are to the

 16 individual component of the AAPI. That has to come

 17 through here I think. And to the degree that you

 18 can also inform us as to what that would mean for

 19 potential uncertainties I think that would be

 20 important.

 21 Anything else on 21? Twenty-two.

 22 DR. KUMAR: Discuss that or what? Charlie,

 23 question 13, I think that will really explain what

 24 we want.

 25 DR. NUGENT: This is the cover letter. This

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 1 is the language of the cover letter and I just

 2 want -- that didn't come up. So I thought I would

 3 show that and then go to question 13.

 4 DR. RUSSELL: Question 13, yes. This is

 5 basically saying in our last letter we didn't think

 6 a full probabilistic uncertainty analysis was

 7 practical.

 8 DR. KUMAR: We said a sensitivity analysis

 9 should be conducted and we expand that in the

 10 question 13, what exactly step-by-step approach was

 11 recommended in the consensus letter. So I just

 12 wanted to mention that.

 13 So if you look at the last line there, that's

 14 where we recommended a sensitivity study to

 15 characterize uncertainty where you propagate

 16 uncertainty in that respect, arrive at an ensemble.

 17 That's noted in this letter. If you go further

 18 down, this is an approach, we said, okay, where you

 19 don't know the exact range, you have a probable

 20 range, use a probable range for Neco, use two

 21 different approaches, propagate those ranges. This

 22 very clearly defines what we asked to be done.

 23 DR. HUBBELL: Yeah. Again, I think we

 24 interpreted it differently in terms of what the

 25 initial statement was and focused more on

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 1 individual sensitivities because of the

 2 complexities in doing this. But, again, we can

 3 certainly investigate it, but, again, given the

 4 substantial amount of effort that's required to do

 5 this on a systematic basis across all the variables

 6 we just need to evaluate that. It is not a trivial

 7 exercise to do it.

 8 DR. RUSSELL: Thank you. Okay. Charge

 9 question 22, Chris.

 10 DR. FREY: Okay. This is a multipart question

 11 and so the first part has to do with insights that

 12 could be gained into potential alternative

 13 additional secondary standards using the AAPI form

 14 by considering several things. And I don't think

 15 I'm the right person to answer this question

 16 because I don't have domain expertise on these

 17 topics, but it did strike me that none of these

 18 topics was particularly mentioned at all in Chapter

 19 9. And Chapter 9 could maybe more clearly make the

 20 linkage between adverse effects and the standard.

 21 So, for example, there could be a discussion

 22 of what are the key hazards associated with aquatic

 23 acidification and maybe discuss some of these of

 24 mortality and pH and ANC, but I don't really have

 25 anything to add to this particular part of, you

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 1 know, Part A of the charge question.

 2 So I guess the question is whether the panel

 3 feels that the document adequately addresses these

 4 issues or if these are missing issues in further

 5 discussion in Chapter 9.

 6 DR. RUSSELL: We can actually take 22-A, B and

 7 C, so do each one -- each subpart -- well, not

 8 sub-subpart -- subpart separately. So, Charlie.

 9 DR. DRISCOLL: Okay. Well, I guess I had a

 10 few thoughts on some of these pieces. In terms of

 11 mortality of aquatic organisms, I am assuming the

 12 person who framed this is referring to like in situ

 13 bioassays and things like that. And I don't know

 14 of any studies beyond ones that were cited in the

 15 report. So I don't know if there is any other

 16 information that could be gained from that.

 17 In terms of the relationships with

 18 biodiversity, I mentioned some minutes ago about

 19 the different, you know, the spatial patterns which

 20 these are built, are they going to translate to

 21 temporal patterns? So I think a little bit of lip

 22 service on that would be useful.

 23 I didn't understand 2-A-iii, relationship

 24 between pH, aluminum and ANC, is that the

 25 interrelationship between -- for a given ANC, how

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 1 does it affect pH, how does it affect aluminum,

 2 things like that? I wasn't --

 3 DR. HUBBELL: I think I didn't write this

 4 question particularly well. What I was trying to

 5 get at was we went through a process in Chapter 5

 6 of justifying certain ANC levels using all these

 7 different types of information.

 8 The question was is that justification enough

 9 or is it, you know, should we give it a lot of

 10 weight and actually determine the range of the

 11 AAPI? Again, recalling that the AAPI is partially

 12 based on the target ANC level as well as these

 13 other considerations about timing of recovery,

 14 uncertainty, all these other factors.

 15 So it was more intended to say how does this

 16 information play into actually picking the specific

 17 levels of the AAPI? That's what we were trying to

 18 get at. I didn't ask the question particularly

 19 well. Using the AAPI form was supposed to push you

 20 in that direction. I don't think I did a very good

 21 job.

 22 DR. DRISCOLL: Okay. Well, I think I get

 23 where you're coming from. I think there have been

 24 discussions in previous documents, such as the REA,

 25 about the use of the ANC. I think it makes sense

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 1 given, you know, that this is a management action

 2 and the challenges of measuring pH and aluminum and

 3 different fractions of aluminum that ANC is

 4 probably the appropriate indicator. But that said,

 5 some of the slop that you see in terms of these

 6 biological responses are undoubtedly due to

 7 variations in pH and aluminum across systems where

 8 you see a comparable level of ANC because fish

 9 don't understand ANC, at least that's what I'm told

 10 anyway. So I think that ANC approaches, I endorse

 11 it, I said that before and I say it again.

 12 Your number IV, I was -- I was very interested

 13 in the document where you had these various target

 14 levels for either pH or ANC by various states, but

 15 I don't recall that there was a lot of

 16 justification given for why -- I can't remember. I

 17 think New York put 6.5 or 6 and Tennessee put

 18 something else and Vermont put something else and I

 19 didn't recall there was justification for that. I

 20 guess given that the states are going to implement

 21 this, it would be probably useful to have some

 22 information about what their thinking was when they

 23 established those values. Is that where you're

 24 coming from on this last comment here?

 25 DR. HUBBELL: Yeah. Interestingly enough,

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 1 some of them specifically mention a particular

 2 species; and that, you know, they chose 6.0 or 6.5

 3 whatever to protect brown trout or something like

 4 that. I think, you know, that's what -- some of

 5 their justifications are focused on macro indicator

 6 species that they felt like people understood and

 7 grabbed onto.

 8 Again, it was more in the range these are

 9 indicators that people thought this was adverse and

 10 kind of that understanding, that broad public

 11 understanding of adversity be brought forward into

 12 helping us pick a level; maybe not, maybe we don't

 13 have to wait on that. It's just a question as an

 14 indicator of adversity, is that a useful benchmark

 15 that can help us identify some levels of target ANC

 16 that might be considered as we move forward? It's

 17 just a question of how much weight can you put on

 18 those or maybe put on those relative to other

 19 pieces of information we have, more direct

 20 scientific findings.

 21 DR. DRISCOLL: Well, I guess, you know, I'm a

 22 little familiar with New York, but I certainly am

 23 not familiar with the other states. I know that in

 24 Europe it's problematic when they do critical

 25 loads. Different countries set different

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 1 indicators and different levels for those

 2 indicators. So that's one of the challenges going

 3 forward. I think it is useful information to find

 4 a background on why they selected where they did.

 5 DR. HUBBELL: Some are not.

 6 DR. DRISCOLL: I guess that's all I had on

 7 that first part.

 8 DR. RUSSELL: Myron.

 9 DR. MITCHELL: I kind of interpreted that's

 10 what you wanted. I thought the document did a good

 11 job of indicating although ANC is not a perfect

 12 indicator in terms of all the adverse effects of

 13 aquatic systems, it's probably one of the more

 14 robust single indicators we can come up with.

 15 DR. RUSSELL: Panel? Okay, 22-B.

 16 DR. FREY: 22-B, the appropriate role of

 17 qualitative and quantitative characterizations of

 18 uncertainty in developing standards using the AAPI

 19 form. I think this just goes back to the comments

 20 I made just a few minutes ago. The paragraph that

 21 was in Chapter 7 that I was quoting partly from

 22 concludes by saying that there is support for an

 23 AAPI that is somewhat higher than the target ANC;

 24 and that's in part because the level of the AAPI

 25 should be relatively high in a buffering context,

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 1 which the language is a little awkward, but to

 2 account for the existence of uncertainties in

 3 several components and then there is also a time

 4 lag issue related to response dynamics. And I

 5 didn't see that translated into Chapter 9 in terms

 6 of informing, perhaps setting the level of the

 7 standard.

 8 So that's an example of where if you -- as you

 9 go across these linkages from ANC to AAPI to the

 10 pollutant concentrations, if in particular there is

 11 a need for bias correction, that really should be

 12 discussed in Chapter 9 and an alternative could be

 13 developed based on any such bias correction.

 14 DR. RUSSELL: Charlie.

 15 DR. DRISCOLL: I feel like I've talked a lot

 16 about uncertainty and I don't have anything to add

 17 beyond what I've already said.

 18 DR. RUSSELL: Myron.

 19 DR. MITCHELL: I'm pretty much in the same

 20 place Charlie's at, talked about different types of

 21 uncertainty and how that can be improved in terms

 22 of putting out this information.

 23 DR. HUBBELL: If I could just try to clarify a

 24 little bit. This is a difficult set of questions.

 25 So what I was looking for in that question was more

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 1 specifically, given what we have now said about all

 2 the uncertainties, what you know about the

 3 uncertainties, what's available in the literature,

 4 what I'm looking for in thinking about the specific

 5 range of values or ranges of standards, are there

 6 specific things we should consider about the

 7 uncertainties that would lead to one particular

 8 adjustment or consideration of the range versus

 9 another? In other words, would you suggest we

 10 should make the range narrower; should we make it

 11 broader; should we make overall the whole thing

 12 higher or the whole thing lower?

 13 In terms of specifically when you get to point

 14 of setting an AAPI and setting a standard, how does

 15 uncertainty play into that? Not just simply

 16 thinking about better characterization of

 17 uncertainty, but translating that into something to

 18 do with the standard. Does it change the

 19 considerations?

 20 DR. RUSSELL: Myron.

 21 DR. MITCHELL: I would suggest, Bryan, that in

 22 that area the most important things are there

 23 processes or inputs that are not included in the

 24 AAPI, and how would including those affect that

 25 standard? That's the major factor.

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 1 DR. HUBBELL: Okay. That's the SO2 and

 2 sulfate.

 3 DR. MITCHELL: Exactly, and DOC in the waters.

 4 DR. HUBBELL: All right.

 5 DR. RUSSELL: Panel? Rudy.

 6 DR. HUSAR: Lacking the corrections of bias

 7 corrections that has already been done for the

 8 presentation, you predict a model and you just kind

 9 of adjust it to give texture to it with the real

 10 presentation. Well, similar kind of bias

 11 adjustment could also be done for SO2 and that way.

 12 You see, you're exposing yourself to real

 13 substantial questions about it.

 14 DR. SCHEFFE: Quick response. We could do

 15 that with precipitation because of all the

 16 observations. There are not that many observations

 17 for SO2, particularly in rural areas. That's one

 18 thing. It's a little more complicated by the way

 19 SO2 is used and the transference ratio is embedded

 20 in the modeling. So there needs to be further --

 21 DR. HUSAR: But at least try it.

 22 DR. RUSSELL: So, Bryan, actually to -- maybe

 23 I'm -- what you just said, see if I'm somewhat

 24 interpreting it correctly, is that relative to the

 25 health-based standards one of the things that

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 1 formed the lower end where we set the health-based

 2 standard is the uncertainty grows in terms of the

 3 likely health effects as you get lower. Is that

 4 the same sort of question given what we understand

 5 about the uncertainty, how does that influence

 6 where we might set the AAPI? How does it work into

 7 the actual setting the AAPI? And given the

 8 uncertainty might be like this, we might set it one

 9 place and if it was like that, we might set it

 10 another place.

 11 DR. HUBBELL: Find a point on the range.

 12 DR. RUSSELL: I think that really -- your

 13 question was at that point is given our

 14 understanding of the uncertainty, should we set the

 15 AAPI higher or lower, maybe it shouldn't affect it

 16 at all? Excluding the biases, maybe we just say we

 17 have to recognize this is uncertain and go forward

 18 with our best estimate.

