202-234-4433 Neal R. Gross & Co., Inc. 

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## U.S. ENVIRONMENTAL PROTECTION AGENCY + + + + + CLEAN AIR SCIENTIFIC ADVISORY COMMITTEE (CASAC) NOx & SOX SECONDARY NAAQS REVIEW PANEL + + + + + MEETING

+ + + + +

THURSDAY, APRIL 1, 2010 + + + + + The meeting convened at 8:30 a.m.

in Salons A, B, & C of the Marriott at Research Triangle Park, 4700 Guardian Drive,

Durham, North Carolina, Armistead Russell, Chair, presiding. MEMBERS PRESENT: ARMISTEAD RUSSELL, Chair

PRAVEEN AMAR

ANDRZEJ BYTNEROWICZ* LAURAINE CHESTNUT ELLIS B. COWLING

CHARLES T. DRISCOLL, JR.202-234-4433 Neal R. Gross & Co., Inc. Page 2 MEMBERS PRESENT (Cont.): PAUL J. HANSON RUDOLF HUSAR

DALE JOHNSON*

NARESH KUMAR

MYRON MITCHELL

RICHARD L. POIROT KATHLEEN WEATHERS*

SCIENCE ADVISORY BOARD STAFF:

KYNDALL BARRY, Designated Federal Officer

VANESSA VU, Director, SAB Staff Office

*Participating via teleconference Page 3

C-O-N-T-E-N-T-S Call to Order and Opening Remarks 8 Ms. Kyndall Barry Designated Federal Official Opening Remarks of 10 Dr. Vanessa Vu SAB Office Director Opening Remarks of Dr. Ted Russell 13 Chairman Introductions 18 Background and Schedule for NOx and SOy 21 Secondary NAAQS Review

Ms. Lydia Wegman 21 Director, Health and Environmental Impacts Division Environmental Protection Agency

Dr. Bryan Hubbell 28, 50 Office of Air Quality Planning and Standards

Environmental Protection Agency

Introduction of the Policy Assessment 30

Dr. Tara Greaver 30 Office of Research and Development Environmental Protection Agency

Dr. Rich Scheffe 40 Office of Air Quality Planning and Standards Environmental Protection Agency

Questions and Answers 54, 107 Page 4

C-O-N-T-E-N-T-S (CONTINUED)

Public Comment Period 85

Ms. Pat Brewer 85 National Park Service

Status of SAB Integrated Nitrogen 91 Committee Dr. Otto Doering 91 Chair Dr. Russell Dickerson 93 Questions and Answers 96 PA Discussion - Chapter 2 112

Dr. Naresh Kumar 113

Charge Questions 1 and 2 113

Charge Question 3 114

Dr. Ellis B. Cowling 115

Discussion 124 PA Discussion - Chapter 3 141 Lauraine Chestnut 141

Charge Question 4 141

Charge Question 5 150 Dr. Praveen Amar 152 Discussion 155 Page 5

C-O-N-T-E-N-T-S (CONTINUED) PA Discussion - Chapter 4 185 Mr. Rich Poirot 185

Charge Question 7 185

Charge Question 8 187

Charge Question 9 190

Dr. Paul J. Hanson 196 Discussion 198 PA Discussion - Chapter 5 222 Dr. Praveen Amar 222, 289, 309

Charge Question 10 222

Charge Question 11 223

Charge Question 11A 223

Charge Question 11B 224

Charge Question 11C 234 Charge Question 11D 238 Charge Question 11E 241

Charge Question 12 289

Charge Question 13 309 Charge Question 14 319 Dr. Rudolf Husar 259, 270, 291

Dr. Naresh Kumar 265, 291, 310202-234-4433 Neal R. Gross & Co., Inc. Page 6

C-O-N-T-E-N-T-S (CONTINUED)

PA Discussion - Chapter 5 (Continued)

Mr. Rich Poirot 273, 292 Dr. Charles Driscoll 281, 296, 317 Discussion 286, 300, 318 PA Discussion - Chapter 6 319

Dr. Charles Driscoll 320, 344, 352, 364 382, 387, 392 Charge Question 15 320 Charge Question 16 344

Charge Question 17 352

Charge Question 18 364

Charge Question 19 382

Charge Question 20 387

Charge Question 21 392 Charge Question 22 395 Dr. Andrzej Bytnerowicz 328, 344, 362, 364 383,394

Dr. Ellis Cowling 331, 346, 362, 385 Dr. Myron Mitchell 333, 347, 363, 365 Dr. Kathleen Weathers 334, 349, 364, 366 383

Discussion 334, 366, 383, 387 396 Page 7

C-O-N-T-E-N-T-S (CONTINUED)

PA Discussion - Chapter 7 397

Dr. Paul Hanson 397 Charge Question 23 397 Charge Question 24 398 Dr. Kathleen Weathers 399

Discussion 402

PA Discussion - Chapter 9 403

Dr. Myron Mitchell 403

Charge Question 25 403 Charge Question 26 404 Dr. Lauraine Chestnut 405 Discussion 407

Discussion of Executive Summary 415

Summary of Major Review Comments 417 Dr. Ted Russell Page 8

1 P-R-O-C-E-E-D-I-N-G-S

2 8:30 a.m. 3 MS. BARRY: Good morning. 4 I'm Kyndall Barry, the Designated 5 Federal Officer for the Clean Air Scientific 6 Advisory Committee, NOx and SOy Secondary 7 NAAQS Review Panel. 8 I would like to open this public 9 meeting with a short statement. The CASAC was 10 established under the Clean Air Act as an 11 independent scientific advisory committee to 12 provide advice, information, and 13 recommendations on the scientific and 14 technical aspects of air quality criteria and 15 National Ambient Air Quality Standards, also 16 known as NAAQS. 17 The NOx and SOy Secondary Panel is 18 convened under the auspices of CASAC. The 19 Panel is meeting to peer review EPA's Policy 20 Assessment for Review of the Secondary NAAQS 21 for NOx and SOy, the first external review

22 draft. Page 9

1 Consistent with the requirements 2 of the Federal Advisory Committee Act and with 3 EPA policy, the deliberations of the Panel are 4 conducted in public at meetings for which 5 advanced public notice is given. FACA also 6 requires that, as DFO, I maintain records of 7 deliberations of the Panel, make publicly 8 available the meeting summaries, and provide 9 opportunities for public comment. 10 During the public comment period 11 scheduled to begin today at 9:30, we will hear 12 comments prepared on behalf of the National 13 Park Service by Ms. Pat Brewer. 14 The minutes of this meeting are 15 being taken to summarize discussions and 16 action items in accordance with the 17 requirements under FACA. These minutes will 18 be certified by the Panel Chair, Dr. Ted

19 Russell. 20 The Panel's draft reports on the 21 peer review of the Policy Assessment will be 22 forwarded to the chartered CASAC for their202-234-4433 Neal R. Gross & Co., Inc. Page 10 1 consideration and approval at a public 2 teleconference scheduled for May 3rd. 3 I would also like to note that the 4 members of this Panel are in compliance with 5 federal ethics and conflict-of-interest laws 6 that pertain to them. Therefore, waivers were 7 not needed or considered for any of the 8 panelists. 9 Thank you for your attention and 10 participation at this meeting. It is now my 11 pleasure to introduce Dr. Vanessa Vu, the SAB 12 Office Director, and Dr. Ted Russell, the 13 Chair, for their opening remarks. 14 Thank you. 15 DR. VU: Good morning, everyone. 16 Thank you, Kyndall, for the DFO 17 opening remarks. 18 I would like to welcome everybody 19 to the public meeting of the Clean Air 20 Scientific Advisory Committee, the peer review 21 panel for the welfare standards for NOx and 22 SOy. Page 11

1 First, I would like to express my 2 sincere thanks to all the members of the CASAC 3 Panel and Dr. Ted Russell, Chair of the Panel, 4 for your time and your participation in this 5 important review. 6 The agency has asked you to review 7 the first draft of the Policy Assessment 8 document for proposing the joint NAAQS 9 standards for NOx and SOy. 10 I would like to recognize that 11 with this presentation this morning we have 12 many representatives from OAQPS, led by Ms. 13 Lydia Wegman, Dr. Bryan Hubbell, from the 14 office. 15 One of the things that I would 16 also want to share with you, that there is an 17 ongoing SAB study, the group called Integrated 18 Nitrogen Committee, led previously by Dr. Jim 19 Galloway, and the Vice Chair is Dr. Tom Theis, 20 and now currently chaired by Dr. Otto Doering. 21 The SAB is working in the last two 22 or three years now to develop a recommendation Page 12 1 to the Administrator regarding the effects of 2 reactive nitrogens and make recommendations 3 with regard to the integration of risk 4 management of reactive nitrogen species and 5 identify research needs for that, for this 6 important group of nitrogens that could impact 7 the human health and ecological systems. 8 So, given that this group has some 9 relevancy in looking, and recognizing the SAB 10 study, we are delighted to have Dr. Otto 11 Doering. Joining him is Dr. Russell 12 Dickerson, who is a member of the Committee, 13 who will give you a brief status update of the 14 SAB study, which we hope to be complete in 15 June this year, as well as some of the key 16 recommendations that are pertinent for your 17 consideration for this Panel. So, I 18 appreciate that Dr. Ted Russell asked the INC 19 Committee to talk with you briefly about this 20 important SAB study. 21 In addition, I really appreciate 22 that public input is an important process for Page 13 1 CASAC's deliberation, and I appreciate the 2 written comments and summary statements from 3 the public commenters. 4 Finally, I would like to recognize 5 Kyndall Barry, the DFO for this Panel, and all 6 our personnel to make this meeting possible. 7 With that, I would like to turn it

8 over to Dr. Ted Russell. 9 CHAIRMAN RUSSELL: Thank you,

10 Vanessa. 11 I would like to thank the Panel

12 and all the other stakeholders who have come 13 today and, in particular, OAQPS, for putting 14 together this document. I think it is almost 15 historic what you all have been able to do. 16 I am also very appreciative that 17 you are asking for our advice on many, many 18 different fronts, on what used to be 39, now 19 29 different question fronts. Hopefully, we 20 will be able to give you the advice that you 21 are looking for, and certainly, if you have 22 other questions.202-234-4433 Neal R. Gross & Co., Inc. Page 14 1 And to the Committee, obviously, 2 it has been a while. When we were last here, 3 I would say sort of the endpoint was that they 4 couldn't get to where they wanted to be. 5 Luckily, they were able to get some extra time 6 to really, I think, start finishing up on 7 their policy in a way that I think was 8 appropriate, given all of the other work that 9 they had done and that this Committee had 10 done, the advice that we had given them. Now 11 we are seeing some of the fruits of those 12 efforts in terms of the policy document. 13 Recognizing that this is really 14 quite a different policy document than you 15 would see in the other CASAC reviews, first, 16 it is very much oriented towards the secondary 17 standard, and it goes across media, makes a 18 major difference. But, also, the fact, I sort 19 of equate, look at and compare this to how 20 they do the policy documents to the primary

21 standards. 22 I think one of the things we want Page 15 1 to keep in mind, and what we want to do as we 2 go through this, is look at the uncertainties 3 and how well they have scientifically linked 4 all the steps. I always like to realize that 5 we are the Scientific Advisory Committee. So, 6 the more we can provide on the science, I 7 think it can be quite helpful to them. 8 We have got a lot to do today. 9 Again, going through really the eight chapters 10 and all of the charge questions means we are 11 going to have a busy schedule, both during the 12 day and, I hate to say it, I think there's 13 going to be a fair amount of writing that has 14 to be done this evening as well. 15 So, if you look at the schedule, 16 OAQPS is going to be presenting the background 17 and the schedule. Actually, I wouldn't mind, 18 Lydia, if you could say something about what 19 has happened or transpired from the last 20 meeting until this meeting, just so the 21 Committee will have an idea what has happened 22 and why. Page 16 1 So, after that, we will have the 2 public comment period. Then, as Vanessa said, 3 I invited the Chair of the INC, this 4 Integrated Nitrogen Committee, to talk with 5 us. I was hoping the report would be done at 6 this point, but it is not released and out 7 yet. But, still, I think the information that 8 they can provide on their deliberations would 9 be useful as we go forward. I didn't want to 10 wait until our next get-together or next 11 teleconference for them to present. 12 By the end of the day -- that is 13 really where we want to look at next -- if you 14 see, it has "recess for the day" and "writing 15 session". Because like what we have done 16 before, tomorrow morning what we want to do is 17 be able to go through the responses to the 18 charge questions as well as the letter that we 19 will write, the cover letter. 20 So, what would be good is if, at 21 the end of the day, each of the leads for each 22 of the chapter discussions could put together Page 17 1 the bullets of what they think are the most 2 important points, so we can review those as a 3 Committee before everyone goes off for their 4 writing sessions. 5 In terms of the writing, again,

6 each of the leads should come back tomorrow 7 morning and, actually preferably late tonight, 8 if you could email to Kyndall and me your 9 responses in a way that we can review them 10 tomorrow? And hopefully, to be in pretty good 11 shape. 12 Because, as you know, what is 13 going to happen tomorrow morning is we are 14 going to go through each of those, discuss 15 them as a group, do some editing for content, 16 not grammar and such. We can do that, too, 17 but, hopefully, not spend too much time on 18 wordsmithing. With the hope that, come lunch, 19 maybe a working lunch, we will have this thing 20 in pretty good shape. 21 Because what will happen after we 22 are done is that Kyndall and I will, then,202-234-4433 Neal R. Gross & Co., Inc. Page 18 1 start doing the wordsmithing, get it edited 2 down. This will be done in conjunction with 3 the Committee. In particular, each of the 4 different chapter groups, we will interact 5 with them to get their comments as we go. 6 Then, do we have a schedule for 7 the telephone sort of review of this yet? 8 MS. BARRY: Not yet. I wanted to 9 see how much we got done. 10 CHAIRMAN RUSSELL: Right. So, as 11 you maybe recall from the last one, then this 12 edited letter would then be discussed by CASAC 13 as a whole for their approval. Then, it would 14 be sent out under Jon Samet's signature. The 15 better shape it is in at that point, the 16 faster that next meeting will go as well, and 17 the more productive it will be. 18 With that, if there's no 19 questions, seeing none, what I would like to 20 do is have everyone introduce themselves. 21 I am Ted Russell, and I am from 22 Georgia Tech. Page 19

1 Ellis, do you want to start us

2 off? 3 MEMBER COWLING: Okay. I'm Ellis 4 Cowling from North Carolina State University. 5 MEMBER DRISCOLL: Charlie 6 Driscoll, Syracuse University. 7 MEMBER HANSON: Paul Hanson, Oak 8 Ridge National Laboratory. 9 MEMBER AMAR: Praveen Amar with

10 NESCAUM. 11 MEMBER POIROT: Rich Poirot, State

12 of Vermont. 13 MEMBER CHESTNUT: Lauraine 14 Chestnut, Stratus Consulting. 15 MEMBER MITCHELL: Myron Mitchell,

16 SUNY ESF. 17 MEMBER KUMAR: Naresh Kumar, 18 Electric Power Research Institute. 19 MEMBER HUSAR: Rudy Husar, 20 Washington University in St. Louis. 21 MS. WEGMAN: Do you want us to go

22 around? Page 20

1 CHAIRMAN RUSSELL: Well, at least 2 introduce yourselves before you present. That 3 would be good. 4 MS. WEGMAN: Okay. Then, I will 5 introduce people, too. 6 CHAIRMAN RUSSELL: On the phone? 7 MEMBER WEATHERS: Ted, do you want 8 those of us who are on the phone to say hello? 9 MS. BARRY: Yes, please do. 10 MEMBER JOHNSON: This is Dale 11 Johnson, logged in on the phone. 12 MS. BARRY: Good morning.

13 MEMBER WEATHERS: And Kathleen 14 Weathers from the Cary Institute of Ecosystem 15 Studies. 16 MS. BARRY: Andrzej, are you with 17 us this morning? 18 (No response.) 19 Okay. 20 MS. WEGMAN: Do you want us to

21 start? 22 CHAIRMAN RUSSELL: Here we go. Page 21 1 Lydia? 2 MS. WEGMAN: Thank you, Ted. 3 Good morning again, everybody. 4 I am Lydia Wegman. I am the 5 Director of the Health and Environmental 6 Impacts Division in OAQPS. 7 I want to thank you all again for 8 coming, for all the work you have done in 9 reviewing the documents that we have given you 10 to date, and especially for the work you have 11 done in reviewing this first draft Policy

12 Assessment. 13 I agree with Ted that this is a 14 unique and innovative rulemaking on which we 15 are all engaged. We are very much dependent 16 on your advice for helping us to make this

17 successful. 18 I want to thank you for the help 19 you have given us already in getting us more 20 time in order to do this review. The letter 21 that you wrote reflecting on the benefits of 22 having additional time to think about how to202-234-4433 Neal R. Gross & Co., Inc. Page 22 1 bring this standard to fruition, rather than 2 just, in essence, giving up where we were, was 3 very helpful. I think it was helpful to us 4 and to those who had to consider whether to 5 give us more time, the litigants in this case. 6 And to respond to Ted's question, 7 which I was planning to do, what we succeeded 8 in doing is talking to the litigants in the 9 case, and they agreed to give us additional 10 time for this review, in the hope that we 11 could, in fact, develop a new approach, new 12 multi-pollutant approach to reducing emissions 13 and setting a standard for deposition from NOx 14 and SOy. 15 This review is extremely important 16 to us. It is a multi-pollutant review. It is17 the first time that we are taking a multi18 pollutant approach to the secondary standards. 19 The particular approach that is laid out in 20 this first draft Policy Assessment is 21 completely new and one on which we really need 22 your advice to help us refine it and bring it, Page 23 1 we hope, to fruition with a final standard in 2 March of 2012. I will show you the schedule 3 when I am done with this. 4 I very much want to thank CASAC, 5 not only for its work in the review, but also 6 for encouraging us and those who had to help 7 make this decision to give us more time, 8 because the additional time has been 9 absolutely crucial, of course, to bringing us 10 to the point we are at today. 11 So, that is what has happened, in 12 essence, since the last time we met. That is 13 why we have had as much time as we have, and 14 it continues. We have about not quite two 15 years from where we are today to issue a final

16 standard. 17 Unless there are any questions on 18 that, I am going to proceed with my first few 19 slides and then turn it over to Bryan. 20 So, first, we have a very strong 21 team, as always, working on this review. Dr. 22 Bryan Hubbell has been the lead. We've got Page 24 1 Dr. Rich Scheffe here, and behind me we have 2 Tara Greaver and Chris Davis and Randy Waite, 3 all of whom have been critical players on the 4 team. There are other members of the team in 5 the audience, but I will have them each 6 introduce themselves as they come forward and 7 speak with you. But this is our team. 8 Many of you have seen this slide 9 before, but I want to remind you all of the 10 elaborate process in which you and we are all 11 engaged. This is the overall picture of our 12 NAAQS review process. What you see 13 highlighted in red is the Risk and Exposure 14 Assessment, which, thanks to your help and the 15 reviews you provided on the first and second 16 draft of that, was completed in September. We 17 are now up to the first draft of the Policy 18 Assessment, as you know. I will say a little 19 bit more about that in a minute. 20 Once we get through the second 21 draft of the Policy Assessment and the final 22 Policy Assessment, we are going to move on to Page 25 1 the rulemaking phases. So, your comments on 2 both the first and second draft of the Policy 3 Assessment will be extremely important in 4 helping us move forward to the proposed rule. 5 So, what you have already given us 6 comments on are the Integrated Science 7 Assessment, which, as I think you all know, is 8 a synthesis of the most policy-relevant 9 science. That provides the foundation for 10 this review and helps inform the Risk and 11 Exposure Assessment and, of course, the Policy

12 Assessment. 13 The Risk and Exposure Assessment, 14 you gave us many helpful comments on, where we 15 tried to characterize the nature and magnitude 16 and uncertainties associated with selected 17 ecological endpoints, and we considered recent 18 air quality conditions and impacts in areas

19 that do meet the current standard. 20 We did some case studies on which 21 you advised us, which have helped to inform 22 the Policy Assessment.202-234-4433 Neal R. Gross & Co., Inc. Page 26 1 Just as a quick reminder on the 2 role of the Policy Assessment, it is designed 3 to bring together the science and the Risk and 4 Exposure Assessment and to help bridge the gap 5 from science to policy. It is an essential 6 link to the next step in the process, which 7 will be a proposed rule. 8 What we have done in the Policy 9 Assessment, as you know, and will be doing, is 10 to consider the adequacy of the current 11 standard and, then, in the next draft think 12 out alternative standards which may be 13 appropriate to consider in light of the work 14 that has been done on both the review of the 15 evidence and then the Risk and Exposure 16 Assessment, and the advice you give us on the 17 approach that we are taking to setting the 18 standard. That is, of course, what we very 19 much want your advice on today. 20 We do, in fact, have many charge 21 questions. I think we will have additional 22 questions as we go forward in the discussions Page 27 1 today because I think we have some questions 2 on some of the comments you have given us so 3 far. We hope we can have a good discussion on

4 that. 5 Then, just to go over the 6 schedule, because I am not sure all of you are 7 aware of it, we have given you the first draft 8 of the Policy Assessment. We are having the 9 CASAC and public review running through the 10 end of this month and, of course, today's 11 public meeting. 12 We plan to have a second draft of 13 the Policy Assessment, based on all the 14 comments that you give us and the public 15 comments we receive, by late July of this 16 year. Then, we will give you, of course, an 17 opportunity to review it, as well as the 18 public. We plan to have a public meeting on 19 the second draft of the Policy Assessment in 20 mid-September. 21 Then, we plan to issue the final 22 Policy Assessment by the end of November of Page 28 1 this year. Between then and July 12th, where 2 we have a court-ordered date, July 12th, 2011, 3 we will be developing the proposed rule and we 4 will have the proposed rule signed by July of 5 2011. We will have a comment period, which 6 will be a 90-day comment period leading up to 7 the final rule on March 20th of 2012. 8 So, that is the schedule that we 9 are all working against. If there aren't any 10 questions on that, I am going to turn it over 11 now to Bryan. 12 Is it Bryan or Rich? 13 DR. HUBBELL: Yes, I am going to 14 just introduce for a moment. 15 MS. WEGMAN: Okay. 16 DR. HUBBELL: So, we struggled a 17 bit with what to present you, because, as you 18 are aware, this is a very complicated 19 document. We decided to focus our 20 presentation, and Rich Scheffe and Dr. Tara 21 Sullivan, I'm sorry, Tara Greaver, are going 22 to provide us with an overview of Chapter 5, Page 29 1 which is focused on conceptual design for the 2 form of the standard, and Chapter 6, which 3 talks about some of the options we are 4 considering for elements of the standard. 5 So, while we are not trying to 6 downplay the importance of the other chapters 7 and the charge questions on those chapters, we 8 felt that these are the two chapters that 9 really needed the most elucidation to help you 10 focus in your comments to us. 11 Part of that presentation is going 12 to be something that is actually not fully 13 characterized in the document itself because 14 we have been trying to expand on an example to 15 help walk through some of the more complicated 16 aspects of the conceptual model. So, 17 interspersed within these pieces that talk 18 directly to the elements of the chapters, 19 there is an example that I hope will help make 20 things clearer. 21 So, with that, I will turn it over 22 to Tara. We are going to start with Tara.202-234-4433 Neal R. Gross & Co., Inc. Page 30 1 Don't believe the agenda. We are going to 2 start with Tara, and she is going to walk 3 through the beginnings of Chapter 5. 4 DR. GREAVER: Okay. As Bryan 5 mentioned, in the first draft Policy 6 Assessment we have focused on developing a 7 form of the standard that is based on 8 protecting ecosystems from aquatic 9 acidification. 10 This diagram illustrates that 11 conceptual design of the form. This builds on 12 similar diagrams that were presented in the 13 Risk and Exposure Assessment. 14 So, the blue portions of the 15 diagram refer to ecological components and 16 show how an ecosystem indicator, A and C, is 17 related to deposition by an ecosystem 18 acidification model. Then, deposition is 19 related to concentration of an air quality 20 indicator, as the deposition transformation of 21 function. 22 So, these bidirectional arrows Page 31 1 indicate that these relationships may be 2 considered from both directions, depending on 3 the question of interest. 4 For example, if you identify a 5 target level of ANC, you can calculate the 6 concentrations of your air quality indicators 7 that will allow an ecosystem not to exceed 8 that target ANC. Conversely, if you measure 9 your concentration of air quality indicators, 10 you can then calculate your ANC and compare 11 that to your limit, your target. 12 So, our goal is to develop a form 13 of this standard that reflects these 14 relationships. In the following presentation, 15 we are going to demonstrate the two ways that 16 we can present these standards. 17 The first are a series of tradeoff 18 curves for atmospheric deposition and 19 concentration. Those are working from left to 20 right on this diagram. Then, we are going to 21 talk Atmospheric Acidification Potential 22 Index, which was developed by working from Page 32 1 right to left on this diagram. 2 Next slide. 3 Now we will go through the example 4 for the conceptual design. When we first 5 began, we asked ourselves, how can we use 6 acidification models to inform this standard, 7 acknowledging that acidification models are 8 designed for application to catchment scale, 9 and that it would be inappropriate and 10 unfeasible for us to model every catchment in 11 the U.S., especially since the standards are 12 designed to protect public welfare, and not 13 necessarily every catchment? 14 So, we then developed an approach 15 to evaluate a distribution of critical loads 16 from a population of catchments, and from that17 distribution, select an appropriately18 protective deposition level that we are 19 calling a deposition metric. We would hope to 20 identify these populations, so that they would 21 represent national acid sensitivity 22 categories. Page 33

1 The criteria for these categories 2 is under development. In this first draft, we 3 suggested they could be based on geology, and 4 ask CASAC if multiple criteria or other 5 criteria might be a better way to do that. I 6 would also like to note that the value of the 7 deposition metric will vary among the acid 8 sensitivity categories. 9 So, at this point, throughout the 10 rest of this presentation, we are going to use 11 the terms "category" and "spatial area". With 12 this slide, we would like to define those. A 13 category, as I mentioned on the previous 14 slide, refers to a classification of acid 15 sensitivity in the landscape. An area refers 16 to a specific spatial unit. It would probably 17 be larger than an individual catchment, for 18 which we are going to develop values for 19 parameters of our Acidification Potential 20 Index. We will talk a little bit more about 21 that in following slides. 22 So, continuing on with our202-234-4433 Neal R. Gross & Co., Inc. Page 34 1 example, with the first diagram, we are 2 showing the population of catchments that we 3 use in the Adirondacks. So, for each of those 4 catchments, we calculated a critical load. 5 Then, the second diagram here shows a 6 cumulative distribution of critical loads that

7 were calculated for ANC level of 50. 8 Along the Y-axis, we have the 9 percentage of the population protected from a 10 critical load exceedance. Then, along the 11 X-axis are deposition of nitrogen and sulfur 12 in units of milliequivalents for meter squared 13 per year. 14 So, you can see that, in order to 15 protect every catchment in that population 16 from exceeding their critical load for an ANC 17 level of 50, we would not be able to allow any 18 deposition. If we wanted to protect 83 19 percent of the population, a level of 20 deposition of 100 could be allowed. If we 21 wanted to protect 10 percent of the 22 population, a level of deposition of 400 could Page 35

1 be allowed. 2 Here, this slide shows the 3 acidification model that we have suggested in 4 this first draft. This is the model to 5 calculate a critical load at the catchment 6 scale. Now, in order to distinguish between 7 the critical load at the catchment scale and 8 our deposition metric, we introduced a new 9 notation. That new notation is DL%eco, 10 meaning a deposition load that represents 11 percentage of our ecosystems. 12 Now our deposition metric may be 13 used to develop tradeoff curves. I am just 14 going to go to the next slide, where we show 15 the example and talk through it.

16 Here we have a tradeoff curve for 17 a nitrogen and sulfur deposition. So, this is 18 showing two potential choices in deposition 19 metrics. 20 The first one, the blue line, is 21 indicating, if your ANC level is equal to 50, 22 and you wanted to protect 50 percent of the Page 36 1 lakes in the population, that is what your 2 curve would look like. It is a little less 3 protective than the pink line, which would 4 allow you to protect 95 percent of the lakes 5 in your population.

6 There are two other features of 7 this diagram that I would like to point out. 8 The first is NECO, and that indicates the 9 amount of nitrogen that the ecosystems would 10 take up before it contributes to leaching and 11 aquatic acidification. We have also CASAC a 12 charge question to ask CASAC's advice on what 13 the best way is to calculate that term. 14 The second feature I would like to 15 point out is the gray vertical line. That is 16 the reduced nitrogen deposition. We developed 17 that number by looking at the average value of 18 reduced deposition over our population area. 19 So, what we need to do is, once we 20 have determined our deposition metric, is we

21 need to subtract the amount of reduced 22 nitrogen. That is indicated by the first Page 37 1 equation on this slide. 2 The next step is to convert the 3 deposition to an atmospheric concentration. 4 We do that using V terms. These V terms are 5 the deposition transformation ratios. Those 6 are developed by CMAQ. Again, these 7 calculated for a specific area, in this case, 8 over the Adirondacks. But the criteria, in 9 general, for defining these areas over at a 10 national scale are under development. 11 So, once we subtract, reduce 12 nitrogen, this is what our curve looks like. 13 You can see now that the X-axis is for NOy, 14 and the previous tradeoff curve is for N, and 15 the Y-axis has remained the same as SOy. 16 So, the next tradeoff curve. This 17 slide is out of sequence. So, we are just 18 going to skip over this one. 19 The next tradeoff curve here is 20 once we have made that conversion from 21 deposition to atmospheric concentration. The 22 blue area, underneath the blue line, any202-234-4433 Neal R. Gross & Co., Inc. Page 38 1 combination of NOy and SOy concentrations 2 would be protective of your target, which in 3 this case would be to protect 50 percent of 4 your leaks in the population. 5 The pink area are all the 6 combinations that you could have to achieve 7 protection of 95 percent of your population. 8 The triangle indicates the current 9 concentrations in the Adirondacks. So, right 10 now, the concentrations are protective of 50 11 percent; however, not protective of 95 percent 12 of the catchments there, for an ANC level of

13 50. 14 If we can continue on to the next 15 slide, with that slide, we would like to 16 summarize our conceptual approach and, also, 17 to show how this example leads into the 18 development of our AAPI. 19 So, with the first equation, that 20 is showing the deposition metric minus reduced 21 nitrogen. Equations 2 and 3 are showing how 22 deposition loads of SOy -- that should say, Page 39 1 "SOy" -- and NOy are converted to atmospheric 2 concentrations. The resultant tradeoff curves 3 will vary among the acid-sensitive categories. 4 However, the ANC limits will be 50. They will 5 all be designed to have a target value of ANC, 6 in this example, an ANC level of 50. 7 So, the deposition equation, No. 8 1, can be rearranged to solve for a calculated 9 ANC. This value could be compared to your ANC 10 limit or your target ANC. That is what we are 11 showing with equation No. 4. 12 So, then, comparing your 13 calculated ANC to an ANC limit is the basis 14 for our suggested form, the Atmospheric 15 Acidification Potential Index. What you could 16 do is, if you knew your concentrations at a 17 given location, you could calculate the 18 resultant ANC level and compare it to a 19 standard or a national target. 20 So, in essence, the AAPI 21 represents the ecological indicator side of 22 that conceptual design and the diagram that we Page 40 1 started with. It can be expressed in two 2 ways, as a tradeover curve that gives the 3 combination of NOx and SOy that satisfies 4 specific target ANC limit for a percentile of 5 catchments, given the NHx deposition and the 6 V terms for a particular, that should say, 7 acid sensitivity category, perhaps based on 8 geology or other criteria. 9 Then, the AAPI is calculated value 10 of ANC expected with your given values of NOx 11 and SOy. And again, this calculated AAPI 12 could be compared against a level selected by 13 the Administrator. 14 So, with that, I would like to 15 turn it over to Dr. Rich Scheffe. 16 DR. SCHEFFE: Thank you, Tara. 17 One other point I would like to 18 note, since we are bridging across atmospheric 19 systems and aquatic and terrestrial systems, 20 a key part of our team is Dr. Jason Lynch from 21 our sister office in Washington, the Office of 22 Atmospheric Programs. Without Jason, a lot of Page 41 1 the ecosystem modeling work and everything 2 else -- we really relied on him quite heavily. 3 Could we go to the next slide, 4 please? 5 All right, moving into the various 6 elements of the standard, if we talk about the 7 indicator, the indicator, again, because we 8 are talking about National Ambient Air Quality 9 Standards, we are talking about atmospheric 10 indicators, those atmospheric indicators will 11 be NOy, which we are referring to as total 12 reactive oxidized nitrogen. NOy, basically, 13 is all of the oxidized products of NOx 14 emissions and, also, the oxidized sulfur 15 components. 16 Although, in concept, we talk 17 about all possible sulfur species, in 18 practice, we are really talk about sulfur 19 dioxide gas and particulate sulfate. These 20 are really the measurable portions that are 21 available through quite a bit of routine 22 monitoring in networks.202-234-4433 Neal R. Gross & Co., Inc. Page 42 1 We will also note that, throughout 2 the document, we have used the terms "NOX" and 3 "NOy" interchangeably, which goes a little bit 4 against the grain in terms of the standard 5 atmospheric science definitions. We recognize 6 that. Several of you have commented on that. 7 The averaging time that we are 8 talking about will be based on the annual 9 averaging time. Over the next few slides, we 10 will get into more depth on the slide. At 11 this meeting, we don't intend to talk about 12 the level. That will be the subject of the 13 next document and the next two meetings. 14 Now Tara introduced the 15 Atmospheric Acidification Potential Index. 16 What I would like to do here is start with 17 words, then show it in equation form, then 18 explain where the equation came from, and then 19 start picking apart some of the parts of that 20 equation. 21 The AAPI is really the natural 22 background ANC minus the contribution to Page 43

1 acidifying deposition from reduced nitrogen, 2 minus the acidifying contribution from 3 oxidized nitrogen and sulfur. In essence, a 4 single nationwide AAPI level would be set, and 5 for all intents and purposes, this is what we 6 are referring to as the national standard. 7 The AAPI takes into account the 8 natural ability of an ecosystem to neutralize 9 acid inputs and accounts for the contributions 10 of reduced nitrogen deposition. This, again, 11 is another topic of questioning and 12 introspection throughout many of your

13 comments. 14 Because of the constraint that 15 contributions of reduced nitrogen deposition 16 are separated from the oxidized forms, this 17 effectively decreases the relative amounts of 18 NOy and SOy necessary to meet a target value. 19 In other words, we have to make up for reduced 20 nitrogen in the overall mass balance from 21 oxidized forms of nitrogen/sulfur. 22 Now the AAPI can be expressed as Page 44 1 an equation or used in the NOy and SOy 2 tradeoff curves, as Tara has just taken you 3 through. The AAPI has the same units as ANC, 4 but it is not ANC. The AAPI is a calculated 5 term, and it is applied at scales much greater

6 than the catchment level. 7 Now, if we transition into the 8 equation form of the AAPI, here are the 9 different terms. The G term is the natural 10 background. It basically incorporates the 11 processes due to natural weathering and supply 12 of base cations as well as the ability to 13 uptake nitrogen in the system. 14 The NHx term, that is a loading 15 term basically representing deposition of 16 ammonia and ammonium ion. Then, on the right 17 side, those are the oxidized forms of nitrogen 18 and sulfur deposition. Q reflects the 19 hydraulics, the runoff at the system. 20 We have transformation ratios for 21 both nitrogen and sulfur, the V terms. And I 22 have explained the rest of those terms. Page 45

1 Now, if we look at this equation, 2 if we start with, if we go back to, and Tara 3 showed you this equation, this is essentially 4 the critical load modeling expression for 5 deposition load. Really, the AAPI is simply 6 derived from this expression. If we 7 substitute ambient concentrations of SOy and 8 NOy for the deposition values that we have in 9 these terms, and we rearrange the terms in 10 terms of the only term here that is really 11 fixed, which is the ANC limit, we rearrange 12 this and can simply express this in the form 13 of the AAPI, which now, essentially, the AAPI 14 is a function of the ambient air indicators 15 NOy and SOy, SOy, of course, representing the 16 sum of sulfur dioxide gas and particulate

17 sulfate. 18 So, the beauty of this is that now 19 we have the representation of a national 20 standard that can be judged by looking at 21 indicators in the air, the compliance of which 22 can be judged by looking at these indicators202-234-4433 Neal R. Gross & Co., Inc. Page 46

1 in the air. 2 We move on to the next slide and 3 look a little bit more in-depth, basically, at 4 the different components in that AAPI 5 equation. As we have noted, the G term 6 represents the natural background. In most of 7 the cases, we want to emphasize that, in terms 8 of aggregation, we are not talking about 9 aggregating at the watershed level. We are 10 talking about aggregating either at what we 11 would call an acid-sensitivity area or an 12 acid-sensitive category area, which is much 13 larger than just a single watershed area. G, 14 again, is really going to be dominated by the 15 weathering rates and the nitrogen retention 16 characteristics. 17 Reduced nitrogen loading, as many 18 of you know, we do not have a robust network 19 that measures reduced nitrogen. We have some 20 measurements of ammonium. We have some in wet 21 samples. We have a very, very limited network 22 of ammonium in dry samples. That largely Page 47

1 isn't used. 2 So, the best information for 3 deriving the estimate of reduced nitrogen 4 deposition is through modeling. We intend to 5 use the CMAQ model, the annual average, 6 probably over three consecutive years of 7 modeling to arrive at that value. 8 The transformation ratio terms, VNOy 9 and VSOx, these, again, are extracted from the 10 modeling results. Essentially, what we do is 11 we look at an area of interest. Let's say the 12 Adirondacks. We look at all of those grid 13 cells. And for all of those grid cells, we 14 look at the ratios of deposition, the 15 concentration, total deposition of all sulfur 16 and all nitrogen species, and divide that by 17 the ambient concentrations, and arrive at 18 these values. These are set parameters. 19 Okay? These are set in the equation. 20 In effect, the real dependent 21 variables from thinking of this are really the 22 ambient air indicators NOy and SOy. These are Page 48 1 the indicators that will be used to judge 2 compliance. This implies that there would 3 have to be observations. This also implies

4 that down the road there would be an

5 enhancement of some of these measurement 6 techniques for NOy and particulate sulfate, 7 for FRM, or Federal Reference Method, or 8 Federal Equivalent Method considerations.