 19 DR. HUBBELL: I think that's what I was

 20 looking for. Karen, do you have any official

 21 comments?

 22 MS. MARTIN: No. I think what Ted is saying

 23 now is appropriate.

 24 DR. HUBBELL: I think that's what we're

 25 looking for.

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 1 DR. RUSSELL: The panel gets that. I think

 2 that is an important consideration because, again,

 3 when we start talking later about what might set

 4 the standard and all the components thereof, how

 5 does our understanding of uncertainty influence

 6 that.

 7 DR. HUBBELL: Thank you.

 8 DR. RUSSELL: Anything else from the panel on

 9 that one? C.

 10 DR. FREY: So C is asking about I guess some

 11 temporal aspects that might be considered in

 12 setting the standard in terms of setting the time

 13 trajectory of the response, the effect of episodic

 14 acidification events; and then also asks for us to

 15 consider whether setting the standard should also

 16 be done in a way that is protective of other

 17 adverse effects, such as terrestrial ecosystems

 18 acidification or excess nutrient enrichment.

 19 I don't really personally have much to

 20 contribute here because this is not my area of

 21 expertise, but it seems like we also heard some

 22 discussion about spatial variability maybe even

 23 within a region; and to the extent there is spatial

 24 and temporal variability such that there is small

 25 geographic areas or short time periods that need to

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 1 be protected, that might imply some kind of

 2 correction or adjustment.

 3 And, you know, as far as the protecting

 4 against other adverse effects, I don't have a

 5 personal opinion about it. I guess the question

 6 there would basically be operationally should the

 7 standard be more stringent than it might be only

 8 for aquatic acidification, if that would lead to

 9 protection for these other effects. I guess that's

 10 my understanding of the question. And I don't

 11 personally have the answer to that, but the panel

 12 might.

 13 DR. RUSSELL: Charlie.

 14 DR. DRISCOLL: Okay. So I think that there is

 15 information that is available on the response to

 16 changes in the ANC through use with dynamic models.

 17 And so, from our experience, to reach steady state

 18 for systems in the Adirondacks or systems in the

 19 northeast it depends on how you define steady

 20 state. You know, they never really come to steady

 21 state, but maybe something on the order of 200

 22 years, something like that. I'm sure for the

 23 southeast it's longer given the accumulation of

 24 sulfur in the soil. So it's a pretty long time

 25 frame.

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 1 The other thing I think is relevant with

 2 effect to the trajectory analysis is in terms of

 3 how the F factors change. And you can track F

 4 factors through dynamic models. And they do go

 5 through a hysteresis pattern, so that informs the

 6 assumption about a constant effect and how that's

 7 used in the reconstruction. You could also do that

 8 for time series data. There are hysteresis in time

 9 series data that might help inform -- form this. I

 10 think it's going to be a long time for these

 11 systems to come to steady state.

 12 In terms of episodic acidification, I think

 13 that there was quite a bit of information on that

 14 in the ISA. And generally there is, you know, for

 15 work that we do in the northeast, we lose about 50

 16 microequivalents per liter, sometimes more, but

 17 that's probably a good ballpark figure. I think

 18 that's part of the reason for having a target ANC

 19 on the order of 50 because it helps protect against

 20 episodic acidification.

 21 And co-protection, so I think Dale spoke a

 22 little bit about that in that this is about

 23 terrestrial acidification. And I was interested in

 24 the analysis that was done about co-protection for

 25 terrestrial acidification. So, from my experience,

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 1 there have been quite a few studies across the

 2 country that have looked at time series of soils,

 3 repeated measurements of soils. And Dale knows

 4 much more about this than I do, but they virtually

 5 all show loss of base cations. So I think that's

 6 consistent with what he is saying, is soils are

 7 reacidifying at least in wet areas. There is not

 8 examples of them accumulating base cations, maybe a

 9 few, but the vast majority are losing. Where if

 10 you look at surface water values, they're pretty

 11 much all, at least in the northeast, they're

 12 increasing in ANC.

 13 So in my mind that speaks to the fact that,

 14 you know, maybe soils are more sensitive than

 15 surface waters because soils are, you know, are

 16 continuing to acidify or at least maintain their

 17 conditions, where there is some recovery of surface

 18 waters. But that said, undoubtedly if you reduce

 19 the load there would be co-protection benefit

 20 associated with it.

 21 So I don't think anybody in this room would

 22 argue that there would be a certain amount of

 23 benefit. We might argue about the degree of that.

 24 One thing that I wanted to add in though the

 25 thing you didn't do was you had a little bit of

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 1 information on mercury and methylation of mercury.

 2 So you downplayed that probably with good reason.

 3 But I think there is also -- in the northeast there

 4 is a pretty strong relationship between ANC and

 5 biotic mercury concentrations. I don't think

 6 anybody knows why it is. But, in fact, I was

 7 looking at it today for zooplankton and fish and

 8 loons, and if you increase the ANC by a few

 9 microequivalents per liter, if you follow the

 10 empirical relationships, you know, they're very

 11 sensitive to ANC, extremely sensitive to ANC. So I

 12 think, you know, if you increase ANC, you would

 13 have to get some benefits in terms of biotic

 14 mercury, which haven't been mentioned in this

 15 document at all.

 16 DR. RUSSELL: Myron.

 17 DR. MITCHELL: Obviously, it's a major

 18 challenge in terms of using the aquatic AAPI form

 19 and looking at how that is going to affect

 20 terrestrial systems. We know that terrestrial

 21 systems are time framed substantially different.

 22 We also know that in some of these systems things

 23 like an uptake and retention seem to be highly

 24 variable. We don't understand what's causing that

 25 variability. That's going to cause some problems.

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 1 Clearly the loss of base cations, maybe not

 2 just base cations, it might be specific cations,

 3 such as calcium, seems to be a real critical

 4 nutrient for certain tree species, particularly

 5 sugar maple. And then we don't know that there is

 6 going to be other factors happening over time,

 7 there is going to be changes in climate, CO2

 8 concentration, which can have an effect both on the

 9 aquatic and terrestrial component. That's going to

 10 allow -- that's going to make the predictions more

 11 difficult. Some could be enhancing, some it will

 12 make it more difficult to reach some of these

 13 targets.

 14 DR. RUSSELL: Panel? Dale.

 15 DR. JOHNSON: Follow up on that soil

 16 acidification. I don't know of any study where

 17 soils in human regions have spontaneously increased

 18 in base saturation. The only indications I can

 19 think of is on Walker Branch where we had some

 20 calcium-rich vegetation, trees fall down and die

 21 and decompose and they released their calcium back

 22 in the soil, liming. Other than that, natural

 23 acidification processes, including tree uptake and

 24 carbonic acid leaching will continue. So they

 25 don't recover I don't think. It's a hypothesis.

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 1 DR. RUSSELL: Panel?

 2 DR. HUBBELL: Could I ask one more question,

 3 please?

 4 DR. RUSSELL: Yes.

 5 DR. HUBBELL: Charlie, you said you agreed on

 6 the dynamic models recovery can take 200 years or

 7 more. One of the things we tried to discuss in the

 8 document was if you then want to try to see some

 9 type of change and movement toward your target ANC

 10 within the next 20, 30, 50 years, a generation or

 11 generations from now, is there a way to understand

 12 that relationship so that you can set a target load

 13 in the 50 to 100-year time frame that would match

 14 sort of what that steady state response would be?

 15 In other words, if I really wanted to get to

 16 ANC of 50 by -- in 100 years or 50 years, maybe

 17 it's not possible, but if I wanted to get there in

 18 50 or 100 years, is there a way to adjust the AAPI

 19 in such a way that it would get me there? Would I

 20 need to set an AAPI of 80 to get an ANC of 40?

 21 DR. DRISCOLL: I think you could develop --

 22 I'm an engineer, we do this all the time -- a

 23 safety factor, you know, to try to look at -- I

 24 mean, I'd have to go in and actually do some

 25 calculations to suggest what that might be, but I'm

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 1 sure with MAGIC calculations you could pull that

 2 out. It's a model, but, you know, at least it

 3 would be something. But I think -- so I was moved

 4 in the last report to put in a little figure that

 5 Ted, I know at least, liked showing differences

 6 between a target load value and say 2030 in a

 7 steady state value. And it's, you know, it's

 8 pretty substantial in some cases. But I think

 9 there is enough experience with enough models that

 10 one could try to do something on that regard if you

 11 wanted to.

 12 DR. RUSSELL: Does that clarify it? Okay.

 13 Twenty-three. Kathy.

 14 DR. WEATHERS: This is another one of those

 15 questions that may require some clarification. It

 16 seems like there is confusion from a number of us.

 17 This asks the question about whether the existing

 18 standards for NOx and SOx should be retained to

 19 provide protection against direct adverse effects

 20 of vegetation due to gas phase exposures. It seems

 21 to me that there was justification for that in a

 22 document you provided, but it wasn't clear

 23 whether -- whether we're talking about an

 24 additional standard here. What's the purpose of

 25 this question and how does it figure into this?

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 1 DR. HUBBELL: The purpose of the question is

 2 to say right now we're protecting almost entirely

 3 by this new set of standards and a new form,

 4 completely different averaging times and so forth.

 5 The question is, you know, does this become a

 6 replacement standard or does it become an

 7 additional standard?

 8 What we're trying to figure out is based on

 9 the fact that there is no evidence to suggest that

 10 all of a sudden direct exposures are not

 11 phytotoxic, you know, shouldn't we potentially

 12 think about retaining the existing standards while

 13 adding an additional standard to cover depositional

 14 effects?

 15 This is a question to the panel, do you agree

 16 we should retain the existing standards in their

 17 existing forms to protect against those specific

 18 phytotoxic effects?

 19 DR. WEATHERS: My answer to that is yes based

 20 on the information here, but there is still an open

 21 question about whether the new standard would

 22 result in air concentrations that are lower or

 23 higher than this standard.

 24 DR. HUBBELL: Yes. Given they're not matched

 25 well in terms of temporal and spatial things, the

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 1 chances that they would actually, you know, exactly

 2 protect in the same way are probably not that high.

 3 The question is do you still need this existing

 4 standard to make sure you protect against those

 5 effects?

 6 We have not evaluated what would happen to

 7 those. Again, given that we've established that,

 8 you know, almost everybody meets the current

 9 standards and we're talking about something

 10 additional, what we're really talking about is

 11 preventing things from going backwards because of

 12 high powering or annual concentrations.

 13 DR. WEATHERS: So my answer is that was

 14 desirable. I think that was the answer of others

 15 too.

 16 DR. RUSSELL: Any disagreement on that?

 17 Charlie.

 18 DR. DRISCOLL: I'm probably going to expose my

 19 ignorance here, but are there really -- are there

 20 issues of nonattainment for this standard? I

 21 didn't think there were any or very few issues for

 22 nonattainment for the standard where the emissions

 23 are going to go down.

 24 DR. HUBBELL: It's not necessarily clear that

 25 they're going to go down in all locations at the

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 1 exact time frame. That's the question. One of the

 2 standards, for example, is a very short-term

 3 standard and one is an annual standard. We're

 4 talking about three to five-year standards.

 5 Clearly you have places where you have short-term

 6 peaks that are not protected. The question is do

 7 you leave protections in place or do you think it's

 8 appropriate to move away from those?

 9 DR. DRISCOLL: Well, see, it would be good to

 10 see how this all plays out, but my read on the

 11 situation is that as it currently stands, it's not

 12 really a problem and if we have this new standard

 13 if this would go forward that would be much more

 14 comprehensive. And I would think it would be

 15 desirable to have something that was more

 16 comprehensive than have the current standard.

 17 DR. HUBBELL: To be clear, you can have both.

 18 DR. DRISCOLL: I know, I'm just trying to

 19 eliminate some bureaucracy. So, anyway, I guess I

 20 have some, you know, I feel differently than my

 21 colleagues I guess about the standard.

 22 DR. WEATHERS: Only insofar as the bureaucracy

 23 is the issue.

 24 DR. DRISCOLL: Yeah. If it's not -- if there

 25 are no issues concerning nonattainment and it seems

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 1 unlikely that the emissions are going to increase

 2 in the future, why do we need it?

 3 DR. RUSSELL: Well, one question might be, and

 4 you can correct me if I'm wrong, let's say that

 5 they didn't go forward with a new standard

 6 deposition. We certainly don't want to recommend

 7 that they get rid of the old standard, old

 8 secondary standard.

 9 DR. HUBBELL: Yeah. I think that's an

 10 important distinction is that if you made the

 11 recommendation that it should be removed entirely,

 12 that's different than saying that you think it

 13 should only be replaced by a new standard or exists

 14 in addition to the new standard. There are some

 15 subtleties in terms of what you would like to

 16 happen to it, assuming that either the standard

 17 went forward, the new standard went forward or did

 18 not go forward. That's a good question.

 19 DR. DRISCOLL: I'm not competent to talk about

 20 phytotoxicity, but I feel like if this new approach

 21 is more comprehensive and it's going to be more

 22 protective, then I wouldn't really see any reason

 23 to retain the old standard if the new standard was

 24 going to go forward.

 25 DR. WEATHERS: Is there a question where you

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 1 run into a situation with tradeoff curves that you

 2 could end up with higher let's say SO2

 3 concentrations and lower NOx and they would be high

 4 enough to effect vegetation?

 5 DR. HUBBELL: Possibly so. And the other

 6 thing to remember is the spatial differences are

 7 fairly important here because we're talking about

 8 focusing on aquatic acidification and the

 9 phytotoxicity protection would exist everywhere.

 10 That's just a question.

 11 MR. POIROT: There are some new monitoring

 12 requirements for SO2 that we don't know how those

 13 are going to turn out or what kind of

 14 concentration.

 15 DR. RUSSELL: Praveen.

 16 DR. AMAR: I'm confused. Are we suggesting

 17 that the new standard could replace the existing

 18 standard, or we will have two standards, one for

 19 direct effects one for AAPI?

 20 DR. HUBBELL: That's essentially what we're

 21 asking you is do you want to -- given that we're

 22 moving forward with this new plan for a standard,

 23 do you also recommend retaining the existing

 24 standard to provide that extra protection in areas

 25 or under, you know, time periods that might not be

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 1 covered or protected fully by these new

 2 deposition-based standards?

 3 DR. AMAR: I understand bureaucracy, so we are

 4 we saying that we will have two different

 5 processes, two different steps?

 6 DR. HUBBELL: Well, existing standards are in

 7 place already. We would simply retain those. I

 8 don't think that requires any new -- retain, you

 9 don't have to do anything new, correct? It

 10 requires no action. It just maintains the existing

 11 protections.

 12 DR. AMAR: It requires some kind of planning

 13 process for states, no?

 14 DR. HUBBELL: No, because it's simply

 15 retaining the existing standard. There would be no

 16 change. So there would be no need for new sets or

 17 new actions.

 18 DR. AMAR: I'm thinking implementation, I

 19 know. But I'm saying there must be some

 20 implementation requirements of existing SO2

 21 standards. Implementation meaning what do states

 22 have to do, submit a plan?

 23 DR. HUBBELL: They've already had to do that.

 24 DR. AMAR: They will also do that in the

 25 future.

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 1 DR. HUBBELL: Only if the standards were

 2 changed. Let Karen speak to this.

 3 MS. MARTIN: I was just thinking about the

 4 question this way: Do you believe that there is a

 5 scientific basis to have a three-hour average SO2

 6 standard at the level it's at to protect against

 7 direct effects of exposure to SO2? That's a

 8 question. Do you believe that is still a relevant

 9 standard to protect against effects that should be

 10 protected against?

 11 The issue of whether a new standard, were it

 12 to be set, multi-pollutant AAPI-related standard,

 13 it's hard to imagine a three to five-year average

 14 standard protecting against all instances of

 15 three-hour average peaks. And, therefore, since

 16 one can't -- wouldn't conceivably provide

 17 protection from the other averaging time, then the

 18 question is, is there a scientific basis to attain

 19 it? I think that's a fairer way to think about it.

 20 DR. WEATHERS: That's basically is there a

 21 scientific basis that vegetation is affected,

 22 right? Because one of the issues was, well, no

 23 area has been in nonattainment, everyone has been

 24 in attainment, is it still an issue?

 25 MS. MARTIN: That's rather irrelevant to

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 1 whether or not --

 2 DR. WEATHERS: That's what I'm saying.

 3 MS. MARTIN: -- the standard is appropriate

 4 based on the underlying scientific information.

 5 Does it remain an appropriate standard presuming it

 6 was an appropriate standard when it was set based

 7 on some scientific evidence, does that scientific

 8 evidence still remain relevant and does the

 9 standard still remain relevant?

 10 DR. WEATHERS: Right. And correct me, we

 11 didn't spend much time in this panel talking about

 12 that scientific evidence. So what I would suggest

 13 in regard to this question is that the scientific

 14 evidence or the digestion of that that was

 15 presented here suggests that the standard should

 16 remain in effect based on the fact that vegetation

 17 would be affected by SO2 concentrations. That's a

 18 question I'm asking since I have to write the

 19 answer to this.

 20 DR. RUSSELL: I think actually we can go back,

 21 but that's when we had gone over the ISA, we

 22 essentially came to that conclusion is that there

 23 is still that potential even though there may not

 24 be any nonattainment questions at this time, the

 25 science has not changed appreciably to suggest that

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 1 that is no longer the case.

 2 So the question, we can discuss this, though I

 3 sort of want to say just because of the bureaucracy

 4 we should do away with standard that could be

 5 protective. For one, I mean, there is actually the

 6 issue that it is a terribly different scale than

 7 which we're looking. We have this very

 8 concentrated SO2 in a plume coming from some source

 9 that would not really be impacting an area that's,

 10 you know -- actually, one of the designs of a new

 11 standard, what we're going over now, it would be

 12 potentially applying in very, very different areas.

 13 Sort of the whole parts of the midwest may not be

 14 of that great of concern, maybe so, maybe not, we

 15 just don't know at this point.

 16 So I think if we said get rid of it, we'd have

 17 to say that there is no longer the scientific

 18 evidence to suggest that it's supported.

 19 DR. WEATHERS: Agreement among the people?

 20 DR. RUSSELL: Any other questions, comments on

 21 that from the panel?

 22 Okay. Sort of the big one, if we really think

 23 about this in its entirety, we'll again take this

 24 in parts. This is a four-part problem. Judge your

 25 time accordingly, as we tell our students. So

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 1 24-A.

 2 DR. WEATHERS: I see this whole series of

 3 questions as a reiteration in some ways of the

 4 questions that were asked earlier and that the big

 5 question, as Ted framed it, which is, is this an A

 6 to Z document; and if not, where are the holes?

 7 What are the issues?

 8 So my answers to this are, again, are

 9 reiteration. So the first part it looks to me 24-A

 10 that the research has shown that acidifying

 11 atmospheric deposition at its current levels

 12 results in ecosystem functional effects. And the

 13 information in Chapter 2 to 4 reinforce that. So

 14 was it your intention to reiterate?

 15 DR. HUBBELL: The intention was to reiterate

 16 and ask you again to provide your judgments as a

 17 panel on the options or ranges for the various

 18 different elements. After the first point -- after

 19 A -- B, C and D are talking about picking a target

 20 ANC value; picking an appropriate percent of

 21 waterbodies to protect; and then taking that and

 22 helping us put it all together into what would an

 23 AAPI standard or options for an AAPI standard look

 24 like, including those various different items.

 25 DR. WEATHERS: Right. So this is really

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 1 asking the question, given what's proposed, the

 2 averaging time, form and level. What do you think

 3 about that?

 4 DR. HUBBELL: Form and level, but also

 5 including the complexities that we have here, which

 6 is target ANC value, percent of waterbodies to

 7 protect; and to the extent you care to opine on it,

 8 helping us narrow down the spatial averaging, for

 9 example. If you think it's appropriate to go after

 10 a target ANC of 30 because you're focusing on, you

 11 know, the five bins of sensitive areas, that kind

 12 of compilation of things. That's what we're

 13 looking for.

 14 DR. WEATHERS: My inclination is to take that

 15 as a whole.

 16 DR. RUSSELL: B, C and D?

 17 DR. WEATHERS: Yeah, take that as a whole.

 18 And my response is that I think that the indicator

 19 and average time to form the levels that you pose

 20 in those ranges make sense. There is a

 21 justification for them throughout this document.

 22 The challenges I think that haven't been

 23 addressed in this document, to which I certainly

 24 don't have an answer, has to do with the spatial

 25 averaging, how it is that you aggregate and lump

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 1 across the country, whether it's about the critical

 2 loads or it's about the ecoregions. So I think

 3 that there is some missing pieces there in order to

 4 make a determination.

 5 And then how big a problem it is. This goes

 6 back to the uncertainties question. How big any

 7 particular aspect of AAPI actually is that we

 8 don't -- that we can't constrain some of those, the

 9 base cation, how much of it -- it's clear that

 10 concentrations result in deposition; that there are

 11 ecological effects from deposition; that ANC is a

 12 reasonable indicator of aquatic acidification.

 13 So, again, I think the questions come back to

 14 you all to refine this spatial aggregation pieces.

 15 There is not enough information in this document to

 16 give some suggestions about that, from my

 17 standpoint. And to frame the uncertainties and the

 18 sensitivities in a way that would I guess as

 19 scientists make us comfortable about saying yeah,

 20 the AAPI is reasonable and justifiable.

 21 DR. HUBBELL: On the spatial aggregations

 22 issue, do you feel that there is enough information

 23 to get rid of any of the options that we've laid

 24 out?

 25 DR. WEATHERS: To get rid of any of them?

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 1 Probably the one nation.

 2 DR. HUBBELL: That's pretty clear.

 3 DR. WEATHERS: But what I would like to see

 4 more of is the reasoning behind some of the spatial

 5 aggregation. Again, I'm looking for some way to

 6 either line up the limitations of the data in terms

 7 of spatial aggregation, so we'll have everything

 8 spacially aggregated in multiples of CMAQ windows

 9 or process level information. That's the

 10 limitation or to aggregate in a way that you have

 11 with ecoregions in some sort of defensible way that

 12 says we're lumping things together because we know

 13 these ecological regions have effect on regions of

 14 the AAPI in particular ways.

 15 DR. RUSSELL: Rich?

 16 MR. POIROT: I agree with Kathy almost on a

 17 point-by-point basis. I guess I felt like, you

 18 know, once we get by the adversity question, which

 19 I think you made a good case and you've supported

 20 it well, the target ANC value seems like somewhat

 21 an easier part of the decision. There seems to be

 22 a pretty clear huge point in there. I think you

 23 can justify that quite well even at several

 24 different levels.

 25 I wouldn't necessarily advocate though making

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 1 that decision and then, you know, moving on because

 2 I don't have a sense of how all of the parts of it

 3 might fit together. It may well be that a slightly

 4 more or less lenient ANC level will fit better with

 5 the selection of percentage links and that sort of

 6 thing. But anyway it seems to me you've got a

 7 pretty good basis for a pretty clear recommended

 8 level or range without too much variation.

 9 As we have been talking about earlier, there

 10 are just -- to me, the implications of the options

 11 for selecting percentage of links to be protected

 12 wasn't for me explained with enough clarity that I

 13 felt like I could easily choose among them.

 14 I might not encourage you to take the one, the

 15 one population option off the table just because it

 16 actually helps to clarify the others. It shows in

 17 a way why that might not be a good choice. So I

 18 would leave it in there I guess.

 19 But, again, I think that the trick is to

 20 explain these more clearly. And I keep reflecting

 21 back to the old days, not that long ago, of the

 22 staff papers where I used to, you know, what I used

 23 to like about them when we were talking about

 24 getting rid of them was that you guys do all the

 25 heavy lifting and we would just have to come back

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 1 with our judgments on whether you had made some

 2 good choices or not.