9 We do have FRMs for sulfur 10 dioxide. We do routinely measure particulate 11 sulfate, as many of you know, in over 500 12 sites nationally. We are starting to 13 routinely measure NOy at some of our NCore 14 sites, but they do not have reference 15 equivalency status. 16 So, to finish up on the modeling 17 and the monitoring issues, I think I have 18 pretty much covered this, about the use of 19 CMAQ for deriving or setting the parameters 20 for reduced nitrogen deposition and the 21 transformation ratios and some of the 22 implications for the FRM/FEM status for NOy Page 49 1 and particulate sulfate. 2 The next meeting, we plan to go in 3 quite a bit more depth in terms of the 4 monitoring issues, not only from a methodology 5 perspective, but also from a network design 6 perspective. 7 I will just finish up with two 8 slides that we use for addressing the adequacy 9 of the current secondary standards for NO2 and 10 SO2, just to give a quick snapshot of 11 indication of where we need to fill in some of 12 the spatial regimes. 13 There's two issues that crop up. 14 One, NO2 and SO2 by itself are not adequate to 15 cover all of the mass constituents of oxidized 16 nitrogen/sulfur in the atmosphere. And 17 secondly, our networks generally are 18 population- and/or source-oriented, and are 19 not really well-placed to pick up signals from 20 the important receptor areas. We recognize 21 that. That will be a strong topic of the next 22 report.202-234-4433 Neal R. Gross & Co., Inc. Page 50 1 DR. HUBBELL: All right. So, I am 2 just going to finish by mentioning some of the 3 things we are already thinking about, in 4 thinking about our next draft of the Policy

5 Assessment. 6 Obviously, one of the areas that 7 has been highlighted, several areas that have 8 been highlighted by the members so far in the 9 written comments are that we need to be, 10 obviously, much more clear and consistent in 11 our mathematical notation. We have been 12 developing this on-the-fly, and as we change 13 equations and ideas about how to present 14 things, notations shift, and sometimes it is 15 hard to keep up with our own notation. 16 So, we will work very hard to make 17 sure that we are consistently defining both 18 our variables and our notations as we move 19 through, and avoiding the use of "reduced" 20 when we are talking about decreases. That is 21 something that we have struggled with because, 22 in our minds, we think "reduced" means Page 51

1 "decreased". But, chemically, obviously, it 2 means something different. 3 We are going to be planning on 4 expanding our discussions of uncertainties in 5 a number of different ways. One is that we 6 are going to be looking at the uncertainties 7 in the actual evidence and Risk Assessment, 8 and how that plays in terms of implications

9 for the levels and forms of the standard. 10 Then, we are going to be also 11 looking at uncertainties in the elements of 12 the standard. We have just gone through the 13 fact that a lot of the parameters of this AAPI 14 are things that are going to have to be 15 modeled or approximated through different 16 types of categorical variables. We will be 17 looking at how to expand our discussion of 18 uncertainties in the treatment of those 19 parameters. 20 We are hoping to do a better job 21 covering the other endpoints. We think we can 22 go a long ways towards increasing our ability Page 52

1 to discuss terrestrial acidification. We have 2 some ideas about how to think through the 3 ideas of nutrient enrichment as well, but we 4 feel that that is a little further down the 5 road. So, our definite focus for the next 6 draft is to at least expand to terrestrial 7 acidification. 8 We also want to spend some time in 9 the next draft expanding our discussions of 10 national representation. You will notice in 11 a lot of our discussions that we have really 12 focused a lot on the Eastern U.S. with some 13 touching on the Western U.S., but we want to 14 try to expand our discussions to cover more of 15 the overall national picture. 16 We are also going to be looking 17 at, can we expand our ability to talk about

18 the effects and how the effects can be 19 characterized on a national scale as well? In 20 other words, for example, the relationship 21 between ANC and fish species diversity, we 22 want to look at how that can be expanded. Page 53 1 Then, we will be thinking more, 2 and I am sure that you are going to have lots 3 of good comments for us on this, but on the 4 role of reduced nitrogen, how it can be 5 incorporated in our existing form of our 6 standard in a way that reflects the current 7 status of the science as well as getting any 8 inputs from you on alternative ways that you 9 would like us to think about reduced nitrogen. 10 Then, the last part, and it will, 11 hopefully, start the government coming into 12 our second draft, is a much more thorough 13 discussion of the basic elements of the 14 alternative secondary standards, including a 15 discussion or beginning a discussion about 16 levels of the standard, and what might be 17 appropriate to be protective of public

18 welfare. 19 So, with that, I think that is the 20 end of our formal presentation. We certainly 21 would be happy to have any questions right

22 now.202-234-4433 Neal R. Gross & Co., Inc. Page 54 1 CHAIRMAN RUSSELL: Thank you, 2 Bryan. 3 Questions from the Committee, from 4 the Panel, about the presentations so far? 5 Or, was it just so absolutely clear? But I 6 see Richard's hand. 7 MEMBER POIROT: I was just 8 wondering if we could maybe look at one of 9 those tradeoff curve diagrams. 10 DR. HUBBELL: All right. Would 11 you like it in terms of deposition or 12 concentrations? 13 MEMBER POIROT: Oh, they are the 14 same thing, aren't they? 15 DR. HUBBELL: Yes, they are. 16 Okay. 17 MEMBER WEATHERS: Could you 18 mention which slide you are looking at? 19 DR. HUBBELL: We are referring to 20 slide No. 17.

21 MEMBER WEATHERS: Thanks. 22 MEMBER POIROT: Well, then I was Page 55 1 wondering if you could kind of -- my question 2 is, in terms of the role of reduced nitrogen, 3 if we were thinking of this as representing an 4 actual location or population, or something, 5 whatever the regulatory metric is, could we 6 move from one side of the line to the other or 7 in the correct direction by controlling 8 reduced nitrogen? Wouldn't that change the 9 nature of the relationship? Even though it 10 isn't directly addressed in the regulatory 11 metric, couldn't we get in the right direction 12 by -- I almost said "reducing it" -- by 13 diminishing it, decreasing it? 14 DR. HUBBELL: Well, the 15 interesting thing about the nitrogen part of 16 this is that it, obviously, depends on the 17 ability of the ecosystem to take up nitrogen 18 as well. So, if you are in a situation where 19 the ecosystem has plenty of room to take up 20 the nitrogen, then what you are really doing, 21 as Tara analyzed, you are moving this line 22 towards the origin. Okay? Page 56 1 So, basically, what you are doing 2 is, if you reduce, if you decrease the 3 nitrogen, if you decrease the reduced 4 nitrogen, then what that ends up doing is 5 giving you more ability to have additional 6 atmospheric oxidized nitrogen without really 7 compromising the system. It frees up 8 buffering capacity that could then be used to 9 uptake the oxidized forms of nitrogen. 10 If you are in a situation where 11 you have very little buffering capacity, then, 12 yes, the reduced forms of nitrogen are both 13 potentially going to directly reduce the 14 acidification as well as giving you more room 15 to work with your oxidized forms of nitrogen. 16 So, nitrogen is nitrogen in the 17 system the way that we are viewing it. So, it 18 is just a matter of how much is being utilized 19 in the system already before you think about 20 adding on the oxidized forms of nitrogen. 21 That is why we are treating it this way. 22 The way we are treating it is we Page 57 1 are basically saying that, the more reduced 2 nitrogen you have, it means the less ability 3 that you have to not reduce the oxidized forms 4 of nitrogen in a substantial way in order to 5 still meet your acidification targets. 6 So, again, it is not allowing for 7 direct control because, again, once we fix 8 these parameters in our model, once we fix the 9 ammonia, it is basically a fixed adjustment to 10 the buffering capacity that lasts until we 11 update the standards. Because you have to be 12 able to -- again, these are parts of the 13 standard. These are not things that are going 14 to be measured and then used to judge 15 compliance. They are parts of the standard, 16 as we currently have them envisioned. So, 17 they will be set as an amount. 18 Then, there's a number of comments 19 from the Committee already about, well, of 20 course, it is going to change over time. And, 21 yes, it is, but we need to factor in that 22 uncertainty or that potential variability over202-234-4433 Neal R. Gross & Co., Inc. Page 58

1 time.

2 CHAIRMAN RUSSELL: Praveen? 3 MEMBER AMAR: Yes, thank you. 4 Thanks, all of you. 5 A quick question of Rich also and 6 you. You mentioned a number of times area. 7 I think, Rich, you were saying, you know, 8 we've got to figure out what acid sensitivity 9 area is going to be. And it is much larger 10 than, I think you said, sensitive ecosystem

11 area. 12 So, how are we going to figure 13 that out? Because in that table later, where 14 you talk about calculating the velocities and 15 deposition, you simply say "area". What is 16 the thinking there? 17 DR. HUBBELL: Well, it is a 18 balancing process. As far as we are aware, 19 there's not a distinct, defined, scientific 20 area that we can just pick. 21 One way to think about it is that 22 the bigger your area, the more likely you are Page 59 1 to need to try, if you want to protect the 2 most sensitive water bodies within that area, 3 you are going to need to adjust your 4 percentile, for example, of protection that 5 you would need. If you are in a very small, 6 homogeneous area, you can stick the mean value 7 of the critical loads within that, and you are 8 probably going to be protective of the 9 sensitive areas within that. 10 So, there is going to be a bit of 11 a tradeoff between the size of the area and 12 the percent of protection that you will need 13 within that area, if you are trying to protect 14 the most sensitive water bodies. 15 DR. SCHEFFE: But I think, as a 16 first step, I think what we are talking about, 17 when we define, let's say, the boundaries of 18 an area, we are talking about an area that has 19 very, very similar characteristics with regard 20 to the types of watersheds in there, the 21 topography, the soils, the underlying geology,

22 and so forth. Page 60

1 DR. HUBBELL: And I will also 2 point out that one of the factors that may end 3 up coming into our discussions is the 4 homogeneity in the air quality coming in 5 because it needs to be much easier, obviously, 6 to monitor a location that covers a very 7 similar area than to have to try to cover an 8 area that has got a great deal of 9 heterogeneity in the deposition patterns, and 10 then you have to try to monitor lots of 11 internal locations within that and figure out 12 a way to characterize overall deposition and 13 air quality within that spatial area. 14 So, I think air quality 15 considerations will come in, factors that lead 16 to changes in the deposition rates related to 17 those concentrations. Then, as Rich said, 18 also, the underlying ecosystem characteristics 19 will also be important. 20 MEMBER AMAR: So, the area here 21 could extend to tens of miles?

22 DR. HUBBELL: Yes. Page 61

1 MEMBER AMAR: Or hundreds of 2 miles? 3 MEMBER WEATHERS: This is Kathleen

4 Weathers. 5 Maybe this is inferred, but are 6 you talking about, when you are talking about 7 air quality, about the grid cell size, 8 basically, over which CMAQ can predict 9 deposition? Because that seems to me also a 10 practical consideration. 11 CHAIRMAN RUSSELL: Kathleen, we 12 missed the first part of your question. So, 13 could you repeat your question?

14 MEMBER WEATHERS: Yes. I was 15 wondering, in talking about air concentration 16 and area, are you talking about the CMAQ model 17 and its ability to model deposition over a 18 certain area? So, wouldn't that be a 19 constraint as well, a practical constraint? 20 DR. HUBBELL: Well, certainly, we 21 couldn't have anything, it would be very 22 difficult to have anything less than 12202-234-4433 Neal R. Gross & Co., Inc. Page 62 1 kilometers because we don't have the ability 2 right now with CMAQ to model less than 12- 3 kilometer grids. So, we are thinking at this 4 point of areas covering multiple 12-kilometer 5 grids. 6 DR. SCHEFFE: But this does get 7 into the homogeneity of an area because a lot 8 of the deposition is going to be driven by a 9 lot of the micro-meteorological factors, all 10 of the vegetation, and the surface 11 characteristics. So, to the extent that there 12 is a greater degree of homogeneity, that would 13 lead into more consistent deposition modeling 14 in that area. 15 And just one other thing. Some of 16 our thoughts, you know, the area, like the V 17 terms and the nitrogen deposition, I mean we 18 are thinking of this in a geographical 19 context, that you literally would wrap a grid 20 around an area and estimate those parameters.. 21 We are also exploring the ideas of 22 binning in these categories, where we can get Page 63

1 at some of the intrinsic attributes of the 2 ecosystem, the weathering rates, for instance, 3 through looking at the different geological 4 areas, the underlying bedrock, and some of the 5 soil characteristics, perhaps elevation, as a 6 way of also simplifying, you know, bringing 7 together these areas where we might have the 8 same kinds of acid sensitivity categories in 9 different locations. 10 DR. HUBBELL: So, the only thing I 11 would add is, one of the things that you have 12 all asked about is, are you really settling on 13 geology or are there other characteristics 14 that are possibly important as well? Clearly,

15 there are. 16 I just wanted to emphasize that we 17 certainly understand, and certainly the 18 scientists on our group understand it more 19 than I do necessarily, but we understand the 20 complexities of the processes that lead to 21 both deposition and ecosystem response to that 22 deposition. Page 64 1 What we are trying to do is find a 2 balance between that complexity and the 3 ability to set a national standard in a way 4 that reflects both the scientific availability 5 of the data, which is somewhat limited, but 6 also makes good use of the other sources of 7 information, such as the model. So, it is a 8 delicate balance. That is what we are looking 9 for your guidance on, to help us form those 10 spatial areas.

11 CHAIRMAN RUSSELL: Paul? 12 MEMBER HANSON: If you could flip 13 back to slide 10, then I will make my point. 14 My point extends from the fact that we have 15 sort of jumped into Chapter 5 without 16 discussing Chapters 2, 3, and 4 before that. 17 I look at 83 percent of the 18 population protected, and the labeling on the 19 graphic is we are protecting lakes. Well, the 20 lakes aren't going to disappear. I would 21 encourage you in the document and in the 22 discussion to tell me -- I'm a terrestrial Page 65 1 person -- tell me what it is in the lakes that 2 we are talking about. Are we talking about 3 the diversity of fish populations, the 4 productivity of fish populations? Or are we 5 talking about algal populations? What is the 6 metric that is setting the levels? Of course, 7 I guess you have already alluded to the fact 8 that we are really not going to get into 9 levels today. 10 DR. HUBBELL: Yes. Well, we are 11 going to get into levels in the sense of the 12 information we have about effects occurring at 13 different levels. That is, obviously, 14 Chapters 2 through 4, dealing with those 15 specific issues. 16 In those chapters -- and again, we 17 chose to focus on these particular chapters, 18 but, as I said, that does not diminish the 19 importance of the other chapters at all. In 20 fact, one of the things I was saying that we 21 are going to try to do for the next round is, 22 you know, you have seen those diagrams that we202-234-4433 Neal R. Gross & Co., Inc. Page 66 1 like to refer to as the dose/response diagram, 2 which, basically, shows the response of fish 3 species, the number of fish species to the ANC 4 level, based on that sample population within 5 the Adirondacks and some information on the

6 Shenandoahs as well. 7 Basically, what we are saying is 8 that at 50 -- you know, that is one benchmark 9 -- there are certain effects that are 10 occurring on fish species in terms of the 11 fitness of the fish species and the decline in 12 certain species. At 20, different sets of 13 effects are occurring. And obviously, at 100, 14 what we are saying is, based on our evaluation 15 of the literature, at 100, you are not seeing 16 much response in terms of going above 100 17 doesn't seem to have much benefit for the 18 number of fish species and the diversity of 19 fish species. 20 So, that is, clearly, a choice 21 that will need to be made by the 22 Administrator, and informed by the science, as Page 67 1 to what level of ANC is protective enough of 2 the public welfare. That is the discussion we 3 want to have later because we don't feel like 4 we have got enough information yet to make

5 that call as to what we conclude are levels 6 that are reasonable to propose as a range. 7 So, right now, we are hoping to 8 get your response to the form that we are 9 putting out, the conceptual idea of using this 10 framework to get at those protection levels, 11 but the actual level that is selected and the 12 information that leads to that level, that is 13 something that we are still looking for input

14 on. 15 MEMBER HANSON: Then, I have one 16 other point, if you could flip to slide 22. 17 The point I want to make here is I am not sure 18 the term "G" is very helpful. G consolidates 19 the BC term and the NECO term. What I really 20 want to focus on is the complexity of NECO. I 21 think combining those two masks a tremendous 22 amount of difficulty that will be involved in Page 68 1 the process of defining what is the ability of 2 the ecosystem to take up nitrogen forms and 3 get it out of this equation. So, combining 4 the two seems to gloss over a really big 5 problem. 6 DR. SCHEFFE: Yes, and the 7 intention is not to gloss over the 8 difficulties in terms of trying to 9 characterize nitrogen uptake in systems. Your 10 point is right on. 11 But what this does, by separating 12 G from the other terms, it separates sort of 13 the other intrinsic properties of the 14 soil/water system from the atmospheric system. 15 That is what this does as first order. 16 And you are right, when you then 17 start drilling down into G's, and I think this 18 is where we want some advice in terms of how 19 should we be treating these subelements within 20 G. I couldn't agree more, but it is a good 21 observation. 22 CHAIRMAN RUSSELL: And before you Page 69 1 move away from this slide, in response to what 2 you said with Richard's question, AAPI is 3 going to be the standard, right? 4 DR. HUBBELL: That is the current 5 thinking, yes. 6 CHAIRMAN RUSSELL: So, actually, 7 if you reduce nitrogen load, decrease your 8 reduced nitrogen load, your standard doesn't 9 change. So, actually, that term can change 10 more dynamically, right? Or are you saying 11 that, when you set this standard, you are 12 going to set what the current reduced nitrogen 13 load is and just update that every once in a 14 while? What's the thought on how dynamic that

15 term would be? 16 DR. HUBBELL: Our current thinking 17 and understanding -- and again, this is 18 evolving as well -- but our current 19 understanding is that we will need to set the20 parameters of the equation. All the non21 atmospheric concentration parameters, those 22 things, not NOx and SOy, but all those202-234-4433 Neal R. Gross & Co., Inc. Page 70 1 parameters will be need to be set at the time 2 that we specify the standard. So, it will be 3 part of specifying the standard. 4 CHAIRMAN RUSSELL: At least to me,

5 that sort of reduces or decreases some of the 6 attractiveness of this approach because that 7 doesn't make it such that you could start, a 8 state agency could start doing that tradeoff 9 as a way of meeting this standard. 10 DR. HUBBELL: And again, I think 11 we certainly want to take that comment. 12 Again, we will continue our discussions as to

13 what we can and can't do under what we 14 consider the degrees of room we have under the 15 legal basis for the standards, as to what we 16 can and can't incorporate in a dynamic way. 17 That may be something that we can consider as 18 we move to the next draft of the Policy 19 Assessment, as to whether we can push forward 20 an idea that you can do this dynamically or 21 not, and see what the reaction is on that. 22 DR. SCHEFFE: Or maybe not totally Page 71 1 dynamically, but I think we need to have 2 probably some more precision in terms of the 3 timing sequence when we establish these 4 parameters, contrasting against the timing 5 sequence for judging attainment/not 6 attainment, for setting those areas. 7 DR. HUBBELL: Well, yes. I mean, 8 again, at what point does -- I mean my 9 understanding right now, and again, we have 10 one of our OGC folks here, and she might be 11 able to comment on this. But my understanding 12 now is that we need to fully specify what the 13 standard is when we sign the rule. So, we 14 need to lay out exactly how this standard is 15 going to be measured and how it is going to be 16 determined in terms of the way that we measure 17 NOx and SOy, et cetera. 18 So, my understanding is that we 19 will need to establish those parameters at 20 that time, so that we can tell each area 21 whether or not it is going to be able to be in 22 -- we can set a standard for every area at Page 72 1 that point. So, we will need to have a value 2 for that ammonia, reduced nitrogen term, at 3 that point when we set the standard. 4 The question of whether it can be 5 updated dynamically, I don't know that we have 6 fully explored that yet. That is something 7 that, obviously, we will need to do. 8 CHAIRMAN RUSSELL: Charlie? 9 MEMBER DRISCOLL: Yes, I had two 10 questions that were sort of in response to 11 both Paul and Ted's question. So, the first 12 with respect to Paul's question about the G 13 term, you also don't consider organic acids in 14 that, which will influence the background ANC. 15 Maybe I am biased by areas that are high in 16 wetlands, but that can be quite important in 17 terms of controlling the background ANC, 18 particularly in certain sites in the 19 Adirondacks. 20 There was a little bit of text 21 talking about organic acids, but, by and 22 large, there wasn't any consideration given to Page 73 1 that. So, that was my first question 2 concerning this G term. 3 So, is that something that -- 4 DR. HUBBELL: We will look into 5 that. Jason Lynch, who is our expert on these 6 issues, unfortunately, wasn't able to join us 7 because he was on holiday travel. So, we will 8 need to find out about it. 9 I know that the loadings of acids 10 are in the BC zero term, but I am not sure 11 whether organic acids are in there. 12 MEMBER DRISCOLL: Okay. The other 13 question, which I think was getting to what 14 Ted -- so, I understand what you are doing. 15 I understand you need this type of approach to 16 make this problem manageable across the whole 17 country. But you have a series of assumptions 18 that are inherent in application of this 19 equation, which is really a steady-state 20 equation. 21 We know that these systems are not 22 at steady-state, and some of the assumptions202-234-4433 Neal R. Gross & Co., Inc. Page 74 1 that you have in here, we know that they are 2 not correct. So, the question is the degree 3 to which they are correct. Can they be used 4 as sort of a first-order assumption? 5 So, I was wondering, in my mind, I 6 was thinking that it would be helpful to have 7 sort of a parallel effort along with this sort 8 of major approach to look at dynamic 9 relationships in parallel to really evaluate 10 the ability, you know, these assumptions and 11 to what extent, making these assumptions, are 12 these going to be show-stoppers that are going 13 to result in large errors or problems in terms 14 of applying this equation? 15 I didn't see anything in the text 16 about that type of sort of parallel effort. 17 Now maybe that is something that will be 18 happening in the future. Maybe you have 19 thought about it and rejected it. So, I was 20 just curious about, basically, having an 21 approach to try to test these inherent 22 assumptions. Page 75

1 DR. HUBBELL: Actually, I think 2 that is a really good idea. We recognized 3 going into this that we were making these very 4 first-order approximations. One of the 5 questions that we are hoping to get input on 6 is, we certainly know there's uncertainties, 7 there's assumptions, there's biases. There's 8 various different things built in. 9 One of the questions, obviously, 10 is, can we identify how those would be likely 11 to affect the ability of this type of a form 12 of a standard to provide protection? And can 13 we adjust the way that we think about that 14 form to be able to incorporate those 15 uncertainties, biases, assumptions, et cetera, 16 and make our protectiveness of the standard 17 robust to those uncertainties? 18 Clearly, the more that you can 19 give us in terms of ideas like this, it is 20 great to be able to try to think about. And 21 there's many others that have already been 22 provided in some of the initial written Page 76 1 comments. So, these are very helpful and very 2 specific.

3 DR. SCHEFFE: But we also see a 4 lot of value in the steady-state assumptions 5 here, too. Your question also kind of alludes 6 to a timing aspect, too, in terms of when a 7 system actually arrives at a place. 8 So, all we are actually going to 9 be able to do in this, that the atmosphere 10 will respond at a different rate than the 11 ecosystem will respond eventually because of 12 the steady-state assumptions that are involved 13 there. That is, in a sense, in terms of where 14 we have authority, we have authority on the 15 atmospheric side of things. 16 So, it almost becomes a little bit 17 of a philosophical question in terms of the 18 timing, in terms of when you actually reach 19 the benefits of all the assumptions that were 20 applied in formulating this model. 21 MEMBER DRISCOLL: Well, I 22 understand that, but I guess -- Page 77

1 MEMBER WEATHERS: Charlie, can you 2 speak up? 3 MEMBER DRISCOLL: Anyway, but one 4 of the concerns I had in this direction was 5 evaluating. There was a section in the report 6 evaluating the sensitivity of terrestrial 7 versus aquatic. I commented on this, that a 8 lot of your evaluations are really built into 9 the assumptions that you make. Indeed, most 10 of the available science suggests that soils11 are acidifying while surface waters are de12 acidifying or alkalining, you know, are 13 increasing in ANC. 14 With the steady-state assumption, 15 you build in an inherent bias in your analysis 16 of the sensitivity of terrestrial versus 17 aquatic systems. So, if you are going to make 18 broad generalizations based on these types of 19 assumptions, and they have huge implications 20 in terms of your analysis, I mean that is 21 where I have concerns. Particularly if you 22 are going to blow off terrestrial systems in202-234-4433 Neal R. Gross & Co., Inc. Page 78 1 favor of aquatic, or vice versa, I think you 2 need to understand those assumptions and the 3 subtleties associated with them. 4 DR. HUBBELL: And it would be 5 useful, I think, if you have ideas on other6 adjustments that can be made to the steady7 state model or to the outputs that are a 8 result of the steady-state model that can 9 better reflect these dynamics, especially the 10 relationship between terrestrial and aquatic, 11 or if you can at least point us in the right 12 direction, that would certainly be helpful. 13 And we are hoping not to blow off the 14 terrestrial. 15 MEMBER DRISCOLL: No, no, I was 16 just making a statement. 17 MEMBER JOHNSON: This is Dale 18 Johnson. May I say something here?

19 CHAIRMAN RUSSELL: Is that Dale?

20 MEMBER JOHNSON: I couldn't hear a 21 word Charlie said, except that -- 22 CHAIRMAN RUSSELL: Dale, is that Page 79 1 you? 2 MEMBER JOHNSON: -- he mentioned 3 steady-state -- hello. 4 CHAIRMAN RUSSELL: Dale, is that 5 you? 6 MEMBER JOHNSON: It's me, yes. 7 CHAIRMAN RUSSELL: Okay.

8 MEMBER JOHNSON: I wanted to make 9 a comment on the steady-state thing. I 10 couldn't hear a single word Charlie said 11 except for "steady state". That was one of my 12 big issues with it, too. I don't know what he 13 said, but I think he was probably questioning 14 it. 15 I certainly question in general 16 the use of steady-state models. I mean the 17 system has never been in steady-state. The 18 soils are never in steady-state. Maybe they 19 approach that as they get extremely weathered 20 in tropical forests or something like that. 21 Maybe they get to the endpoint. 22 But a steady-state model is just Page 80 1 really not, it doesn't mimic reality. There 2 are things that happen with sulfate 3 absorption, the absorption, cutting down -- a 4 forest has a hurricane and it blows down, and 5 then, all of a sudden, there's no uptake, and 6 the steady-state is out the window. 7 So, I don't know how far up the 8 wall this is from Charlie's conversation 9 because I couldn't hear it, but I think that 10 assumptions of steady-state are really pretty 11 seriously flawed.

12 MEMBER WEATHERS: I couldn't hear 13 Charlie, either, but I would be interested to 14 know whether there's a suggestion about how to 15 get around that issue.

16 MEMBER JOHNSON: I don't know how 17 to get around it. I think you just have to18 deal with the fact that it is not steady19 state. I mean it is just a fact of life. It 20 is a simple fact. It is like assuming the 21 earth is flat. It's not flat.

22 CHAIRMAN RUSSELL: Paul? Page 81

1 MEMBER HANSON: I just had a 2 moment of clarity listening that I didn't have 3 when I read through the document. The AAPI is 4 being proposed here as an indicator of a 5 standard. But this lefthand side of the 6 equation, the G term, is a characteristic of 7 the ecosystem, but it plays a big role in sort

8 of the end-result AAPI value. 9 In some cases, and the Adirondacks 10 as an example, the inherent characteristics of 11 that ecosystem or that region end up working 12 against that region in terms of attainment of 13 the standard. This seems like an unfortunate 14 inequity perhaps. 15 DR. HUBBELL: Well, yes, we had a 16 choice, and this is the road we have gone 17 down, but a choice of recognizing the inherent 18 differences between ecosystems in their 19 baseline vulnerability because of these 20 characteristics, or simply treating every 21 ecosystem exactly the same and saying we will 22 just pick a level and pick a value of NOx and202-234-4433 Neal R. Gross & Co., Inc. Page 82 1 SOy and just accept it. That is going to 2 overprotect in some areas and potentially 3 underprotect in others. 4 We have gone down this road 5 because we think it gives you that ability to 6 look at what is requisite but not beyond 7 requisite. But it does provide an equity in 8 terms of the level of protection you are going 9 to see, but perhaps an inequity in the 10 potential concentrations or contributions of 11 NOy and SOy to that system. That is the

12 tradeoff we faced. 13 MEMBER HANSON: I think that is 14 okay. I just think, when we get to the point 15 of, and it may not be relevant or appropriate 16 for the welfare standard anyway, but when we 17 start thinking about responsible people and 18 how one would go about achieving such a 19 standard, I don't see how we don't end up 20 pulling back and thinking of it as a totally 21 national standard and sort of throwing regions 22 out in terms of the mitigation aspects. Page 83

1 Because the root cause of what causes the 2 Adirondacks to be out of attainment is coming 3 from somewhere else for the most part. 4 DR. HUBBELL: Yes, and that is 5 part of the process, once you have a standard, 6 of figuring out how you are going to implement 7 it and designations, and so forth. They will 8 have to reflect those multitude of 9 contributions of other sources outside of that 10 region. 11 If I could just make one statement 12 about the dynamic models question, I think one 13 of the questions we will have to deal with, if 14 we go to the dynamic models, which Tara and I 15 were just talking, we think that is definitely 16 doable, to look at that parallel process. But 17 one of the questions is, if, for example, you 18 do have some dynamics in the model that 19 suggest that harvest of the timber is going to 20 affect the nitrogen uptake and change the 21 dynamics, we will have to decide, do we22 evaluate this system under potential worstPage 84 1 case or under the average case across that 2 dynamic system. That is just something 3 additional we will need to take into account. 4 Certainly, if you have ideas on that kind of 5 information, that will be helpful as well. 6 CHAIRMAN RUSSELL: Rich, one last 7 question. Sorry about that, Rudy. Then we 8 have to get to the public comment. Then we 9 have to get to the INC presentation. 10 MEMBER POIROT: I just wanted to 11 suggest a possible approach to complement that 12 would be that, over the last 30 years or so, 13 we have been doing this grand experiment. You 14 could actually be predicting your AAPI for 15 changes that have happened in the 16 concentration and deposition rates, and 17 compare it to your ANC and how well did you do 18 or would you have done using a steady-state 19 assumption for the experiment that we have 20 just completed.

21 DR. SCHEFFE: Sort of a 22 retrospective analysis of the last 30 years. Page 85 1 CHAIRMAN RUSSELL: So, at this 2 point, actually, 9:30, we are going to have 3 public comment. We only have one person. We 4 will give Pat five minutes, at which point we 5 will hear from the INC Committee. Then, if 6 EPA wants to stay up there, we will get back 7 and Rudy can ask his question before we go on 8 to Chapter 2. 9 So, Pat? 10 Or do you have to say something 11 official? 12 MS. BARRY: We have a microphone 13 here for you. 14 Please be mindful you have five 15 minutes. Thank you. 16 MS. BREWER: Hi. I'm Pat Brewer 17 from the National Park Service. I know many 18 of you all as I was the Technical Coordinator 19 for the Southern Appalachian Mountains 20 Initiative and then for VISTAS, the regional 21 planning organization in the Southeast. So, 22 some of our work has been cited in the Policy202-234-4433 Neal R. Gross & Co., Inc. Page 86

1 Assessment. 2 Our National Parks are treasured 3 natural resources and many of them are 4 sensitive to nitrogen and sulfur deposition. 5 That is why the Park Service is so interested 6 in EPA's progress on this standard. 7 We support EPA in developing a 8 secondary standard to protect the sensitive 9 resources and note that EPA has clearly 10 demonstrated that the current secondary 11 standards are not adequate to protect 12 sensitive resources. We commend EPA over the 13 significant progress that has been made since 14 the Risk Exposure Assessment in addressing 15 those relationships. 16 I think the key point today, and 17 it has already come up in your discussions, is 18 there is an art in trying to define the 19 relationships between concentration and 20 deposition in ecological systems. We 21 recognize these relationships are exceedingly 22 complex. Yet, at the same time, you have to Page 87 1 simplify them without oversimplying, in order 2 to come up with a standard that is relevant on 3 a regional basis, much less a national basis. 4 So, we support EPA's proposed 5 Acidification Potential Index for quality of 6 acidification. We have to point out that EPA 7 needs to make clear, as you forward it into 8 the public, that this standard would not be9 protective for systems that are nitrogen10 limited, like the alpine lakes in the Western 11 United States or the California Montane 12 ecosystems that, because of additional 13 nitrogen deposition, are seeing a change in 14 their fire ecology, in fire behavior. 15 So, it is important to make it 16 clear to the public that this standard is a 17 first step. We agree that the acid deposition 18 on aquatics is the way to start, but don't let 19 folks feel like this is going to be 20 sufficient, because it won't be. 21 We also encourage you all to look 22 at coastal estuaries. You noted that, Page 88 1 obviously, nitrogen deposition is not the only 2 source of nitrogen in these ecosystems, but it 3 still has to be addressed in order for these 4 ecosystems to recover. You all already 5 mentioned that is something that you are going 6 to be looking into for the future. 7 With respect to aquatic 8 acidification, we agree with acid-neutralizing 9 capacity ANC as the indicator. We would 10 encourage the EPA Administrator to pick the 11 high end of the sensitivity, the 100 ANC. 12 There is not time to go into the spatial and 13 temporal issues, but certainly episodic 14 acidification is a concern. When you set an 15 ANC level for an annual standard, that is 16 including that spring runoff where you may see 17 episodic effects, that your average value, it 18 could be much, much lower in the spring. So, 19 we would like to see you all consider that, as 20 you set that annual number. 21 I am very personally familiar with 22 the bedrock geology. The citation from Page 89

1 Sullivan was actually work that was done in 2 SAMI in regionalizing from the MAGIC results 3 to try to say what stream water chemistry, 4 what might be an indicator, where we didn't

5 have the data to do the MAGIC. We found that 6 the bedrock geology was a good predictor. 7 Obviously, EPA could try some sensitivity 8 analyses to see if the predictions are 9 improved if you would take into account other 10 factors such as forest type or watershed area 11 or soils. So, you all know that. 12 All along, and I think we have 13 come to it some today, but having additional 14 case study examples as you work through your 15 AAPI index to show that, if you targeted this 16 ANC and you were in this sensitivity class, 17 then these are the kinds of levels. I know we 18 have looked at those graphics, but being able 19 to put a little bit more emphasis on that, as 20 you all work on the next section, would be 21 really helpful. 22 With respect to the deposition202-234-4433 Neal R. Gross & Co., Inc. Page 90 1 side, we agree with NADP and using CMAQ. The 2 work that was done under VISTAS on CMAQ model 3 performance was cited -- 4 CHAIRMAN RUSSELL: One minute.