 3 Now it's sort of feeling like you're asking us

 4 to do the heavy lifting and somewhere in between

 5 those two extremes there has got to be some

 6 compromise, but I think it would help if you showed

 7 us clear examples of what some of the advantages

 8 and disadvantages of some of these options are.

 9 That's just what I couldn't see clearly here.

 10 Maybe it was just too new. I'd have to read it

 11 another time. So that's all I had to add to that.

 12 In terms of the -- are we moving on through

 13 all of these parts, Ted?

 14 DR. RUSSELL: Yeah.

 15 MR. POIROT: In terms of the last question,

 16 Part D, I had suggested earlier that the

 17 consideration of could this transfer TNOy, could it

 18 be calculated in other ways that would be almost as

 19 good or just as good? That's my only

 20 recommendation for a slight variation. I don't

 21 even consider it a variation really. It's just

 22 somewhat of an accommodation, especially given the

 23 monitoring constraints, could a method that could

 24 utilize simple CASTNET-type measurements be

 25 utilized on a near-term basis even as we're

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 1 collecting more detailed information to refine it.

 2 That was my only suggested possible variation. I

 3 don't consider it a large one.

 4 DR. RUSSELL: Lauri?

 5 MS. CHESTNUT: So we're doing the whole thing,

 6 A through?

 7 DR. RUSSELL: A through D.

 8 MS. CHESTNUT: So trying to sum things up, I

 9 think in the case for adverse effects due to

 10 aquatic acidification at current levels is well

 11 established and there is even a sense of the, you

 12 know, significance of that; though I have to keep

 13 reiterating I feel that the ecosystem services has

 14 to -- should always include the nonuse concepts,

 15 that public welfare is affected by the protection

 16 of these resources in their natural state even if

 17 people don't get direct use from them.

 18 I'm not sure that the information about the

 19 degree to which there is adverse effects in the

 20 other categories has been brought forward enough.

 21 It is sometimes described as this is -- it can

 22 cause these kinds of things, but I keep wanting to

 23 see so how much of an area is affected; you know,

 24 what percentage of the forest; or what -- not just

 25 that these are important resources, but this level

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 1 of deposition is causing this much impairment, even

 2 if dollar values, total numbers can't be put on it.

 3 I was a little concerned in several places in

 4 the document that the potential benefit of going to

 5 ANC levels higher than 50 seemed to be kind of

 6 downplayed. I mentioned that in some of the

 7 language. And there seems to be some inconsistency

 8 between some of the presentation. I wasn't also

 9 clear if there is also some -- what that -- why

 10 it's -- there is increasing uncertainty about what

 11 the benefit would be, probably beyond 50. Is it

 12 that we don't know about how the lakes will -- the

 13 waters will respond; or is it that we don't know

 14 how big the benefits are once we have a resource

 15 that at least has all of the pieces that should be

 16 there and then it's just kind of getting less

 17 acidic? So I'm still a little -- I think that

 18 could be tightened up to give more information

 19 about the base system to make those decisions.

 20 This percentage of the waterbodies, I came

 21 back to a question about, well, in an area like the

 22 Adirondacks now, what percentage are below those

 23 levels now? I mean, we're not talking 50 percent,

 24 are we, is it 10 percent? I mean, I don't know

 25 what -- it seems to me if we're looking at 50, 75

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 1 or 90, it would be useful to see that alongside how

 2 many are below, what percentage are below 50 now

 3 under the current conditions.

 4 And if those waterbodies that would not

 5 respond to reductions in emissions, pollution

 6 levels, or deposition levels are excluded, I'm not

 7 sure why a hundred percent isn't in the set.

 8 What's the justification for a target less than a

 9 hundred percent if it's not feasibility?

 10 So this question I think Charlie raised about

 11 do you leave them all in and then make some

 12 adjustment for the fact that some won't be

 13 responsive, but if you've taken the unresponsive

 14 ones out, then I need to see what's the

 15 justification for -- or I'd like to see what's the

 16 justification for, is it uncertainty or is it

 17 feasibility?

 18 DR. HUBBELL: Well, I mean, in the primary

 19 standards, for example, it's always well understood

 20 that we're trying to protect sensitive populations,

 21 but not necessarily every sensitive individual.

 22 And we're trying to get at that same concept here,

 23 that we're trying to protect the sensitive

 24 population. That is a policy question as to what

 25 is a reasonable percentage to target in terms of

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 1 the sensitive population. It's not incorporated

 2 explicitly, when you do the primaries, they don't

 3 pick a number and say we're going to protect

 4 95 percent of the population. It's more of a

 5 consideration. But here, because it determines the

 6 critical load, we have to pick the specific

 7 percentage, which makes it more difficult because

 8 then we have to justify that specific percentage.

 9 So I understand the point that, you know, once

 10 you fill it out, that means everything that is left

 11 is part of the sensitive population, but it doesn't

 12 mean that we have to protect every individual in

 13 that sensitive population.

 14 MS. CHESTNUT: I agree, but I think that needs

 15 to be justified. Plus I'm not sure what is an

 16 individual on this scale. Yeah, we don't protect

 17 every fish, every tree, but a watershed, a lake, a

 18 stream, is that an individual?

 19 DR. GREAVER: That is an individual in the

 20 sense of this population of waterbody. A waterbody

 21 is an individual. We should note given the 7,500

 22 waterbodies that we have now if we protected

 23 100 percent of them, we would have zero allowable

 24 deposition. That's one of the reasons.

 25 DR. SCHEFFE: It gets back to the discussion

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 1 in terms of screening out waterbodies and

 2 everything else because if you go at the tails of

 3 that distribution, you would have, as Tara says,

 4 you would have zero critical load allowable for the

 5 most sensitive waterbodies. It becomes unstable

 6 using that kind of metric. Not unstable, totally

 7 unfeasible.

 8 DR. HUBBELL: Not even just unfeasible, it

 9 becomes I think inappropriate because you're not

 10 trying to protect every one of those individual

 11 lakes.

 12 MS. CHESTNUT: Right. And, you know, one lake

 13 may not rise to the level of an adverse effect. So

 14 there is --

 15 DR. HUBBELL: That's part of the discussion.

 16 MS. CHESTNUT: -- that's kind of why I'm

 17 asking, well, so where are we now? We have this

 18 conclusion that there is adverse effects now. So

 19 what percentage are below these levels now?

 20 DR. LYNCH: So if you just look at critical

 21 loads for Adirondacks, you can think of it two

 22 different ways. If you look at monitored sites

 23 within it where you have data exceedance based on

 24 current deposition through 2008, 2009, it's about

 25 40 percent. If you then take the E-map

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 1 probabilistic population and you just model that,

 2 which is a smaller number of lakes, but those lakes

 3 are supposed to be represented through weighting

 4 factors, the percentage around 30 percent that

 5 don't meet and that's an ANC of 50.

 6 DR. HUBBELL: So, again, I think, you know,

 7 obviously if we chose something then more than

 8 70 percent, we would be requiring some reductions

 9 in NOx and SOx. So I agree with you that we have

 10 to find a way to justify these. Ultimately it's a

 11 justification that's based on policy decisions

 12 that's informed by the science.

 13 And part of I think what you have asked before

 14 and what we're trying to understand, there was

 15 another comment and we mentioned this, what are the

 16 characteristics of those lakes that are left behind

 17 that don't get the full set of protection that get

 18 a lesser set of protection?

 19 And, you know, we're still looking at that,

 20 and Ginger I think was doing some work on this.

 21 It's a mixed bag. There is no characteristic of

 22 those lakes. They're not all giant lakes, small

 23 lakes, or heavily recreated lakes. It's a mixed

 24 bag. So it's difficult to say do you gain

 25 something special by going another 5 percent

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 1 coverage.

 2 MS. CHESTNUT: And I think that the analysis

 3 of what -- so if you get 90 percent above 50, you

 4 get so many percent above 20, it's helpful to put

 5 some of that in perspective. But it does seem like

 6 in terms of like what's a reasonable range that

 7 50 percent -- you're looking at 50, 75 --

 8 50 percent is not enough, you know.

 9 DR. HUBBELL: And that's helpful to know that

 10 that's the judgment of what you think.

 11 MS. CHESTNUT: I don't know if that's a

 12 uniform thing. It strikes me that the protection

 13 is, you know, somewhere between 75 and 100 and, you

 14 know, I understand there is reasons why you back

 15 off from 100. But is 90 the top, should it be 95?

 16 I don't know.

 17 DR. RUSSELL: Open it up. Panel comments?

 18 Naresh. Actually, I think it would be good if

 19 everyone formulates their thoughts on this one as

 20 to how comfortable one is in making such

 21 recommendations and at the end of the day what

 22 should we, as a body, recommend if Bryan asked for

 23 ranges on these various components of the standard.

 24 And, you know, I guess in the past before my time,

 25 they actually one time went around the table and

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 1 voted on things. I'm not sure we need to do that,

 2 but still getting everybody's individual input I

 3 think would be good. Naresh.

 4 DR. KUMAR: I think two issues, one is what

 5 level of ANC is protective against adversity. I

 6 see there is enough discussion in Chapter 5, a

 7 range between 20 and 50, let's say, that could be

 8 chosen, but the form of the standard is not ANC.

 9 The form of the standard is AAPI. That's where I

 10 have a problem because I think, given the lack of

 11 complete quantities in answer in the analysis, I

 12 don't think the Administrator would have a high

 13 degree of confidence in a particular level of AAPI

 14 would indeed provide either a requisite level of

 15 protection or be overly protective.

 16 And the way that it uncertainty has been

 17 described qualitatively has a potential to give a

 18 false sense of confidence in the overall

 19 uncertainty. I was looking at a discussion on page

 20 72 and top of 73 where, you know, possible what the

 21 low level of -- low level of confidence means. And

 22 confidence is low, AAPI could be adjusted upwards

 23 or downwards depending on where you want to put

 24 emphasis, whether you want to put emphasis on

 25 providing a requisite level or whether you want to

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 1 put an emphasis on not being overly protective.

 2 So I think I would add to that if the level of

 3 confidence is too low, it makes A, B standard

 4 questionable because it's not robust enough in that

 5 case.

 6 I know some of the members of the panel have

 7 presented that the discussion of uncertainty in

 8 this document is much more than the previous

 9 standards, but, again, we have to realize that what

 10 we're talking about is very complex; and a lot of

 11 the complexity cannot be evaluated because of a

 12 lack of data. So there is a need to have a

 13 quantitative evaluation of uncertainty. And unless

 14 we can really gain confidence in that, I think it's

 15 premature to talk of any levels of annual standards

 16 on the form of the AAPI.

 17 DR. RUSSELL: Other input? Ellis, you were

 18 about to say something. Dale?

 19 DR. COWLING: Dale had his hand up first.

 20 DR. JOHNSON: Mine won't take long. You know

 21 what I'm going to say. It needs more balance I

 22 think. I don't share your faith in the models.

 23 Not that they're bad, but all models are bad, per

 24 that wonderful article by Oreskes in 1994. And if

 25 the models -- I've heard that in some cases MAGIC

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 1 predicts pH 6 and high-based saturation in 1860 in

 2 some of these northeast soils. If that's the case,

 3 I know it's wrong. It can't be.

 4 So what I think I'd be more convinced by is

 5 something Charlie recommended, go look at those

 6 datasets that have actually shown a response of

 7 aquatic systems through reduced sulfur inputs.

 8 It's happened and it's published and Charlie's told

 9 you so.

 10 So I think that approach would be good, a good

 11 way to look at it. Maybe take the approach that

 12 the CO2 modelers do where they take the CO2 signal

 13 and de-convolute it and try to figure out all the

 14 factors affecting it. Something like that would

 15 convince me a lot more than would a modeling

 16 exercise, especially in the steady state model,

 17 which I don't think is of value. That's it.

 18 DR. RUSSELL: Ellis.

 19 DR. COWLING: I'd like to make a comment about

 20 question 2 or 2-B rather -- 24, I've misspoken

 21 three times now, regarding target values for the

 22 ANC. I think the figure that is on page 571, which

 23 is labeled 5-23, that's the figure number, is a

 24 figure that offers an opportunity to understand or

 25 to communicate a lot of these relationships. This

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 1 particular plot shows ANC on one axis and pH on the

 2 other. But you could make that kind of a curve,

 3 and take real data to produce it and put a whole

 4 bunch of different X and Y coordinates on that

 5 draft and decorate it with some of the biological

 6 effects, like mortality or degrees of biodiversity,

 7 and aluminum concentrations versus ANC. Plotting

 8 all those things against ANC and then trying to tie

 9 that to an AAPI says well.

 10 So commend that particular figure as a very

 11 valuable communication asset as you go about the

 12 business of talking about -- about the target

 13 values of ANC that would be appropriate in a

 14 variety of circumstances in the sensitive regions

 15 of our country. So I hope you look at 571 and 523

 16 as something to use as a model for communication

 17 purposes.

 18 DR. RUSSELL: Other comments? Praveen.

 19 DR. AMAR: Thank you. I'm going to take what

 20 Rich has said earlier and I've been stirring at

 21 this question for quite some time with regard to

 22 what you said. And I think Richard said, which I

 23 seem to like, what is missing here I think, you

 24 know, after three years of this work and

 25 recommendation, and I thought maybe you were going

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 1 to make a recommendation to EPA saying based on all

 2 we have heard throughout the years, we think this

 3 is what you need to do with respect to ANC and

 4 AAPI. And how does one make -- decision making in

 5 the presence of uncertainty? We talked about

 6 Chapter 7 and there is a lot of uncertain things,

 7 but you still make a decision; and you say then the

 8 consequences of that decision making is the

 9 plusses, the minus, the benefits.

 10 Questions like in my mind, which we've been

 11 talking about in a time trajectory of recovery. If

 12 we had ANC of 20, 50 or 100 approximately in the

 13 AAPI, how many lakes will recover in the next 20

 14 years, 50 years, 30 years? I don't have a sense of

 15 scale of what we do here and what will happen in

 16 years to come. And maybe that's part of the

 17 recommendation that EPA proposes a certain AAPI

 18 that says here are the consequences of meeting that

 19 and the time trajectory of that. I mean, I don't

 20 have a sense of it, but I think it might be very

 21 useful in the context of this document.

 22 DR. RUSSELL: So I'm going to try to twist the

 23 discussion in a second, but before going to sort of

 24 twisting it, EPA, do you have any questions for us

 25 at this point?

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 1 DR. HUBBELL: I don't. Karen, do you have any

 2 follow-ups?

 3 MS. MARTIN: No.

 4 DR. RUSSELL: Okay, then. How I'm going to

 5 twist -- yes, Chris.

 6 DR. FREY: I guess something I think may be

 7 missing here is, you know, at least with the

 8 primary standard there is usually some assessment

 9 in the -- I think in the Policy Assessment of the

 10 health benefit, for example, of an alternative

 11 standard. And, you know, for example, if we set PM

 12 at this level or at that level here is the avoided

 13 number of adverse health effects.

 14 What I didn't see in Chapter 9 was suppose we

 15 use ANC of 20, or suppose we use ANC of 50, what

 16 would be the benefit after, I don't know, 5, 10, 20

 17 years, whatever it would be, what's the avoided

 18 adverse effect? And I don't know if that's because

 19 it's not possible to do that analysis, but that

 20 might also help crystalize the questions about the

 21 uncertainties because in interpreting those kinds

 22 of estimates one could say, well, we think this is

 23 an underestimate for this reason or it's an

 24 overestimate for that reason and, therefore, we

 25 should be over or underconfident in setting the

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 1 level. And I don't know, I guess I'm just curious

 2 if there is a reason why there isn't that kind of

 3 analysis here or whether it's possible to do that?

 4 DR. HUBBELL: It's really difficult to do

 5 that. And, again, given where we are with the

 6 document, you know, we obviously could have -- we

 7 could choose, you know, an aggregation method and a

 8 percent waterbodies and an ANC target and say,

 9 okay, if we were to meet that what would that mean

 10 in terms of changes in ANC levels and then try to

 11 back through that now.

 12 There is an assessment -- there is a

 13 discussion at least in Chapter 3 where we talk

 14 about, you know, going to an ANC of 20 or going to

 15 an ANC of 50 in the New York area, it gets, you

 16 know, around a billion dollars in annual benefits.

 17 And we talk about the fact that, obviously, if you

 18 extrapolate that to other locations because we

 19 don't have good data on that, if we were to

 20 extrapolate it, it would lead to substantially

 21 larger benefits.

 22 That exercise could be done. And certainly,

 23 again, the difference there is that's focused on,

 24 you know, for a target ANC, you met every one, as

 25 opposed to an AAPI which embodies the percentile

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 1 and the other factors. So it could be done.

 2 Again, the data is very limited in terms of

 3 specific damage functions that are broadly

 4 extrapolatable to a lot of different streams and

 5 river types -- I mean streams and lake types.

 6 So I think, again, it's a question of how

 7 broad we can make the assessment. Certainly in

 8 certain case study areas it's already been done and

 9 could be done probably with some assessment of how

 10 the uncertainty would play out, but, again, it's

 11 going to have a lot -- it's going to have a lot of

 12 uncertainty in the calculation itself.

 13 Again, for primary examples it's a little more

 14 straightforward. Certainly there are large

 15 uncertainties as well in those assessments, but

 16 there is a lot more history involved in doing them

 17 and there is a lot more scrutiny that they've been

 18 put through because of the multiple reviews. And

 19 it's not -- again, it's not clear that the same

 20 kind of data is available to us.

 21 DR. RUSSELL: Rudy.

 22 DR. HUSAR: Yeah, the question is to what

 23 would make -- what makes me uncomfortable and that

 24 is that I don't seem to have a view, an answer to

 25 the question as to why is it that after you go

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 1 through this AAPI calculation, what is it -- why is

 2 it that you would have, let's say, a lake's in

 3 compliance, other one would not?

 4 In case of a primary standard because of the

 5 sense -- because all populations of all people are

 6 equal, the cost of the actual damage is clearly air

 7 pollution, dirty air, no question about it. But

 8 now when you have this kind of an AAPI where you

 9 have this balancing situation that on one hand you

 10 have the driver that caused the pollutant, the

 11 stressor, but then on the other hand you have a

 12 compensating factor on the other side.

 13 Now, wouldn't that be the situation that,

 14 well, it could very well be that you have a

 15 relatively flat deposition field, but then what

 16 really is causing a problem is the fact that that

 17 particular population is not able to protect itself

 18 or whatever. And so that kind of assessment of

 19 totality, at the very coarsest level, I thought

 20 that would be helpful. I'm not getting it from

 21 these, but it could be calculated. So to break

 22 down that AAPI at least into those two major

 23 components.

 24 DR. HUBBELL: I'm not sure I followed that.

 25 So what would you specifically be breaking it out

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 1 into? What are the two components?

 2 DR. HUSAR: You're supposed to have some kind

 3 of deposition -- the index that is associated with

 4 the driver, you know, the deposition kind of

 5 driver. And suppose you normalize it to one or

 6 something, okay, all right; and you say, okay, then

 7 you have a corresponding index for the sensitivity

 8 on the other side.

 9 DR. HUBBELL: So you want to split the

 10 equation in there as two pieces?

 11 DR. HUSAR: So that by looking at say, okay,

 12 this particular lake is highly sensitive even

 13 though the concentrations are the same or the

 14 deposition is the same, but it's highly sensitive;

 15 therefore, the reason is it's in noncompliance is

 16 because of that.

 17 In other situation it is because of the high

 18 stress. It is relatively opaque because of

 19 sensitivity, but if you stress it high enough, it's

 20 going to break. So separating those two and

 21 identifying quantitatively is something that you

 22 could do.

 23 DR. SCHEFFE: Let me respond. The AAPI does

 24 actually do that. It does separate the sensitivity

 25 with regard to the ecosystem components and how

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 1 that controls and the deposition components and how

 2 that controls. And I think what you're asking for

 3 though makes sense. I think what you're asking for

 4 is some other sort of a more generalizable analysis

 5 that looks at these different waterbodies, I don't

 6 know exactly at what kind of spatial scale, and to

 7 add some intelligence as to these are the types of

 8 waterbodies in these locations that are

 9 intrinsically more sensitive. These are the ones

 10 that intrinsically tend to be more dominated and

 11 affected by deposition than others. And I think

 12 that's kind of a reasonable kind of analysis. I

 13 think that does make some sense, but I want to be

 14 clear that the AAPI does do that, it does separate

 15 the sensitivities.

 16 DR. HUSAR: You guys don't show it. If it has

 17 the form, the separation is there, but you're not

 18 convincing -- you're not conveying that in the

 19 document as to show now how do those two interact

 20 in creating this result.

 21 DR. HUBBELL: So say we were to have that, I'm

 22 trying to figure out how that would -- how would

 23 that help us inform what the level of the statement

 24 ought to be or the form? I'm not sure. It would

 25 be interesting to know.

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 1 DR. HUSAR: It's not necessarily including the

 2 level, but it's more of kind of on the confidence

 3 side.

 4 DR. HUBBELL: It's more the uncertainty and

 5 confidence.

 6 DR. HUSAR: Confidence. Because if, for

 7 instance, it turns out that the sensitivity, let's

 8 say, varies only by 10 percent, but the magnitude

 9 of the stressor varies by a factor of 10, well,

 10 clearly that's where you have to figure that's

 11 where you have to put your sensitivity analysis and

 12 uncertainty on the one that really does vary, that

 13 actually does, is the causal factor.

 14 On the other hand, if it turns out that this

 15 other one that's vary -- sensitivity varies a heck

 16 of a lot more, that's where you have to put your

 17 effort in defending. It's more of a defensibility

 18 rather than setting the actual value. Value

 19 setting is clearly going to be policy.

 20 DR. RUSSELL: Anything else from the panel

 21 before I twist things around?

 22 Okay. Thank you. So I'm sitting here, you

 23 know, and I want some help from the panel in that

 24 we're about to write what I think is our most

 25 important letter yet in this process. I may be

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 1 wrong on that, but I think this is the one a lot of

 2 people are going to really read because we are

 3 about to the point of helping to advise most

 4 specifically on the standard. And we've got this

 5 document in front of us that we've now read through

 6 maybe a few times.

 7 And one of the questions I think we have to

 8 address in the letter is how ready is this document

 9 to go forward in terms of advising -- well, first,

 10 how well it's advised us or informed us and how

 11 will it inform the Administrator in making this

 12 rather tough choice, given how complex this system

 13 is. And wrapped into that question, I mean,

 14 wrapped into that is how would it advise on each of

 15 the pieces of the standard that we've sort of I

 16 think glanced around, but haven't really gotten any

 17 too specific except say we are having troubles with

 18 some of the specificity since we don't really have

 19 a great feel for it. And at the same time there is

 20 always a question are we ready to -- I mean, should

 21 we proceed forward with this type of standard at

 22 all given its complexity and everything, all the

 23 values that go with that and the knowledge that we

 24 have at this point? I mean, in terms of EPA has

 25 done a tremendous job I think in sort of laying

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 1 this out and saying these are the things that

 2 really should go in it. We've come up with some

 3 comments on the individual pieces, some of the

 4 uncertainties.

 5 How ready are -- I mean, are we ready to also

 6 put our names to a document saying go forth, it's

 7 there? And if not, why not; if it is, why it is.

 8 So that's where I'm sort of sitting at this point

 9 and I want to get people's comments on that, raise

 10 that discussion and see what people think.

 11 Do people see what I'm saying? I mean, if I

 12 didn't -- I hope people understand, at least enough

 13 people understand that they can start a discussion

 14 such that we will understand. Dale.

 15 DR. JOHNSON: I'm not. You know the reason

 16 why. I just described it.

 17 DR. RUSSELL: Andre, you've been quiet.

 18 DR. BYTNEROWICZ: Catching up on my lack of

 19 sleep. I think the concept is good and I am really

 20 happy that we got to this point, but I'm not ready

 21 to vote for that yet because of the level of

 22 uncertainty.

 23 DR. RUSSELL: So when you say that, be

 24 specific.