5 MS. BREWER: -- as some of the 6 evidence. 7 The last comment I would make is 8 with regard to reduced nitrogen, we have 9 encouraged EPA to use this process and, also, 10 you are going through a parallel process on 11 the NAAQS for fine particles. Reduced 12 nitrogen is important, and as you can 13 establish the need to be able to regulate, 14 even if it is not a criteria pollutant. 15 And to close, then, I would like 16 to encourage EPA to allow us to participate as 17 you discuss monitoring approaches and what 18 areas and what species are needed. 19 In summary, we do support the 20 scientifically-defensible approach for the 21 secondary standard. This has come a long way, 22 and having done work in the decade of the Page 91 1 eighties, it is a long time coming, but we are 2 really glad to see it. 3 Thank you. 4 CHAIRMAN RUSSELL: Thank you, Pat. 5 Are there any questions from the

6 Panel for Pat? 7 (No response.) 8 Okay. With that, do we have Otto 9 Doering or Russ Dickerson on the phone? And 10 do you have a plan for how you are going to 11 present this? And do you have any other 12 material? We have something from Russ. 13 So, Otto, are you on the phone? 14 DR. DOERING: Russ, are you on the 15 phone? 16 DR. DICKERSON: I am, indeed, 17 Otto. How are you? 18 DR. DOERING: Okay. Good. I 19 thought I would just start out with a little 20 bit of an introduction. Then, this is really 21 Russ' show in terms of your particular 22 interest with NOy versus NOx monitoring. Page 92

1 This comes out of the work of the 2 Integrated Nitrogen Committee. We are in our 3 third year. We hope fervently we are going to 4 get this wound up soon. 5 There's a broad range of 6 recommendations from this report, all the way7 of fairly applied things to dealing with non8 point nitrogen sources, to things with respect 9 to monitoring and others such as the ones that 10 Russ is talking about. 11 I think I should indicate that, 12 for all the recommendations and all the things 13 we have done, No. 1, the group that has been 14 involved in this is a fairly broad-ranging 15 group, all the way from an animal scientist to 16 a production agronomist, to me as an 17 economist, to people like Russ and Paul 18 Stacey from Connecticut. 19 As we have gone through this, each 20 of us who has not understood what is going on 21 in one of these areas has required that the 22 person involved technically has explained it Page 93 1 to us so we understand it. I think we can say 2 that, from what Russ is talking about, in 3 essence, the whole group really backs his 4 recommendation on this. 5 So, Russ, why don't you go ahead? 6 DR. DICKERSON: Thank you. 7 Good morning, everybody. 8 Since the Integrated Science 9 Assessment for Nox and SOy, the measurement 10 community has been pointing out that, for 11 ecological effects, NO2 was only part of the 12 problem, and often a small part of the total 13 oxidized nitrogen problem. But the monitors 14 don't even measure NO2 specifically right now. 15 So, everybody should have a piece 16 of paper in front of them with basically one 17 page describing the problem and an easy 18 solution to it. The monitors, as currently 19 configured, are fine for demonstrating 20 compliance with the NO2 standard, in that they 21 have positive interferences. But they really 22 measure neither NOx nor NOy. So, it would be202-234-4433 Neal R. Gross & Co., Inc. Page 94 1 substantially better for the scientific 2 community, for model evaluation, for 3 determining whether NOx emissions controls 4 have been effective or not, to convert 5 basically all of those NOx monitors into NOy 6 monitors. 7 That is really straightforward and 8 relatively inexpensive because the primary 9 difference between a commercial NOx monitor 10 and a commercial NOy monitor is the position 11 of the catalytic converter that changes higher 12 oxides of nitrogen back into NO nitric acid. 13 So, the current suite of monitors could be 14 reconfigured or new monitors could be 15 purchased for about the same price as a NOx 16 monitor. There's some small differences in 17 calibration and maintenance, but other than 18 that, it is a pretty straightforward fix. 19 Then, we would have a better 20 handle on what is actually being measured. 21 Right now, if a model and an observation NOx 22 disagree, we don't know if that is because Page 95 1 there's something wrong with the model or 2 because there are substantial interferences in

3 that NOx measurement. 4 So, for a while, it was thought 5 that, for polluted urban environments, NOx is 6 such a large fraction of the NOy, that NOy 7 measurements were not necessary. But recent 8 work in very polluted environments, Mexico 9 City and Houston, have demonstrated that this 10 is not the case. So, anywhere between half 11 and two-thirds of the NOy during the important 12 times of the day might be NOx, but there are 13 substantial other compounds of interest. 14 That is basically it, the problem 15 and an easy solution. So, what we are 16 recommending is a change in the monitoring. 17 There is another recommendation 18 that EPA begin to reconsider what the criteria 19 pollutant is. NO2 is still, of course, a 20 specific pollutant that needs to be monitored 21 and kept track of because of its health 22 effects, but the ecological effects are Page 96 1 certainly not limited to NO2. So, for a 2 secondary standard, a more appropriate 3 criteria pollutant would be total reactive 4 nitrogen, which would include the ammonia or 5 the sum of reduced reactive nitrogen and 6 oxidized reactive nitrogen. 7 So, at this point, I will be happy 8 to take questions. 9 CHAIRMAN RUSSELL: Thank you, Russ

10 and Otto. 11 Maybe it is too early to say, 12 since the report is not finalized, but what is 13 going to be your recommendation about having, 14 well, including reduced nitrogen as a criteria 15 pollutant? Is that going to be a 16 recommendation from your Committee?

17 DR. DICKERSON: I don't want to 18 speak for the entire Committee, but I think 19 the Committee will certainly point out that 20 reduced reactive nitrogen is equally important 21 in terms of the ecological effects. That is 22 the heart of our report. We don't have the Page 97 1 authority necessarily to say the current 2 criteria pollutant is wrong, but I think -- 3 Otto, correct me if I am wrong -- we will 4 certainly recommend that EPA reconsider the 5 criteria pollutants and think about making NOy 6 and NHx the species of interest, or at least 7 the indicator. 8 DR. DOERING: Yes, that is where 9 we are coming from at the moment, and I don't 10 see any change in that. 11 CHAIRMAN RUSSELL: Any other 12 questions for the INC folks? 13 MEMBER WEATHERS: Is there any 14 recommendation beyond measuring more chemical 15 species to measure in different areas, to 16 expand the monitoring network, not only for 17 the chemistry that is being measured, but, 18 also, spatially across the nation? 19 DR. DICKERSON: Yes, there is such 20 a recommendation, that the current especially 21 deposition network is inadequate in spatial 22 coverage and in the species that they measure.202-234-4433 Neal R. Gross & Co., Inc. Page 98

1 That is one of our recommendations. It is 2 probably not emphasized as much as conversion 3 from NOx to NOy because it will cost more, 4 but, absolutely, there are species that are 5 not being measured and places that are not 6 monitored. 7 I forget which recommendation it 8 is. I don't know if you have all the 9 recommendations in front of you, Otto, or not. 10 DR. DOERING: No, I don't. 11 DR. DICKERSON: But one of them is 12 enhanced monitoring. 13 CHAIRMAN RUSSELL: Rich? 14 MEMBER POIROT: Russ, it's Rich 15 Poirot. 16 DR. DICKERSON: Hi, Rich. 17 MEMBER POIROT: I was wondering 18 if, given that the NOy measurements would 19 definitely include some highly-reactive20 species with quick deposition velocities, so21 called, like nitric acid, what about the 22 height of the probe? Is that also a part of Page 99 1 the recommendation? That is to say, are there 2 reasons that we want to be higher above the 3 ground, for example, in measuring NOy than we 4 traditionally have been in trying to measure

5 NOx? 6 DR. DICKERSON: Well, that is a 7 good question. With a rapid deposition 8 velocity for nitric acid, something like 2 9 centimeters per second for unusually buoyant 10 conditions, it would be the gradient. I don't 11 think that gradient is such that it is 12 necessary to measure nitric acid at, say, 50

13 meters rather than 2 or 3 meters. There are 14 some papers that describe the gradient in 15 nitric acid from observations. 16 So, no, the short answer to your 17 question is, no, we did not consider or 18 recommend changing the height of the monitors, 19 but it is something we will take into 20 consideration. 21 MEMBER POIROT: I guess the other 22 question, if I could quickly follow up in a Page 100 1 different direction, is, are there possible 2 ways to improve upon our NO2 measurement 3 capabilities, since we are now in the process 4 of trying to deploy a whole new near-roadway 5 NO2 monitoring network with instruments that 6 apparently don't know whether they are 7 measuring NOx or NOy? 8 DR. DICKERSON: Yes, a great 9 question. Take a look at the second 10 paragraph, halfway down. It is a more 11 expensive fix, and I suppose they would have 12 to go through vetting from the EPA. But there 13 are at least two commercial devices now that 14 measure NO2 with specificity. 15 There's a photolytic converter 16 that you can buy from a little company that 17 Marty Buhr just started out in Colorado. They 18 use photo diodes that are specific to NO2. 19 So, that is one possibility. 20 The other is there is -- now I've 21 forgotten my own instrument -- a laser cavity 22 ringdown device that is specific to NO2 and Page 101 1 has adequate sensitivity and specificity. I 2 think we got Model 1, Serial No. 1, and we 3 demonstrated that it works, but it has to be 4 proved to be adequate for long-term monitoring 5 yet. 6 So, yes, those would be my 7 recommendations, that we move toward specific

8 measurements of NO2. Those are two 9 possibilities for doing it. There are other 10 techniques, like tunable diode lasers, and so 11 on, but they are substantially more expensive. 12 DR. DOERING: I think, generally, 13 in terms of what we tried to do in the 14 Integrated Nitrogen Committee report, we have 15 signaled a number of these areas. We have not 16 gone into tremendous depth in terms of how 17 they would be done. That relates to your 18 roadside monitoring, for example. 19 Basically, I think we felt that 20 this was a bit beyond us in terms of actually 21 recommending these kinds of things, but we 22 have raised them as what we think are202-234-4433 Neal R. Gross & Co., Inc. Page 102 1 important issues. 2 CHAIRMAN RUSSELL: Ellis? 3 MEMBER COWLING: Russ and Otto, 4 this is Ellis Cowling speaking. 5 I am very pleased to hear you 6 speaking about the importance of bearing in 7 mind the fact that it is the total reactive 8 nitrogen forms that we need to be concerned 9 about. I am thinking about this very fine 10 statement which is more thoroughly documented 11 than I remember in the earlier drafts of the 12 INC report that I have seen. 13 But I wonder if you will be 14 offering recommendations for improvement of 15 the methods by which to measure the 16 chemically-reduced forms of nitrogen, as you 17 have emphasized so nicely in this 18 recommendation to the Panel about the 19 chemically-oxidized forms of nitrogen. 20 DR. DICKERSON: The problem is it 21 is a long document. I think somewhere in 22 there we do make some recommendations. We Page 103 1 certainly can. And we can review the existing 2 techniques for measuring ammonia and ammonium. 3 I think, being a poor university 4 professor and always trying to put experiments 5 together on a shoestring budget, the cheapest 6 and most direct way is with filter packs. 7 They seem to be reliable for 12- or 24-hour

8 measurements. 9 So, while it may be beyond the 10 scope or beyond our charge to thoroughly 11 evaluate ammonia monitoring techniques, 12 especially because that is still a research 13 project, the filter packs are pretty reliable 14 certainly for the total of ammonia plus 15 ammonium, which is what we need. And there 16 are ways to separate out the vapor phase from 17 the particulate phase.18 So, the clever micro19 meteorologists could probably, without a huge 20 increase in effort and budget, begin to give 21 us estimates of dry deposition of ammonia the 22 way they do nitric acid right now, based on Page 104

1 fast met information and slow chemical 2 information. 3 So, Ellis, I can make sure that 4 NH3 and NHx monitoring is at least briefly 5 reviewed in this document. 6 MEMBER COWLING: Another thing, if 7 we are trying to decrease the amount of ANC 8 that we have in an aquatic or in a terrestrial 9 ecosystem, the manager has a choice, whether

10 to decrease the amount of reduced forms of 11 nitrogen or to reduce or to decrease the 12 amount of the oxidized forms of nitrogen. 13 It will be interesting, in this 14 continuing exploration of how the AAPI will be 15 implemented, to think about what the manager's 16 choice might be. Should I decrease the amount 17 of chemically-reduced forms of nitrogen or 18 should I decrease the amounts of the oxidized 19 forms of nitrogen, in order to control the ANC 20 in the manner that will be protective of the 21 maximum number of the different catchment 22 areas within my sensitive area? Page 105

1 DR. DICKERSON: Yes, that is a 2 great question. Otto, you can chime in on 3 this. 4 But the Committee decided early on 5 that one of our points is that a mole of 6 nitrogen, whether it is ammonia or NOx, is 7 pretty much equivalent in terms of its 8 ecosystem damage, its adverse effects on 9 ecosystems. So, we do not recommend one over 10 the other. We say that they are basically 11 equivalent. Probably for health effects, 12 there is some equivalency, too. But 13 determining whether or not NO2 or ammonia is 14 worse for your health is also beyond our 15 scope. 16 But the real problem is -- and I 17 don't think we have an answer to this -- what 18 if you are trading NOx for N2O? We don't 19 know. That is also beyond our scope, and that 20 one is not so clear. Is a mole of N2O the 21 same as a mole of NO2 in terms of its total 22 damage to the earth's health?202-234-4433 Neal R. Gross & Co., Inc. Page 106 1 DR. DOERING: Yes, this is one 2 basically that we just, frankly, have not 3 gotten that far. So, the question you raise 4 on this, Ellis, is still going to be a 5 question that is going to need to be raised

6 after we do what we do. 7 CHAIRMAN RUSSELL: Okay, thank 8 you, Otto and Russ. 9 Actually, I am not sure if you all 10 are planning to look at the Policy Assessment 11 document that OAQPS has put together on this 12 with ORD and OAR, but it would always be of 13 interest if you do look at it, and if INC had 14 any comments on the approach. 15 But, with that, I think I cut Rudy 16 off. So, I was going to let Rudy ask his last 17 question before we start approaching the 18 charge questions. 19 But, before I do, are there any 20 other just absolutely burning questions for

21 Otto and Russ? 22 (No response.) Page 107

1 Thanks again. 2 DR. DOERING: Good. I hope this 3 has been helpful to you. 4 CHAIRMAN RUSSELL: Oh, thank you 5 again. Yes, it has been, and we look forward 6 to getting your report, which I guess is a few 7 months away? 8 DR. DOERING: We hope. 9 CHAIRMAN RUSSELL: Okay. 10 DR. DOERING: And we are looking 11 forward to it as you are. 12 (Laughter.) 13 CHAIRMAN RUSSELL: Right. 14 Rudy? 15 MEMBER HUSAR: Yes, Rudy Husar. 16 I have a question regarding the 17 conceptual layout here, and hoping for 18 clarification as to whether or not do I

19 understand that. 20 Among the many issues, new 21 approaches here, you had to deal with the 22 multi-pollutant aspect of this standard. I Page 108

1 see that to be taken into consideration in a 2 couple of ways. 3 One was this tradeoff curve that 4 looks at the relationship between sulfur and 5 nitrogen, which has kinks and shapes and 6 procedures, on the one hand. 7 DR. DOERING: Yes. Excuse me, 8 please. Can I interrupt for a second? 9 Could you get closer to the phone? 10 It is breaking up, and we are having 11 difficulty hearing your question. 12 Russ, are you okay? Hello. 13 MS. BARRY: Actually, Otto, this 14 is Kyndall. 15 The question that Rudy is posing 16 is actually one for EPA. 17 DR. DOERING: Oh, okay. 18 MS. BARRY: Yes. But thank you -- 19 DR. DOERING: Okay. So, you're 20 finished with us? 21 MS. BARRY: We are, and we thank 22 you so much for your feedback and the update Page 109 1 on the Integrated Nitrogen Committee's report. 2 DR. DOERING: Okay. Bye-bye.

3 MS. BARRY: Thanks. 4 And before we continue on -- 5 MEMBER WEATHERS: It is still true 6 that we can't hear you, Rudy. 7 MS. BARRY: Okay. I was going to 8 actually make a request. I have gotten a few 9 emails. Please be mindful to use your 10 microphones when you are making comments, so 11 that our people that are on the phone can hear 12 you clearly. 13 MEMBER HUSAR: Okay. Is this any

14 better? 15 MEMBER WEATHERS: Yes, much. 16 MEMBER HUSAR: Okay. So, for the 17 first one, part of the question pertains to 18 the use of the tradeoff curve, which is 19 completely a non-linear relationship between 20 the two compounds that attempts to combine the 21 two, and, essentially, tries to devise a new 22 parameter that is some sort of a combination.202-234-4433 Neal R. Gross & Co., Inc. Page 110

1 On the other hand, we have the 2 equation here on this slide 22 which, then, 3 implies a linear summation of the two terms. 4 So, I am not quite sure how those two are5 being reconciled as dealing with the multi6 component, multi-pollutant aspect. 7 DR. HUBBELL: Well, in Chapter 6, 8 towards the end or I guess the middle of 9 Chapter 6, we talk about how the specific 10 equations for the tradeoff curves are derived, 11 starting with the conceptual equation. I 12 think it is actually in Chapter 5. 13 Basically, where the non-linearity 14 comes in, it is a linear equation with a 15 threshold, basically, and basically saying 16 that you've got this kink occurring where 17 you've got the NECO term. So, basically, it is 18 a linear equation relating NOx and SOy in 19 terms of producing a value AAPI once you have 20 passed that threshold. 21 So, if you actually look at the 22 set, it is a set of conditional functions. Page 111 1 So, this is expressed just as a linear term, 2 but there is actually a conditionality in 3 here. So, those tradeoff curves are 4 conditional. No. 1, they are conditional on 5 the ammonia level, but they are also 6 conditioned on that G, which actually has the 7 NECO term in it. This, actually, I think, is 8 getting at the point earlier that perhaps we 9 should just keep them separate and call one 10 piece of it the baseline weathering rate and 11 then deal with the NECO as a separate term. 12 Because that actually leads to a conditional 13 set of functions. 14 They are linear. They've just got 15 a conditional kink. So, it is a spline 16 function, basically, with a flat part on the 17 spline. 18 CHAIRMAN RUSSELL: Rudy, did you

19 have a second? 20 MEMBER HUSAR: No, I will come

21 back later. 22 CHAIRMAN RUSSELL: And it looked Page 112 1 like Rich also wanted to respond or no? No, 2 Rich? I thought you were grabbing the 3 microphone. No. 4 Okay. Thank you. 5 Then, with that, if you look at 6 the agenda, we are close to on time. So, we 7 are going to move into our discussions of the 8 various chapters and charge questions, 9 starting with Chapter 2. 10 What I thought we would do is in 11 each chapter there is multiple charge 12 questions, and if the lead can give just a 13 very brief sort of synopsis of the charge 14 questions and then lead the discussion, we 15 will go from there. 16 So, with Chapter 2, actually, I 17 guess, it is up there, so everyone can read 18 it, in which case I think there's no real 19 reason for him to repeat it. 20 So, Naresh, if you just want to go 21 into the response to the charge question and, 22 overall, if you've got comments beyond just Page 113 1 the charge questions on Chapter 2, this would 2 be an appropriate time to give those as well. 3 MEMBER KUMAR: Okay. Good 4 morning, everyone. 5 I will be brief on my comments 6 here because I think others on the Panel may 7 have more to say on this chapter than I do. 8 It is a long question, but I have a short 9 answer to this. 10 I think most of the members of the 11 Panel believe that EPA has done a good job of 12 summarizing the information in the ISA and 13 REA. So, both Question 1 and 2 kind of ask us 14 to comment on the summary that EPA has done, 15 information presently in the ISA for the 16 Question 1 and REA for the Question 2. 17 Having said that, I think there 18 were some comments that the clarity of the 19 information could be improved. That could 20 apply to the whole report, as I think a lot of 21 comments in terms of typos in general, but in 22 complete sentences. It became very hard202-234-4433 Neal R. Gross & Co., Inc. Page 114 1 reading for the whole report. So, you had a 2 lot of comments that you received. So, 3 hopefully, the next version will be much 4 better into the readability. 5 And also, one comment I have is 6 that a lot of the assessment in this chapter 7 is based on the ecosystem models. There's no 8 summary of kind of assumptions underlying 9 those models as well as the limitations of 10 those models. I think it would be very useful 11 to have that included as a summary in this 12 chapter because that will also help 13 understanding the results and the subsequent 14 chapters. 15 So, if you can move on to the 16 next -- are we going to ask the panelists for 17 all the questions or -- 18 CHAIRMAN RUSSELL: No, let's do, 19 you can respond to all three. 20 MEMBER KUMAR: Okay. So, the 21 third question talks about the uncertainties. 22 I thought that there is an inadequate job done Page 115 1 in addressing the uncertainties. The way EPA 2 staff has done it, they have provided some 3 confidence levels on the databases as well as 4 the models used. They come up with a ranking 5 on the confidence level, high, fairly high, 6 intermediate, or low intermediate. 7 It was not clear how they arrived 8 at those rankings. I saw some of the comments 9 from the panelists, and some of them did not 10 agree with EPA's rankings. So, I think it 11 would be very useful to articulate in the 12 document how you arrived at those rankings, so 13 that others can understand and then maybe can 14 comment on this later on. 15 That's all I have on this. 16 CHAIRMAN RUSSELL: Thank you,

17 Naresh. 18 Ellis? Speak into the microphone, 19 please, Ellis. 20 MEMBER COWLING: Oh, yes. Thank 21 you for your reminder, Ted. 22 I was especially pleased about two Page 116 1 things in Chapter 2. One was we now have 2 critical loads in U.S. EPA discussions, and 3 they are welcome. It's about time, and I'm 4 very delighted to see that you are really 5 embracing this idea, which has been so widely 6 accepted and so widely used, and used to 7 useful purpose in Europe, and now it is 8 finally being accepted as a principle, as it 9 perhaps always should have been recognized 10 that ecosystems are not the same as people in 11 terms of the desirable responsibilities for

12 the U.S. EPA. 13 The other thing I would like to 14 comment about is the wonderful illustrations 15 on pages 41 and 42 in Chapter 2. So, let me 16 ask, first of all, who created those? 17 DR. GREAVER: Those were initially 18 presented in the REA. And who created them? 19 I believe the EPA in collaboration with RTI

20 made those. 21 MEMBER COWLING: Well, 22 particularly page 42, and I guess I did not Page 117 1 remember. I said in my remarks that I had 2 never seen them. Well, I have reviewed the 3 ISA, but I sure missed it or maybe you printed 4 it in color and it was more impressive. 5 (Laughter.) 6 But what you have done on 7 especially page 42 is given a pictorial method 8 to understand what you mean by sensitivity to 9 acidification across our country in a way that 10 I congratulate you for having done. I urge 11 that you get it published in the open 12 literature. It is sufficiently informative 13 and valuable in terms of what you are seeking 14 to accomplish. 15 So, I would like to know the name 16 of whoever did put it together for the ISA and 17 offer some personal encouragement for them to 18 get this published in a suitable or maybe more 19 than a single journal, in fact. 20 DR. GREAVER: I would clarify that 21 they were originally presented in the REA. 22 Information was in the ISA, and then the202-234-4433 Neal R. Gross & Co., Inc. Page 118 1 figures were created for the REA. 2 DR. HUBBELL: But we will 3 certainly pass on that. 4 DR. GREAVER: Yes, absolutely. 5 MEMBER COWLING: Well, I was, as 6 you can tell, enthusiastic. 7 But I was also impressed that 17 8 of the 19 references that are given in the 9 figure on page 42 -- I've forgotten the figure 10 number; so, I'm referring to it by page number 11 -- are not in the list of references at the 12 end of the chapter. 13 DR. HUBBELL: And I'll let you 14 know now, we certainly recognize that actually 15 that happens a number of times throughout the 16 document. I think someone else noticed that 17 we were incomplete in our referencing in terms 18 of some things need references, et cetera. 19 That is certainly something we are going to 20 improve on. All these references were in the 21 REA, but they should be brought forward into 22 the Policy Assessment as well. Page 119

1 MEMBER COWLING: Yes. Okay. 2 Well, that's maybe a small point, but those 3 references certainly ought to be in this 4 published version of these two diagrams that 5 I hope to see in the open literature sometime

6 soon. 7 Those are the two major comments 8 that I have. If you have read what I said in 9 my initial comment, I believe it would be 10 desirable -- this is a Policy Assessment 11 document. You are choosing to be constrained 12 by the fact that you have only six criteria 13 pollutants and that the chemically-reduced 14 forms of nitrogen are not yet a part of the -- 15 but you have done a very clever thing: we 16 will take it as given, and then we can see how 17 much of a decrease in nitrogen oxide emissions 18 would be necessary to achieve a total reactive 19 nitrogen. 20 I would urge you to examine the 21 whole of this Policy Assessment document and 22 to use total reactive nitrogen repeatedly, Page 120 1 even though you do not intend to design a 2 standard which will be aimed at the management 3 of total reactive nitrogen. 4 Now you have chosen not to mention 5 the great difficulty you would face if you 6 tried to get a seventh criteria pollutant 7 established in the present history of the U.S. 8 EPA. It would be an unprecedented 9 achievement, I must say, and would be highly 10 desirable for exactly the same reasons that 11 you have decided to deal with ecological 12 effects separately from public health. 13 They are not the same. They 14 should not be managed in the same way. It 15 will take a different way of thinking to 16 manage and to undertake -- and you have heard 17 this from me before. This U.S. EPA is not the 18 Public Health Protection Agency of our nation. 19 It is the Environmental Protection Agency of 20 our nation, and it is splendid that in the 21 33rd year, I guess it is, of the history of 22 the U.S. EPA, ecosystems are now being given Page 121 1 the respect in terms of the responsibility of 2 the agency that I think was intended when the 3 Clean Air Act was passed. 4 So, I think what you are doing, 5 taking two pollutants at a time, separating 6 secondary standards from primary standards in 7 the review process, and embracing critical 8 loads, EPA is making marvelous progress in its 9 34th year -- 10 CHAIRMAN RUSSELL: Fortieth. 11 Actually, this is their 40th year. 12 MEMBER COWLING: Well, it depends 13 on whether you count the creation of EPA, I 14 guess, in '67 or 1970. Nevertheless, I make 15 the same statement. Keep on. 16 (Laughter.) 17 You're doing the right thing. I 18 think it is marvelous that you got the 19 extension of time. 20 What is his name? Ukali, the 21 communication with Ukali that I had the 22 opportunity to have personally was a very,202-234-4433 Neal R. Gross & Co., Inc. Page 122 1 very interesting encounter, I must say. I 2 don't know whether what I said to Ukali made 3 any difference in the ultimate decision, but 4 I am very pleased, in fact, that you've got 5 the time to do this right. 6 And I expect you will be even 7 stressed out with the two years that you have 8 to get this done. So, carry on, and I 9 congratulate you again for making this 10 progress in a very fine way. 11 And there's lots of refinements. 12 My first opening comment: take on and explain 13 why the chemically-reduced forms of nitrogen 14 and, as Charlie Driscoll says, the organic 15 forms of nitrogen -- if we are going to be 16 talking about total reactive nitrogen, and 17 Hans Paerl in this part of the world, and I 18 expect it is true, if you think about the 19 proximity to, say, the Adirondacks of the 20 intensive animal agriculture in the southern 21 part of Ontario, that it would be highly 22 desirable to be thinking more earnestly about Page 123 1 the organic forms of nitrogen. And at least 2 according to Hans Paerl's measurements in the 3 New River here in North Carolina, a third of 4 the total reactive nitrogen in precipitation 5 in North Carolina is in organic forms. 6 Yesterday I was participating in a 7 review of the ecological research program 8 being conducted at Camp Lejeune. One of the 9 interesting observations that was made by one 10 of the more well-informed aquatic and coastal 11 persons, Stan Riggs, was that we have 12 transformed eastern North Carolina from a 13 largely organic-based ecosystem to an 14 inorganic-based ecosystem. That is what has 15 happened as the result of the huge investment 16 that our country is making by consuming meats 17 produced in North Carolina. 18 I checked on this. We do not 19 always now produce more meat than any other 20 state in the United States, but we do almost 21 every year have some months in which we 22 produce more meat in this State than in any Page 124

1 other state of the United States. 2 So, these very substantial changes 3 that are taking place in our society, 4 including the development and concentration of 5 animal agriculture, is something that needs to 6 be regarded as a continuing challenge for the 7 U.S. EPA, and particularly from the standpoint 8 of ecosystem effects. 9 End of my remarks. 10 CHAIRMAN RUSSELL: Thank you, 11 Ellis. 12 So, let's see, Chris is not 13 available. So, let's open it up to the Panel. 14 Any further Panel comments, questions -- I see 15 Paul's hand -- on Chapter 2?

16 MEMBER HANSON: I won't belabor 17 these, but I wanted to emphasize a few things 18 that I have written up for you to consider. 19 My Chapter 2 comments reflect sort of my 20 enthusiasm as I started at the beginning of

21 the document and read to the back. I have 22 similar concerns for the whole document, but Page 125 1 this is where I happened to write them down. 2 The first one, that the wording 3 throughout the document tends to be lazy and 4 it forgets from time to time that it is 5 talking about sensitive ecosystems and uses 6 wording that suggests that the conclusions 7 that it is drawing apply to every ecosystem 8 everywhere, and that is clearly not the case. 9 So, look at my individual 10 suggestions and consider it throughout the 11 rest of the document, to emphasize often that 12 you are talking about a particular species or 13 a particular sensitivity of a system, not 14 ecosystems in general. 15 The other thing, which is a 16 semantic issue about wording, is that there is 17 a lot of wishy-washy language in Chapter 2 and 18 elsewhere. You talk about things might do 19 this; they maybe will happen, probably shows 20 up. And in one case in particular, you talk 21 about the EPA believes something. I don't 22 care what you believe. I would be interested202-234-4433 Neal R. Gross & Co., Inc. Page 126 1 in knowing what you can support with data. 2 And finally, or two more things, 3 in figure 2.9, which is one of the figures 4 that Ellis likes, and I like it as well, but 5 I think the caption and the details in it can 6 be improved. The caption for 2.9 talks about 7 observed and experimental effects, and then it 8 lists one through twenty examples that are 9 embedded within the map of the United States. 10 I think it is important for every 11 one of those examples to indicate which ones 12 are experimental and which ones are not, 13 because we don't want people looking at it to 14 presume that those are things that are 15 actively happening under ambient conditions, 16 if they are not. 17 And finally, in Section 2.3.1, 18 which was the discussion about the direct 19 phytotoxic effects of NOx and SOy, which I do 20 encourage you to keep and include, I just 21 thought I was surprised that at the very end 22 of it there wasn't a very succinct summary Page 127 1 statement that says that, for the most part, 2 these direct phytotoxic effects are not 3 happening under current NOx and SO2 exposures. 4 MEMBER JOHNSON: This is Dale

5 Johnson. 6 I want to strongly second Paul's 7 first two comments. I have the same, exact 8 impression, and want a strong second to that. 9 CHAIRMAN RUSSELL: Thank you. 10 Actually, while we have you, do you have any 11 other comments on Chapter 2? 12 MEMBER JOHNSON: No, just that as 13 a general for not just Chapter 2, but the 14 whole thing, finding modeled or actual effects 15 in most sensitive systems or two or three 16 species, or something like that, doesn't mean 17 everything. 18 A general comment is, what's the 19 purpose? Are we trying to get an overall 20 assessment across the country? And if so, it 21 is not doing that. Or are we aiming at trying 22 to protect really sensitive ecosystems? And Page 128 1 the implication throughout here is that this 2 is an overall catastrophe befalling us, and it 3 is based on assessment of the most sensitive 4 ecosystems. 5 CHAIRMAN RUSSELL: Thank you.

6 Praveen? 7 MEMBER AMAR: Yes, a quick 8 question. What Ellis was saying earlier, and 9 you mentioned that EPA is choosing to be 10 constrained with respect to ammonia. I had a 11 simple question. Primary standards, ozone, 12 criteria, VOC I guess not, but we do control 13 VOC to meet criteria pollutant. 14 Bring that concept here. You have 15 AAPI, which is going to be the new secondary 16 NAAQS kind of. Within that, ammonia could be 17 very much considered, just like SOy and NOx, 18 precursor to that AAPI. And therefore, maybe 19 you don't have constraints, if you are trying 20 to just address a precursor to something which 21 is a secondary standard. 22 DR. SCHEFFE: I think Ted was Page 129 1 alluding to that as well. It gets into the 2 timing issue that Bryan talked about, the time 3 of actually setting the standard in terms of 4 what parameters are set versus how those are 5 updated. That is something we are going to 6 have to look at pretty closely between now and 7 the final proposal. 8 MEMBER AMAR: I mean including 9 strategies to manage ammonia emissions or 10 control emissions. 11 DR. HUBBELL: Yes, I think that is 12 an interesting idea. I think I will want to 13 talk about that with our OGC, the legal folks, 14 as to whether or not you can consider 15 something that is in the equation a precursor 16 to the pollutant that you are trying to 17 regulate for the standard, whether AAPI is the 18 pollutant or whether AAPI is simply the 19 statistical way or the form that you are using 20 to express the relationship to the pollutant 21 that is of interest, which is the indicator 22 pollutant.202-234-4433 Neal R. Gross & Co., Inc. Page 130 1 So, I think we are going to have 2 to work that out with our discussion with our 3 legal folks, but certainly the role that that 4 term plays, that NHx deposition plays, is 5 clearly of great importance. We will be 6 trying to explore that more right now, as well 7 as in the next draft. 8 And certainly we welcome all ideas 9 about how we might think about it. 10 CHAIRMAN RUSSELL: Thank you. 11 Charlie?

12 MEMBER DRISCOLL: One comment I 13 had about this section specifically, but, 14 also, it is throughout the document, is that 15 I felt that the referencing was very uneven. 16 I have no experience with writing a policy 17 document. I write more technical documents 18 that tend to be fairly heavily referenced, but 19 I would run into sections that were fairly

20 well-documented and others that there were 21 very specific statements where there were no 22 references. So, I would urge you, whatever Page 131 1 you do, try to be more consistent to the

2 document. 3 CHAIRMAN RUSSELL: Other questions

4 from the Panel?