 25 DR. BYTNEROWICZ: Well, for me a black box is

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 1 the AAPI. It's what's behind that. So if I don't

 2 see step by step that there are lots of uncertainty

 3 and especially transformation of ANC to AAPI and

 4 deposition and also major components leading to

 5 that deposition of specific chemical compounds, I'm

 6 not convinced we are there yet.

 7 DR. RUSSELL: If that was given -- because I

 8 think that's actually something reasonable they

 9 could do, maybe not to us, but to the

 10 Administrator -- do you think that would close the

 11 loop?

 12 DR. BYTNEROWICZ: For me, it would get me to

 13 like 90 percent.

 14 DR. RUSSELL: Okay. I'll tell you on the

 15 health-based standards 90 percent is not a bad

 16 thing.

 17 DR. WEATHERS: So could we back up?

 18 DR. RUSSELL: He votes yes.

 19 DR. BYTNEROWICZ: Not yes, not yet.

 20 DR. RUSSELL: What he said is given a

 21 comprehensive uncertainty analysis associated with

 22 the AAPI, he could be 90 percent there. Actually,

 23 I think -- is that --

 24 DR. BYTNEROWICZ: Eighty-five.

 25 DR. RUSSELL: Eighty-five. We keep talking,

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 1 it will go down. I should definitely not have said

 2 yes. I don't think that's what he said. Lauri?

 3 MS. CHESTNUT: Doesn't that depend on what the

 4 uncertainty analysis shows?

 5 DR. RUSSELL: And it could. That's something

 6 we have to think about.

 7 DR. MITCHELL: I guess I would suggest within

 8 the comments from the panel and the interchange, it

 9 seems like it's a great opportunity, EPA has done a

 10 great job of trying to put together a very complex

 11 standard in which there are two elements with all

 12 their different chemical species and to not have

 13 that -- and also we recognize that there certainly

 14 are significant environmental effects associated

 15 with acidification of waters as well as soils. So

 16 certainly it is an opportunity and need to go

 17 forward.

 18 On the other hand, some important limitations

 19 in terms of what has been done up to date -- not

 20 that there has not been a lot done, clearly a lot

 21 of work has been done -- have been indicated that

 22 would seem to solidify this and at the end of the

 23 day make it go forward in an easier way.

 24 Particularly I like the suggestion of doing some

 25 hindcasting and showing how this would actually

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 1 play out. I think that would give a lot of

 2 confidence that this is a workable thing and show

 3 what the limitations are. Something like that

 4 would really help I think, at least myself, in

 5 terms of this. I just don't know how to do that

 6 step wise in terms of the process. For me what

 7 happened -- to go back and see what the past was

 8 and start out using the model knowing what the

 9 chemistry has been in measured components.

 10 DR. JOHNSON: To the past through known

 11 measurements.

 12 DR. MITCHELL: Yeah, known measurements. We

 13 don't want to hindcast other measurements. That's

 14 not helpful.

 15 DR. RUSSELL: I'll be the one to ask, okay,

 16 let's say they can't do that within the time frame,

 17 remember the time frame which I think is the second

 18 slide we've seen today. It's not very loose.

 19 DR. MITCHELL: Right, I understand that.

 20 DR. RUSSELL: Assuming that's not there, where

 21 would you come down? It's a tough question.

 22 DR. MITCHELL: That's a hard -- I guess

 23 depends on what other components got addressed.

 24 That's not a make it or break it situation because

 25 other substantial concerns I would like to see

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 1 addressed over the next few months. I'm not sure

 2 where I sit, somewhere between 75 and 80 percent.

 3 DR. WEATHERS: So I have a suggestion, which

 4 is I wonder if we ought to create that list. If

 5 AAPI is what is making most of us uncomfortable,

 6 not the big picture, we ought to create that list

 7 very quickly and then ask the question what if

 8 these things can be done and which of them are most

 9 compelling. So hindcasting is one. I mean, you're

 10 the chair. Is that a good suggestion?

 11 DR. RUSSELL: Last week in this very room we

 12 had people send in their votes on something, in

 13 essence, looking at that and getting all the

 14 people's individual concerns in. And we can do

 15 that -- actually, we could do it early -- that's

 16 something I'm trying to get out of the group right

 17 now is what are these things that are most

 18 uncomfortable?

 19 DR. LYNCH: Can I ask a direct clarification

 20 to Myron's question?

 21 DR. RUSSELL: Sure.

 22 DR. LYNCH: When you mean hindcast --

 23 DR. MITCHELL: That's a bad term. I meant

 24 using past data, which you can actually use the

 25 AAPI index. Hindcast was a mischosen word.

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 1 DR. LYNCH: I just want to just make clear,

 2 the idea of using MAGIC to go back in time.

 3 DR. MITCHELL: No. The idea is actually use

 4 measured data over time where those data are

 5 available.

 6 DR. RUSSELL: So, actually, as we go around

 7 the room, if people can answer Kathy's question, I

 8 think that would be good.

 9 DR. AMAR: Which is?

 10 DR. RUSSELL: What are the components that are

 11 currently giving people the most problems? You

 12 want to rephrase it?

 13 DR. WEATHERS: I think that's it. I think

 14 what I've been hearing, certainly myself, is that

 15 we know that air pollution has ecological effects.

 16 We know that deposition is associated with

 17 concentration in some way and that deposition is

 18 the relevant flux of interest. We know that ANC is

 19 a reasonable indicator of aquatic acidification.

 20 All the pieces of the standard we seem to feel

 21 really comfortable with, but the AAPI is causing

 22 pause. I'm trying to figure out for myself and

 23 others what would, if anything, would cause us not

 24 to trip over the AAPI?

 25 DR. AMAR: Maybe the answer to that question

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 1 is what's the alternative display? We were

 2 introduced to the concept about six months ago,

 3 about a year ago.

 4 DR. RUSSELL: More like a year.

 5 DR. AMAR: We've gone through that. We saw

 6 what the components were, how they're calculated,

 7 how they're modeled and how they're measured and so

 8 on. I've been thinking about the alternative

 9 because we kind of -- AAPI to me is simply a

 10 collection of what we knew.

 11 DR. WEATHERS: Again, what I'm hearing is the

 12 alternative is this group says this is a great

 13 idea, go forward or this group says we're not there

 14 yet. I mean, again, so I'm not suggesting that in

 15 a short amount of time that everything be done.

 16 I'm suggesting that there has been an enormous

 17 amount of work done. It's a really impressive set

 18 of elements.

 19 DR. AMAR: I think we're not there yet in

 20 terms of explaining this to ourselves and EPA

 21 explaining it to itself, but I think it's more of a

 22 communication thing. I was teaching years ago

 23 about what was the line about simple sentences at

 24 least tell the truth. And really I don't think

 25 we've done a good job of explaining, writing and

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 1 thinking about it, all the various components. The

 2 science part we have done well. I don't think

 3 we've done the explanation part very well.

 4 DR. WEATHERS: I think actually some of the

 5 suggestions about what needs to be done have more

 6 to do with giving us some bounds on our confidence

 7 about the elements of the AAPI rather than

 8 quantitative uncertainties. So hindcasting --

 9 wouldn't hindcasting give us some indication of

 10 whether we buy the MAGIC model?

 11 DR. MITCHELL: Use historical data for

 12 evaluation of AAPI.

 13 DR. WEATHERS: Right, because using a series

 14 of models is really a common thing that's done for

 15 climate modeling, for, you know --

 16 DR. AMAR: Primary.

 17 DR. WEATHERS: Yeah, it's not new. There is a

 18 lot of uncertainty still.

 19 DR. RUSSELL: Naresh.

 20 DR. KUMAR: So I guess the problem here, I'm

 21 hearing also is the confidence in the AAPI and you

 22 want to see suggestions from us. I have two

 23 suggestions of what can be done to increase the

 24 confidence at least for my sake. And I agree with

 25 Myron, using the data for the past 20, 30 years and

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 1 seeing how AAPI would predict a change or whatever

 2 in what we're trying to do.

 3 Second, I think I mentioned earlier, we know

 4 CMAQ cannot be evaluated for certain things, what

 5 was the AAPI, but a lot more can be done. I've

 6 given some specific suggestions earlier; and I can

 7 do that again, when the time comes. That's the

 8 second thing is do a more full evaluation of CMAQ.

 9 And third would be the quantitative uncertainty

 10 analysis.

 11 DR. RUSSELL: Actually, as we go along, it

 12 would be good if you note these and e-mail them to

 13 me because there is no way I'm going to remember

 14 them all.

 15 DR. NUGENT: Could you repeat that, that list

 16 you just gave?

 17 DR. KUMAR: You want me to repeat it or you

 18 want me to e-mail it later?

 19 DR. NUGENT: For the minutes, can you repeat

 20 it?

 21 DR. KUMAR: The first is what Myron said.

 22 DR. WEATHERS: Hindcasting of MAGIC.

 23 DR. KUMAR: Not MAGIC, using the AAPI

 24 framework. And number two is I would say complete

 25 evaluation of CMAQ that can be done with the data

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 1 that's available. And three is complete

 2 quantitative analysis of sensitivity.

 3 DR. RUSSELL: Charlie, we haven't heard from

 4 you lately.

 5 DR. DRISCOLL: Well, I'm not uncomfortable

 6 with this approach because I think that, I mean,

 7 there are aspects of it that I think are, you know,

 8 I can understand that are problematic. But I think

 9 from a practical standpoint given that you want to

 10 try to make calculations over large numbers of

 11 watersheds and the time involved that using a

 12 steady state model makes sense. But steady

 13 state -- I mean, watersheds are not at steady

 14 state. They're, you know, dynamic systems.

 15 But I think, as I've said a couple times

 16 today, that I think we know with a fair degree of

 17 confidence how these systems are responding, at

 18 least in terms of acid rain effects. So we've got

 19 long time series of data; and I think we have, you

 20 know, given a unit level of reduction of sulfate

 21 and nitrate. I think we have a good idea of where

 22 they're going to go in the future. And we're

 23 getting more and more information on the biological

 24 response to those reductions. So I'm not -- I'm

 25 not I guess as worried about things as a lot of

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 1 people are I guess.

 2 DR. RUSSELL: Lauri.

 3 MS. CHESTNUT: When you frame the question in

 4 terms of where we're at now and are we -- what's

 5 our bottom line, are we going to recommend going

 6 forward with the standard or say there is not

 7 enough, but given the time restraints, I see it --

 8 I feel a real reluctance after all that's been

 9 accomplished of saying, well, it's not close enough

 10 yet, just go home. And I wonder if there is some

 11 way to look at it in terms of we're confident that

 12 it should go at least this far in terms of picking

 13 numbers, setting a standard. Going beyond that,

 14 you know, may be beginning to impose too much cost

 15 or implementation difficulties; or can we say that

 16 it should be at least a goal of at least this much

 17 while then the details and methods in some of these

 18 other things are worked out in the next round?

 19 DR. RUSSELL: Certainly you can use that to

 20 sort of advise, give advice, you know, I would put

 21 it as the uncertainty might suggest that you go,

 22 let's say, do a lower bound and the choice might be

 23 to tighten it in the future. Certainly that could

 24 be a recommendation here is exactly that, is saying

 25 that there are a lot of things we don't know about

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 1 right now, so maybe you should go to a less

 2 stringent bound at first.

 3 MS. CHESTNUT: Yeah, to keep the momentum

 4 going.

 5 DR. RUSSELL: Because, you know, I can see

 6 some parallels in some of the other NAAQS as

 7 they've gone.

 8 DR. WEATHERS: Can you say more about that,

 9 give an example?

 10 DR. RUSSELL: I would actually say, you know,

 11 that maybe it's a different interpretation, but if

 12 you go back and look at the let's say a prior PM

 13 standard, maybe it would have been set tighter with

 14 more knowledge. And certainly that appears to be

 15 the process is that, okay, it was set at 15 and now

 16 there is reasonable chance that it's going to get

 17 tightened. I mean, just given the level of

 18 uncertainty at first, have it be a less stringent

 19 standard. That can certainly be part of the

 20 thought process.

 21 Would you say that's, you know, you all were

 22 around -- both of you were around at the last --

 23 not the current PM, but the last PM standard

 24 setting process. Reasonable characterization?

 25 DR. COWLING: Yeah.

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 1 DR. RUSSELL: Other -- yes, Ellis.

 2 DR. COWLING: I'm thinking back over the last

 3 two decades. The National Acid Precipitation

 4 Assessment Program began in 1980 and ended in 1990.

 5 The Voderborg (phonetic) Protocol was adopted in

 6 1999, recommending that Europe adopt multiple

 7 pollutant approaches in air quality management in

 8 that continent. In 2004 the National Research

 9 Council published its report on management of air

 10 quality in the United States. In response to those

 11 events, the EPA undertook starting I think it was

 12 2006 when the ISA was -- well, it was produced in

 13 '06; is that correct?

 14 DR. GREAVER: The first draft in 2007, but we

 15 started in 2006, yeah.

 16 DR. COWLING: Okay. And we had an REA

 17 produced in 19 -- in 2007.

 18 DR. GREAVER: 2008.

 19 DR. COWLING: 2008, okay. And we've now had

 20 two rounds of discussions about policy assessments

 21 in the wake of the ISA and the REA. I have

 22 confidence that you guys can get this done in an

 23 adequate way by December of this year. And I

 24 believe that if you do your very best that the

 25 recommendations that Ted and the rest of us will

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 1 try to write will help you do a good job.

 2 And I think it would be a disappointment to

 3 all of us who had some role in these various

 4 national studies, like SNSF, for example, in the

 5 1980s and the NAPAP program in the 1990s, or the

 6 '80s to '90s, if we miss this chance to demonstrate

 7 a capacity of the United States of America through

 8 its Environmental Protection Agency to match what

 9 Europe has been doing, and Europe has its own

 10 problems, the Voderborg Protocol would be realized

 11 in 2011, I believe that you guys continuing the

 12 work that was begun in '06 and has been continuing

 13 to the present time can by December produce

 14 something you are proud of and that our

 15 Administrator will consider very carefully; and

 16 that we will make progress toward managing

 17 acidification in aquatic ecosystems, which is not

 18 the whole story; and that we will produce the

 19 secondary study that is ecologically relevant and

 20 will have at least two pollutants; and a third one,

 21 ammonia added, as given, not the seventh criteria

 22 pollutant, I believe that you can do this by

 23 December. And I will work hard as a member of this

 24 committee to do anything I can to help you succeed

 25 by your deadline.

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 1 DR. RUSSELL: Are there comments? I think

 2 I've heard pretty much from everybody at the table

 3 on this.

 4 Okay. I'd like to end up the day just very

 5 quickly go around and each of the discussant leads,

 6 sort of go and give us an idea of how you're going

 7 to respond to each one of the charge questions and

 8 that way if we have any questions, comments,

 9 additions, we will have a chance to give it to them

 10 before they go and do their writing. Keeping in

 11 mind that after we break, the idea is they get

 12 together with their co-discussants, maybe just for

 13 a few minutes and then they will be writing the

 14 responses this evening, and with the idea that you

 15 e-mail them to Angela and I sometime this

 16 evening -- or this evening is pretty loose. With

 17 that, Lauri.

 18 MS. CHESTNUT: Well, I think the basic answer

 19 is that the definitions of adversity presented here

 20 are appropriate with a few qualifications and

 21 emphasis that -- and I'm not sure how -- this is

 22 like the paragraph you're looking for.

 23 DR. RUSSELL: Yes, it would be a one-paragraph

 24 charge to the question.

 25 MS. CHESTNUT: I mean, I want to make, again,

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 1 the point that the public welfare effects include

 2 the protections that don't just use human direct

 3 use, but the nonuse values, preservation of natural

 4 systems. That seems like the information that was

 5 included in this chapter on the community decisions

 6 and is helpful in painting that whole picture.

 7 And Praveen had the additional point to

 8 mention Title IV program as another piece of that

 9 evidence. It's already been, so I think that's

 10 worth mentioning there. I think that's the main --

 11 the main things.

 12 And then always keeping in mind that there

 13 is -- or keeping in the forefront that there is a

 14 lot known about the adverse effects even though

 15 they can't be quantified all the way through. I

 16 think the descriptions can be brought forward more

 17 consistently 'cause there is that tendency to just

 18 here is what we can quantify and then kind of not

 19 remember well the items.

 20 DR. RUSSELL: Sounds good. Ellis. You can do

 21 two and three at the same time.

 22 DR. COWLING: I promised to deliver already my

 23 contribution. So I'm going to take that over to

 24 Dale's response.

 25 DR. RUSSELL: Actually, I'm saying in terms

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 1 of --

 2 MS. CHESTNUT: Do we have those

 3 electronically, each others?

 4 DR. COWLING: Yes. You can take off what I've

 5 written before.

 6 DR. RUSSELL: They're posted, right?

 7 DR. NUGENT: Before the meeting last night I

 8 circulated to everybody a compilation of comments

 9 that included everybody's comments except the four

 10 that came in super late last night and this

 11 morning. So I'll -- you've got one final, I'll

 12 update that for the last comments.

 13 DR. RUSSELL: So, Ellis, just your responses

 14 to charge question two and three.

 15 DR. COWLING: Well, I just handed that over to

 16 Lauraine. Can you read the two lines that are

 17 underlined in that?

 18 MS. CHESTNUT: So under Chapter 4, question

 19 two? I'm a little confused about where we're

 20 going. Chapter 3, Chapter 4?

 21 DR. RUSSELL: This is supposed to be the

 22 committee's consensus.

 23 DR. COWLING: Are there adverse effects at

 24 present levels? Yes. And has staff appropriately

 25 applied this approach in reviewing the adequacy?

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 1 Yes.

 2 DR. RUSSELL: Very good. Everybody else to

 3 give a one-word response to question four. Dale.

 4 DR. JOHNSON: The same, of course, that there

 5 needs to be more consideration of unintended

 6 consequences, including interactions with other

 7 environmental conditions, such as global carbon

 8 cycling and climate change. Lauraine may not agree

 9 with that, but I'll put in there whatever she sends

 10 me.

 11 DR. RUSSELL: Praveen, question five.

 12 DR. AMAR: Question five had to do with the

 13 structural framework. We're going to say that

 14 that's on the right track, which is really to

 15 endorse the AAPI index. And I think there was some

 16 comments from Myron, I'll try to talk to you later.

 17 We did mention something about CMAQ that we're

 18 talking to.

 19 And I had a point about ammonia, taking into

 20 account I'd still like to make that point that

 21 simply takes into account, and Rich was positive

 22 about that compared to what we had done before. So

 23 that was the question five, that we are on the

 24 right track, the concept is right.

 25 I don't know how quite to say about the next

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 1 question, but to say that's rather complicated. I

 2 still have to figure out what we're going to say

 3 there except the approach of creating the United

 4 States as one big region is simple. And between

 5 the other three approaches, support for the cluster

 6 analysis, asking for more clarification still. And

 7 I did talk during the break about ecoregions and

 8 what they mean asking some more clarified language

 9 in that chapter.

 10 DR. RUSSELL: Comments on those?

 11 DR. AMAR: If anybody has input, send me an

 12 e-mail tonight. And I have the comments of all the

 13 members.

 14 DR. RUSSELL: Andre, seven and eight.

 15 DR. BYTNEROWICZ: Well, seven basically we

 16 agreed that critical load approach is good and

 17 should be pursued. It's a logical way of linking

 18 different departments with approach on this issue.

 19 F-factor is also a reasonable approach and it can

 20 be used.

 21 In regard to filtering, I am changing my

 22 original stand and I am agreeing with Charlie and

 23 with Kathleen that basically filtering should be

 24 avoided for different waterbodies. So that's

 25 basically point 7.

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 1 Point 8 we agree that the proposed approach

 2 makes sense and uses available knowledge. I'd like

 3 to make a comment also that question of reduced

 4 nitrogen species, especially ammonia, should be

 5 taken with question and consideration of steep --

 6 possibility of steep spatial gradients exist and

 7 for the protection of those potentially affected

 8 areas we have to take that into account. And

 9 that's basically it.

 10 DR. RUSSELL: Any additions?

 11 DR. BYTNEROWICZ: And I will be getting

 12 comments from Charlie and from Kathleen. If

 13 anybody has any questions, send them to me.

 14 DR. RUSSELL: Naresh.

 15 DR. KUMAR: I think the variability of NOy

 16 availability and those can be examined further,

 17 namely looking at different chemical mechanisms,

 18 different models. There was some comment from

 19 Praveen on the issue of I guess definition of

 20 course work, you had a recommendation there?

 21 DR. AMAR: No, I wasn't clear because the

 22 question itself wasn't clear. They will address it

 23 in Chapter 8. I'm not sure whether Chapter 8 did

 24 address it or not.

 25 DR. KUMAR: So I guess suggesting for --

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 1 asking for more clarification.

 2 DR. AMAR: I think Rich did respond.

 3 DR. SCHEFFE: I thought it was covered in

 4 Chapter 8. We can talk later, but yeah.

 5 DR. KUMAR: Also on the variability, recommend

 6 we look at variability for dry deposition and wet

 7 deposition transfer functions just to see if it is

 8 a rainfall variation that's causing the changes.

 9 Rich Poirot had a comment on looking at NOx

 10 and nitrate, CASTNET data for this comment or was

 11 it for some other comment, Rich?

 12 MR. POIROT: Well, I guess it could go here,

 13 but it could go maybe elsewhere too.

 14 DR. KUMAR: Yeah, if you want it under here,

 15 then maybe you can send me a few lines on that.

 16 MR. POIROT: Maybe it would be better in the

 17 monitoring section.

 18 DR. KUMAR: That's fine. Okay. On number ten

 19 I think we agreed that the average time of three to

 20 five years is appropriate. So no recommendation

 21 there.

 22 DR. RUSSELL: Anything else from Naresh?

 23 Eleven and 12, Charlie.

 24 DR. DRISCOLL: So I think what I take from the

 25 discussions we're going to conclude that the

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 1 alternative levels of targeted ANC that were

 2 considered were reasonable. They go from

 3 relatively sensitive to relatively insensitive.

 4 And I think that they are, you know, to the degree

 5 that the science informs this, they are reasonably

 6 well -- or linked with adversity in terms of

 7 biological effects. So I was going to basically

 8 say that. Comments?

 9 DR. RUSSELL: Comments? Okay. Thirteen,

 10 Lauri.

 11 MS. CHESTNUT: I think the gist of it is that

 12 the analysis of the co-protection benefits is

 13 useful and probably sufficient for the purposes

 14 here and that there is some co-benefit.

 15 I think a suggestion that other benefits and

 16 disbenefits, whatever you want to call them, should

 17 be at least listed to give a full picture of these

 18 pollutants also contribute to the processes of

 19 human health effects through PM and ozone and other

 20 welfare effects. And Dale's point about the

 21 potential impacts in the other direction, carbon

 22 sequestration and perhaps other nutrient benefits

 23 to put the whole thing in some context, but that

 24 that's -- can just be a descriptive list.

 25 DR. RUSSELL: Number 14 and 15, Rudy.

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 1 DR. HUSAR: It covers uncertainty parts, parts

 2 of the AAPI, but has not dealt with AAPI as a

 3 whole; that is, uncertainty of it as a whole. In

 4 dealing with the uncertainty, Chris has suggested a

 5 use of a more coherent consistent framework in

 6 order to formulate the uncertainty. And Charlie

 7 has also pointed out that there are methods of

 8 uncertainty estimation that go beyond just simply

 9 looking at the pieces of CMAQ let's say.

 10 Naresh brought back the set of suggestions or

 11 ideas that were then specific ideas from the past

 12 as to how one could examine and evaluate the

 13 uncertainty using multiple, literally multiple

 14 perspectives. Both Myron and I have been hammering

 15 around at the CMAQ and the uncertainty associated

 16 with that.

 17 I thought that the main kind of a positive

 18 kind of emergent contribution that might -- that

 19 had been arising that was triggered by the

 20 hindcasting idea, which then was now augmented by

 21 Naresh as saying well, what about hindcasting with

 22 the AAPI as the measure of the hindcasting, right,

 23 so that you can actually see how it has worked.