5 MEMBER WEATHERS: One other 6 specific comment from me, underscoring what 7 Dale and others have said, but with the 8 figures and with the data that are provided, 9 be careful about significant figures. For 10 example, the figure 2.9 shows significant 11 figures well beyond what I think the 12 confidence level is for the deposition. 13 DR. HUBBELL: Are you referring to 14 the map? 15 MEMBER WEATHERS: Yes. Yes, I'm 16 referring to the map and, then, references 17 throughout the document and just paying 18 attention to whether we are really talking 19 about five significant figures of -- 20 DR. HUBBELL: Oh, I see. In the 21 legend, yes, where we have that. Yes, we will 22 make sure we fix that. Page 132 1 MEMBER WEATHERS: Yes, in the 2 legends, in the figure legends, the legends in 3 the maps and the figure legends need to be 4 more extensive and clearer as well, spatial 5 scales, directions, a clear legend. 6 CHAIRMAN RUSSELL: Rich? 7 MEMBER POIROT: This is minor, but 8 it is maybe more of a general example of 9 something that happens elsewhere in the 10 document as well. I noticed on page 31 you 11 give an example of some importantly 12 recreational species that are absent from 13 Adirondacks lakes that acidified. On many 14 occasions throughout the document, you provide 15 a quick example just to illustrate a point. 16 Sometimes the examples maybe aren't the best. 17 In this case, for example, 18 Atlantic salmon likely would not be present in 19 most Adirondacks but for the stocking of them, 20 and the Kokanee salmon is a Pacific species 21 and, again, wouldn't be there if it weren't 22 put there, and alewives don't belong there Page 133 1 unless they are stocked illegally or 2 unintentionally. Then you've got the two 3 tiger species that are genetically-engineered 4 and can't even reproduce. 5 So, obviously, many of these are 6 not there. You don't know whether they are 7 not there because somebody didn't put them 8 there or we tried to put them there or we 9 decided not to put them there. It is just not 10 the best example, I guess. 11 Another one that struck me, I 12 don't notice that it is in this chapter, but 13 on several other occasions. You invoke the14 term sensitive species like brook trout, acid15 sensitive species like brook trout. Probably 16 not the best example. You could even just 17 change that and say, even acid-tolerant 18 species like brook trout. It's just a minor 19 thing. 20 CHAIRMAN RUSSELL: Rich? 21 DR. SCHEFFE: But at least it is a 22 native fish.202-234-4433 Neal R. Gross & Co., Inc. Page 134 1 (Laughter.) 2 CHAIRMAN RUSSELL: So, it is about

3 10:30. 4 DR. GREAVER: One question. 5 CHAIRMAN RUSSELL: Yes, I was 6 going to see -- well, first, I am going to ask 7 Naresh a question. As lead, and particular to 8 the third charge question, do you think you 9 got a response to that? Because that is 10 something that we don't appear to have really 11 addressed so much, but in terms of an adequate 12 response? Actually, this also goes to EPA in 13 terms of, do you think you have heard enough 14 on this one? 15 MEMBER KUMAR: No, I did not hear 16 from anybody else, and I had a comment on the 17 third, but not from anybody else on the Panel. 18 CHAIRMAN RUSSELL: So, definitely, 19 I would get together with your group and make 20 sure that you address this question because 21 this is one I don't think we have talked about

22 here so much. Page 135

1 Tara? 2 DR. GREAVER: My question is 3 regarding the use of the term total reactive 4 nitrogen. We struggle with this one a little 5 bit because that term would include the 6 oxidized, reduced, and organic forms. So 7 many, the majority of, in fact, most of our 8 ecosystem studies have only looked at reduced 9 and oxidized forms and their effects on 10 ecosystems. 11 So, I am wondering if a term such 12 as a total inorganic nitrogen would be 13 acceptable as a way to try to faithfully 14 capture what we see in most of our published

15 data and the ISA. 16 MEMBER COWLING: I feel like you 17 are asking me that question. 18 DR. GREAVER: I'm sorry. I'm 19 asking the whole Panel. 20 (Laughter.) 21 I know you have strong opinions 22 about this, though. Page 136

1 MEMBER COWLING: I think that the 2 precision with which you approach these 3 problems, EPA has regarded oxidized forms of 4 nitrogen as their responsibility. Now it is 5 coming to be realized that chemically-reduced 6 forms of nitrogen -- and you heard this from 7 me before. Reduced is used so many ways with 8 so many meanings. I was interested that even 9 those within EPA find it useful to use the 10 word "decreased", which is not an ambiguous

11 term. 12 So, I seize the opportunity to 13 call attention, if you mean inorganic, but you14 use nitrogen or you use reduced, chemically15 reduced forms of nitrogen or chemically16 oxidized forms of nitrogen, the more precise 17 -- now, of course, it encumbers the language 18 with additional descriptive adjectives and 19 that sort of thing. But if you want to 20 communicate and reason carefully, and 21 understand that it is only inorganic forms 22 that you are really thinking about, and you Page 137 1 prefer not to -- then you must explain, it 2 seems to me, why you are content, when the 3 ecosystems don't care whether organic or4 inorganic, or they will respond to chemically5 reduced or to chemically-oxidized forms in 6 essentially the same way. 7 But I would encourage you to be as 8 precise as you can be without encumbering the 9 sentence structure with too many descriptive 10 adjectives that are not essential to the 11 meaning, and to avoid ambiguous terms that are 12 used for many different purposes and result in 13 confusion, particularly among the public 14 documents or the student who is looking at a 15 Policy Assessment document that is a guide for 16 what he might want to do with the rest of his 17 life. 18 CHAIRMAN RUSSELL: So, Tara, did 19 that answer your question?

20 DR. GREAVER: Yes. How I would 21 proceed is to define total reactive nitrogen, 22 and then indicate specifically where we mean202-234-4433 Neal R. Gross & Co., Inc. Page 138 1 total inorganic nitrogen. 2 CHAIRMAN RUSSELL: You would say 3 that specifically?

4 DR. GREAVER: Yes. 5 CHAIRMAN RUSSELL: Right. I mean 6 that would be my thought, is that reactive 7 nitrogen, total reactive nitrogen could 8 include organic forms.

9 DR. GREAVER: Yes. 10 CHAIRMAN RUSSELL: So, when you 11 are specific to not addressing organic forms, 12 you would say total inorganic reactive 13 nitrogen. 14 Rich? 15 DR. SCHEFFE: Yes, I think, 16 especially when we talk about organic forms of 17 nitrogen, I think probably in the next draft 18 we have to provide a little bit more 19 explanation at least where we see a lot of the 20 uncertainties in this area. 21 I mean, right now, in the NADP 22 network, for instance, there's some talk about Page 139 1 reporting forms of organic nitrogen or 2 actually a total organic nitrogen in those 3 measurements. Now, from a measurement 4 perspective and even a modeling perspective, 5 organic nitrogen is actually a significant 6 component. I mean we do measure -- I mean we 7 don't measure it directly, but peroxyacetyl 8 nitrate is a major component of NOy that comes 9 across in the reduction chemiluminescence 10 techniques. 11 So, you know, there is a mixed 12 treatment here. I think we probably have a 13 responsibility of clarifying that quite a bit

14 as we move on. 15 MEMBER COWLING: Incidentally, the 16 total reactive nitrogen is defined in the INC 17 report as radiatively-reactive nitrogen, 18 biologically-reactive nitrogen, and -- oh, my 19 heavens, what's the third one? -- 20 photochemically-reactive nitrogen. Well, you 21 have a glossary, and ensuring that the 22 glossary is appropriate to the uses that are Page 140 1 made of the language is important. 2 CHAIRMAN RUSSELL: Rich, one last 3 thing. Then, we will get a break.

4 DR. SCHEFFE: Yes. Just to be 5 clear, though, I think, in concept, and 6 perhaps not mathematically, but in concept, we 7 are considering all total reactive nitrogen in 8 these processes in concept. 9 MEMBER COWLING: And it's very 10 fine that you are doing that. I think all of 11 us feel that we are pleased that you are 12 embracing all the different forms of nitrogen 13 and recognize that they have all these 14 different kinds of reactivities. 15 CHAIRMAN RUSSELL: Okay. Thank 16 you all. 17 With that, we are scheduled to 18 have a break until 10:45. We are starting 19 about 10 minutes late. So, let's make it

20 10:50 to be back. 21 (Whereupon, the foregoing matter

22 went off the record at 10:40 a.m. and went Page 141

1 back on the record at 10:53 a.m.) 2 CHAIRMAN RUSSELL: Laura, you are 3 up. 4 MEMBER CHESTNUT: There's so many 5 questions in there. 6 This chapter kind of feels a 7 little like an aside, when I actually think it 8 is really central to what has to be decided 9 here. So, I will just launch in. 10 I think that the ecosystem 11 services descriptions in here is well-done. 12 It is concise. It explains the connections. 13 But in the broader sense, what is missing is 14 in many places, so what specifically is the 15 injury, the loss from the deposition that is 16 currently happening? 17 I think the chapter does a pretty 18 good job of that with the aquatic acid 19 deposition, but, even there, I think -- and I 20 will get to some of the specifics. 21 I mean, the significance here is 22 that you can go through all the chemistry, all202-234-4433 Neal R. Gross & Co., Inc. Page 142 1 the biology. Unless you can say why this 2 matters, then how do you make the policy 3 decisions? 4 So, that connection needs to be 5 made, and it is not in dollars and cents. It 6 needs to be made in description that is broad, 7 that is comprehensive, because you can't do it 8 in the dollars and cents because we don't have 9 the methods to do that with the ecosystem 10 services. 11 Let me go to some specific things. 12 Starting early on, I really like all this 13 language taken from other agencies and 14 statutes and management documents that 15 describes all these different resources that 16 we are managing to protect the integrity of 17 the ecosystems in various different wordings. 18 Then, there's some nice maps and 19 things, but there's a little, I think, too 20 much focus on the federal Class I, when people 21 care about all the natural areas, their state 22 parks, their local parks. It is too limited. Page 143 1 So, when we look at these maps that are on -- 2 again, I don't know the page number. I wrote 3 it down. I guess it is 3-4 and 3-5. 4 I mean I like the idea, but there 5 are state and national forests. There are a 6 lot of areas where these things matter, 7 including, I think, aren't the Adirondacks a 8 State park? That's not a national park. 9 So, I just, again, take the big 10 picture here. 11 DR. HUBBELL: We noticed after we 12 put together the maps that we had left out a 13 lot of areas. We are trying, actually, now to 14 get all the shape files put together so we can 15 do those overlays. We appreciate that that is 16 going to give us a better picture. 17 MEMBER CHESTNUT: Yes, and there's 18 a whole lot of different management 19 jurisdictions, but, again, it like squeezes it 20 if you just limit it to one. 21 Then, when we get to the economic 22 valuation, I have a lot of specifics on what Page 144 1 was brought into here from the appendix from 2 the REA. But, in general, I think, again, it 3 is too much on what we can put a number on and 4 not enough on the big picture of why this 5 matters. Whether or not we can put a dollar 6 number on it, these things matter. But it has 7 to focus on the change, the increment, the 8 specific loss that is connected to the 9 deposition. 10 So, we get that with the aquatics, 11 where we have so many lakes in this area that 12 cannot support several species of fish that 13 would have been there or should be there in 14 its natural state. That begins to give the 15 sense of this magnitude. 16 Yes, you can go ahead and talk 17 about the loss in recreation value, but that 18 is not the only reason. There's all the other 19 reasons why people care about having natural 20 areas that can support the species that are 21 supposed to be there. And it is in services, 22 but, anyway, I am belaboring it. Page 145

1 But I think, for that reason, that 2 specifically the RFF study that asked the 3 population in New York about -- specifically 4 describe acid deposition and it needs to be 5 mentioned more, and not just the recreational 6 fishing. I know we like the fishing numbers 7 better. We feel more confident about them. 8 But the other study is really important. 9 There's a lot of people who don't fish that 10 care about the protection of the ecosystems. 11 Even if you don't want to stress the numbers 12 too much, I think that evidence, in and of 13 itself, is really important to be brought

14 forward here. 15 When the numbers are talked about, 16 there needs to be a little more information 17 brought forward. There is a range mentioned 18 of 4 million to 300 million for the 19 recreational fishing. I think that is mixing 20 together, when I looked back at the appendix, 21 it is mixing together some annualized numbers 22 and some present-value numbers, which are202-234-4433 Neal R. Gross & Co., Inc. Page 146 1 really different measures. That needs to be

2 clear. 3 All of these are just New York 4 residents. That needs to be stressed. 5 Whenever these numbers are put out, their 6 limitations and what they are measuring needs 7 to be clear. Then, the story, you know, what 8 it is telling us, why it is important, and 9 what it is missing. 10 So, let me see. I have a couple, 11 maybe they are quibbles, but I think they are 12 important in terms of economic valuation. 13 There's one place where it says -- I guess 14 page 76 -- that the valuation doesn't 15 necessarily tell us if there's an adverse 16 effect, which is true. It is that there could 17 be a really small thing. It is, you know, a 18 penny or it is a dollar. It is not really to

19 the level of adverse. 20 But a substantial value, I 21 think it doesn't tell us a threshold. It 22 doesn't say, okay, if it is $1.50, then it is Page 147 1 adverse, and if it $1.00, it's not. We are 2 not going to get that from it. But I think we 3 certainly know it when we see it, you know, 4 when it is big enough, that this is something 5 we care about. So, it kind of undercuts the 6 usefulness of the valuation. I think the main 7 problem is that there's an awful lot of pieces 8 that we don't have the tools to put a dollar

9 value on. 10 Then, there is another comment 11 about preferences that I think shouldn't be 12 there. The people's preferences are only, I 13 think, not just I think, but I think the 14 economics field would say, though I don't know 15 if I can speak for everybody. But if people 16 don't know what the implications are of 17 something, I don't think that their 18 preferences are a valid basis for 19 policymaking. 20 I mean underlying welfare 21 economics is the presumption that people have 22 the information they need to make the choices Page 148 1 that reveal their preferences. If they don't 2 have the information, if they don't know what 3 the implications are, then the whole thing

4 crumbles.5 So, for example, in a state-of6 preference study, it is really crucial how it 7 is explained to people what it is they are 8 valuing. If you are looking at their 9 behavioral choices, it is implicit that they 10 know what they are choosing between. 11 So, the assumption that public 12 preferences are paramount is only valid when 13 they are informed. They are only going to 14 lead to efficient allocation of resources when 15 they are based on information or informed 16 choices, which is why, again, the policy 17 report has to explain why this matters because 18 just the chemistry is not going to get it

19 across. 20 So, this comes up particularly 21 with the terrestrial effects here. Here's

22 where there's some numbers of the total value Page 149 1 of hiking or fishing or recreation activities 2 that really are not informative about what's 3 the impact from the kind of deposition that we 4 have now. So, are there dead trees? What's 5 the impact on the forest health? People care 6 about the habitat, integrity. It is making it

7 more vulnerable to other -- what's the harm 8 that is happening now and how widespread is 9 it? It is not articulated here. 10 I am a little fuzzy about the 11 dollar numbers that are there that look pretty 12 small. I think they are for commercial 13 harvest of the red spruce and the sugar maple.

14 I know Paul had some comment on that whole 15 thing which I think makes a lot of sense. I 16 will let him go on with those. 17 I guess that is the end of my 18 comments on Question 4. So, should we do it 19 question-by-question or go through the whole 20 chapter? 21 CHAIRMAN RUSSELL: Oh, go through 22 the whole chapter in one shot.202-234-4433 Neal R. Gross & Co., Inc. Page 150 1 MEMBER CHESTNUT: Okay. Question 2 4 kind of covers the whole chapter. I think 3 Question 5 is just about the presentation of 4 ecosystem services. It is just the same thing 5 again. I think the explanation of the basic 6 concepts is well-done. It is relating it to 7 the specific effects of NOx and SOy 8 deposition. 9 Then, in terms of the critical 10 uncertainties, it is clear, as you go through 11 the whole document, a really crucial decision 12 that has to be made here is, what level of ANC 13 is sufficiently protective to -- I forget the 14 exact words, but for protection of public

15 welfare. 16 Can this analysis of the economic 17 valuation, the services, shed any light on the 18 range of 50 to 100 in the ANC? It looks to me 19 like in some of the valuation studies there's 20 a significant benefit of going from 50 to 100. 21 So, that needs to be addressed somehow of, 22 well, what is the additional gain? Page 151

1 Maybe there's practical 2 limitations, that it is not possible to get 3 there, but that needs to be differentiated 4 from, is there a benefit? I mean, when I look 5 at that curve relating fish species and ANC 6 levels, it looks like there is a steady 7 dropoff in the number of species that can 8 survive as you go down. So, the document 9 seems to be kind of leaning toward, well, 50 10 may be good enough, but I don't see the case 11 made for that, or how we would differentiate

12 where. 13 And it is the same thing with the 14 percentage. That was really kind of startling 15 to think about, oh, yes, well, we are probably 16 not going to be able to get to 100 percent. 17 So, what percentage would you choose? I have 18 no idea. What percent is good enough? I 19 think those are really crucial uncertainties 20 that are here in this section. 21 CHAIRMAN RUSSELL: Thank you.

22 Praveen? Page 152

1 MEMBER AMAR: Yes, a few extra 2 comments in addition to Lauraine. 3 I was the second reader for this. 4 I am glad this chapter is here in this Policy

5 Assessment. 6 My main comment, I think, the 7 first one with respect to public adversity, 8 the type, intensity, and scale. I think the 9 chapter doesn't do a good job of scale in

10 terms of numbers. 11 I wrote a comment here. I said, 12 "Purpose of numbers is really not numbers at 13 all, but insight." 14 There are quite a bit of numbers. 15 I went through the chapter, you know, how much 16 damage here, how it was calculated, and the 17 range goes all the way from a very small 18 number like $690,000 with respect, I guess, to 19 the market value of red spruce, all the way up 20 to $12 billion with a "b" for what 21 Californians think the value of trail hiking 22 is. It looks like four orders of magnitude Page 153 1 difference. I don't think that is right. At 2 least I don't get it. And if it is, you know, 3 maybe that is what it is. 4 But what will help here, I think,

5 because there are a lot of numbers all over 6 the chapter, maybe put them in one place, a 7 table or a figure. Even though the method of 8 calculation is different, the geography is 9 different, but to say here is what is in the 10 literature for various monetized value of 11 these benefits. 12 So, that was one comment, just 13 because numbers are here, but without kind of 14 holding people's hands, especially policy 15 people's hands. Believe me, we are not very 16 numerate in policy. So, you have got to tell 17 us what that means. That is No. 1. 18 Then, finally, the comment on 19 uncertainty, which was the last question here, 20 I think I would like to commend EPA on not 21 only here, but all the other parts. I think 22 the right question about uncertainty is not202-234-4433 Neal R. Gross & Co., Inc. Page 154 1 the uncertainties are there. I mean, what 2 else is new? But the issue is, what's the 3 effect of those uncertainties? What are they 4 with respect to ecological systems, services?

5 What's the effect of that and what we are 6 trying to do, which is to establish secondary

7 standards? 8 So, it is a function, and it is 9 uncertainty as a driver to what we are making 10 decisions on and how much does it matter. 11 That is the right way to pass, instead of just 12 uncertainties by themselves. I think that is 13 a good point. I don't think we have answered 14 it here or even other places. 15 But one suggestion here I had, not 16 only for this chapter, because I know Ted had 17 mentioned earlier, maybe have one place in the 18 second draft, a chapter of uncertainties, all 19 on a relative basis with respect to CMAQ and 20 ecosystem models. So, kind of put it in one 21 place. Say here is your primer on uncertainty 22 for all the components, in one place, not in Page 155 1 various chapters. Maybe it is in the 2 appendix. I don't know. But it could be 3 helpful. 4 Then, people will read it at one 5 time. You know, we keep on talking about 6 uncertainty all the time, but how do you kind 7 of explain that to people? 8 And one minor comment. I know the 9 word, but I don't think a lot of people would. 10 "Consumer surplus," I mean it is mentioned, 11 the word. I think we have got to have a 12 little explanation of what that means. 13 That's it. 14 CHAIRMAN RUSSELL: Thank you.

15 Paul? 16 MEMBER HANSON: When we get to 17 aquatic stuff, I won't have anything to say. 18 (Laughter.) 19 Well, actually, I do want to say I 20 think this is just a really important chapter. 21 This is your sales pitch. This is the whole 22 reason we are sitting around the table today, Page 156 1 is because out there there's a perception 2 there's an adverse effect from these things. 3 So, getting this presentation of Chapter 3 4 correct is really important. 5 Having said that, I do have a few 6 critiques. I don't see anything in here 7 addressing natural rates of change versus 8 anthropogenically-induced change. Clearly, a 9 lot of the arguments are about with deposition 10 or acidification something will change. 11 There's nothing here to help the reader or the 12 public to distinguish what's good or bad in

13 that context or adverse. 14 On page 68, lines 23 to 29, 15 there's a really, I think, a critical 16 statement about critical loads. Well, I won't 17 read it out here, but it basically indicates 18 that the critical load has embedded in it a 19 definition of what adverse is. So, some 20 researcher, group of researchers, has used an 21 adversity definition to define a critical 22 load. Yet, here you are using the critical Page 157 1 load as the basis for defining adversity. It 2 represents an interesting circular argument, 3 and perhaps you should discuss that in some 4 what more depth or give us a reaction to that. 5 I don't have an answer myself. 6 Biodiversity change, certainly 7 relevant and of interest to many people. 8 Think about whether there is a policy-relevant 9 background to that. It comes back to the 10 rate-of-change issue, I think. You know, what 11 kind of changes are happening anyway versus 12 what could be attributed to, in particular in 13 this case, acidification or nutrient 14 enrichment? 15 I guess we have had two emphases 16 on the citation for the dollar amount of 17 adverse costs associated with the spruce 18 forest industry. At $690,000 a year, that is 19 just not a strong argument. I would probably 20 take that out. It is not even a strong 21 argument for doing research on the topic. I 22 mean we are talking about multiple202-234-4433 Neal R. Gross & Co., Inc. Page 158 1 million/billion dollar solutions to an air 2 pollution issue, and we shouldn't justify that 3 based on an annual loss of $690,000. The 4 government should simply figure out who has 5 been affected by that and reimburse them for 6 their loss perhaps. I am getting off-track. 7 Then, on page 88, there's general 8 discussion about fractional effects of NNS 9 deposition on recreational use, I believe is 10 what it was referring to. I guess I would 11 like you to try to figure out what the 12 fraction is. Sort of the interpretation of 13 the wording is that deposition is eliminating 14 all recreational use and that is how you are 15 trying to quantify what people should be 16 concerned about. Certainly, that is not the

17 case. 18 I believe that text was referring 19 to possible loss of some species within a 20 southern California ecosystem. Granted, that 21 would not be a good thing. On the other hand, 22 I doubt that that will keep people from using Page 159 1 the ecosystem altogether. So, you have got to 2 figure out what fraction of reduction in 3 recreational value that would imply.

4 That's all. 5 MEMBER CHESTNUT: Could I just 6 follow up on one thing? 7 CHAIRMAN RUSSELL: Lauraine, then 8 Myron. 9 MEMBER CHESTNUT: I really liked 10 that paragraph on critical loads. It finally 11 kind of clarified a confusion. I think that 12 this document kind of gives it the right -- I 13 don't know if it is the way the science 14 community has used the term, but a critical 15 load here, the way I understand you are 16 explaining it, is the amount of deposition

17 that could be tolerated before some effect 18 happens. But it doesn't necessarily tell us 19 whether that effect is adverse or not, which 20 is a policy judgment. 21 So, depending on the effects that 22 you want to protect against, then there comes Page 160 1 out of that your critical load to prevent that 2 effect, or whatever your threshold thing is.

3 DR. HUBBELL: If I could comment 4 on this for a minute, because within our own 5 community we have been very careful about 6 trying to clarify what we mean by critical 7 load. Because there is a lot of looseness 8 around the term that actually comes out in the 9 policy community. If we look in Europe and 10 they talk about critical loads, they are not 11 all meaning critical loads to protect the same 12 thing. They choose a critical limit, which is 13 usually the level of the ecological indicator 14 that they are trying to preserve. 15 So, when you are talking about a 16 critical load, it should go along with it, 17 critical load to protect for an ANC of 50 or 18 an ANC of 20, or a base-cation-to-aluminum 19 ratio of 10, or whatever you are going to do. 20 So, we have tried to be very 21 careful. In Tara's presentation, you see we 22 say critical loads for an ANC 50 to protect Page 161 1 the population of 95 percent of the 2 catchments. So, we are trying to be very 3 careful to tie the critical load to the effect 4 that you are trying to prevent. 5 I think we are very much in 6 agreement with you that it is an incredibly 7 critical statement to say that it is a policy 8 judgment as to what that critical limit is. 9 That is why what we are really saying, when we 10 talk about picking an AAPI, we are hoping it 11 is informed by both the target ANC and, also, 12 in this case by the percent of catchments you 13 are trying to protect, and by the critical 14 uncertainties and limitations in the other 15 elements of the equation. 16 So, we are trying to reflect that 17 by saying that you are driving towards some 18 target limit that represents an ecological 19 indicator, rather than just saying it is a 20 critical load, as if that has no policy 21 implication. So, we are 100 percent in 22 agreement with you on that. We are trying to202-234-4433 Neal R. Gross & Co., Inc. Page 162 1 follow that through into our policy 2 application, but driving it back to how you 3 define what adversity is. 4 That is a really, obviously, as 5 you pointed out, it is a very tricky thing to 6 do. We are really still struggling with that. 7 So, obviously, any references and things can 8 be very helpful there. 9 CHAIRMAN RUSSELL: Myron? 10 MEMBER MITCHELL: I just want to 11 almost echo what Paul said of the importance 12 of this particular chapter with respect to 13 ecosystem services. It is really an excellent 14 opportunity for EPA to educate the public of 15 the role of ecosystem services. And if we can 16 show all these SOy and NOx regulations can 17 enhance ecosystem services, that is really 18 going to -- not only for this particular 19 aspect, but for all kinds of other things 20 going on in the environment. 21 I have one concern associated with 22 this chapter related to the declination within Page 163 1 the chapter of looking at positive effects. 2 By saying you are not going to look at 3 positive effects, in addition, my concern is 4 it is going to be looked at as being a very 5 biased analysis. You are only looking at the 6 bad side and not the good side. 7 So, I think some addressing of the 8 positive elements, and maybe how they are -- 9 that the deleterious impacts are much greater 10 than the positive impacts, but by saying you 11 are not going to do it I think leaves an 12 opening that this document could be criticized 13 as only looking at the bad aspects. 14 DR. HUBBELL: And maybe Lydia can 15 help me phrase this as well, but the focus and 16 the scope of this has been on looking at the 17 effects that are adverse to public welfare. 18 That is the statute's language. 19 MEMBER MITCHELL: Right. 20 DR. HUBBELL: So, looking at the 21 effects of NOx and SOy depositions that are 22 adverse to public welfare, focusing on Page 164 1 sensitive ecosystems that are sensitive to the 2 adverse effects, has always been the focus of 3 these assessments. It is not that we are 4 ignoring. We acknowledge that they are these 5 nitrogen impacts that occur in these other 6 ecosystems, especially in managed ecosystems, 7 and acknowledging that those occur, but that 8 is not the focus of the review of the

9 standards. 10 MEMBER MITCHELL: Well, I remember 11 that they put in that document, the paragraph, 12 I think it is the bottom of page 84. It just 13 kind of indicates we're not going to do this. 14 Maybe that is the place in the context, that 15 they are aware that there are these positive 16 impacts, but in terms of looking at the 17 adverse components, we are not looking at this 18 particular analysis. 19 DR. HUBBELL: Yes. In Chapter 4, 20 where we talk about the adequacy of these 21 things, there's more of a -- 22 MEMBER MITCHELL: Right. Page 165

1 DR. HUBBELL: -- discussion about 2 that. Again, there's, obviously, discussion 3 about whether that is an adequate treatment of 4 that discussion. 5 But, again, the emphasis has 6 always been in these assessments on looking at 7 the sensitive ecosystems -- 8 MEMBER MITCHELL: Right. 9 DR. HUBBELL: -- and the impact, 10 adverse impacts on the sensitive ecosystems. 11 MEMBER MITCHELL: Right. 12 MEMBER JOHNSON: Then, the entire 13 document is biased. You know what I am going 14 to say, what I have been saying all along. I 15 totally agree with Myron. This is a huge 16 mistake. 17 There is an entire community right 18 now, including some from EPA, that are trying 19 to find out, there is an argument going on 20 whether nitrogen deposition is contributing to 21 carbon sequestration, and therefore, has an 22 effect on the global carbon issue. So,202-234-4433 Neal R. Gross & Co., Inc. Page 166 1 somebody at some level is going to address 2 this. You can either rise to it or have your 3 document be dismissed as one-sided, I think. 4 I think it is a big mistake. 5 CHAIRMAN RUSSELL: Lydia? 6 MS. WEGMAN: Sorry. Thanks. 7 This is Lydia Wegman, for those on 8 the phone. 9 We can talk about benefits. In 10 fact, we do need to look at the benefits. I 11 think Myron and Dale are both right on that.

12 The statute does talk about 13 looking at all the effects associated with a 14 pollutant or pollutants. So, that is 15 something that we can add in, and it sounds 16 like we are getting some strong advice to do 17 that. So, we will figure out how to weave it 18 in there. 19 DR. HUBBELL: Yes, and again, to 20 clarify, there is language in there. Again, 21 whether it is sufficient language, that is 22 another question. But we do have language in Page 167 1 there talking about what effects are occurring 2 due to nitrogen deposition in forests and the 3 effects on productivity, and the same with the 4 agricultural lands. The question of whether 5 that is an adequate treatment, that is 6 certainly something that we look for advice

7 on. 8 But, again, I think the focus of 9 all our case studies in those areas has been

10 on areas where there are adverse effects 11 occurring, but adding additional language that 12 acknowledges the nitrogen cycle and how 13 atmospheric nitrogen plays a role in that, I 14 think certainly we can increase that. And we 15 can probably increase our discussion of the 16 rationale for why it is playing the role that 17 it either does or does not play in our current 18 Policy Assessment. I think we can certainly

19 enhance that. 20 MEMBER HANSON: I mean I would put 21 in a third vote -- this is Paul -- for adding 22 the beneficial aspects of this or, at the very Page 168 1 least, characterizing what percentage of the 2 land area of the U.S. is subject to the 3 adverse effects, and by virtue of that not 4 being a relatively small number compared to 5 other places where nitrogen might be, 6 fertilizing systems, for example, and the 7 message will be gotten across. 8 But, as I understand the process, 9 this Policy Assessment is the primary thing 10 the Administrator would have available at that 11 level of decisionmaking for judging and12 bringing into bear all of the societally13 relevant issues. So, understanding that 14 nitrogen deposition has an upside is a really 15 important message to pass along. 16 I think part of this discussion is 17 all about understanding that the ecosystems 18 respond to nitrogen, NOx and SOy inputs from 19 the atmosphere, differently than human beings. 20 The extension of that is that we have to allow 21 for the fact that there may be an upside. It

22 hasn't been the case for ozone. There's Page 169 1 really no upside. There's no upside perhaps 2 for particulates. There's no upside for lead. 3 But here we have a case where it is just 4 different. This Policy Assessment document

5 should reflect that. 6 MEMBER WEATHERS: I agree. 7 MEMBER JOHNSON: This is Dale. I 8 am going to have to go do my day job pretty 9 quick here, so I want to make a couple other 10 comments. Then, I will probably log off and 11 get ready to go. 12 In table 3-1, it didn't mention 13 forest products as ecosystem benefits, timber 14 production, furniture, wood, things like that. 15 It seems like you should. 16 And along those same lines, 17 loblolly pine has got to be the most important 18 timber species in the country. It is followed 19 probably my Douglas fir. So, Paul's point 20 about red spruce not being economically-viable 21 needs to be followed by, you know, there 22 should be some mention at least of, if you are202-234-4433 Neal R. Gross & Co., Inc. Page 170 1 going to talk about timber production at all, 2 you are surrounded by one of the most 3 important timber-producing areas in the whole 4 country. 5 And then, we talk about the 6 beneficial effects. Yes, that was all. And7 using the two case studies, over8 extrapolating, I think -- and Paul already 9 mentioned that. 10 So, those were my comments on this 11 section. 12 DR. GREAVER: So, I would like to 13 make one comment on that and just see what is

14 CASAC's feedback. 15 In the ISA, the way we 16 characterized the upside that we are talking 17 about is that, if you add nitrogen to18 ecosystems, most ecosystems are nitrogen19 limited. So, you are going to see an increase 20 in productivity. 21 Then, we take that a step further 22 to say that, if you see an increase in Page 171

1 productivity, a lot of times that correlates 2 to an increase in growth rate for some 3 species. So, then, you will have a change in 4 the amount or the growth rates of some species 5 relative to others, so you may change 6 biodiversity or community composition. So, we 7 could definitely bring that whole line of 8 thinking into the Policy Assessment. 9 Then, the other argument, if I am 10 characterizing this correctly, is that 11 nitrogen deposition could increase carbon 12 sequestration, which, again, is related to 13 increase in productivity. But, at the same 14 time, we would then also want to bring in that 15 nitrogen deposition can increase NO2 and 16 methane production from the microbial 17 communities. So, we can certainly bring in 18 all of that reasoning if CASAC agrees with

19 that. 20 I guess the third thing to think 21 about is, in an ecosystem that is managed for 22 agricultural yield, maybe wood production, Page 172 1 oftentimes in those ecosystems you have the 2 managers putting on a lot of nitrogen as 3 fertilizer, 100, 200, or 300 kilograms of 4 nitrogen per hectare per year. 5 We didn't really cover that very 6 much in the ISA because nitrogen deposition 7 would only be adding a small addition to those 8 ecosystems that are managed. But we could 9 certainly bring up that idea as well, that 10 even though in most of those systems that are 11 managed for wood yield they are receiving a 12 lot of nitrogen by the managers, but the 13 additional contribution by nitrogen 14 deposition, presumably, would contribute to 15 their growth as well. 16 MEMBER JOHNSON: Well, actually, 17 that is true. In agriculture, you are right. 18 They put on those levels of nitrogen per year. 19 In forests, you might put on that level every 20 five years or ten years. So, deposition could 21 be quite a bit more of a contribution. 22 But you can argue for or against Page 173 1 it. I am just saying that completely 2 dismissing it is a bad idea. In previous 3 reviews of this debate right now about whether 4 nitrogen deposition -- there was an article 5 recently by Peter Hogberg in Sweden about it. 6 He says there's absolutely no doubt that 7 nitrogen deposition is increasing growth in 8 carbon sequestration. 9 So, I just think that you can do 10 it or you can have somebody else at a higher11 level or some other reviewer or some pro12 pollution-type group do it for you. Take your 13 choice. 14 I think it needs to be an 15 objective assessment. This is a scientific 16 panel, and I think we need to be objective, 17 look at both sides. 18 I am not arguing that nitrogen is 19 good. I'm not arguing that it is bad. It is 20 all a question always of amount. 21 CHAIRMAN RUSSELL: Dale, are you 22 going to be back this afternoon?202-234-4433 Neal R. Gross & Co., Inc. Page 174 1 MEMBER JOHNSON: No. I'm swamped 2 with students and classes. So, tomorrow 3 morning, I can do the same thing. I don't 4 know what time you guys start. The difference 5 is tomorrow I will have to be out the door 6 quite a bit earlier. I have got to be to work 7 by 8:00. So, I will have to log off at 7:00, 8 which is 10:00 your time. So, until 10:00 9 tomorrow morning, I can log on again. 10 CHAIRMAN RUSSELL: Okay.