 24 And it quantitates Charlie's comments that yes,

 25 indeed, there is all this information that is

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 1 already available by which we could then see how

 2 this AAPI really works, which is what we have not

 3 seen. Maybe that way one creates a level of

 4 confidence.

 5 In this AAPI I think nobody has expressed

 6 explicit direct concern that there is something

 7 wrong with it. It is just we would like to know

 8 more how it really works.

 9 DR. RUSSELL: Charlie, 16 and 17.

 10 DR. DRISCOLL: So in our discussion we talked

 11 about the uncertainty associated with MAGIC and

 12 steady state water chemistry model. So I'd just

 13 try to summarize comments if people have additional

 14 things on that, I'll try to add in things that

 15 could be considered with respect to the uncertainty

 16 analysis.

 17 Seventeen is a little bit problematic. I

 18 guess we could have a very long list. I think if

 19 people have ideas, I think there are a few things I

 20 took notes on that people thought were high

 21 priorities, I'll try to list a few very important

 22 research and data collection items.

 23 DR. RUSSELL: Rich.

 24 MR. POIROT: Well, the monitoring questions

 25 were quite narrowly focused. I think we might want

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 1 to think about a paragraph that we put in the cover

 2 letter that's outside of the focus of the

 3 monitoring questions, and among other things, would

 4 be supportive of the multiple objectives that were

 5 listed at the beginning of the monitoring chapter

 6 and emphasize their special importance for this

 7 NAAQS review and that they are also justified for

 8 many other reasons. This is a good place for that.

 9 We might do something like that.

 10 In terms of the specific charge questions, the

 11 first one 18 is asking about is the use of an

 12 open-face collector as a potential

 13 sulfate reference method for this standard and the

 14 specific use of the CASTNET open-face sampler as a

 15 reference. I guess I'd like to see us sort of be

 16 supportive of that even though we are additionally

 17 recommending that the monitoring subcommittee be

 18 consulted on the various approaches.

 19 Ditto for ammonia, ammonium, I think this

 20 committee could and should be supportive of the

 21 collection of additional ammonia measurements not

 22 as a necessary component, but as a highly desirable

 23 component and implementing the standard.

 24 And, finally, the last question relates to a

 25 small subset of sites where highly sophisticated

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 1 measurements of the different more exotic

 2 components of NOy be conducted. And, you know, my

 3 sense on that is that I'm not sure that we can roll

 4 out really a network in the first place. I don't

 5 know quite how to answer that.

 6 Certainly, yes, those additional measurements

 7 would be useful, but -- and desirable, but I think

 8 I'd like to recommend that the -- that we advise

 9 the agency to consider optional combinations of

 10 existing programs like CASTNET and CORE and the

 11 possibility of enhancing existing monitoring

 12 programs as an alternative to or a component of

 13 monitoring convective specifically --

 14 DR. RUSSELL: Actually, just thinking about

 15 it, in terms of going to AAMS, you might recommend

 16 that they enlarge or enhance the panel during that

 17 portion, just to have some individuals who are --

 18 who are experts in deposition, measurement and also

 19 aquatic effects or some relationship there because

 20 I think that would be something that would be

 21 missing.

 22 MR. POIROT: I wish I had gotten more comments

 23 from others on this panel because we know what's

 24 going to happen when we take it to those guys.

 25 DR. RUSSELL: We knew.

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 1 MR. POIROT: The other guys are even worse.

 2 So if anybody has any additional thoughts on the

 3 measurements, e-mail them to me.

 4 DR. RUSSELL: Chris?

 5 DR. FREY: Twenty-one and 22. Twenty-one, my

 6 general sense of what could be said there is that

 7 the overall characterization of uncertainty is

 8 addressed in the responses to charge questions 14

 9 through 17 and is a good starting point, but that

 10 the panel would like to see further interpretation,

 11 preferably quantitatively where possible, of the

 12 uncertainties in the components of the AAPI and the

 13 AAPI itself, particularly as it pertains to degree

 14 of confidence in setting levels of the standard.

 15 And I might add, maybe this is picking up what

 16 Praveen said, and Bryan and I talked at the break

 17 too. It's just explaining this standard to anybody

 18 is a challenge. And, you know, maybe one thing

 19 that would help is to separate the air and the

 20 non-air components of the AAPI. And when we talk

 21 about uncertainties, talk about them for

 22 air-related parts and the non-air-related parts;

 23 and get some insight as to, you know, how much of

 24 the uncertainty is related to things not related to

 25 air versus related to air might be useful for us to

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 1 know that.

 2 I'm just trying to see if I missed anything

 3 from comments that others made 'cause I wrote notes

 4 that I can't read. Charlie said a few things. I

 5 guess the point Charlie was making is that there is

 6 a lot of research I guess from an uncertainty

 7 perspective is sort of like a windowing method

 8 where, you know, we can do this disaggregated

 9 analysis bottom up uncertainties and aggregate them

 10 to a combined uncertainty, and we can end up with

 11 an uncertainty much wider than justified by

 12 evidence from the field perhaps because we're not

 13 appropriately dealing with covariances or other

 14 kinds of dependencies on the data. Considering how

 15 the uncertainty is bounded by other information and

 16 discussing that in Chapter 9 would be helpful. So

 17 I think that's question 21.

 18 Twenty-two if anybody has any input, feel free

 19 to e-mail me and Ted, but I didn't get the sense

 20 that there was a whole lot to say on Part A. And,

 21 you know, maybe we could just reaffirm that the,

 22 you know, the foundation for setting the standard

 23 based on aquatic acidification seems like an

 24 adequate basis for setting a secondary standard.

 25 Certainly there are other things that might be

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 1 considered if there was enough evidence to quantify

 2 them, but it seemed like on some of these specific

 3 points it wasn't clear that there was much to go on

 4 beyond what's already in the document. So that was

 5 my sense of that discussion.

 6 On Part B, this is the appropriate qualitative

 7 and quantitative characterization of uncertainty.

 8 I think that goes back to what I said for charge

 9 question 21; and maybe just reaffirm that the panel

 10 would like to see a little bit further sensitivity

 11 analysis of the AAPI in maybe a more holistic way

 12 considering not just elasticity, but range

 13 uncertainties and maybe how multiple uncertainties

 14 combined to affect the AAPI; or in the inverse

 15 calculation, how uncertainties in the AAPI might

 16 affect inferences on NOy and SOx.

 17 Part C, I think we had some discussion about

 18 whether there was geographic or temporal effects at

 19 smaller scales than the spatial and temporal

 20 averaging that's the basis of the options for the

 21 standard and whether that would motivate any kind

 22 of adjustment to the level of the standard. I

 23 don't get the sense we had a strong conclusion

 24 about that. So it could be something EPA could

 25 discuss. If the committee thinks that EPA should

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 1 do something, you know, I can incorporate that into

 2 the response.

 3 DR. RUSSELL: Kathy.

 4 DR. WEATHERS: So I think the bottom line on

 5 23 is the science hasn't changed appreciably. We

 6 are not in favor of increasing bureaucratic

 7 hassles, but the standard is set for something

 8 which the science is known, so we can stay. Then

 9 there are a couple of other fine points.

 10 MR. McNAMARA: Speak to the mike, please.

 11 DR. WEATHERS: The science didn't change

 12 appreciably. And so for that reason the standard

 13 could stay.

 14 We also had some questions that if it's useful

 15 to you that I write out I will do so, some

 16 questions about whether there is any connection

 17 between the standard that is being proposed here

 18 and the protection for vegetation. So is it

 19 helpful to reveal some of those questions in that

 20 discussion we had about bureaucracy?

 21 DR. HUBBELL: Not particularly. But, again, I

 22 think, as Karen pointed out, if the science still

 23 supports the current standard, that's what's most

 24 important.

 25 DR. WEATHERS: Yeah. And for 24 I think that

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 1 the bottom line is that the panel agrees with many

 2 of the suggestions for target values, levels.

 3 There are cases in which I think the panel agrees

 4 because it seems like the science is there and the

 5 range is supportive.

 6 There are other cases where more information

 7 would be needed or is needed, some clarification is

 8 needed. So, therefore, we're not making specific

 9 recommendations that are different from the ones we

 10 made. I'll clarify those.

 11 And a question about the big pieces, the AAPI

 12 components and other questions we'll address some

 13 of those concerns and reiterate what we're talking

 14 about here relevant to this question. It will

 15 be -- I don't know what -- Rich and Charlie I think

 16 you're on this with me. Who else was on this with

 17 me?

 18 DR. RUSSELL: Charlie, Charlie was 23.

 19 Lauraine. It sounds like people are getting tired.

 20 With that, I see EPA has a question for us.

 21 MS. MARTIN: Recognizing the time of day and

 22 everyone is getting tired, I did want to make a

 23 couple observations that I would like to offer to

 24 you as you think about how you're going to develop

 25 your letter tonight and tomorrow. One

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 1 recommendation to think about identifying types of

 2 additional work that we might do that would be most

 3 useful and informative to help provide a degree of

 4 confidence to move forward with the kind of

 5 standard that I think we hear you're all

 6 directionally supportive of, if we but did

 7 sufficient analysis to have sufficient confidence

 8 in the approach.

 9 I would really -- it would be extremely

 10 helpful to us for you to articulate those thoughts,

 11 prioritize them to the extent you can. We always

 12 work within time constraints, but time constraints

 13 aren't always inflexible. And having the

 14 opportunity to understand what you all think would

 15 be the most useful things for us to do allows us

 16 then to think about potential alternative paths

 17 forward to address those.

 18 In doing that, I would also urge you to think

 19 about does the information that has been pulled

 20 together in this five-year review cycle -- and by

 21 that I mean all the science presented in the ISA,

 22 the analysis presented in the REA -- do you believe

 23 that is a sufficient body of information to inform

 24 consideration of potential new standards if there

 25 were but further policy-relevant analysis done of

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 1 that information; or do you believe that it really

 2 takes another several years' worth of accumulating

 3 research information to have sufficient information

 4 to inform those judgments?

 5 That's not necessarily what I was hearing, but

 6 there is a very big difference between those two

 7 things. And clearly articulating your views on

 8 that point as well would be very helpful for us to

 9 think about alternative paths forward.

 10 DR. RUSSELL: Karen, thanks. That was going

 11 to be my parting thing is to -- if you recall, one

 12 of the things I want everyone to get their lists of

 13 what analyses you think need to be finished up to

 14 get to the state where the document is ready to

 15 adequately inform CASAC and the administrative team

 16 on how it might be biased in NAAQS. Karen wants

 17 that more specifically.

 18 So get that information to me because that is

 19 I think a very important piece of what we are going

 20 to transmit to the agency in this letter is exactly

 21 that. So, with that, I think we can be adjourned

 22 for the day.

 23 (Meeting adjourned at 5:25 p.m.)

 24

 25

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 1 STATE OF NORTH CAROLINA )

 2 COUNTY OF WAKE )

 3 CERTIFICATE OF REPORTER

 4 I, MAREN M. FAWCETT, Registered Professional

 Reporter and Notary Public in and for the State of North

 5 Carolina, duly commissioned and authorized to administer

 oaths and to take and certify depositions, do hereby

 6 certify that I attended the meeting on October 6, 2010

 and that the preceding transcript, was reported by me

 7 verbatim to the best of my ability, and then reduced to

 typewritten form under my direct supervision; that the

 8 foregoing is a true and correct transcript of said

 proceedings to the best of my ability and understanding;

 9 that I am not related to any of the parties to this

 action; that I am not interested in the outcome of this

 10 case; that I am not of counsel nor in the employ of any

 of the parties to this action.

 11

 12 IN WITNESS WHEREOF, I have hereto set my hand, this

 the _____ day of October, 2010.

 13

 14

 15 ___________________________

 16 Maren M. Fawcett, RPR

 Notary Public - North Carolina

 17 Certificate No.: 200621500068

 My Commission Expires: 7/31/2011

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 20 Maren M. Fawcett, RPR

 Bryant Court Reporting Service

 21 P.O. Box 1401

 Cary, NC 27512

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