11 MEMBER JOHNSON: But the rest of 12 today is really, really shot for me. 13 CHAIRMAN RUSSELL: All right. 14 Thank you. 15 MEMBER JOHNSON: Okay. 16 CHAIRMAN RUSSELL: That will put 17 us almost to the end of the meeting tomorrow. 18 That would be good. 19 MEMBER JOHNSON: Okay. 20 CHAIRMAN RUSSELL: Other questions 21 or comments on this chapter? Charlie? 22 MEMBER DRISCOLL: I had a minor Page 175 1 suggestion, and that is, there is a section on 2 TMDL that is focused on eutrophication, but

3 there have also been at least a few TMDLs for 4 acidity, maybe not as successful as we would 5 like. But I think it would be worthwhile to 6 mention those. 7 DR. HUBBELL: On that particular 8 issue, one thing we have been considering, and 9 this is related to the ecosystem services 10 aspect as well as to just sort of benchmarks 11 for action, is we were considering -- you 12 know, there's not a lot of direct valuation 13 studies that can inform some of these 14 discussions as to what is adverse. 15 But one of the thoughts we had was 16 potentially to look at where states or local 17 areas have actually taken action, in other 18 words, where they have put in place a TMDL or 19 at what point they decided that the ecosystem 20 services losses are enough that they need to 21 take action. And basically, do a sort of 22 revealed preference from an institutional Page 176 1 standpoint as to, at what level of ecosystem 2 impairment did they decide that action was 3 necessary? So, we are sort of interested in 4 whether you think that is a reasonable line of 5 thinking. It is a little difficult to try to 6 collect some of the data, but before we even 7 went down that road, we were wondering what 8 your response to that was. 9 MEMBER WEATHERS: Do you have any 10 sense of how much data is out there, I mean 11 just anecdotally are out there? 12 CHAIRMAN RUSSELL: Say that again? 13 MEMBER WEATHERS: Do you have a 14 sense of how much data are available out there 15 on those types of topics? 16 DR. HUBBELL: Well, there's 17 certainly data available on the types of 18 programs that are in place and when those 19 programs were enacted. The question is how 20 well we can link to that levels of deposition 21 or loadings that might have been the cause for 22 those actions. We are not sure at this point. Page 177 1 We are just considering whether that would be 2 something that you would see as valuable as 3 helping us make our determinations. 4 CHAIRMAN RUSSELL: Rich? 5 MEMBER POIROT: Charlie had 6 mentioned the acid lake TMDLs, and so forth. 7 Vermont was one of the states that did that. 8 In writing the TMDL -- I remember this because 9 I was the one they asked to help them write 10 the language -- they specifically put in the 11 request for some assistance from EPA to 12 apportion the excess deposition over the 13 critical loads back to sources, so that we 14 could undertake the process of seeking 15 reductions in those. That is as far as it 16 went, and there wasn't anything we could do 17 locally to achieve that TMDLs. But there will 18 be some examples like that. 19 Just this week, while I was 20 reviewing this document, our lawyer came in 21 with some questions about a TMDL process for 22 the Long Island Sound, Connecticut River202-234-4433 Neal R. Gross & Co., Inc. Page 178 1 system. It is very, very fully developed. It 2 surprised me, the extent to which they have 3 valuated this, modeled all kinds of different 4 sources of nitrogen, apportioned it to the 5 different states. 6 We are actually asking for some 7 specific reductions in point-source emissions 8 in Vermont, discharges to the Connecticut 9 River Watershed. It struck me, after all 10 these years of whining about Ohio, I am the 11 Ohio for the Connecticut River. 12 (Laughter.) 13 And it was ironic because the 14 point-source discharges are only a tiny 15 fraction. Most of the Vermont contribution 16 actually was apportioned to atmospheric 17 deposition because we've got the biggest 18 catcher's mitt in the drainage. Really, that 19 is the only reason. 20 But it is a good example of a 21 program that is pretty far advanced, to the 22 point where they are starting to take action. Page 179 1 I am sure Chesapeake Bay Watershed is maybe 2 even more fully developed. So, I'll bet you 3 will find some good examples there. 4 And to finish off that point a 5 little bit, I guess I wonder about the 6 possibility of thinking about NAAQS in a TMDL 7 concept or the possibility of working those 8 two kinds of approaches from different sides 9 of the same Environmental Protection Agency 10 together. 11 CHAIRMAN RUSSELL: Charlie? 12 MEMBER DRISCOLL: Yes, I would 13 second that. I think that these things are 14 moving forward. So, as Dale says, you can 15 either ignore it or something is going to 16 happen. So, I think it would be useful to do 17 an analysis of why they proceeded, I agree. 18 I think the one in New York, I was 19 involved in reviewing that, and just the 20 wheels fell off at some point in time. I know 21 some of the reasons, but I don't know all of

22 the reasons. Page 180

1 But there are others that are 2 going forward with respect to acidification. 3 There's a bunch of nitrogen, as Rich says. 4 So, it seems to me it is front and center, and 5 a little bit more detail I think would be 6 helpful. And some thoughts about how you are 7 going to consider these parallel efforts and 8 reconcile them at the end of the day, I think 9 would be helpful as well. 10 CHAIRMAN RUSSELL: Lauraine? 11 MEMBER CHESTNUT: Just in terms of 12 how helpful other decisions other areas have 13 made in terms of what levels they are going to 14 protect, I think you would have to look at 15 what they based that on. I mean you are still 16 going to have to -- just the fact that 17 somebody else made a decision about what level 18 to protect, I don't think is going to be 19 sufficient for you to justify a national 20 standard decision. 21 But their reasoning as to how they 22 picked what level they are trying to protect Page 181

1 at would be -- 2 DR. HUBBELL: I'm just trying to 3 decide whether that reveals any preferences 4 about their constituents or whether it is 5 really just revealing an institutional 6 process. 7 MEMBER CHESTNUT: Well, what do 8 you think? 9 (Laughter.)

10 DR. HUBBELL: I'm not sure. 11 MEMBER CHESTNUT: I mean, yes. 12 DR. HUBBELL: Also, I wanted to 13 point you, just in case people weren't mapping 14 this as well as I was hoping they were going 15 to, but we can move this as well. But we do 16 have, on page 138, which is part of Chapter 4, 17 we do have about a two-page discussion about 18 the beneficial or the effects of nutrient 19 enrichment on the forests and on agriculture. 20 Perhaps it is not as pointed as Dale would 21 like in terms of saying that these things are 22 good, but it does go through the positive and202-234-4433 Neal R. Gross & Co., Inc. Page 182 1 negative influences and the potential 2 difficulties in determining the marginal 3 impacts of nutrients in forests, whether they 4 are positive or negative. 5 Then, in terms of agricultural 6 practices, it points out that there is 7 actually a number of reasons, and, in fact, 8 there's a large portion of the agricultural 9 lands in the U.S. in which nutrient enrichment 10 is not a positive. It is actually a negative 11 because it takes away some of the natural 12 buffering capacity that we use that land for 13 when we spray animal waste and other types of 14 nitrogen from livestock processes, when we 15 spray that onto these fields. 16 So, it is actually not necessarily 17 a good thing to be adding nitrogen into these 18 systems, even though under a no human 19 intervention process it would be positive, but 20 that is not the way that we treat these lands. 21 So, there is some discussion in 22 there. We can bring it up. We can elaborate Page 183 1 on it. We can move it into Chapters 2 or 3, 2 if we need to do that, but it is there. 3 CHAIRMAN RUSSELL: Ellis? 4 MEMBER COWLING: Along the line of 5 a state or a group of states doing some things 6 about these matters, I would commend to you 7 there's a very nicely written-up case study -- 8 you have been using case studies -- in the INC 9 report, done by Paul Stacey on this Long 10 Island Sound TMDL way of working things. So, 11 that if you are looking for something that is 12 pretty well-documented and researched and 13 balanced in its perspective, I think you would 14 find Paul Stacey's part of the INC report very 15 helpful to look at. You might even be able to 16 just abstract it in some way or persuade him 17 to be one of your consultants. 18 DR. HUBBELL: Thank you. 19 CHAIRMAN RUSSELL: Lauraine, do 20 you think you've got a good feel for what the 21 Panel has to say on this chapter? 22 MEMBER CHESTNUT: I think so. Page 184 1 CHAIRMAN RUSSELL: And EPA, did 2 you have any other questions for the Panel at 3 this point? 4 DR. HUBBELL: I did want to 5 clarify one point. In terms of the percent, 6 you were asking about how we would not only 7 select the level of ANC, but also what percent 8 of the catchments we would try to protect. 9 One of the things we are starting 10 to look at -- and again, this is still an 11 initial effort -- we are starting to look at 12 what types of ecosystems we left in those 13 tails. In other words, if we protected 95 14 percent of the catchments within the 15 Adirondacks, what are the characteristics of 16 that 5 percent? Are they contributing 17 proportionally to the ecosystem services as 18 the proportion that we are actually trying to 19 protect? Are they contributing 20 disproportionately, et cetera? 21 So, the idea is to try to look at 22 what the characteristics of the lakes are, the Page 185 1 streams, or other ecosystems that would be not 2 covered versus what would be covered, and see 3 whether or not we are protecting the sensitive 4 ecosystems that are of most concern from an 5 ecosystem services standpoint. 6 MEMBER CHESTNUT: Yes, that would 7 help, give you more information, but still, at 8 the end of the day, there's going to be, how 9 much is enough? 10 DR. HUBBELL: Yes, and ultimately, 11 just like with the human health standards, it 12 is a policy choice. 13 MEMBER CHESTNUT: Right. 14 CHAIRMAN RUSSELL: Thank you. 15 Moving on to Chapter 4, Rich. 16 MEMBER POIROT: Chapter 4, for the 17 most part, addresses the question of the 18 adequacy of the current standards. It goes a 19 bit beyond that, too, in several ways. It 20 sort of becomes the air quality 21 characterization chapter and even starts to 22 ask about the adequacy of existing monitoring202-234-4433 Neal R. Gross & Co., Inc. Page 186 1 programs really to assess not only the current 2 standard, but possible future standards. 3 So, the first Charge Question 7 4 gets to the assessment of adequacy. It seems 5 to me that you have done a really thorough job 6 in addressing that question. I think it can 7 be addressed, first, in a sort of simple, but 8 compellingly-logical way by considering the 9 information provided by the effects-related 10 networks, the LTM program and the TIME program 11 and EMAP, and so forth, that clearly document 12 not only that effects are occurring and have 13 occurred, but, further, also are starting to 14 document some changes in effects as the rates 15 of deposition have been recently changed 16 somewhat, on the one hand. 17 And on the other hand, the 18 existing networks to measure SO2 and nitrogen 19 dioxide that show that standards are being 20 attained. So, in other words, effects are 21 being observed, despite the fact that 22 standards have been attained is a very simple, Page 187 1 but compelling argument, I think. 2 Then, you break it down further in 3 a convincing way to me, and what's wrong with 4 the standard? Let me count the ways. The 5 indicator is not correct. The averaging time 6 is too short. The single pollutant approach 7 is not correct, either. 8 So, I think you have really made a 9 good argument that all aspects of this current10 secondary standard are not ecologically11 relevant. So, that was my kind of response to 12 the first Charge Question 7. 13 Should I just keep going, Ted?

14 CHAIRMAN RUSSELL: Yes.

15 MEMBER POIROT: I had a harder 16 time with Charge Question 8. I am going to 17 need some help from some of the smarter folks 18 on the Committee to try to get a better sense 19 of this. 20 But it is asking about the 21 timeframe as it relates to the adequacy of 22 standards. There's sort of a parallel Page 188 1 situation, I think, with lead pollution, for 2 example, where the current effects are some 3 combined function of the current deposition 4 and historical deposition, along with a lag 5 time sort of an association, as will the 6 response be some combination of current and 7 continuing deposition rates, along with some 8 various kinds of lag functions. 9 I know Charlie had some comments 10 about the use of the steady-state model and 11 encouraging alternative ways of looking at it. 12 I don't know the extent to which that really 13 applies to adequacy of current standards, but 14 it seems to me it is likely that the situation 15 is that, given current rates of deposition of 16 sulfur/nitrogen compounds, which have been 17 somewhat reduced since what they were 30 years 18 ago, there will be, of this entire population 19 of potentially-affected surface waters, for 20 example, some that have shown improvement and 21 may continue to improve somewhat at current 22 rates of deposition. There will be others Page 189 1 that have not shown improvement, but would 2 likely improve if deposition rates were 3 reduced. Then, there would be yet others that 4 are unlikely to improve much, no matter how 5 much you reduce the rates. 6 So, I guess in terms of them 7 specifically trying to answer this question, 8 too, it might be worthwhile talking a little 9 bit, introducing a little bit the concept of 10 time to recovery or time to some expected 11 endpoint, rather than just sort of an absolute 12 concept. 13 But, again, as I say, I thought it 14 was a difficult question. I didn't think I 15 had a great answer for it. 16 The other little aspect of the 17 timing thing, that I don't think it is what 18 you meant by the question, but I didn't know 19 where else to stick it in, was I wasn't 20 completely convinced that the treatment of 21 episodic acidification was -- you mentioned it 22 on several occasions, and you describe the202-234-4433 Neal R. Gross & Co., Inc. Page 190 1 process, but it seems to be assumed that a 2 specific level of long-term steady-state ANC 3 would be sufficient, I guess, to guard against 4 the episodic effects. If that is the case, 5 maybe you could state that clearly. 6 It just occurs to me that there 7 may be certain systems that are much more 8 sensitive to episodic influences than others, 9 almost irregardless of their base-level ANC. 10 So, I don't know if that is an issue or not. 11 Anyway, I'm sorry I didn't really 12 have much of a good answer for you on that 13 question. Hopefully, others will fill that 14 in. 15 Question 9, to what extent are the 16 characteristics of air quality in deposition 17 appropriately characterized relevant to review 18 of this secondary NAAQS? I thought for the 19 most part these were very useful presentations 20 of information that was either derived from

21 measurements or from models.

22 I noted that there seemed to me to Page 191 1 be a few possible errors in some of the 2 figures that show up in the captions, but, 3 then, that modifies what you are saying the 4 figure shows. 5 Just for example, it seemed to me 6 that the total sulfur deposition map was not 7 in the same units, even though it is reported 8 to be, as the total SO2 deposition map, 9 because there is more total SO2 deposition of 10 sulfur than there is indicated total sulfur 11 deposition of sulfur. So, my guess is that 12 you are actually showing deposition of SO2 in 13 micrograms per cubic meter. 14 The same thing for your sulfate 15 map. I think you are probably actually 16 showing total sulfate. I don't know that for 17 a fact, but it looks too high to me to be 18 actually converted back to sulfur. 19 So, there are a few things like 20 that which are probably just wording changes 21 in the captions. 22 I would have liked to have seen a Page 192 1 map of total reduced nitrogen deposition, 2 which is not shown. I would also like to see 3 the map that shows the fraction of total 4 nitrogen that is in oxidized versus reduced 5 form. I think that would be useful in this 6 kind of a characterization. 7 At some point, you try to make the 8 argument or ask the question about the 9 adequacy of current networks to determine 10 whether current standards are adequate for 11 protection. And you start getting into the 12 question of, well, we don't have this total 13 SO2 plus SO4 and we don't have the NOy 14 measurements. I thought that was kind of 15 stretching things a little bit. 16 You don't need either one of those 17 things to assess the adequacy of current

18 standards. You would need those to assess the 19 adequacy of the proposed future standards. 20 I got to thinking maybe you are 21 trying to slip that in there in case you don't 22 end up getting the standards, but you want the Page 193 1 new monitoring, in which case I will be more 2 supportive. 3 (Laughter.) 4 But it just seemed like kind of a 5 weak argument. You actually don't need the 6 NOy to know whether the current standards are 7 adequate or not. 8 But, on the other hand, I liked -- 9 at some point, you've got to be examining the 10 question of, what do we need for measurements 11 in the future? To put it in this chapter is 12 fine. 13 I had one other point I wanted to 14 make. Oh, when you make that argument, it 15 occurs to me what you really need to do it 16 that way, or that kind of an approach to get 17 at adequacy, is to show me that you can better 18 use NOy as the indicator of total nitrogen, 19 oxidized nitrogen deposition, than you can use 20 NO2 to answer that same question. 21 And the same thing for you could 22 show me that you can use the combined total of202-234-4433 Neal R. Gross & Co., Inc. Page 194 1 SO2 plus SO4 as a predictor of sulfate 2 deposition, as opposed to just using SO2. 3 That is how you could show the inadequacy of

4 the current networks and also show the 5 superiority of the new proposed air quality 6 indicators. 7 Which gets me a little bit into 8 the next chapter, but there's just one figure 9 in Chapter 5, which is figure 5-5, which is 10 the ratio maps, the MAGIC conversion of the 11 air quality to deposition, which I really 12 wanted to see those. I was curious, what do 13 they look like? And I couldn't see it in the 14 figure. And it occurred to me that you could 15 introduce that concept in this Chapter 4 and 16 maybe expand upon it a little bit more in 17 showing some of these ratios. 18 I don't know if this is getting 19 way off the topic or not. I will finish it up 20 quickly, Ted. But as long as we are using the 21 model to show these kinds of ratios, I am 22 assuming it is easy to ask different kinds of Page 195 1 questions of the model. So, one kind of 2 question I was thinking, could you ask whether 3 or not NOy minus NO might actually be a better 4 predictor of deposition than total NOy is? I 5 ask that because I don't think NO dry deposits 6 for beans, and it is not very soluble, and it 7 doesn't wet deposit either, plus when you 8 measure NOy, you get NO. So, you would have 9 the data to do that. It is a minor point. 10 Rich is looking at me skeptically. 11 If you had time, I would be curious to know. 12 Now, pushing things along in that 13 direction, however, how bad a predictor of 14 total oxidized nitrogen deposition is the 15 measured sum of nitric acid and particulate 16 nitrate? It is not perfect, but how bad is 17 it? Because if it wasn't too bad, then I 18 dearly would love to see all that new NOy 19 data, but if it isn't too bad, we could get by 20 with both the nitrogen and the sulfur metrics 21 using existing networks with modest 22 enhancements to filter pack technology, Page 196 1 instead of needing a bunch of new continuous 2 instruments everywhere. But that is a minor 3 point. 4 So, I'm done. 5 CHAIRMAN RUSSELL: Thank you.

6 Paul? 7 MEMBER HANSON: I agree completely 8 with Rich's assessment of the answer to 9 Question 7, which is that the current form of 10 the standard is not appropriate. And if he 11 can capture in his worded statement what he 12 said verbally, we will be on target. 13 No. 8 gets off into the aquatic 14 effects region, or that is how I interpreted 15 the question. I don't personally have a lot 16 to contribute, other than to reiterate somehow 17 or another, based on what I have read, you 18 need to capture these short-term dynamics. 19 So, in the averaging time concept, if that is 20 what No. 8 is asking about, in the aquatic 21 systems, somehow or another, the sensitivities 22 under those short-term pulses have to be Page 197 1 captured. 2 As far as terrestrial systems go, 3 I guess we will get to those questions 4 eventually. I don't see them as being as 5 sensitive as the aquatic, maybe not even part 6 of the issue when it comes to setting the

7 standard. 8 But in a timeframe with respect to 9 them, it would be a long-term slogging 10 cumulative thing. Myron may disagree. We 11 will find out. 12 No. 9, I just wanted to express my 13 thoughts on No. 9 along the lines -- what did 14 I write here in the margin? "It's as good as 15 it gets." I think you are doing what you can

16 do. 17 I am interpreting what you are 18 trying to do as NO2 and NO primary pollutants 19 coming from anthroprogenic processes, and they 20 represent precursors to this cascade of other 21 forms of nitrogen. They don't reflect the 22 reduced forms, but we will have to deal with202-234-4433 Neal R. Gross & Co., Inc. Page 198 1 that as best you can. 2 But to that extent, I would go 3 with what goes up must come down. I think 4 that is essentially what CMAQ is trying to do.

5 That's all I have. 6 CHAIRMAN RUSSELL: Thank you,

7 Paul. 8 Myron, I think the ball was put in 9 your court by Paul. 10 MEMBER MITCHELL: Mine? Okay. 11 I guess mostly focusing on 12 Question No. 9, and looking at the 13 distribution of the depositional components, 14 it seems like to me the actual figures kind of 15 show the different types of networks. It 16 would be more useful to actually show what the 17 networks are measuring and what the 18 distribution of those measurements are. 19 It seems like some of the 20 measurements are probably done quite well, 21 like the wet sulfate deposition, while, 22 obviously, we all know that ammonia is done Page 199 1 very poorly. Having that more clearly 2 documented within this chapter I think might 3 be helpful. 4 I have a major concern that goes 5 through the document. That is the utilization 6 of CMAQ. There's a lot of output given of 7 CMAQ. I would like to see maybe less CMAQ 8 output and more comparisons of CMAQ output 9 with other measurements, like NADP wet 10 deposition versus CMAQ measurements. 11 And also, I have concerns about 12 whether the CMAQ is going to be available for 13 hindcasting as well as forecasting. The 14 numbers of years available for CMAQ are 15 probably limited. 16 Obviously, there is a lot riding 17 on the utilization/application of CMAQ within 18 EPA. I think there's opportunities here to 19 show what it does well and maybe what it 20 doesn't do well, but let's have an honest 21 evaluation of that, because it is going to 22 drive a lot of different things. Page 200

1 I think that we have discussed 2 this before in terms of some of the other 3 documents. More can be done to give a more -- 4 versus accepting that CMAQ is going to fill in 5 the holes, I think it would be better to say, 6 well, we are pretty confident that these holes 7 are being filled in well, and we are a little 8 less confident of that, just making a robust, 9 accurate, as-best-as-possible evaluation. 10 I know the complexities. CMAQ is 11 a very complex model. But within this 12 document, the dependence upon that is very, 13 very high. So, I would suggest some 14 indication of what it is doing well and where 15 some of the problems might be, and how it can 16 be utilized over long timespans as well as 17 over different spatial scales, how that is 18 going to happen.

19 DR. HUBBELL: Just to ask for a 20 little bit of clarification on that, it would 21 be really great, if there are specific 22 comparisons or tests, or other things that you Page 201 1 think are most appropriate -- obviously, 2 there's the traditional sets of comparisons 3 that are done for ambient concentrations. But 4 if there are some specific ones that you would 5 like to see, to the extent we can get those, 6 that would be great. 7 MEMBER MITCHELL: I would suggest, 8 like Bryan, like look at some of the CASTNET 9 values that are actually measured, and then 10 actually do that in terms of the actual CMAQ 11 estimated values for some of the 12 concentrations, and obviously at different 13 deposition estimates, if you use the CASTNET 14 network than if you use the CMAQ estimates. 15 I think it needs to be somehow put into the 16 mix. 17 DR. HUBBELL: What about dry 18 deposition? That is one of the things -- 19 MEMBER MITCHELL: Well, that is 20 the big one, you know. But I think CMAQ also 21 estimates wet deposition as well. 22 DR. HUBBELL: It does, and we can202-234-4433 Neal R. Gross & Co., Inc. Page 202 1 compare that. 2 DR. SCHEFFE: I think you have 3 made the point, or others on the Panel, that 4 even just comparing the ambient species, 5 because that is the best we can do, and I 6 think we need to do a better job of conveying 7 that in the report. 8 MEMBER MITCHELL: Right, right.

9 DR. SCHEFFE: And we also have 10 some other approaches that deal with wet 11 deposition that get into some of the PRISM 12 techniques -- 13 MEMBER MITCHELL: Right. 14 DR. SCHEFFE: -- in terms of 15 spatially spreading the precipitation fields 16 out in a much more -- 17 MEMBER MITCHELL: Right, right, 18 right. 19 DR. SCHEFFE: So, we will try to 20 bring those details out more. 21 MEMBER MITCHELL: I think that 22 would be a more helpful document than just a Page 203 1 series of these outputs showing the CMAQ 2 predicting this. Fewer of those and more 3 comparative things, actually showing what it 4 is doing and how well it is doing it.

5 DR. SCHEFFE: But to be clear -- 6 MEMBER MITCHELL: Right. 7 DR. SCHEFFE: Okay, to be clear, 8 do we do feel that the treatment of dry 9 deposition embedded in CMAQ is superior than 10 the treatment of dry deposition that is 11 conveyed through CASTNET, through the modeling 12 of the dry deposition processes itself, not 13 the ambient measurement part. 14 MEMBER MITCHELL: Right, right. 15 DR. SCHEFFE: So, that has to do 16 with the incorporation of so much information 17 that CMAQ allows you to do -- 18 MEMBER MITCHELL: Right.

19 DR. SCHEFFE: -- over a much 20 greater space and much greater resolution. 21 But that is another issue. 22 MEMBER MITCHELL: But it is an Page 204 1 interesting thing. It may be beyond this 2 report, but actually having that someplace out 3 in the literature, and how the community is 4 going to use that type of information in terms 5 of what we are going to use for our dry 6 deposition estimates, right? 7 CHAIRMAN RUSSELL: And when you do 8 that related to the uncertainties, I think 9 that is the real thing that we want to get out

10 of that. 11 DR. HUBBELL: The uncertainties in 12 the modeling --

13 CHAIRMAN RUSSELL: Yes. 14 DR. HUBBELL: -- algorithms or -- 15 CHAIRMAN RUSSELL: Well, in your 16 comparison of the observed, the simulated 17 values. Obviously, there's going to be 18 differences. So, how does that impact our 19 understanding of the uncertainties? 20 DR. HUBBELL: Okay. 21 CHAIRMAN RUSSELL: I mean that is 22 the interpretation we would want out of this. Page 205 1 DR. HUBBELL: Okay. 2 CHAIRMAN RUSSELL: And it comes 3 down to your ranking of where are the major 4 uncertainties in this process. That is 5 informed by this comparison. 6 DR. HUBBELL: Right. And as you 7 are well aware, Ted, just comparing the model 8 outputs with observational data doesn't really 9 give you a full understanding of 10 uncertainties. It just gives you at least one 11 point-to-point comparison. 12 CHAIRMAN RUSSELL: Right. I mean 13 it doesn't fully characterize it, but 14 certainly it gives you -- 15 DR. HUBBELL: It gives you 16 direction. 17 CHAIRMAN RUSSELL: It gives you a 18 much better idea than if you do not inform it 19 with that comparison.

20 DR. HUBBELL: Yes. 21 CHAIRMAN RUSSELL: Oh, Kathy, were 22 you trying to say something?202-234-4433 Neal R. Gross & Co., Inc. Page 206 1 MEMBER WEATHERS: Yes, I just 2 wanted to underscore a lot of what is being 3 said here, and also encourage EPA to make that 4 comparison, because I think it also reveals 5 some of the uncertainties or frailties of the 6 model, whether it is a CASTNET deposition 7 model or it is a CMAQ deposition model. 8 So, I think it is really important 9 to do, and it is also really important to do 10 to underscore the importance of a lot of the 11 different monitoring programs that exist. I 12 think they are more complementary than is 13 suggested in the document as it is right now. 14 It seems that there's a strong bias toward, I 15 guess, describing the utility of CMAQ. I 16 think CMAQ is really important for this 17 analysis, but the other monitoring networks 18 are also critically important for evaluating 19 deposition. 20 So, I am underscoring some of what 21 has already been said by Myron and Ted.

22 CHAIRMAN RUSSELL: Naresh? Page 207

1 MEMBER KUMAR: I have a specific 2 comment, and then I will use that to make a 3 general comment. Figures 4.10 to 4.12 or 4 4.13, I think if you look at 4.10 and 4.11, 5 you show CMAQ on some additional SO2 and 6 sulfate, and in 12 and 13 you are showing the 7 observed CASTNET values, but the years are 8 different, first of all. I think one is 9 sulfate and one in SO2, and the legend is also 10 different. So, it is very hard to compare. 11 I mean this is the only comparison that I saw 12 in this chapter, and it is very hard to 13 compare. 14 Nonetheless, if you look at SO2, 15 the model SO2, where it says measured SO2, you 16 can see the model is like almost 17 overpredicting by a factor of four. So, that 18 kind of makes you wonder whether the model is 19 a good job and whether it can be used, should 20 be used as a -- the confidence in the model, 21 I guess it gives you an idea of that. 22 Having said that, I think I had Page 208

1 made a comment in the last discussion of the 2 REA that the model evaluation was inadequate. 3 Maybe now is the time to bring some of the 4 suggestions that were made in the REA. 5 Again, granted, we don't have the 6 dry deposition measurements, but we do have 7 NOx, NO2, or other species. Since species are 8 acting as a proxy for deposition in this 9 approach, it would be good to show those 10 comparisons. 11 I mean I can give you the writeup 12 that we had last time to include in the 13 comments maybe. I think we should include

14 that. 15 MEMBER POIROT: That comparison 16 you just made between the SO2, that was 17 related to the same comment I made. I think 18 they got the SO2 map wrong, the CMAQ SO2 map. 19 DR. SCHEFFE: Well, yes, and 20 there's two other things. We purposely tried 21 -- well, how do I say this? In total honesty, 22 it is not proper to actually do even that Page 209 1 visual comparison between those charts, of 2 course, because that interpolation between the 3 CASTNET sites for SO2 is just not appropriate. 4 It is a convenient picture to 5 basically show the lay of the land, but in 6 terms of then comparing it to what you get out 7 of a model where you have 12-kilometer space, 8 well, in this case I believe it is 12- 9 kilometer space, it just isn't adequate. 10 But, absolutely, we have to do a 11 better job in trying to kind of explain those 12 models to observation comparisons. We did a 13 little bit of that in the REA in the 14 appendices, but I think we have to bring that 15 out a lot more, especially for this 16 nitrogen/sulfur species. 17 CHAIRMAN RUSSELL: And since it 18 has been brought up, and this is in my 19 individual comments, which I'm not sure you 20 got ahead of time, my preference for all the 21 units is in terms of equivalence per meter 22 cubed or something like that. I mean just do202-234-4433 Neal R. Gross & Co., Inc. Page 210

1 it because that is nice and consistent and it 2 is readily compared across species. 3 DR. SCHEFFE: Yes. Yes, it's a 4 great point. Of course, as you know, what 5 happens is we get these things churned out, 6 and they are churned out with preprocessed 7 routines that are in there, you know, the unit 8 of the day that was in that post-processing 9 routine. 10 (Laughter.) 11 We apologize for that, the 12 confusion that that has caused.

13 CHAIRMAN RUSSELL: Other comments 14 on this chapter? Lauraine? 15 MEMBER CHESTNUT: A question came 16 up for me in going through this chapter. 17 Clearly, the case is made that the current 18 secondary standards are not adequate. But I 19 am wondering what is going to happen down the 20 road with the PM and ozone primary standards, 21 which are going to force precursor reductions 22 of the same pollutants that we are talking Page 211

1 about here. 2 I know it is complicated to try to 3 look at that, but just a question came up how 4 -- so how far is that going to get us? And 5 how much? Is it going to be far enough? Is 6 there any way to know? 7 DR. HUBBELL: Luckily, that is 8 what we analyze in our Regulatory Impact 9 Analyses, but it does not come into play when 10 you are determining the levels of the 11 standard. That is why we focus on current 12 conditions, which incorporate the current 13 standards, but not full implementation. 14 What we end up doing is saying, 15 look, you know what, it is great. Our 16 standards for ozone and PM are going to lead 17 to reductions that will make it much easier to 18 potentially attain the secondary standards for 19 NOx and SOy. I mean, certainly, we expect 20 that the large regional programs, both that 21 deal with mobile sources, but also to deal 22 with the transport of SO2 and NOx that is Page 212 1 being addressed through our Clean Air 2 Interstate Rule, we expect that is going to 3 have a significant benefit for any kind of 4 program to attain secondary standards for NOx 5 and SOy. But we generally do not take into 6 account future implementation programs when 7 you are designing standards based on current 8 conditions. 9 CHAIRMAN RUSSELL: Rudy?

10 MEMBER HUSAR: Yes. On the 11 question of the Regulatory Impact Analysis, 12 where the multiple regulations relationship is 13 examined, is that going to be part of CASAC? 14 DR. HUBBELL: No. That is not 15 part of the rulemaking itself. That is 16 actually something to satisfy an Executive 17 Order that requires us to cost/benefit 18 analysis, and it accompanies the rulemaking 19 package, but it is not actually part of the 20 rulemaking itself. In other words, it doesn't 21 go into the decision on the level of the

22 standards. Page 213

1 CHAIRMAN RUSSELL: Other questions

2 from the Panel? 3 (No response.) 4 And any other questions from EPA 5 in terms of our discussion and clarification? 6 DR. HUBBELL: No. I just will say 7 those were very helpful comments about how to 8 proceed forward on CMAQ. I think that is very 9 helpful. 10 CHAIRMAN RUSSELL: With that -- 11 MEMBER POIROT: Could I ask if we 12 could put Question 8 again? 13 CHAIRMAN RUSSELL: They only seem 14 to have the beginning question of each 15 chapter. So, no, we can't put up Question 8.

16 MEMBER POIROT: Oh.

17 CHAIRMAN RUSSELL: You can read 18 it. 19 (Laughter.)

20 MEMBER POIROT: "What are the 21 views of the Panel on the timeframe of 22 ecological response related to current202-234-4433 Neal R. Gross & Co., Inc. Page 214 1 deposition? The adequacy evaluation relies on 2 recent NOx/SOy deposition and on long-term 3 steady-state ANC. Does the Panel agree that 4 long-term steady-state ANC is the most 5 appropriate representation of ANC for 6 evaluating the adequacy of current standards?" 7 I don't feel comfortable with my 8 own answer to that. And if I have to write up 9 the summary, I don't quite know what to put. 10 So, I was hoping others might. It's a hard 11 question. 12 (Laughter.) 13 DR. HUBBELL: It's a good 14 question. 15 MEMBER POIROT: Maybe EPA could 16 help us a little bit by providing a little 17 more detail of what you are really after

18 there. 19 DR. HUBBELL: Well, what I was 20 after when I tying it together is that we do 21 a current conditions assessment, but that 22 current conditions reflects previous Page 215

1 deposition as well as current deposition. Any 2 changes we make now to deposition will affect 3 both current ANC, but also future ANC. 4 So, we are looking at sort of this 5 weighted average of past problems with 6 deposition and deposition that is to come, 7 sort of like Christmas past, Christmas future, 8 and Christmas present, and here we are at the 9 present and we are trying to evaluate whether 10 or not the current standards are adequate to 11 protect against ANC-related effects that are 12 occurring today. It is difficult to tease out 13 exactly how to determine that when you've got 14 deposition from the past that is also having 15 an impact through release of sulfates, et 16 cetera, in the soil. 17 So, it is just to make sure that 18 the current steady-state ANC is an adequate 19 representation of current conditions or 20 conditions that are expected to result in the 21 future from deposition today. It is just 22 trying to figure out how we deal with the fact Page 216 1 that this is a dynamic system, and that the 2 effects that you are seeing today are a result 3 of past problems, and the effects that are 4 occurring in the future are going to be 5 resulting from today's standards. And how do

6 we evaluate those? 7 MEMBER POIROT: I was afraid that 8 was what you meant. 9 (Laughter.) 10 CHAIRMAN RUSSELL: And now Rich is 11 looking for some guidance, I think, from our 12 more aquatically-oriented people. 13 MEMBER DRISCOLL: So, as I alluded 14 to earlier, this is a challenging aspect of 15 the problem. But I think that one potential 16 approach to at least sort of inform the nature 17 of the beast would be you could show some18 projections, either through paleo19 reconstructions or through model calculations. 20 Some of those are sort of indicated. I think 21 there are a few plots of MAGIC hindcasts. 22 But I think that maybe to try to Page 217 1 address this is you could expand that and not 2 only include ANC, but include some terrestrial 3 indicators, such as soil, calcium status, or 4 exchangeable base status, and absorbed sulfur, 5 and these other things that are going to come 6 into play in terms of the long-term ANC.7 Because you are using a steady8 state, but even the systems now, there's no 9 really current steady-state. The systems are 10 changing. So, at least you could talk about 11 the steady-state in the context of what we 12 anticipate has gone on in the past and what we 13 anticipate might go on in the future. 14 I don't know. That is not a very 15 good answer, but at least it places things out

16 there that the reader can understand at least 17 some of the natures of the assumptions, at 18 least compared to our best understanding of 19 the dynamic environment. 20 I don't know. Does that help, 21 Rich?

22 MEMBER POIROT: Some. Is there a202-234-4433 Neal R. Gross & Co., Inc. Page 218 1 way you can provide some example 2 illustrations? I am thinking of some of the 3 recovery papers, Stott, et al., that have 4 looked at response to reduced rates, that some 5 systems have been quite responsive; others 6 have not. I think that is part of your 7 argument about whether the steady-state,

8 whether the current -- 9 DR. HUBBELL: One of the things 10 that we have been thinking about and trying to 11 figure out some ways to look at this is, you 12 know, one of the things that I have heard from 13 our folks, especially Jason Lynch, is that, 14 even if under current conditions, even if you 15 kept the deposition the way it was right 16 today, in some locations it might recover over 17 time, a long period of time. But that 18 reducing, decreasing the amount of deposition 19 beyond that level that we are at today would 20 speed up the recovery period. So, one of the 21 benefits is an enhanced recovery over a time 22 period. Page 219

1 We can potentially, I think, look 2 at, well, if you held things at the current 3 conditions today and projected forward, what 4 would the overall recovery period be? And 5 then what would happen if we were under 6 different levels of NOx and SOy? 7 What we can't seem to figure out a 8 way to do, although there is, again, some of 9 the hindcasting that can help us through this 10 process, is take away all the bad things that 11 happened in the past, the large amounts of 12 sulfate deposition from previous years. That 13 is a little more difficult to figure out how 14 we would address that part of it. 15 But at least I think, going 16 forward and saying, look, if the current 17 conditions were the law of the land for the 18 next 20 years, what would be the result of 19 that, that change today? 20 And we were also trying to think 21 of, could you do a pulse? Could you say, 22 okay, what if we just changed this year? What Page 220 1 would that overall impact be over time, to say 2 what is the impact of a current condition? 3 But that doesn't seem very meaningful. 4 So, we are just trying to figure 5 out how to best balance this information. So, 6 if you have any ideas, that would be great. 7 We will continue to muddle through, otherwise. 8 But it would be great if you have some ideas 9 to help us move forward. 10 I think the idea of doing some 11 additional projections and hindcasts, and so 12 forth, might be a way to move forward. 13 Thank you. 14 MEMBER WEATHERS: It is important 15 to continue to distinguish, I think, between 16 chemical changes and biological changes as 17 well that have different lag times to 18 recovery. 19 CHAIRMAN RUSSELL: Charlie, were 20 you going to give us one last word? 21 MEMBER DRISCOLL: Yes, I was just 22 going to mention, in terms of looking at Page 221 1 hindcasts, or whatever, it would also be 2 probably instructive to compare, presumably, 3 faster-reacting Northeast glaciated systems 4 with unglaciated systems, which at least in

5 terms of sulfur would be more slow. 6 So, you have got those two case 7 studies. You could contrast those two and 8 illustrate some of those additional issues. 9 DR. HUBBELL: Okay. That is good. 10 Thank you. 11 CHAIRMAN RUSSELL: Okay. It is 12 about 12:10 So, it is time to break for

13 lunch. We are due back at one o'clock. 14 So, thank you very much. 15 (Whereupon, the foregoing matter 16 went off the record for lunch at 12:13 p.m. 17 and went back on the record at 1:08 p.m.)

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22202-234-4433 Neal R. Gross & Co., Inc. Page 222

1 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N 2 1:08 p.m. 3 CHAIRMAN RUSSELL: So, now that 4 EPA is back, we can begin. This would be 5 starting with Chapter 5, which, as noted, is 6 Praveen taking the lead. 7 MEMBER AMAR: All right, let's

8 start. 9 Okay, Chapter 5, the first 10 question, No. 10, do we like the conceptual 11 framework of what is being proposed here? And 12 the answer I had here is, yes, it looks good. 13 You are trying to connect A to B to C to D, 14 and with one exception, which has been talked 15 about quite a bit, how to handle ammonia. You 16 just mentioned it, too. So, I won't go into 17 that in more detail. 18 I think, to the extent you can 19 measure it or estimate it and dynamically 20 change it over the years, and when you 21 calculate AAPI, that may be one way to address 22 ammonia, more than like -- I don't know what Page 223 1 you said. Control, which is controlling -- 2 what was the word you used? 3 DR. HUBBELL: I said you can 4 control for without controlling it. 5 MEMBER AMAR: Okay, yes. 6 Controlling is the real thing, and controlling 7 for is the mathematics. 8 Okay, that is the Question No. 10. 9 I mean that was my simple answer. 10 Eleven, it has many, many parts. 11 I think that is where we might have to figure 12 out who is going to be writing different 13 parts. 14 They start with the relevance. 15 What is the relevance of the conceptual design 16 for developing standards to protect against 17 acidification effects? And within that, the 18 first question, No. 1, what do we think about 19 the ecosystem acidification models? 20 I have one general comment, not 21 knowing all the great details about MAGIC and 22 FAB and SSWC. It might also be influencing Page 224 1 how you do the uncertainty. 2 That is, are these models at this 3 time, with their calibration, validation, 4 testing, and so on, are they at the same level 5 as atmospheric science people think of CMAQ? 6 I don't know the answer, but I think it is a 7 fair question to ask. Are we at that point 8 where these models are good as they can get? 9 That is the only thing I can think of there. 10 For Question No. B, this whole NECO 11 business or nitrogen eco, there are two

12 versions. The calculations based on that are 13 quite different. 14 Then, also, I think the report 15 does talk about there is a third way to handle 16 this thing by somehow constraining SSWC

17 results. I don't know what that means. But 18 maybe there's more than two methods being 19 talked about, but there are three. At least 20 that is the way I saw it.

21 And the text itself -- no? It 22 talks about a third approach, a staff Page 225

1 approach, to -- it talks about, let's see, 2 "where SSWC results are critically lowered or 3 constrained by NECO," and how and by how much? 4 I mean that is what I thought. 5 So, are there three approaches? 6 There are two equations, but there may be 7 three approaches. 8 DR. GREAVER: The way that we 9 presented it was to take the SSWC model and 10 then constrain by a NECO term, and then two 11 ways to develop that NECO term. One is using 12 the calculations that are in the FAB model, 13 and then second was to subtract leaching from 14 deposition. So, those are the two ways that 15 we were thinking about doing it. 16 MEMBER AMAR: Okay. Then, the 17 second approach, which has a simpler 18 mathematical expression, and it is based on 19 measured leaching, isn't that generally maybe 20 more accurate? That is what I was thinking. 21 Would it be because it is based on

22 measurement?202-234-4433 Neal R. Gross & Co., Inc. Page 226 1 DR. GREAVER: We wanted to get 2 some advice on that.

3 MEMBER AMAR: I have no -- I don't 4 know what to say, but maybe others would. I 5 looked at kind of the way it was structured, 6 it might be -- 7 DR. GREAVER: The better approach?

8 MEMBER AMAR: Yes. 9 MEMBER WEATHERS: One thing that 10 is true is that, then, that latter model 11 relies heavily on having reasonably-good 12 deposition estimates.

13 DR. GREAVER: Yes. 14 MS. BARRY: Kathleen, could you 15 repeat that, please? 16 MEMBER WEATHERS: I was just 17 reflecting that looking at deposition and 18 leaching relies on reasonably-accurate 19 deposition measurements.

20 DR. SCHEFFE: And one of the 21 distinctions, too, that second method is, I 22 think, much more reflective of a dynamic Page 227 1 system because it is actually measuring what 2 comes out and what comes in. So, it is a 3 little different in terms of its construct. 4 MEMBER AMAR: So, would we care to 5 guess, for example, at this time the second 6 method should give you what Kathleen said? If 7 you had accurate deposition measurements, 8 would it give you better results? Or we don't

9 know? 10 DR. GREAVER: Again, we wanted to 11 get some advice on that. I would think so. 12 I would think that if you are measuring 13 leaching, if you are measuring the difference 14 between deposition and leaching, I think it is 15 a pretty safe assumption that the difference 16 is being taken or immobilized by the 17 ecosystem, rather than trying to get estimates 18 of each of those parameters and then model

19 them. 20 MEMBER AMAR: That is what I 21 thought. There were fewer degrees of freedom

22 here. Page 228 1 DR. GREAVER: Right. 2 MEMBER AMAR: And if you could get 3 that right, maybe you will get it more

4 accurate. 5 DR. GREAVER: I think so. 6 MEMBER WEATHERS: It is a stated 7 math balanced approach. 8 CHAIRMAN RUSSELL: Rich, then 9 Rich, and I will go with Rich Poirot, then 10 Rich Scheffe. 11 MEMBER POIROT: I just wanted to 12 ask, as a point of clarification, I didn't 13 really feel like I fully understood the real 14 differences between the approaches to the 15 extent that it seemed like the second approach 16 could be done by direct measurement, more or 17 less, but could only be done at any given 18 point in current time where you actually had 19 leakage or excess nitrogen coming through. 20 I somehow got the impression 21 possibly the first modeled method you might 22 actually be able to look over longer and Page 229 1 project into future time periods, such that 2 you would be talking about something that 3 might not yet be occurring, but that would 4 happen in the future. At least that was the 5 impression that I got. 6 And let me just finalize my 7 confusion. So, therefore, thinking of one as 8 being something that was actually looking more 9 forward to the future, and the other which was 10 based on direct measurements, I was surprised 11 to see that in your case study you were able 12 to do it both ways for the same system. How

13 can that be? 14 DR. GREAVER: How could it be? We 15 could do it both ways because, for each of 16 those catchments, we have data to do the17 modeling. Then, we also had the empirically18 measured data to look at the difference 19 between deposition and leaching. So, then, we 20 were able to compare the two of them. 21 What we found is that we have a 22 much higher number for how much the ecosystem202-234-4433 Neal R. Gross & Co., Inc. Page 230 1 is retaining when we look at the measured 2 dataset versus the modeled estimate. 3 MEMBER POIROT: Does that, 4 therefore, imply that in the future those 5 systems would be able to retain less? 6 DR. GREAVER: I don't know what it 7 implies about the future. I think you make a 8 really good point that the measurements are 9 made for a point in time. So, maybe you have 10 measured it on a day where there's a lot of 11 leaching. We don't have any indication of

12 what that would mean over the course of a 13 year, for example; whereas, I would have to 14 look more closely at the model, but, 15 intuitively, I would think that the model 16 might take in some of the variability, might 17 account for some of the seasonal variability 18 in calculating the NECO term. But that is a 19 good point. 20 DR. SCHEFFE: And Charlie brought 21 that up earlier, too. I mean, remember now, 22 the modeled assumptions, those are parts of Page 231 1 the steady-state models, the FAB model, in the 2 first approach, in which you try to actually 3 look at those processes. You actually try to 4 look at estimates of what we think the 5 nitrification rates are, the uptake rates, and 6 everything else are. 7 And in the other approach, it is 8 just an out minus an in, basically. So, the 9 other approach kind of semantically I think it 10 is proper to think of that as a more dynamic 11 approach, where the first approach is based 12 more on the consistency of the attributes of 13 that ecosystem, that there are assumptions 14 that the nature, you know, that there isn't a 15 lot of harvesting and everything else going on 16 in terms of how you are stipulating those 17 functions. 18 So, you are right. Insight about 19 one can be used sort of in a prospective20 longer-term sense versus one kind of a near21 real-time sense is more or less on target as

22 well. Page 232

1 DR. GREAVER: So, what does that 2 mean? Are we better off looking at a model 3 where we know there are some assumptions and 4 uncertainties, but we think we are at least 5 taking into account variability? Or are we 6 better off to stick with the measurement? 7 DR. HUBBELL: Or is there some way 8 that we need to combine the two? That is one 9 other option. 10 DR. GREAVER: Or maybe think of a 11 way to combine the two? Yes? 12 DR. HUBBELL: Again, any thoughts 13 on relative weights to put on those different 14 methods, that would be very helpful.

15 MEMBER WEATHERS: As I understand 16 it, they are two really different things. So, 17 the first model is looking at prophecies of 18 cycling within the black box; the other model 19 uses input/output. So, they are quite 20 different things. 21 DR. SCHEFFE: Yes, they are. In 22 theory, one could say that, if you had all the Page 233 1 processes characterized right for the system 2 of interest, that over a certain period of 3 time, if you exercise those processes, that it 4 would converge to the same kind of inputs and 5 outputs that you get from the other approach. 6 DR. HUBBELL: We are just saying 7 the other option, of course, is instead of 8 taking it just at one point in time, is to 9 look at either some type of an average over a 10 longer period of time or some other type of 11 dynamic representation of the value of the 12 leaching minus the deposition. So, maybe we 13 can think of some -- I don't know what kind of 14 time churn we have in very many locations. 15 So, that would be the only limitation, is it 16 would depend on the observational data we had. 17 But, again, we might be able to 18 use, at least in locations where we do have 19 that, if we looked at a longer-term trend, 20 perhaps we could match that with some of the 21 modeled outputs in those same locations to see 22 how well they match up.202-234-4433 Neal R. Gross & Co., Inc. Page 234

1 Tara likes that idea. 2 (Laughter.) 3 MEMBER AMAR: Oh, to me?

4 CHAIRMAN RUSSELL: Yes. 5 MEMBER AMAR: Okay. The Question 6 No. C, that has to do with, is bedrock geology 7 the way to go? What I read in the document 8 and others who know more than I do, it seems 9 like that is the variable we have chosen. It 10 may not be the best, but it is more than 11 adequate, I thought. 12 And if you really wanted to go 13 beyond bedrock geology, that is what you are 14 asking us, one suggestion would be -- I mean, 15 of course, there is a whole series of things 16 you can have, elevation, watershed area, and 17 so on, what's in your report. But do some 18 kind of sensitivity analysis, whether that 19 really helps. Do you have a better 20 presentation? And then validations through 21 surface chemistry data, if you are going to 22 include all these extra variables. And also, Page 235

1 be concerned about co-variant variables. I 2 mean you have to kind of choose independent 3 variables versus, you know, they vary with

4 each other. 5 And also, I think I am just 6 concerned this could be an open-ended 7 exercise. You have to be very careful. I 8 mean, how do you bring in more variables? Do 9 you bring one at a time, two at a time? And 10 then, decide maybe bedrock geology is the way 11 to go. It may not be best, but more than 12 adequate. And also, simplify it. 13 So, that is where I was, but I'm 14 sure others will have different opinions. 15 DR. HUBBELL: And let me just, 16 because I think sometimes we are used to 17 talking about this, but we don't clarify it. 18 The reason why we need to do this process of 19 categorization is that we don't have the 20 critical load modeling for every location. 21 So, the idea is to simplify enough that we can 22 transfer from locations where we do have Page 236 1 critical load modeling to those where we

2 don't. 3 The more refined we get in our 4 classifications, the less number of critical 5 load calculations there will be within each of 6 those categories to come up with a 7 representation. So, you gain specificity, but 8 you run into issues with sampling error and 9 other things that come in at that point. 10 So, there is a balance that we are 11 trying to achieve here in coming up with these 12 broader categories. So, keeping that in mind, 13 obviously, we are looking to make sure we 14 don't assign classes to these ANC values or to 15 the bedrock weathering rates and nitrogen 16 retention that they don't belong with, but we 17 do want to try to maintain at least some 18 ability to transfer the knowledge we do have 19 of critical loads to these unmodeled areas. 20 And one thing maybe we can clarify 21 in the next draft is just we have been talking 22 about where some additional critical load Page 237 1 modeling might be being done, because there is 2 some going on. 3 Do you remember where else it was 4 going to be?

5 DR. GREAVER: Some of the 6 locations that we talked about were, I 7 remember, through Maryland there's been a lot 8 of critical loads work. So, we thought maybe 9 we could look at the distribution of critical 10 loads in that area. 11 Then, Jason had a lot of ideas 12 right through Maine and more extensively in 13 New England, and then more modeling in 14 Pennsylvania as well. Those were the sites

15 that I recall. 16 DR. HUBBELL: Yes. So, to the 17 extent we can cover a lot more areas with the 18 actual critical load modeling, there will be 19 less need to transfer to all those areas, and 20 it gives us much more of a database to 21 transfer from. But that is the goal of doing 22 this. It is not something to come up with202-234-4433 Neal R. Gross & Co., Inc. Page 238 1 categories but to come up with ways of 2 transferring information from places where we 3 do have critical load modeling to the places

4 where we don't. 5 CHAIRMAN RUSSELL: Keep going. 6 MEMBER AMAR: Oh, keep going. 7 Okay. 8 The next one is D. That is the 9 issue of the aggregation. How do you go from 10 catchment, I guess, all the way to add up for 11 the national scale? 12 I think here that the concept is 13 two concepts. You keep on saying in the 14 presentation this morning specify; you know, 15 you are going to have some fraction of percent 16 of lakes or population of water bodies which 17 are going to be protected, and how do you do 18 it, whether it is 50 percent, 95 percent. I 19 think it is policy call more than a science 20 call. But you have got to figure that out. 21 Also, once you have a percent of 22 lakes protected, you are also thinking about Page 239 1 an area. That is a concept I had talked with 2 Rich. Then, how do you look at sample size? 3 Are you protecting all lakes? Are you 4 protecting average lakes, so to speak? And in 5 the end, how do you define the area and, 6 within that, the fraction of the lakes you are 7 trying to protect? It is going to determine, 8 I think, how this degradation comes about. 9 I don't have the answer, but I 10 think I understood what you were trying to 11 say.

12 DR. HUBBELL: And one of the 13 things, again, that we are hoping to add next 14 time is actually showing some tradeoffs 15 between the ANC level that you are picking and 16 the percentile of protection, and what happens 17 in terms of the critical loads when you 18 balance those off. So, we are hoping to 19 provide some more insights, but we would 20 certainly like to understand, if there are 21 some natural characteristics or other things 22 that can help us define the spatial regions in Page 240 1 a little more scientific way, then we would 2 welcome those. But, ultimately, there's going 3 to be some policy judgment there as well. 4 MEMBER AMAR: Could you, for 5 example, when you are selecting your initial 6 sample, choose only lakes which you know, 7 based on current information or perhaps 8 historic data, they are, indeed, sensitive? 9 Then, maybe extrapolate there or do the 10 aggregation based on a sample which is kind of 11 self-selected upfront, which kind of leads to, 12 then, more protection down the road. 13 DR. GREAVER: In our example for 14 the Adirondacks, we know that that is a 15 sensitive area. So, they are going to have 16 pretty low critical loads compared to not 17 sensitive areas. Then, even within that 18 population, what we did is about 10 percent of 19 our population size would have natural acidity 20 lower than ANC of 50. So, we actually 21 excluded those, yes, because we realized that,

22 no matter -- we would have to -- Page 241

1 MEMBER AMAR: What you do, yes. 2 DR. GREAVER: Right. 3 MEMBER AMAR: I wonder if there

4 are other comments from others. 5 CHAIRMAN RUSSELL: Actually, if 6 you go through Question E -- 7 MEMBER AMAR: Okay, E.

8 CHAIRMAN RUSSELL: -- and then we 9 will move on to the next. 10 MEMBER AMAR: All right, our 11 comments, of course, we talked this quite a 12 bit, reduced nitrogen, the deposition metric. 13 I think you kind of know where this Panel is 14 and how to account for it. I don't think we 15 need to say more. I don't think I have said 16 anything different here. 17 I would just make the point, I 18 mean, unlike SOy and NOx emissions, which are 19 going down with all kinds of federal and state 20 programs, ammonia emissions are going up. 21 They are going up, I don't know, 10-15 22 percent. You can look at the statistics.202-234-4433 Neal R. Gross & Co., Inc. Page 242 1 They kind of scale on population and food 2 production and animals, and so on. 3 So, that is one pollutant which, 4 you know, if you are going to control for it, 5 it is going up. That is something I think, of 6 course, you recognize. This approach, it is 7 simply going to confer nitrogen or reduce 8 nitrogen; it is not going to provide impetus 9 to reduce ammonia emissions. It will simply 10 take that into account, but that is what you 11 are proposing. I mean it is very clear to 12 you, I think. 13 DR. HUBBELL: Yes, it is. 14 DR. SCHEFFE: A little 15 clarification, though, because we heard from 16 Russ and Otto in terms of their treatment of 17 reduced and oxidized forms of nitrogen that, 18 for all intents and purposes of the Act, they 19 had the same endpoint effects from an 20 ecosystem perspective. That is, more or less, 21 the approach we have taken here by combining 22 this. Page 243

1 But I know Charlie, in some of his 2 comments, really raised the question about the 3 different behaviors of reduced nitrogen and 4 oxidized nitrogen throughout the soil, 5 basically, throughout the soil, water kind of

6 surfaces. 7 So, Charlie, if you care to kind 8 of comment a little bit about that, to help, 9 to maybe guide us in terms of how you want us

10 to address that? 11 MEMBER DRISCOLL: Yes. So, I 12 guess a concern I had is that all nitrogen is 13 assumed to react the same, but, in fact, it 14 won't react the same. There are a couple of 15 issues associated with that. Ammonium is a 16 cation, and nitrate is anion. If nitrate is 17 retained, it is alkalizing. If ammonium is 18 retained, it is acidifying. Plus, you have 19 the process of potential nitrification, which 20 is an acid-generating process. 21 So, if you do simulations where 22 you explicitly track these processes, and you Page 244 1 put in a mole of ammonium and a mole of 2 nitrate, all things being equal, you will get 3 different changes in ANC. Now maybe those 4 levels of differences are not large enough for 5 you to be concerned about, but they clearly 6 exist. 7 So, I think this is something that 8 at least should be addressed because, clearly, 9 these two inputs, from an acid base 10 standpoint, will be processed differently and 11 have different implications with respect to

12 ANC. 13 Do you understand what I am 14 saying? 15 DR. HUBBELL: Yes. If you have

16 some references that show some of these 17 experiments, then maybe that is something we 18 could reference in a document, to say that it 19 is a concern and, also, to get an idea of what 20 the relative balance of the two are. That 21 would be helpful. 22 MEMBER DRISCOLL: Yes. Way back Page 245 1 in the day -- I'm dating myself here -- but2 there were, like in the mid-eighties/early3 eighties, there were a lot of papers on proton 4 and alkalinity balances, tracking all these 5 things. So, I can give you some references. 6 We are actually doing some 7 simulations looking at the effects of nitrate 8 versus ammonium. So, I could actually get 9 some stuff together for you for the 10 Adirondacks, although it is not published, but 11 at least it would give some idea of the 12 magnitude. But I can send you some

13 references. 14 DR. HUBBELL: Yes, that would be 15 great. 16 MEMBER DRISCOLL: I will put 17 myself a note, but if I forget, it would be 18 good for you to send me an email reminding me. 19 I promise all sorts of things; I only remember 20 a fraction of those. 21 DR. HUBBELL: Thank you.

22 DR. GREAVER: And one more202-234-4433 Neal R. Gross & Co., Inc. Page 246 1 question on that note. Would you say it is 2 true that a lot of times in the literature, 3 when acidification modeling is done, nitrate 4 and ammonium are considered to be of equal 5 acidifying strength, even though that is an 6 incorrect assumption? 7 MEMBER DRISCOLL: I believe within 8 MAGIC, generally, the way it is done is 9 there's like a balance on nitrogen, and that 10 balance is assumed, you know, how much comes 11 in, how much goes out. Then, that balance is 12 propagated through time. Even though the 13 inputs may change, the relative amounts of 14 leaching remain the same. So, I don't believe 15 MAGIC differentiates between oxidized and 16 reduced nitrogen. P-NUT does. So, you will 17 see differences. So, I don't think with MAGIC 18 you will see any differences, but with other 19 models that explicitly consider those 20 processes, you will clearly see differences. 21 DR. HUBBELL: But even though the 22 model doesn't it include it, that is something Page 247 1 that, then, adds additional uncertainty to the 2 model results, when you are looking at 3 different balances of ammonia and nitrate 4 input? 5 MEMBER DRISCOLL: Well, it 6 suggests, well, it is just a lack of 7 consideration of these various acid-based 8 processes. So, it is a simplification that is 9 used within MAGIC. It just stems from the 10 fact that ammonium is a cation and nitrate is 11 an anion. As they undergo transformations, 12 they have different effects in terms of the 13 overall acid-based chemistry. 14 DR. HUBBELL: Do we have any idea 15 of what direction that might be, if there is 16 a directional bias or if it is a magnitude of 17 uncertainty? 18 MEMBER DRISCOLL: Yes. Nitrate, 19 when it is being taken up, it will be a net 20 alkalizing process because it is an anion 21 being removed and it will generate a unit of 22 ANC, where ammonium, it depends on the extent Page 248 1 of leaching. But if the ammonium is just 2 taken up, then it will be an acidifying 3 process. If it is taken up and then 4 nitritified, it will have two steps of 5 acidification. So, generally, inputs of6 ammonium followed by leaching will be an ANC7 decreasing process. 8 DR. HUBBELL: Okay. 9 MEMBER DRISCOLL: So, there will 10 be some differences, depending on, you know, 11 from system to system. 12 DR. HUBBELL: It sounds like 13 something we need to include in our discussion 14 of model uncertainties and bias. 15 MEMBER DRISCOLL: Yes, so that was 16 my point. I think that it would be good to 17 acknowledge this. 18 As long as I have the floor, I 19 don't know how we are doing. I had some 20 comments on the NECO which were sort of 21 relevant to this. 22 One thing that wasn't considered, Page 249 1 we have talked a little bit about organic 2 nitrogen and atmospheric deposition, but you 3 also have organic nitrogen that is leaching. 4 So, when you do a mass balance to do an 5 input/output, are you going to include organic 6 nitrogen? I think somebody mentioned that 7 there is maybe fewer observations of organic 8 nitrogen versus inorganic nitrogen from

9 watersheds. But on some watersheds where 10 there have been studies, more than 50 percent 11 of the nitrogen leaching can be organic 12 nitrogen. So, it can be a significant factor 13 that hasn't been addressed in this NECO term. 14 So, I think that that is something that is 15 worth considering. 16 The other thing that I meant to 17 ask, and this will just indicate the rush I 18 had to review this document and the limited 19 time I had, but in the appendices which I 20 didn't review, did you do an evaluation of the 21 two approaches, the mass balance approach

22 versus the flux measurements for202-234-4433 Neal R. Gross & Co., Inc. Page 250 1 denitrification and nitrogen? Was that done 2 in an appendix? And if so, can you tell me 3 which one? 4 DR. GREAVER: A comparison between 5 the two NECO approaches?

6 MEMBER DRISCOLL: Yes. 7 DR. GREAVER: We didn't talk about 8 that more in the appendix. 9 MEMBER DRISCOLL: So, you asked 10 for guidance on which we thought was better.

11 DR. GREAVER: Yes. 12 MEMBER DRISCOLL: So, if you had 13 done an evaluation, I was going to look at 14 that. But if you hadn't, one suggestion that 15 I would have would be that you might look at 16 that because there is a lot of literature out 17 there. There were several papers that have 18 done input/output budgets. Of course, they 19 have different inputs, which just makes the 20 whole thing problematic. But there's quite a 21 bit of literature I think that could be used 22 to evaluate the advantages and disadvantages Page 251 1 of those approaches. 2 DR. GREAVER: What we did do in 3 Chapter 5, at the end of Chapter 5, when we go 4 through our example, we do show the values 5 that we calculated using both approaches for 6 NECO. We don't go into it in much more detail

7 than that. 8 But when we looked at deposition 9 minus leaching, we came up with a much higher 10 value. It is about 16 milliequivalents of 11 nitrogen that is being uptaken by the 12 ecosystem versus when we did it with the 13 modeling it was about 20.

14 MEMBER DRISCOLL: Yes. 15 DR. GREAVER: So, that is the 16 extent of the comparison that we did. 17 MEMBER DRISCOLL: I'm surprised 18 you could get them that close. 19 (Laughter.) 20 DR. GREAVER: Yes, really? I 21 thought, oh, no, this is pretty far. 22 DR. HUBBELL: I was going to ask Page 252 1 one more followup on that organic nitrogen. 2 You mentioned that in some cases 50 percent is 3 coming from the leaching -- 4 MEMBER DRISCOLL: There are many 5 examples. 6 DR. HUBBELL: But let's say we 7 just focused on NOx and we decreased the NOx 8 emissions, so the oxidized nitrogen coming in. 9 So, then, that means that a larger fraction is 10 going to end up being from organic nitrogen? 11 MEMBER DRISCOLL: Well, I was 12 talking about from a leaching perspective. 13 So, if you are doing an input/output --

14 DR. HUBBELL: Yes.

15 MEMBER DRISCOLL: We talked 16 previously about organic forms of nitrogen and 17 atmospheric deposition. 18 DR. HUBBELL: Right.

19 MEMBER DRISCOLL: What I was 20 referring to was, if you are comparing inputs 21 per outputs, you always have organic nitrogen 22 which is part of the outputs. Page 253

1 DR. HUBBELL: Yes.

2 MEMBER DRISCOLL: And that

3 wasn't -- 4 DR. HUBBELL: I am just trying to 5 get an idea of whether it is proportional. In 6 other words, is it because organic nitrogen is 7 50 percent of the deposition and, therefore, 8 it is also 50 percent of the leaching? Or is 9 it that it is somehow more available for 10 leaching than it is in terms relative to its 11 deposition potential? 12 MEMBER DRISCOLL: There are people 13 here who probably know more about this than I 14 do, but it seems to be at least somewhat 15 coupled with the leaching of dissolved organic 16 carbon. So, if you have got a system that has 17 more dissolved organic carbon, there will be 18 more organic nitrogen. So, it really pertains 19 to the processing of nitrogen through the 20 biological system and then the associated 21 leaching. 22 But I think it is a very uncertain202-234-4433 Neal R. Gross & Co., Inc. Page 254

1 science. What are the controls on dissolved 2 organic nitrogen losses? But maybe others

3 would want to comment on that. 4 DR. HUBBELL: Okay. Thank you.

5 MEMBER WEATHERS: Just one other 6 additional comment. This is Kathy. 7 In most cases of measured organic 8 nitrogen leaching there's a different pattern 9 for inorganic nitrogen than organic nitrogen. 10 So, the controls appear to be different within

11 watersheds.

12 DR. HUBBELL: And so what would 13 the implication of that be for looking at the 14 overall patterns? 15 CHAIRMAN RUSSELL: Actually, 16 Myron, I think you can address this. 17 MEMBER MITCHELL: If you take a 18 look at what I have seen in the literature, 19 looking at DON leaching versus inorganic N 20 leaching, the organic N leaching tends to be 21 a little more constant among watersheds than 22 that associated with inorganic. Page 255

1 There is some coupling between DOC 2 and DON, but it is not direct, and there is 3 some variation. So, there's some 4 possibilities maybe I've seen some kind of a 5 fixed level or something like that at least 6 may account for it. It is not as bad as the 7 inorganic N problem. 8 DR. HUBBELL: That is what I was 9 actually trying to get. Is there some way we 10 can do a control for that with a relatively 11 spatially-homogeneous kind of factor? 12 MEMBER MITCHELL: Then, organic N 13 tends to be higher in those watersheds that 14 have proportionally less inorganic N. 15 DR. HUBBELL: Okay. All right. 16 CHAIRMAN RUSSELL: Okay. 17 MEMBER WEATHERS: May I add one 18 more suggestion --

19 CHAIRMAN RUSSELL: Yes.

20 MEMBER WEATHERS: -- to the EPA 21 for looking at the literature? Is that a yes? 22 CHAIRMAN RUSSELL: Oh, yes. Go Page 256

1 ahead, Kathleen. 2 MEMBER WEATHERS: So, your 3 question about cations versus anions, you 4 might look to the study for the manipulated 5 nitrogen input to watersheds or to ecosystems 6 because often there is a discussion about the 7 difference between adding ammonium nitrate or 8 ammonium or nitrate in terms of processing. 9 So, those studies, Bear Brook, a lot of the 10 manipulated studies in the East where nitrogen 11 has been added are good descriptions of the 12 differences in behavior. 13 DR. HUBBELL: Thank you. 14 CHAIRMAN RUSSELL: Ellis? 15 MEMBER COWLING: What Kathy has 16 just said reminds me of something that I was 17 thinking of when Charlie was talking a minute 18 ago. If you change the ratio of oxidized 19 forms of nitrogen to chemically-reduced forms 20 of nitrogen, there will be differences in the 21 short-term, but, Charles, wouldn't in the 22 longer-term -- and we are thinking about Page 257 1 changing a policy which might be averaged over 2 three years -- would you also feel that these 3 differences between changing the ratio of 4 oxidized to chemically-reduced forms of 5 nitrogen would in the long-term affect, cause 6 important differences in the ecosystem 7 response? 8 MEMBER DRISCOLL: I would guess 9 that they would, but your comment or question 10 I think is appropriate because the residence 11 time of nitrogen within a forest system is 12 quite a long time for many systems. There are 13 rather large pools of nitrogen. So, they 14 cycle over long periods. 15 But I am going to go back to some 16 of our model simulations for the Adirondacks 17 on ammonium and nitrate because I am just 18 talking off the top of my head. So, I will 19 have to get back to you, and I can give you 20 some idea of the magnitude of at least what 21 the models suggest. It doesn't necessarily 22 mean it is reality, but we can check it out202-234-4433 Neal R. Gross & Co., Inc. Page 258 1 anyway. 2 MEMBER COWLING: Let me just 3 further ask, Kathy, would you agree with what 4 Charles just said? 5 MEMBER WEATHERS: That he going to 6 go back and look at the models? 7 (Laughter.) 8 I'm kidding.

9 MEMBER COWLING: No. I was10 thinking about the differences in the longer11 term versus shorter-term influences of 12 changing the ratio of oxidized forms of 13 nitrogen to -- 14 MEMBER WEATHERS: Yes, well, I 15 agree that, for a lot of ecosystems, nitrogen 16 retention is over the long-term, but the dogma 17 is you add ammonium and it is labile, 18 biologically labile, and moves into the 19 organic pools pretty quickly. So, it is 20 really a question about how quickly does that 21 nitrogen get mineralized and nitrified, so it 22 becomes a mobile anion. So, yes, there are Page 259 1 lag times. 2 CHAIRMAN RUSSELL: Thank you. 3 Actually, what we will do is, instead of going 4 through all of Chapter 5 person-by-person, 5 move on to individuals, based on each question 6 at this point. 7 So, Rudy, Questions 10 and 11? 8 MEMBER HUSAR: Okay. Eleven, I 9 have no contribution to. 10 The Chapter Question 10 is on the 11 conceptual framework, structure, the 12 representation of the different parts. So, 13 these are kind of general comments because 14 that is all I can do with my background here, 15 particularly a biological systems point of 16 view. 17 It is my understanding that this 18 chapter is, in fact, where the rubber meets 19 the road. This is where the connectivity, 20 this is where the various multidimensional 21 aspects of this are pulled together and 22 connected across media, first of all. Then, Page 260 1 you have pollutants that link up. Then, like 2 contributions, like the natural part of the 3 source, the organic of the source, and et

4 cetera. 5 So, clearly, how do you represent 6 that? And whether or not the linkages are 7 properly set up, obviously, determines whether 8 or not the outcome of that model will be 9 proper. 10 I thought that expanding that 11 conceptual representation -- I am talking 12 about the general picture, you know, source, 13 air pollution, deposition effect, et cetera -- 14 that part is, of course, appropriate generic 15 description of the causality of the 16 epidemiology, or whatever impacted it. So, in 17 that sense, it isn't really something that can 18 contribute too much to emphasize, to 19 eliminate, and to communicate the complex 20 problem, whereby I am talking about the 21 communication part is very important in the 22 sense that the natural system itself isPage 261

1 tremendously complicated. But if we add 2 additional artificial complexity by inadequate 3 description, that makes things a little worse. 4 So, I am addressing these 5 artificial complexities that have been 6 introduced in the process of the work itself. 7 So, the conceptual framework might be 8 extended, let's say, by looking at both, 9 adding extra specific parts to, let's say on 10 the air quality side, that is, SOy and NOx 11 separate. After all, that is the essence of 12 this unique effort to introduce a multi-media 13 standard. Because it is the nature of that 14 interaction that makes this specific. So, 15 that is one suggestion. 16 So that, just jumping ahead, so 17 that, whenever you have then the equation, the 18 final equation on the AAPI, there are these 19 terms in there that belong to SOy/NOx. Then, 20 those are clearly identified parts in your 21 conceptual diagram, rather than kind of 22 inferred from some equations. Okay?202-234-4433 Neal R. Gross & Co., Inc. Page 262 1 And a very similar comment 2 pertains to the G part of your function. What 3 that means, of course, is that there has to be 4 somewhere in the conceptual diagram a natural 5 something or another. It may be geology 6 and/or its consequence on its contribution to

7 ANC. 8 So, having those pieces that you 9 are using in the equation somehow represented 10 in the conceptual diagram, in the actual 11 sections, there wasn't really much on that. 12 It was somewhat of a problematic or additional 13 artificial complexity has been remedied to 14 some extent by Rich Scheffe in this table that 15 you presented now where you actually do 16 summarize. Okay? You have an extra table 17 that says, oh, this term is that; that term is 18 that; this is where it is coming from, et 19 cetera. But you have the picture and the 20 corresponding references always that links 21 these parts. 22 Now, additional, artificial, Page 263 1 unnecessary complications are introduced in 2 even changing the fundamental functional 3 diagram. Okay? The fundamental diagram is 4 that there is a causality diagram which is not 5 given by nature. So, emission sources, 6 transport, and concentrations, deposition, et 7 cetera. In other words, the flow of materials 8 certainly seems like a natural kind of a

9 framework. 10 So, flipping that around just for 11 your convenience, indicating that you are now 12 actually going the other way around, 13 determining, is an extra complication 14 unnecessary because you could just deal with 15 that with two sets of arrows. The flow of the 16 arrows go this way in that diagram, and the 17 way you determine your critical load or 18 emissions going that way. Okay? So, we are 19 not necessarily flipping the diagram because 20 you want to keep that to be stable, 21 unchanging. Okay? 22 Then, there is an array of Page 264 1 nomenclature and introduction of terminology. 2 I just did not realize even some of those that 3 were in my field. For instance, atmospheric 4 deposition, transformation function, and then 5 there is another one that has to do with 6 deposition as being a deposition, velocity 7 being a rate constant. Well, I mean 8 deposition rate. 9 Well, those are all the same. 10 Okay? So, it is simply the ratio 11 concentration or deposition of concentration 12 and having a term that doesn't involve 13 transformation because it is not a 14 transformation. It is a removal. It is a 15 rate of moving materials. 16 So, these are the general comments 17 that I can contribute. This, also, in a sense 18 then, is a kind of volunteering to add a few 19 comments to the Question 13, which deals with, 20 do figures, examples clarify or represent, and 21 so on. Because many of these comments, in 22 fact, do try to address that issue as to what Page 265 1 is in the figures, what's in the text, and how 2 they are related, et cetera. 3 So, tightening that relationship 4 so that this incredibly complex situation 5 could then be represented from the multiple 6 views, through the pictures, through the text, 7 and then through the constant reminding as to 8 how those actually relate to the ultimate 9 formula that you have. 10 CHAIRMAN RUSSELL: Thank you. 11 Naresh? Now you can address both 12 Question 10 and 11. 13 MEMBER KUMAR: Okay. Going to 14 Question No. 10, this is on the framework. I 15 felt that the framework is okay. I mean ANC 16 does affect, is affective of the deposition, 17 and there is a linkage between deposition and 18 concentration. 19 Where the problems might be are 20 the actual linkages. What I mean by that is 21 there's not much discussion, I mean 22 clarification, on the uncertainties in those202-234-4433 Neal R. Gross & Co., Inc. Page 266 1 linkages. Again, I am talking both of the 2 linkages, between deposition and ANC as well 3 as the deposition and concentration. 4 So, the end result is that while I 5 feel it is necessary that we have a standard 6 for AAPI, I don't have any degree of 7 confidence in the concentration that one might 8 get out of applying the sequestration, whether 9 those concentrations are in the range of a 10 factor of two, five, or even ten. Reading 11 this chapter, I just don't get that idea, what 12 it might mean. 13 So, my suggestion is like there 14 was a suggestion made in the morning of maybe 15 doing a paleo-calculation with dynamic models. 16 How about you also do a parallel sensitivity 17 calculation where you use the models that you 18 are proposing, but for the case study, at 19 every step of the process, do the sensitivity 20 calculation and propagate those numbers, and 21 in the end maybe you can get some idea of the 22 degree of confidence you have in your numbers? Page 267 1 I think that would be very useful for the 2 Administrator when she has to make a 3 determination of the standard, you know, "What 4 degree of confidence do we have in what I a 5 proposing?" So, that would be my suggestion

6 on that. 7 Going to No. 11, I don't have 8 comments on every one of those, but I think

9 one concern I had on the NECO was -- and I 10 don't understand this one; this is not out of 11 my expertise -- but given that you are getting 12 two very different answers on these 13 approaches, I didn't see any insights on why 14 that is happening. So, I don't know if others 15 on the Panel have any suggestion on what can 16 be done to really understand the differences 17 between those two approaches. 18 Again, if you are going to do a 19 sensitivity calculation, you probably want to 20 use both the numbers and see in the end what 21 different answers you get. But it would be 22 very useful to get some insights on why the Page 268 1 numbers vary so much as they do. 2 I think I would like to make a 3 comment on the reduced nitrogen also. I think 4 it has been mentioned quite a bit since the 5 morning that the treatment of reduced 6 nitrogen, the way it is right now, I mean I 7 also don't support that. 8 The main thing is, I mean, there 9 are problems for treating it as constant over 10 time. Notwithstanding that, I think the staff 11 has done a lot of work in trying to propose 12 ANC as an indicator. So, if the AAPI or ANC 13 is the final form of the standard, then what 14 Praveen mentioned in the morning, why not have 15 the NHx term also the dynamic term, and it 16 doesn't have to be a precursor? I think you 17 already are thinking of doing that. 18 The problem with keeping it fixed 19 is I think it sends the wrong message to the 20 states, so that they don't have to worry about 21 ammonium because ammonium is a fixed term, so 22 they don't have to worry about that. Page 269

1 We realize that there are a lot of 2 problems with understanding ammonia emissions, 3 even some of the chemistry. So, if there is 4 no impetus to improve that, I think it will 5 never happen. So, maybe it would be a good 6 idea to include it as a dynamic term. 7 DR. HUBBELL: Yes, and followup on 8 that is, certainly, we would appreciate 9 comments on, if we are going to be thinking 10 about including reduced forms of nitrogen more 11 dynamically, what are the ways we need to be 12 moving in terms of measurements, in terms of 13 where do we need to monitor in terms of its 14 representing the spatial distribution of 15 ammonia over different area sizes? If we are 16 talking about breaches that are affected by 17 transport of ammonia, and so forth, is it 18 sufficient to get one monitor representing a 19 whole area? Or if there are specific 20 limitations or other things about the 21 inventories that might be a problem for us, 22 any ideas you have about things we can improve202-234-4433 Neal R. Gross & Co., Inc. Page 270 1 that area I think would be very helpful. 2 CHAIRMAN RUSSELL: Rudy, you 3 wanted to add something else?

4 MEMBER HUSAR: Yes. Just to 5 follow up on that. If the conceptual diagram 6 is clipped off so that it begins at ambient 7 concentrations, which is the way it acts, I 8 certainly realize that there are certain 9 rationales for that. But I am also figuring 10 that there are also other consequences of 11 that, of not including the emissions in that. 12 Even on the ambient concentration, 13 a great part, a large fraction of the 14 estimation of the ambient concentration 15 actually comes from the model, meaning that 16 relationship between what is coming from 17 upstream outside your box, so to speak. Okay? 18 Looking at the conceptual diagram, 19 places like the states where, if you look at 20 it, if the sources are included, see, they 21 would immediately say, well, this term is 22 unrelated to that; that other term is maybe Page 271

1 related to the other kind of sources. 2 So, that kind of taking, not 3 including all the vital system components, 4 particularly those that are drivers, in other 5 words, like causes of change, causes of the 6 actual outcome, not including those, it seems

7 to me that leaves a lot of room for 8 misinterpretation and it is incomplete. So, 9 give a concentration and what would be the 10 cost or the rationale of perhaps simply 11 including in the general picture those. 12 Because each one of the terms that you have in 13 your ultimate equation there, it does actually 14 ultimately go back to the sources. 15 DR. HUBBELL: I think that is an 16 excellent point. One of the things I was 17 thinking, though, is that what we were trying 18 to avoid is the impression that the control of 19 the emissions, the sources and specific 20 sources were things we needed to think about 21 in setting the standards. But it is not the

22 controls so much as the fact that the Page 272 1 parameters that we are talking about, the 2 ammonia and the deposition ratios, that, in 3 fact, those are determined based on the 4 modeling, and the modeling relies on the 5 emissions inventories. I think what we can do 6 is put it as an input rather than as a causal 7 determinate in that sense. 8 MEMBER HUSAR: Exactly. 9 DR. HUBBELL: Okay.

10 MEMBER HUSAR: You don't have to 11 deal with it, or do deal with it, but just the 12 idea that it is there -- 13 DR. HUBBELL: It is one of the 14 factors, yes. 15 MEMBER HUSAR: -- as an input. 16 DR. HUBBELL: Well, I hope that 17 what I am hearing is that would, hopefully, 18 give some signals, then, to the community that 19 this is an important thing; we need to spend 20 some time thinking about how we are measuring 21 it or modeling it, hopefully. 22 CHAIRMAN RUSSELL: Rich? Page 273

1 MEMBER POIROT: I don't have a lot 2 to add on 10. Generally, I agree with 3 everything Praveen said, especially the points

4 that he took from me. 5 (Laughter.) 6 It must prove I'm not a 7 Republican. 8 (Laughter.) 9 But still agree with what I used 10 to say. 11 (Laughter.) 12 One thing on No. 10 that struck me 13 is that the strength of this is that, you 14 know, you are actually projecting something 15 based on air quality measurements, this ANC 16 that can be measured. That is pretty neat. 17 I mean, in that sense, you always have an 18 ability to go back periodically and evaluate 19 how well you have been doing. So, that is a 20 way of addressing and evaluating your 21 uncertainties and your biases, and so forth. 22 So, I really liked that aspect of the202-234-4433 Neal R. Gross & Co., Inc. Page 274 1 approach. 2 On No. 11, I guess I don't really 3 have anything to add on A. 4 On B, as I had pointed out before, 5 I am a little uncertain exactly really what 6 the differences are in those approaches. As 7 Naresh said, why they give such different 8 numbers is curious. 9 You know, one thing, I get the 10 impression that within recent years, within 11 the past decade or so, we have seen examples 12 of so-called nitrogen breakthrough within our 13 times that haven't existed before. And all of 14 a sudden, we are starting to see it. So, that 15 makes me think that this idea of simply what 16 would appear to be the simple direct let's 17 measure the difference may miss the point. 18 What if we see systems that are accumulating 19 nitrogen now that are just below that 20 breakthrough point? Are we going to be able

21 to evaluate those? 22 Of course, there's also a more Page 275 1 rapid-scale temporal variation in terms of the 2 ecosystem's ability to utilize the nitrogen. 3 That is why we see the episodic pulses in the 4 spring. It is mostly nitrate that has been 5 not utilized by the ecosystem; whereas, had 6 that same rate of nitrate deposition occurred 7 during the summer, it could be then utilized. 8 But in northern systems, that is what episodic 9 acidification is. 10 So, my sense was that certainly 11 the second approach was simpler and more 12 straightforward and more directly derived from 13 measurements, but possibly the first one could 14 be considered as more future-looking and more 15 protective. I just don't know enough to be

16 comment further on that. 17 On 11C, bedrock geology, I think 18 you have made a good case that it is, of all 19 the variables you have considered, it is by 20 far the most important. The next question is, 21 are there other variables for which you can 22 have access to nationally-consistent data that Page 276 1 could improve upon that? 2 The first that comes to my mind 3 might be surface soil composition and geology. 4 I know there are in the Northeast glacial till 5 models that move the soil away from the 6 bedrock material in certain directions that 7 have been shown to be helpful, but that kind 8 of information may not exist everywhere. I 9 think you need to look for consistent data 10 sources nationally. 11 Regarding the aggregation over 12 spatial scales, I think Praveen made the good 13 point that this talking about percentages of 14 lakes in an area, just it strikes me as 15 necessarily a pretty much totally subjective 16 decision. Granted, the Administrator is much 17 wiser than I am, but, still, I don't 18 understand what real basis there is to say a 19 certain percentage of lakes we are going to 20 give up on or not protect. 21 So, it is inherently somewhat 22 subjective at least. Then, when you further Page 277 1 combine that with possibly expanding or 2 shrinking the area within which you are 3 calculating the percentage, it starts to get 4 very squishy-feeling.

5 I wouldn't rule out that 6 possibility. I don't want to say that in 7 advance. You may end up with your categories, 8 or whatever, finding a way to select areas 9 such that percentage of lakes within them 10 makes more sense than it does in the abstract. 11 But some of these are very difficult to 12 evaluate. They sound like reasonable 13 approaches until we actually see the maps and 14 the tables and the calculations. 15 But I guess I was just wondering 16 if it might be possible to modify that concept 17 of percentage of lakes to being something like 18 percentage of lakes which are potentially 19 susceptible or which were potentially 20 susceptible to acidification within an area. 21 Once you do that, then, all of a sudden, it 22 doesn't matter so much. The size of the area202-234-4433 Neal R. Gross & Co., Inc. Page 278 1 and the homogeneity of the lakes within it 2 becomes somewhat less important, if what we 3 are really only focused on are the lakes that 4 are potentially affected. 5 In some ways, there isn't really 6 even much logic to fold in that subset of the 7 population of lakes that were never 8 potentially susceptible and aren't protectable 9 or even relevant, much in the same way as we 10 wouldn't fold in rocks within that area. They 11 just don't apply. 12 So, to me, you might be able to 13 use that, especially if you are making14 calculations anyway of estimated pre15 industrial ANC levels, and so forth. Maybe 16 you could modify that in some ways. 17 The last part E of 11, the method 18 to account for reduced nitrogen, I think you 19 have been very clever and innovative about 20 working it in, but not working it in within 21 the constraints of the law. I was a little, 22 I guess, disappointed to learn this morning, Page 279 1 however, that we set that number and keep it 2 fixed forever. Especially going back to my 3 first point, since this is something that can 4 easily be periodically reevaluated, possibly 5 we periodically reevaluate that NHx 6 contribution as part of it, and kind of build 7 that into your proposed standard.

8 DR. HUBBELL: Yes. When I 9 mentioned before, we have reevaluated our 10 thought process on that already. 11 MEMBER POIROT: Oh, yes. 12 DR. HUBBELL: Immediate reaction. 13 (Laughter.) 14 And we think that perhaps we have 15 more of a latitude to do that kind of dynamic 16 adjustment than I had originally thought. So, 17 we are going to embrace that concept and 18 evaluate it more for the second draft, but we 19 think that is probably a better way to go. 20 So, hopefully, we can satisfy everybody pretty 21 quickly on that. 22 MEMBER POIROT: Yes. Okay. Good. Page 280

1 That's all I have.

2 DR. HUBBELL: Can I ask one more 3 followup? On your concept of evaluating ANC, 4 I wanted to make sure everybody understood why 5 we went with the AAPI approach rather than 6 just saying let's go measure ANC, because 7 somebody might ask that, "Well, why don't you 8 just measure ANC?" 9 The problem, of course, is that 10 ANC is not solely determined by the things 11 that we are controlling; the NOx and SOy 12 deposition and other things also change over 13 time, not just the ammonia deposition, but 14 nitrogen from other sources, other types of 15 inputs. 16 So, just as with health, we have 17 to be very careful about thinking about, 18 quote, "accountability". Did you actually see 19 the change in the final thing? Because unless 20 you have controlled for all the other things 21 that are changing over time, if you try to 22 attribute either a positive or a negative Page 281 1 change in ANC to that action that you are 2 doing without controlling for other things, 3 you can get bad answers. 4 You might say, "Oh, well, ANC went 5 down, even though you were decreasing NOx and 6 SOy emissions. That must be a bad thing to 7 do." That is not at all necessarily the 8 answer if you haven't controlled for the other 9 factors. So, just a note of caution about 10 measuring ANC directly. 11 CHAIRMAN RUSSELL: Charlie? 12 MEMBER DRISCOLL: Okay. I 13 commented on some of these things, but I will 14 just try to go through them quickly. 15 For 10, I think the framework is 16 good. I support it. I think it makes sense. 17 On 11A, I mentioned this morning 18 about the fact that I think that you need to 19 go with a steady-state model, but I think it 20 would be good to have a parallel effort not 21 only with dynamic models, but I also like 22 Rich's suggestion about using actual measured202-234-4433 Neal R. Gross & Co., Inc. Page 282 1 data to try to track what are some of the 2 limitations in the steady-state approach. 3 On B, the NECO question, I actually 4 think that you would have a very difficult 5 time trying to simulate all the various 6 processes or have values for the various 7 nitrogen processes, uptake, denitrification, 8 and mobilization, because it is going to vary 9 so much from site to site. So, 10 denitrification is going to have to depend on

11 available nitrate as well as a number of other 12 factors as well, uptake, how old the stand is 13 and a variety of climatic factors, vegetation 14 factors. So, I could imagine you could get a 15 lot of variability in each of those processes, 16 and the relevance to a given site, I think it 17 would be a huge challenge. 18 The other issue that I think is 19 problematic in NECO is that you are assuming it 20 is a background, and it is not really a 21 background process, but it is altered by the 22 nitrogen status of the system. That is the Page 283 1 whole idea behind the nitrogen saturation 2 hypothesis. It is just not a switch that

3 turns off and on. 4 So, I would suggest maybe the 5 input/output budget approach. I think that 6 that might be one possibility. But the other 7 thing is I think there are fairly simple 8 nitrogen models that you might be able to try 9 to simulate just nitrogen and then add that 10 into your steady-state model. A number of 11 people have done that in the past. So, you 12 might want to consider that. 13 On to C, I think maybe the bedrock 14 geology is a good way to go. I think it has 15 been used pretty effectively in the Southeast. 16 I think there have been a lot of studies. I 17 think Rich was alluding to this, that it may 18 be problematic in glaciated terrains. But I 19 think it is probably worth pushing forward and 20 evaluating. 21 I think maybe you have a later 22 question about providing additional resolution Page 284 1 to the landscape. I would encourage you to 2 look into those factors, like elevation, 3 watershed, vegetation type. 4 So, D, the aggregation issue, one 5 thing that I was a little bit worried about 6 this, I think, obviously, one has to do it. 7 But even the case studies that you have done 8 for your watersheds in the Adirondacks and in 9 the Shenandoahs, those lakes and those streams 10 are sort of artificially bounded by the 11 definition of what is a lake and what is a 12 watershed. So, there is embedded in those 13 values, if you go to a higher-elevation site 14 or a larger lake, you will get lower values of 15 ANC, and vice versa, if you go to a smaller 16 lake or a smaller watershed, you will get

17 lower values of ANC. 18 So, I think that our definition of 19 what is a watershed and what is a lake is 20 going to affect your numbers. I guess that is 21 just adding another level of complexity and 22 not helping the problem, but probably pointing Page 285 1 out something you already know.

2 DR. HUBBELL: And that was 3 actually one of the things we were trying to 4 look at when we were looking at what is in the 5 bottom tails of the percentiles for over 6 larger areas.

7 MEMBER DRISCOLL: Yes.

8 DR. HUBBELL: It had to do a lot 9 with the lake size.

10 MEMBER DRISCOLL: Yes. 11 DR. HUBBELL: And I raised the 12 question, well, does that mean those are ones 13 that aren't important from an ecosystem 14 services? And of course, the response was, 15 "Oh, no, no, no, they are still very 16 important." 17 But those are the kinds of 18 characteristics that maybe we could look at, 19 and maybe those are important, but I don't 20 know. You have to judge that yet. 21 MEMBER DRISCOLL: I think it is 22 worthwhile to address it. Certainly small202-234-4433 Neal R. Gross & Co., Inc. Page 286 1 lakes is a sensitive issue for New York. So, 2 I am sure that somebody is going to want to 3 see a sentence in there about those issues. 4 But, yes, I agree it is important. 5 Let's see here. I think I talked 6 about the reduced nitrogen issue. Yes, so I 7 guess that's it. 8 We are just going through 11, 9 right?

10 CHAIRMAN RUSSELL: Yes. 11 Open it up to the Panel, Questions 12 10 and 11. Any other people have some other 13 comments? Rudy? 14 MEMBER HUSAR: On 11C, the

15 bedrock -- 16 MEMBER WEATHERS: Rudy, can you 17 speak into the microphone, please? 18 MEMBER HUSAR: On 11C, comment on 19 11C, bedrock as the classification, I just 20 wondered what would be the possibility of 21 including the elevation as a second parameter 22 in the classification, elevation standing for Page 287 1 all kinds of other things that are happening 2 there. I just wondered if that would be 3 appropriate for the aquatic side because I 4 know for sure that on the terrestrial side 5 elevation is definitely going to be a heck of 6 a lot more important. So, just a suggestion 7 that at least give a reason why it would not 8 include elevation beyond many other 9 parameters, of course, that are very 10 important, but that one seems to stand out. 11 DR. SCHEFFE: It is. I mean it is 12 a logical first step. The higher up you go, 13 the less and less soil coverage you have, and 14 the quicker the hydraulic rates, and all that, 15 that add to lower and lower ANC. So, that all 16 fits in. 17 DR. HUBBELL: And it is nicely 18 readily available. So, it is not like it is 19 a difficult thing to put in. 20 CHAIRMAN RUSSELL: Myron? 21 MEMBER MITCHELL: Regarding the 22 utilization of bedrock geology, I think, Page 288 1 obviously, it does do some fairly broad 2 regional components, but as other people have 3 pointed out, especially in glaciated areas, 4 the depth of surfacial material is much more 5 important than the actual bedrock geology. 6 This idea of elevation, I see that 7 could be an easy thing, but also is fraught 8 with problems because it is really not the 9 elevation per se which is controlling. There 10 are some other factors such as soil 11 components. So, possibly, instead of using 12 elevation to actually do it, the controlling 13 factor was to get a stronger situation -- 14 DR. SCHEFFE: Yes, what elevation 15 actually is surrogate for. 16 MEMBER MITCHELL: Yes, exactly.

17 DR. HUBBELL: And to the extent we 18 can get those, and we are in the process of 19 trying to find out which databases are most 20 readily available and how good they are for 21 things like soil type and depth, and so forth. 22 MEMBER MITCHELL: Right, right, Page 289 1 right. Because some places you might have 2 relatively high elevations, and you are going 3 to confuse issues that way. 4 DR. HUBBELL: Yes, and that is 5 what we are seeing with the geology alone -- 6 MEMBER MITCHELL: Right. 7 DR. HUBBELL: -- is that it is a 8 good overall proxy, but when you go to 9 specific areas, it has some issues. 10 MEMBER MITCHELL: Right, right. 11 DR. SCHEFFE: And even elevation 12 would have to be normalized somewhat because 13 the elevation in the East means a lot 14 different than the elevation in other parts of 15 the country.

16 CHAIRMAN RUSSELL: Other comments

17 from the Panel? 18 (No response.) 19 Question 12. 20 MEMBER AMAR: I will just start, 21 but I don't have much to say. I am sure

22 others have more.202-234-4433 Neal R. Gross & Co., Inc. Page 290 1 We talked about this approach. We 2 talked about for aquatic acidification how 3 this framework would work for the other three 4 things, the terrestrial acidification and then 5 nutrient enrichment for both aquatic and 6 terrestrial systems. 7 My sense, again, reading Chapter 5 8 and before, that this approach should work, at 9 least for terrestrial acidification. The 10 base-cation-to-aluminum ratio seems to be 11 equally robust or adequate compared to ANC for 12 terrestrial systems and should work. That was

13 one comment. 14 And the other one, this part about 15 estuaries, I think we had quite a bit of 16 discussion, Chesapeake Bay and the 17 contribution, just making a recommendation

18 that would be useful to have a better sense of 19 the fraction of reactive nitrogen which is, 20 indeed, coming from atmospheric deposition. 21 I know EPA has done modeling. 22 But, then, there is this point Page 291 1 about how atmospheric deposition is not a 2 large fraction, but I thought it was 30 to 40 3 percent. For me, that wasn't small. Do we 4 need to refine that estimate to do something 5 with respect to estuary work down the road? 6 So, those are two comments I had. 7 That is, the BC or AL concept should work I 8 think at the same level of reliability as ANC 9 does for lakes. And then, a better estimate 10 of the contribution from atmospheric 11 deposition or coastal estuaries. 12 That's it. I am sure there are

13 other comments here. 14 CHAIRMAN RUSSELL: Rudy, anything

15 to add on that one? 16 MEMBER HUSAR: Not really, but 17 those people who do know what is needed for 18 terrestrial could help by possibly considering 19 and incorporating those terrestrial-related 20 parameters as early as you can because, sooner 21 or later, you have to deal with them. So, 22 might as well try to, in case of doubt, you Page 292 1 might as well flip toward incorporating 2 terrestrial-related considerations now rather 3 than assume that it can be added later.

4 CHAIRMAN RUSSELL: Naresh?

5 MEMBER KUMAR: I don't have 6 anything to add on this. 7 CHAIRMAN RUSSELL: Rich? 8 MEMBER POIROT: One thing to 9 possibly think about is there seemed to be 10 some occasions where you are comparing the 11 terrestrial indicator and the aquatic 12 indicator in the same areas. That is 13 interesting, the way the results come out. 14 You know, it just occurred to me 15 for starters that just the range that is being 16 considered for ANC, 50 to 100 is a factor of 17 two, but the range that is being considered 18 for the terrestrial BC-to-AL ratio is a factor 19 of ten. So, it is a much broader range in the 20 one case that you are comparing to the other. 21 It sort of looks to me like the 22 more lenient end of the ANC range at 50 is the Page 293 1 approximate analog of the most restrictive end 2 of the terrestrial. That is, when you cut 3 them in that way, about half the systems 4 become more sensitive to one than the other. 5 So, in terms of their relative level of 6 protectiveness, those two opposite ends of the 7 extremes seem to be similar to each other. 8 Then, I was just thinking sort of 9 philosophically that in the long-run if we 10 could actually get these really correct -- I 11 can't imagine that all the sensitive critters 12 have decided to live in the water. That is, 13 I would actually expect the two types of 14 systems, one of which is flowing into the 15 other, to be of equal sensitivity in terms of 16 effects. That's just pure speculation; no 17 science there. But, at any rate, it seemed 18 like a way to think of things. 19 I wasn't sure about this, but in 20 some cases it seemed like you might be trying 21 to make an argument that, since we are more 22 confident in the ANC approach for surface202-234-4433 Neal R. Gross & Co., Inc. Page 294 1 waters, and since it would also be protective 2 of the terrestrial systems, we might just go 3 forward with the aquatic indicator at this 4 point in time. 5 And by the way, I think you could 6 justify doing that, if that is the way it 7 works out. But at the same time, one could 8 also see how combining the two would make for 9 an overall more protective metric or set of 10 metrics. 11 In addition, I guess, the last 12 thing I want to say about that is it seemed 13 entirely likely that you could have 14 variability of your soils within a watershed 15 such that the lake chemistry was not 16 necessarily reflective of all of the different 17 soil chemistry conditions within the same

18 area. 19 So, those were just the only 20 thoughts I had on that. 21 DR. HUBBELL: One request on that 22 is that we are thinking of different ways of Page 295 1 trying to think about the standards covering 2 multiple endpoints. One of them, obviously, 3 is to have a separate standard for the 4 terrestrial, a separate standard for 5 nutrients, a separate standard for aquatic 6 acidification. 7 But another way, of course, is to 8 come up with some type of an indicator or an 9 index that would provide a protection over 10 both types of systems. We don't know what 11 that would look like yet, but we are 12 interested in what your opinions are about 13 trying to move toward an integrated index,14 which is not only multi-pollutant, but multi15 endpoint versus trying to just say, look, you 16 know what, we are going to try to find 17 complementary separate standards that cover 18 these different endpoint categories. We are 19 interested in responses to that as well. 20 MEMBER POIROT: Right, and thanks. 21 I meant also, I mentioned this before, but the 22 whole TMDL thing for both acidified lakes as Page 296 1 well as nutrient deposition effects is pretty 2 well-developed in some cases. It is amazing 3 how confidently they speak of anticipated 4 reductions in the atmospheric deposition of 5 the nitrogen component in making their 6 calculations for all of their discharge 7 things. So, it seems like there might be some 8 very productive interaction between the two. 9 CHAIRMAN RUSSELL: Charlie? 10 MEMBER DRISCOLL: So, I had 11 mentioned before about this comment concerning 12 the problems with steady-state models and the 13 fact that we have ongoing soil acidification 14 that will sort of make this sort of a moving15 target with respect to applying the steady16 state models. 17 But I have been thinking about 18 this, and I was wondering if it would be 19 worthwhile considering something different. 20 So, my sort of simpleminded view of things is 21 if we just consider acidification in the 22 eastern part of the country, we see in the Page 297 1 Northeast there's widespread recovery of 2 aquatic systems. Not all systems are, but 3 most are not continuing to acidify. Most are 4 showing increases in ANC. 5 In the Southeast, most systems are 6 hanging in pretty flat, not a lot of recovery 7 values. But with respect to soils, virtually 8 all the studies that I have seen show ongoing 9 soil acidification. I wonder if it would be 10 worthwhile considering -- I think that there11 is advantage on looking at specific cation-to12 aluminum ratios, as you have done here. 13 But another important metric, to 14 me anyway, is really just the direction of 15 change. I would think that there would be 16 advantages, in addition to targeting a 17 specific value like a cation-to-aluminum 18 ratio, in just lowering the deposition to 19 arrest soil acidification. So, you are no 20 longer depleting the calcium or magnesium 21 pools. You are basically bringing the system 22 down to at least what would be a steady-state202-234-4433 Neal R. Gross & Co., Inc. Page 298 1 value as a minimum, because that will drive 2 the long-term recovery of aquatic systems. 3 But I think this is a very 4 interesting idea, and it has really stimulated 5 a lot of thinking on my part in terms of the 6 coupling of terrestrial and aquatic 7 acidification. I think it is worth pursuing, 8 but I think it would be useful to do it within 9 the context of dynamic models as opposed to 10 steady-state models. 11 I could bring up the other 12 systems, but I don't really have much in the 13 way of a comment, but I have a question, and 14 we may not even want to go down this road. We 15 talked about it a little bit at lunch. 16 But we have this approach for 17 aquatic acidification that you have advanced. 18 I will probably get the acronym wrong. But is 19 that a comparable framework that you would 20 look at for the eutrophication issues or would 21 you do something completely different?

22 DR. HUBBELL: Well the Page 299

1 eutrophication is a little bit different for 2 two reasons. One, it is not multi-pollutant 3 in the same way. 4 MEMBER DRISCOLL: Right. 5 DR. HUBBELL: The second is that 6 we don't have a very clear national indicator 7 that we can use. So, we are struggling a 8 little bit. 9 I will give you a glimpse of what 10 we are thinking about, even though we haven't 11 fully developed it, which is thinking about 12 really nitrogen loadings as more of a bounding 13 condition on some of those tradeoff curves. 14 MEMBER DRISCOLL: Okay. 15 DR. HUBBELL: For example, you may 16 make it so that the higher ends of the 17 tradeoff curve, where you have lots of 18 nitrogen and sulfur, that those would not be 19 a feasible set if you have certain nitrogen

20 bounds. 21 This is still way under 22 development, but that is what we were Page 300 1 thinking, along the lines of more using it as 2 a bounding condition, and then bringing it 3 into our discussion in that way. 4 We are much more thinking of 5 terrestrial acidification in the same way, 6 where we develop some type of an atmospheric 7 index that reflected terrestrial acidification 8 potential. But we weren't thinking of 9 nutrients in that same way, although I will 10 say, again, after our discussion this morning, 11 that clearly we need to be rewriting the AAPI 12 each time we write it as a conditional 13 function that is conditional on the level of 14 the NECO term and other nitrogen inputs. 15 MEMBER DRISCOLL: Okay.

16 CHAIRMAN RUSSELL: The Panel as a

17 whole? 18 MEMBER CHESTNUT: Ted, I don't 19 have an answer for it, but it is just to 20 underscore the significance of looking at a 21 multi-pollutant view; it is not just about the 22 same pollutants or multiple pollutants have Page 301

1 similar effects. It is also the efficiencies 2 of control strategies that are planned to take 3 into consideration all the things that the 4 precursors cause down the road. 5 So, I am just thinking about this 6 in terms of your tradeoff between SOy and NOx. 7 If you are just looking at acidification, the 8 decision, there's going to be a certain

9 tradeoff between those two and then costs of 10 which one is cheaper to control. But if you 11 have somehow factored in or given some weight 12 to the fact that the nitrogen is also causing 13 harm downstream with the eutrophication, that 14 is going to tip that balance. That is the 15 benefit of the multi-pollutant planning 16 strategies. Then, there's the health and the 17 ozone and all of that. But I just want to 18 remind us how significant that is. 19 DR. HUBBELL: Yes, and the 20 nitrogen bounding, it will bring in that 21 somewhat, but it doesn't account for the 22 multiple benefit in that sense in the same way202-234-4433 Neal R. Gross & Co., Inc. Page 302 1 that you are thinking about, I believe. So, 2 it is a little tricky, but, obviously, coming 3 from an economics background, that is one of 4 the reasons why I like the tradeoff curves, is 5 because it allows you to, then, think about 6 later on, when states are trying to deal with 7 this, that they will be able to take that cost 8 curve that relates to NOx to SOy as well, and 9 they will find a nice tangency, and it will 10 all work out great. We will have an optimal 11 solution. 12 But, for now, because we don't13 know exactly how to weight the nitrogen14 related, nutrient-enrichment-related effects 15 versus the acidification effects, do you 16 simply put a bound based on the individual 17 effects of nitrogen versus trying to account 18 for the fact that you get double the benefit 19 for nitrogen reductions? That is really 20 tricky, and it is not clear how we are going 21 to do that yet. 22 CHAIRMAN RUSSELL: Rudy, then Page 303 1 Myron. 2 MEMBER HUSAR: Well, just to add 3 another voice to the chorus here to that, the 4 beginning of the process of going multi, 5 including multiple pollutants, is, of course, 6 the first stage. The other half is the 7 multiple effects out there, that any given 8 pollutant has many different kinds of effects. 9 So, I just keep wondering, also, 10 recognizing that the effect of multiple 11 impacts of the same pollutant is not part of 12 the normal science examination process, to me, 13 that is perhaps the most difficult, the most 14 critical, ultimate kind of management 15 question. At this point, there is no 16 mechanism by which that could be dealt with in 17 a more deliberate fashion, other than by 18 policymaking, that you just make some 19 decisions on the fly, whether or not there may 20 be some kind of an extension of these 21 procedures in these committees and other 22 activities, where such consideration of Page 304 1 multiple pollutants, on the one hand, and 2 multiple effects could be considered. So that 3 you could, then, integrate this over the 4 overall kind of a systems effectiveness of 5 performing, for instance, control 6 considerations. 7 DR. HUBBELL: And that is one of 8 the reasons why we were originally interested 9 in thinking about ecosystem services because 10 they are, if you can get them into similar 11 units, whether it is dollars or some other 12 metric, preferences, et cetera, or value, it 13 is something that can be used to integrate 14 across these multiple effect categories, and 15 potentially allow you to weight things in 16 different ways. 17 I don't think we have made the 18 kind of inroads I wanted to have made on that, 19 but I think it is still a valuable way to 20 aggregate impacts. 21 CHAIRMAN RUSSELL: Myron? 22 MEMBER MITCHELL: I am just trying Page 305 1 to think about how this is all going to play 2 out down the line. One concern I have in 3 terms of using some of these relatively-narrow 4 standards is that across these sites, for 5 instance, using the base cation/aluminum 6 ratio, depending on the actual four species 7 type, if you have like red spruce, they can 8 get by with a lot less base cation than if you 9 have like sugar maple. 10 So, if we are going to be doing 11 these standards, it is going to have to be 12 somehow forest-type, ecosystem-type-dependent. 13 It is going to be pretty meaningless if you 14 have a standard which is just okay for one set 15 of species, but other sets of species do very, 16 very poorly. 17 That always kind of plays off if 18 you think about the DOC and aquatic systems. 19 We have to have, I think, some other 20 subcategories. This would fall off in terms 21 of like the nitrogen aspect. Clearly, 22 nitrogen loading in the mountain West, the202-234-4433 Neal R. Gross & Co., Inc. Page 306 1 actual effect level is much, much less than in

2 the East. 3 So, I am a little concerned, and 4 maybe I am just missing something, about how 5 these spatial differences across the country 6 and species differences across the country are 7 going to play out in terms of developing these

8 standards. 9 DR. HUBBELL: Well, one of the 10 reasons why we picked ANC, again, is that in 11 discussion with Jason, who is our resident 12 ecologist on this, his opinion was that ANC 13 was a relatively-consistent indicator across 14 the country. So, an ANC of 50 was going to be 15 equally protective or not protective 16 throughout the different water bodies. So, it 17 was a good measure because of that. 18 We don't have that for nitrogen. 19 That is a real issue: how do you figure out 20 what an acceptable level is if you don't have 21 a good indicator that allows you to adjust for 22 that sensitivity? It sounds like, also, in Page 307

1 terrestrial acidification when we have a 2 similar problem. 3 So, the question is, you know, we 4 are using, for the AAPI, we are using bedrock 5 geology and these other things to adjust for 6 baseline sensitivity. The question is, are 7 there biological pieces that we need to add to 8 the terrestrial acidification to have an index 9 approach that would adjust -- I mean I don't 10 want to do it species-by-species, but is there 11 a way to -- are there good indicators of 12 species sensitivity to acidification? 13 MEMBER MITCHELL: There's classes, 14 obviously, of trees, some of which are much 15 more sensitive to base cation status than 16 others. Maybe some kind of basic division is 17 needed associated with those types of trees 18 species.

19 DR. HUBBELL: And that would be 20 great, if we can do that, because then we can 21 come up with that.

22 MEMBER MITCHELL: I mean one of Page 308 1 the big issues, obviously, in the northeastern 2 forest is sugar maple decline. And if we 3 don't take account of that within this, we are 4 going to miss a really important issue. 5 DR. HUBBELL: Yes, and I think 6 what we would want to do is, again, similar to 7 like what we are doing when we are saying we 8 are going to use lithology and potentially 9 elevation or soil depth or other things, we 10 could use species classification, the idea 11 being that, wherever that species is, it is 12 going to be sensitive to acidification in a 13 different way to the spruce, for example, or 14 pines or other things. 15 MEMBER MITCHELL: Right. 16 DR. HUBBELL: And if there's other 17 factors, like the soil depth or other things, 18 or other types of factors that we also need to 19 incorporate that are different than what we 20 are doing for aquatic, we just need to

21 understand what those are. 22 CHAIRMAN RUSSELL: Okay. Page 309

1 (Disruption by phone line noise.) 2 It sounds like they are 3 disconnected. While you work on that, we are 4 falling just a bit behind, but don't let that 5 hinder discussion. 6 Question 13, which I think is 7 rather key, I guess we will put it up on the 8 screen in just a second. It has to do with 9 uncertainties. 10 So, Praveen, do you want to start

11 us off? 12 MEMBER AMAR: Yes, yes, okay. 13 So, my writeup is similar to what 14 I said earlier. One good thing is I think we 15 are asking the question correctly. Whether we 16 are answering it or not, that's different. 17 That is, not just the uncertainty and all the 18 variables, but the question is, what's the 19 effect of those uncertainties on what we are 20 trying to do here, which is the secondary 21 standard-setting? So, that is good. 22 I think across the report, not202-234-4433 Neal R. Gross & Co., Inc. Page 310 1 just this chapter, but overall there's 2 description of uncertainty, end of the 3 chapter, high confidence, low confidence. But 4 I think what is being suggested is that we 5 will have a larger description in the next 6 phase, and I suggested maybe a separate 7 chapter, not just to talk about uncertainty 8 for variable A, B, C, D, but talk about them 9 all at the same time. Maybe it is after the 10 report is done in the appendix saying, "Go and 11 read this part." That might be useful for 12 policy-type people, reading all in a relative 13 sense. I mean that was my suggestion. 14 That's it. We have said it 15 earlier, and maybe I am sure that others will 16 have comments uncertainty and how to address 17 it. 18 CHAIRMAN RUSSELL: Other people? 19 I won't necessarily go down the list, but are 20 there other people who want to discuss 21 Question 13? Other responses? Naresh? 22 MEMBER KUMAR: I guess I would Page 311 1 just emphasize the suggestion I made earlier 2 about doing a sensitivity study. 3 DR. HUBBELL: Yes, and I wanted to 4 actually follow up on that. One of the 5 questions or criticisms that we get in a 6 variety of these analyses is the difference 7 between, obviously, a sensitivity analysis and 8 sort of a full-scale probabilistic assessment. 9 Obviously, we can't very easily do that 10 because we don't have the information. 11 So, one of the questions is, are 12 there joint sensitivities that you think are 13 more appropriate than others? Because we 14 can't do every combination of every parameter 15 at every level, but if there are some 16 parameters that you think are going to really 17 interact with each other or are more 18 important, if we could understand what those 19 are, I think that might be very helpful. 20 MEMBER KUMAR: I think others can 21 probably talk more about on the linkages 22 between ANC and acidification and deposition. Page 312 1 But on the CMAQ, for example, you have 2 uncertainty? In emissions, for example, could 3 you use different emissions for ammonia or 4 other components that you might have, so try 5 to get different answers? Even looking at the 6 relationship between deposition and 7 concentration, could you use different years 8 or even different models? We don't have to 9 use CMAQ. What if you look at CAMx, and do 10 you get a similar answer? Or do you get a 11 very different answer? Things like that. 12 DR. HUBBELL: That is, actually, 13 an excellent idea. If we can get a CAMx run, 14 I think that would be very informative. 15 DR. SCHEFFE: Yes, that is, and, 16 actually, one thing we do have at our disposal 17 are five consecutive years of CMAQ runs. We 18 have at least one or two base-year runs of 19 CAMx. Using those as kind of an ad hoc kind 20 of sensitivity analysis, looking at some of 21 those parameters, would be worthwhile. 22 CHAIRMAN RUSSELL: Rudy? Page 313

1 MEMBER HUSAR: Yes. So, the way 2 that could, then, be incorporated, once you 3 have established the uncertainties associated, 4 let's say, with the input parameters, then, of 5 course, you have to have a place to put that 6 in your report, you know. Of course, the 7 conceptual diagram should be a natural place 8 to indicate not only the values, but their 9 corresponding uncertainties associated both on 10 the inputs and some of the arrows that are 11 going from one box to another. 12 DR. HUBBELL: Okay, that is a 13 great idea. 14 CHAIRMAN RUSSELL: So, Praveen, do 15 you think you've got enough information on 16 this? 17 MEMBER AMAR: Well, maybe with 18 respect to uncertainty, I was going to ask 19 maybe others on the Panel, what exactly are we 20 expecting in the next phase? I mean I'm not 21 clear. I know we talked about uncertainties 22 over the last two or three years, since the202-234-4433 Neal R. Gross & Co., Inc. Page 314 1 process, and maybe there are ideas. But what 2 are we expecting, some kind of outline? So, 3 if you wrote something, you would say, "Boy, 4 this is great. That is what we were 5 expecting." I am not clear myself what you 6 are expecting. 7 CHAIRMAN RUSSELL: Well, I will 8 put in what I think, actually, they can do 9 fairly directly, what Naresh is saying to do, 10 the sensitivity analysis. The question that 11 Bryan has asked I think is important, and we 12 didn't really address it here: are there any 13 parameters in their approach that have 14 significant interactions or correlations? 15 Because that is one you might have to treat 16 differently than just a standard sensitivity 17 analysis, essentially, doing one without doing 18 any of the others. 19 My first go is that there's 20 probably a correlation between the 21 transformation deposition ratios between 22 sulfate and nitrate. It is probably fairly Page 315 1 straightforward to take care of those. You 2 know, it would be almost perfectly correlated, 3 but not quite, but close enough, I think. 4 Maybe not. 5 But, on the other parameters, I 6 would like to know from our more aquatic 7 folks, I didn't see that there would 8 necessarily be that much correlation between 9 them, such that they couldn't treat them as 10 independent. So, am I correct on that one? 11 And if they are not independent, how would you 12 do it? 13 (No response.) 14 Hearing none, we will let you 15 think about it, and if I am wrong --

16 DR. HUBBELL: You'll let us know.

17 CHAIRMAN RUSSELL: Yes. 18 Rich? 19 DR. SCHEFFE: So, I think we are 20 using uncertainty in a very, very broad 21 context here, too. I think what you are also, 22 what I am hearing that the Panel is looking Page 316

1 for us is a much clearer and better and in2 depth description of what we think that the 3 gaps of knowledge are as well, and how they 4 might affect kind of the form of this 5 standard, and perhaps eventually the 6 implementation of this standard, which is 7 related to uncertainties, but it is more of a 8 qualitative component. 9 CHAIRMAN RUSSELL: Well, it could 10 be quantitative, but at this point I think you 11 all are saying that it would have to be 12 qualitative since we actually do not 13 necessarily have all the other ones 14 quantified, either at magnitude or 15 distribution. 16 So, one of the things, and I do 17 like the idea of having a chapter really 18 devoted to uncertainty discussion. To the 19 degree it can be semi-quantitative, great, but 20 I think it has to be there, just to inform the 21 process. 22 But even within this chapter, you Page 317 1 can do the sensitivity analysis to inform the 2 process as to whether the major -- and 3 actually, if you look at your AAPI equation, 4 it is not that involved. It depends if you 5 are going to go back and sort of do a full 6 assessment of the sensitivities in your NECO 7 model, or whatever, but I am not sure that 8 that is necessary, either, because I am not 9 sure how informative that would be, in that 10 you are really looking at the uncertainty. 11 Your NECO part is between your observations and 12 your modeled component. I think that is what 13 is mainly informing this, the process right

14 now. 15 Charlie, you raised your hand. 16 MEMBER DRISCOLL: I was just going

17 to mention that there have been a number of 18 uncertainty analyses or sensitivity analyses 19 that have been done in terms of modeling 20 calculations, looking at certain parameter 21 values, inputs, and how projections of ANC 22 respond. So, there is some literature that202-234-4433 Neal R. Gross & Co., Inc. Page 318 1 you could draw on to try to point out, at 2 least in terms of model calculations, how the 3 calculations respond in terms of changes in 4 ANC variability and production. So, I think 5 you could probably pull something together 6 without too much sweat. 7 CHAIRMAN RUSSELL: Lauraine? 8 MEMBER CHESTNUT: I don't know, I 9 guess it fits with this question, but I am 10 also concerned about the uncertainties in the 11 extrapolation or aggregation. Are you talking 12 about taking a sample and doing --

13 DR. HUBBELL: Yes. 14 MEMBER CHESTNUT: And most of this 15 has been about the parameters for that. Then, 16 you are going to apply it to a bigger sample 17 or a bigger population. That just seems 18 worrisome without some verification. I could 19 just hear, "Well, how can you apply that here?

20 I'm not the same as there." 21 DR. HUBBELL: Yes. No, I think, 22 again, one of the things we will try to do is Page 319 1 classify our uncertainties, so that it is 2 clear where they are coming from, from the 3 model aggregation, extrapolation, et cetera. 4 We will also try, I think, a little more, and 5 this kind of gets at the dynamics of this as 6 well, but also try to talk a little bit about 7 temporal and spatial variability and how that 8 plays into our discussion of parameters as 9 well, because they are kind of connected.

10 And to the extent there's a small 11 degree of spatial variability, then the 12 extrapolation issue isn't as big as if there 13 is a huge amount of heterogeneity in the 14 spatial systems. 15 CHAIRMAN RUSSELL: So, let's skip 16 Question 14. I would just guide you to 17 individual comments on what we thought of 18 figures and examples. 19 So, that gets us to Chapter 6. 20 Charlie? And we will do this: we will 21 address Questions 15, 16, and 18 most 22 directly, and see about 19 as well. Other Page 320 1 than that, go more towards the individual

2 comments. 3 So, Charlie, Question 15.

4 MEMBER DRISCOLL: I'm not sure how 5 I got assigned Chapter 6. It looks like a 6 challenge. 7 (Laughter.) 8 So, on to 15. I think that the 9 approach, as I said before, is reasonable. I 10 think that it would be good to evaluate what, 11 so to speak, the soft spots are, albeit 12 suggested doing some relationships with 13 dynamic models and with time series 14 measurements to evaluate it. 15 I think that the averaging time or 16 the indicators I think are appropriate. I 17 think the averaging time proposed to me makes 18 a lot of sense, rather than doing a year 19 value, maybe three-year averages. 20 There was some discussion in the 21 text that I was completely confused by talking 22 about atmospheric events and relating those to Page 321 1 episodic events. I don't really think that 2 that's relevant at all. Usually, the time 3 scales of these materials and watersheds are 4 rather long. I have never seen any studies 5 which talk about the relationship between an 6 atmospheric event and an acidification event. 7 So, I don't think you need to worry too much

8 about that. 9 I think we talked about doing this 10 multi-pollutant approach. It makes sense to 11 me. I think that we don't have enough 12 information to comment on the level, right, at 13 this point in time? That is for the next 14 report. 15 So, I think, in general, I am 16 supportive of the approach, but I think it 17 would be helpful to do some testing of these 18 to the extent that you can with measured data 19 and with manipulations and models and things 20 like that, to the extent you have time and 21 resources available to do those things. 22 DR. HUBBELL: Actually, I wanted202-234-4433 Neal R. Gross & Co., Inc. Page 322 1 to ask a question about this, using kind of 2 the chronic or long-term averages for the 3 atmosphere versus the episodic acidification

4 events. 5 What we were concerned about is 6 that we are likely to get questions about how 7 does setting an annual average-based NOx and 8 SOy standard or three-year average, how does 9 that protect against episodic acidification? 10 What we were trying to do is draw the 11 distinction between the length of time for the 12 atmospheric concentrations and the chronic 13 nature of ANC versus the episodic ANC. 14 So, if there is a better way we 15 can describe that, it would be really -- I was 16 struggling because I had to write that up, and 17 I'm not an ecologist. So, I was trying to 18 figure out a way to describe that and looking 19 for some guidance on how to understand that 20 there are differences between the timeframes 21 on the atmospheric side and the loadings side. 22 MEMBER DRISCOLL: Well, I think Page 323 1 the approach you are using is defensible. I 2 think that it could be improved by doing some 3 more sophisticated modeling. 4 I mean, generally, those processes 5 are really driven by hydrology and hydrologic 6 flow paths more than anything else and then 7 the chemistry, which varies with shallow flow 8 paths versus deep flow paths. 9 So, there will be site-to-site 10 variation in episodic ANC. I think, 11 generally, the Adirondacks probably has the 12 greatest short-term variation in ANC that I 13 have seen in the literature that can be, well, 14 at least 50 microequivalents per liter in some 15 systems, but I think New England and the

16 Southeast show lesser amounts. 17 So, you could maybe finesse this 18 through your limit value, if you can vary that 19 by region or something like that. That might

20 accommodate that. 21 But I think it is more driven by 22 climate and the nature of the snowpack-melting Page 324 1 process because, I mean, usually, at least in 2 the Northeast, the most severe conditions 3 generally occur during snowmelt more than 4 atmospheric processes. 5 DR. HUBBELL: So, here is one of 6 the things we talked about during the break, 7 was the question, well, would it be helpful to 8 have, okay, a long-term standard AAPI that is 9 based on annual average NOx and SOX and then 10 have a backstop that says, okay, you can't 11 have an AAPI in any season that is over a 12 certain amount? 13 But, then, if what you are saying 14 is true, if I am following this, that would 15 still be related to annual NOx and SOy because 16 they are divorced in terms of their temporal 17 patterns. Is that correct? 18 MEMBER DRISCOLL: Right. 19 DR. HUBBELL: So, really, it

20 doesn't make much sense to have a seasonal NOx 21 and SOy standard, even to deal with episodic

22 ANC. Page 325

1 MEMBER DRISCOLL: Right, right. 2 DR. HUBBELL: Okay.

3 MEMBER DRISCOLL: And there have 4 been some studies done which have suggested 5 that you could influence the episodic 6 acidification, which at least in the Northeast 7 is largely driven by nitrate through 8 variations of the base flow ANC, which you 9 might more cost-effectively increase that 10 through sulfur controls rather than nitrogen

11 controls. 12 But I think that that is the 13 easiest way to go. I mean particularly given 14 your time constraints, I don't know if you

15 could do much else. 16 DR. HUBBELL: Okay. All right. 17 DR. SCHEFFE: But, I mean, our 18 logic, though, was very simple. We realized 19 that the episodic problems had to do with 20 hydraulics in the system. But they were a 21 manifestation of a longer-term loading. So, 22 from an atmospheric perspective, that is where202-234-4433 Neal R. Gross & Co., Inc. Page 326 1 we felt we were being covered -- 2 MEMBER DRISCOLL: Right. Yes. 3 DR. SCHEFFE: -- by the annual 4 average. 5 DR. HUBBELL: Actually, we need to 6 work on our writeup on that. 7 MEMBER DRISCOLL: Yes. No, I 8 think, yes, that that's true. I think if the 9 writeup could be made more clear -- you have 10 got a lot of information there that is almost 11 too much information that I think you should 12 just get out of there and minimize the 13 confusion. 14 DR. HUBBELL: So, you know, I was 15 wondering whether it would be of any 16 additional use to present, for example, show 17 that there is no correlation between daily or 18 seasonal fluctuations of NOx and SOy and 19 episodic pulses of acidity. Because then you 20 could say, look, it is just doesn't make sense 21 to do it that way. But if you think it is 22 fairly well-understood and we can just -- Page 327 1 MEMBER DRISCOLL: Well, maybe some 2 other people think it is important, but I have 3 never seen any --

4 DR. HUBBELL: Good. 5 MEMBER DRISCOLL: -- discussion

6 about that. 7 DR. HUBBELL: Okay. All right. 8 Well, we will just try to make it minimized

9 then. 10 MEMBER DRISCOLL: I think the 11 other thing you can point to is that there are 12 very few time series data or any monitoring 13 data of any nature to document the extent of 14 episodic acidification. There is only a 15 handful of intensive monitoring sites. 16 I think, really, you don't know 17 the magnitude of episodic acidification across 18 the whole landscape. You just have a handful 19 of studies to base this on. So, I think you 20 are much better off going with sort of this

21 base-flow value based on some sort of worst22 case scenario or something like that with Page 328 1 respect to episodic acidification. I think it 2 is the best way to go. At least that is my 3 opinion, anyway. 4 DR. HUBBELL: Okay. Thank you. 5 CHAIRMAN RUSSELL: Andrzej, are 6 you on the phone?

7 MEMBER WEATHERS: He was. 8 CHAIRMAN RUSSELL: I know you 9 were. Are you on mute?

10 MEMBER BYTNEROWICZ: Hello.

11 Hello. 12 CHAIRMAN RUSSELL: Andrzej, good. 13 And definitely, Andrzej, don't leave us 14 because we are going to have writing 15 assignments. 16 MEMBER BYTNEROWICZ: Oh, sure. 17 (Laughter.) 18 CHAIRMAN RUSSELL: So, we're 19 hoping you and Kathleen will definitely -- 20 MEMBER WEATHERS: Oh, no, I 21 haven't put the mute button on. 22 (Laughter.) Page 329

1 CHAIRMAN RUSSELL: Well, we know 2 you are there, but you are going to have 3 writing assignments. So, just keep that in 4 mind. Okay, we may email you, I mean if we 5 can't get you at the end, we may email you 6 those in terms of your chapter leads. 7 MEMBER BYTNEROWICZ: Okay. Well, 8 point 15, I think, as Charlie said, I also 9 agree with that. It is a reasonable approach. 10 I think it is a very innovative approach, 11 which I like. The science and logic behind 12 this concept are good and based on current 13 understanding of the effects of atmospheric 14 deposition for aquatic ecosystems. I really 15 would like to compliment EPA authors for 16 developing this concept because I think it is 17 a very interesting step forward. 18 I see a lot of potential problems. 19 We will be discussing them more. Mostly they 20 are related, in my opinion at least, they are 21 mostly related to conversion of the position 22 to concentrations of individual components of202-234-4433 Neal R. Gross & Co., Inc. Page 330 1 deposition or individual chemical species and, 2 also, to the unknown levels of uncertainty at 3 various stages of the proposed methodology. 4 One thing I would like to mention 5 which I wanted to mention before, but I was 6 disconnected. I agree with Charlie that, in 7 regards to an approach for the terrestrial 8 ecosystems acidification of soil, so acidity 9 of soil solutions may be a very good approach, 10 and it may be a very good link to what the 11 Europeans are doing in their approach, ICPP 12 approach to critical loads in Europe. 13 But I see a potential problem in 14 the West because, very often, in arid 15 environments you have problems with getting 16 enough soil solution to measure acidity. So, 17 I would like to hear maybe from the EPA staff 18 how they would like to approach that problem. 19 In regard to acidification of 20 aquatic ecosystems in the West, we have lakes, 21 but they are not as frequently occurring as in 22 the Eastern United States. So, how good of Page 331 1 spatial coverage of understanding of 2 acidifying effects it would have? 3 So, basically, these are my 4 comments to point 15. 5 CHAIRMAN RUSSELL: And actually, 6 just as a comment, what I think we will do is 7 at least wait until the end of each charge 8 question to get EPA's response. 9 MEMBER BYTNEROWICZ: Okay. 10 CHAIRMAN RUSSELL: Ellis? 11 MEMBER COWLING: I agree that 12 this -- 13 CHAIRMAN RUSSELL: Ellis, 14 microphone. 15 MEMBER COWLING: Oh, yes, yes, 16 yes. 17 I find this idea of the AAPI as 18 very sensible and logical. I think it has 19 been well-presented. 20 But I couldn't help but think 21 about what this would mean in terms of the 22 educational demands on the people who are Page 332 1 going to be implementing these. There's going 2 to be a huge amount of effort necessary to get 3 the people who have been doing air quality 4 management in this country to think in these 5 very different terms that would be required. 6 They are not dealing with the relationship or 7 a more or less direct relationship between 8 atmospheric concentration and an outcome, but 9 having to first learn that there is a 10 relationship between deposition and an 11 ecosystem response or a feature of an 12 ecosystem like an ANC. 13 So, my major reaction to item 15, 14 as I wrote down, was to think through what a 15 huge transformation will need to be made in 16 the skills and knowledge awareness of the 17 people who will be implementing these 18 standards, developing state implementation 19 plans, dealing with the question of how do we20 cope when our area has been designated non21 attainment or something of that kind. 22 So, it seems like a logical way of Page 333 1 dealing with this. My major reaction had to 2 do with the challenge of educating people to 3 use it, and to use it in an appropriate way. 4 Do you want to do others like 16

5 or -- 6 MS. BARRY: Well, no. We are 7 staying on 15. 8 MEMBER MITCHELL: So, I agree with 9 what has been said previously. I just would 10 want to emphasize the need to be sure that the 11 episodic component is somehow encapsulated and 12 covered within this because episodic 13 components, if we think about climate change, 14 the predictions are going to become greater 15 and greater. So, I don't think it is 16 necessary to do a detailed analysis of how 17 those climate changes are going to be affected 18 by this, but at least to show how episodes, 19 whether it is snowmelt, but it also can be 20 droughts, can all relate to acidification, and 21 at least maybe show some examples of how the 22 standard would encompass that, without going202-234-4433 Neal R. Gross & Co., Inc. Page 334 1 into a detailed coverage of that. 2 It is robust. That would be the 3 idea, under the conditions of climate changes.

4 CHAIRMAN RUSSELL: Kathleen?

5 MEMBER WEATHERS: I have not much 6 to add to what has been said already. I 7 agree. I do think that it is worth stating, 8 once again, what Charlie was just talking 9 about, which is that there's no reason to 10 expect that real-time atmospheric deposition 11 or concentration would show up in aquatic 12 systems in any measurable way in terms of ANC 13 or anything else. So, making sure that that's 14 clear and that the AAPI, basically, takes into 15 account the terrestrial systems. So, we are 16 looking at an aquatic standard here, but what 17 comes from the atmosphere is being passed 18 through the terrestrial system. 19 We also talked about unpacking the 20 G term a little bit earlier. I think that is 21 still important to do.

22 CHAIRMAN RUSSELL: The Panel? Page 335 1 MEMBER CHESTNUT: Ted? I'm just 2 wondering here, we keep asking questions that 3 add to complexity. It seems like there's 4 large areas of the country that are clearly 5 going to be in compliance because there's no 6 sensitivity. Is there some way to make it 7 simpler there? That, okay, your baseline for 8 something is above this level; we don't need 9 to collect all this data and do all this 10 modeling to determine compliance. I mean it 11 is just you are clearly safe. 12 DR. HUBBELL: Do you want us to 13 respond to that or do you want us to wait 14 until the end? 15 CHAIRMAN RUSSELL: Yes. Actually, 16 at this point, your thoughts on all of the

17 comments. 18 DR. HUBBELL: Okay. 19 CHAIRMAN RUSSELL: Any questions 20 and clarifications. 21 DR. HUBBELL: Let me start with 22 Laurie's because it is a nice opening for me Page 336 1 to say this, which is we were discussing, 2 again, in the break about the issue of areas 3 where nitrogen is beneficial. I have been 4 kind of struggling with this because I'm like, 5 well, the standards will still apply there, 6 but people just won't have to do anything. 7 The question is, well, are you making that

8 clear? 9 So, I think that is one of our 10 hopes this next time around, is to include 11 formally in the way we present these equations 12 that we are only talking about, as Dr. Hanson 13 was saying, we are only talking about 14 sensitive areas. We are not talking about 15 getting major reductions in places that 16 clearly aren't sensitive. 17 Our ANC formulation kind of builds 18 that in because it takes into account the 19 background natural ANC in the process. So, if 20 your ANC is very high already, you know, it is 21 going to be something that is already 22 protected. If it is too low naturally, then Page 337 1 it means that you are not going to try to seek 2 protection that will define the standard in 3 such a way that avoids that. 4 So, I think what we need to 5 provide is a map, which we have tried to do by 6 showing maps of sensitive areas. But we need 7 to show a map of what will the standard look 8 like in those areas that are clearly not 9 sensitive, and are they going to be clearly 10 identified in a way that allows them to 11 understand that additional reductions of NOx 12 and SOy wouldn't be required in those areas 13 that are not sensitive? I think that is what, 14 we will try to find a way to do that. 15 But I think that is correct. I 16 mean the standards will apply everywhere, but 17 the standards may already be complied with in 18 places that have either not much deposition or 19 places that are naturally not sensitive. 20 Either they are not naturally sensitive to 21 acid or they are not sensitive to nutrient 22 deposition in terms of the adverse effects.202-234-4433 Neal R. Gross & Co., Inc. Page 338 1 Places that get benefit from that will be 2 covered, but they won't necessarily have to do 3 anything additional. 4 So, the answer is, yes, we need to 5 do something to try to express that in a very 6 clear way because I think that is what is 7 causing some of the confusion, is an 8 impression that somehow we are going to try to 9 look for reductions in places that simply 10 aren't sensitive. 11 CHAIRMAN RUSSELL: And with those 12 maps, hopefully, side-by-side you also have a 13 map of the air quality metric and the 14 loadings. 15 DR. HUBBELL: Yes, absolutely. In 16 fact, we will probably try to do some type of 17 an overlay of that -- 18 CHAIRMAN RUSSELL: Okay. 19 DR. HUBBELL: -- so that you can 20 see them together, so that you can get an idea 21 of what the concentrations are, what the 22 deposition is, and then what the sensitivity Page 339 1 parameter would be at ANC or base 2 cation/aluminum ratio, et cetera, would be, 3 and where some of the thresholds are. So, 4 yes, I think we are definitely trying to do

5 that. 6 And let me just make one more 7 comment, too. In terms of how to address 8 sensitivity in the West, you know, there is a 9 concern that, for example, for nutrients -- we 10 were talking about that earlier -- that, for 11 nutrients, much lower levels of deposition of 12 nitrogen in the West are going to lead to 13 effects than in the East. Yet, in the West 14 the acidification problem is not as pronounced 15 in terms of sensitivity to the acidification. 16 So, there is clearly different 17 balances of the importance of the different 18 standards in different parts of the country. 19 That is somehow going to have to be reflected 20 in the final statement about the 21 protectiveness nationwide of the different 22 types of standards. I am not sure exactly how Page 340 1 we are going to deal with that yet, but it is, 2 clearly, something we have to address. 3 DR. SCHEFFE: And I would like to 4 kind of circle back a little bit. Andrzej 5 raised the point about the individual species 6 and some uncertainties. I would like to bring 7 this a little bit back to some of the 8 uncertainties in general. 9 We have talked about how complex 10 this is, and we keep adding another layer of 11 complexity here, there, and everything, but I 12 would actually like to show how in some ways 13 we have a great opportunity here, that it 14 might not be all that complex from a certain 15 perspective. It has to do with aggregation. 16 I will use the analogy. When we 17 use the CASTNET data -- and by the way, we do 18 quite a lot of evaluations of CMAQ using the 19 CASTNET data because it is a very rich 20 multiple-pollutant dataset. We look at that 21 CASTNET data. We don't look at the individual 22 species necessarily. We don't look at just Page 341

1 nitric acid alone or ammonium alone. 2 The reason we don't do that is 3 because there's artifacts associated with the 4 monitoring methods. We combine those, and 5 when combining those, we have a lot more 6 confidence in the total nitrogen that is 7 provided by those CASTNET measurements. We, 8 then, have a lot more confidence that the 9 model is actually reproducing those values for 10 the right reasons. 11 A lot of what we are talking about 12 here is multiple aggregation steps. So, the 13 beauty of NOy, for instance, it is an 14 aggregation of many, many species. If you 15 asked us to base a standard on NO2 alone in 16 rural areas or NO alone or nitric acid alone, 17 that would be extremely difficult. The 18 uncertainties would be all over the place. 19 But when we start aggregating and 20 combine those, there's a lot of canceling out 21 of those uncertainties. We have a lot of 22 confidence from a general mass balance202-234-4433 Neal R. Gross & Co., Inc. Page 342 1 perspective that what comes out from the 2 emission sources and our inventorying of 3 emissions, what gets transformed in the 4 atmosphere and eventually wet deposits from a 5 total mass balance is pretty darn good. We 6 have a lot of confidence in that. 7 Do we have much confidence in the 8 individual species? No. So, I mean, that is 9 something that is very important to bear in 10 mind. 11 A similar argument for sulfur, not 12 quite as important because of fewer 13 complexities in sulfur. And I would say the 14 same thing, that we are also aggregating time 15 and space quite a bit here as well. We are 16 not talking about looking at time and space 17 comparisons at the hourly or the daily level. 18 We are talking about doing that at the annual 19 level. That is the driver that is pushing all 20 of this. 21 Also, in terms of space, we are 22 not looking at an individual catchment. As we Page 343 1 have all noted, we are looking at areas that 2 are going to be aggregated. 3 So, I think there's a lot of 4 possibilities here that the complexities and 5 the uncertainties are not overwhelming and 6 they are very manageable. 7 CHAIRMAN RUSSELL: And that brings 8 us right into Question 16. Rudy, if it is 9 something quick, we can do it before -- 16, 10 which deals directly with uncertainties. 11 MEMBER HUSAR: Sixteen. Move on. 12 CHAIRMAN RUSSELL: Sixteen, 13 because 16 is the uncertainty question. 14 Charlie?

15 MEMBER BYTNEROWICZ: Hello.

16 Hello. 17 CHAIRMAN RUSSELL: Andrzej? 18 MEMBER BYTNEROWICZ: That's me, 19 yes? Okay. 20 CHAIRMAN RUSSELL: Oh, we forgot

21 Kathleen. 22 MEMBER BYTNEROWICZ: Charlie Page 344 1 first, yes, or me? 2 CHAIRMAN RUSSELL: Well, did we 3 have any further discussion on 15? 4 (No response.) 5 Or let's move on to 16. Sixteen. 6 Charlie? 7 MEMBER DRISCOLL: Okay. I really 8 don't have anything to add beyond what I 9 already had to say, that there are several 10 sensitivity or uncertainty studies that have 11 been conducted on acidification processes and 12 acidification models that I think could help 13 bound this uncertainty. I really can't 14 comment on some of the issues concerning -- 15 where is it here? -- averaging times, but I 16 think some of the other things have been 17 discussed in the literature and could be 18 utilized. 19 CHAIRMAN RUSSELL: Andrzej? 20 MEMBER BYTNEROWICZ: So, is that

21 me now?

22 CHAIRMAN RUSSELL: Yes. Page 345

1 MEMBER BYTNEROWICZ: Yes. Okay. 2 Well, I think the lowest level of uncertainty 3 would be for ANC, protection in fish related4 to ANC. On the other hand, concentration-to5 deposition ratios, there is a high level of 6 uncertainty, of course. I would like to learn 7 more about that aggregation of individual 8 species and how you will deal with that 9 because it sounds quite intriguing to me. So, 10 maybe those issues could be somehow dealt with 11 in a new, innovative way. 12 The position relative to reactive 13 issues such as NH3 or regarding nitrogen 14 present a high level of uncertainty, and 15 deposition velocities to terrestrial 16 ecosystems even more. 17 I think one weak point in regards 18 to what we can do on the national scale is 19 relying on CMAQ for reduced nitrogen for 20 ammonia because, generally, from what I know 21 and what my colleagues know and others, CMAQ 22 is really not dealing with reduced ammonia202-234-4433 Neal R. Gross & Co., Inc. Page 346 1 well. So, here I would expect that there's 2 quite a lot of uncertainty related just to our 3 abilities to understand distribution of 4 ammonia on a national scale, especially in

5 remote areas. 6 So, these are my comments for this 7 point. 8 CHAIRMAN RUSSELL: Ellis? 9 Microphone. 10 MEMBER COWLING: Thank you. 11 I was thinking of uncertainty with 12 regard to spatial variability as being much 13 better handled than uncertainty with regard to 14 temporal variability. That was the only

15 comment that I had. 16 I also suggested that Rich Poirot 17 probably would have a better insight into 18 these matters than I think I would from my 19 experience since he is an air quality manager, 20 and I can only kibitz about such things. 21 MEMBER POIROT: I agree with 22 Ellis. Page 347

1 (Laughter.)

2 CHAIRMAN RUSSELL: You have 3 kibitzed well.

4 MEMBER MITCHELL: Just to echo a 5 couple of the comments, it can be a major 6 challenge to look at uncertainty, matching the 7 depositional component from CMAQ, because of 8 spatial and temporal differences with the

9 measurements. We talked about that before. 10 DR. HUBBELL: One piece on that. 11 I don't know if we have mentioned this, but we 12 also considered, in addition to taking grid 13 cell and calculating the ratio of deposition 14 to concentration of air, we could also take 15 the average deposition over an area and 16 average concentrations and construct a ratio

17 there. 18 We did some quick analysis of 19 that, and they varied in certain locations. 20 In certain of the sensitive areas, they varied 21 more than others. But in some locations, they 22 are almost identical when you do that, which Page 348 1 suggests there's a lot of homogeneity in both 2 deposition and concentrations. But in areas 3 where there's not, that is one of those cases 4 where maybe we need to shrink the area. That 5 is one of my questions about, is that 6 something that guides the size of a spatial 7 area that we need to work with? 8 MEMBER MITCHELL: Yes, that is 9 going to be a major issue because sometimes 10 overlap with a CMAQ type of thing, you 11 actually have sensitive and unsensitive areas 12 in the same pixel, right? 13 DR. HUBBELL: Yes, that's right. 14 So, it just depends on how much we feel like 15 we need to get down to the details. It may be 16 that we find that in certain types of 17 locations we need to do finer-scale CMAQ 18 modeling. That is something we will have to 19 think about, whether that is something we can 20 do or not. Again, it is difficult sometimes21 to do that if you don't have the properly22 matched emissions and meteorology and other Page 349 1 things at those levels. But it is something 2 that we can consider.

3 CHAIRMAN RUSSELL: Kathleen? 4 MEMBER WEATHERS: Yes. So, I 5 would just like to underscore the comment that 6 someone made about aggregation terms and the 7 importance of that in looking at these 8 uncertainties. I hadn't really been thinking 9 about it that way and had had some angst over 10 the need for defining a lot of the 11 uncertainties at some smaller temporal scales 12 and/or spatial scales. But I think that is 13 really important. 14 We know from experience that, when 15 you look at models like P-NUT or CAM, which 16 tries to do daily models, they are off 17 usually. But if you look at an annual number, 18 they often line up. 19 We know the same is true from 20 looking at CMAQ and CASTNET and NADP data, 21 where the total deposition over an annual 22 basis matches pretty well for those CASTNET202-234-4433 Neal R. Gross & Co., Inc. Page 350 1 points. But if you look at the differences 2 between concentration and dry deposition, 3 there are quite a few differences. 4 So, aggregation I think is really 5 key in looking at these uncertainties to an 6 appropriate scale, temporally a year or three 7 years and spatially as well. 8 CHAIRMAN RUSSELL: And again, I 9 think as we have said on the prior chapter, 10 having a chapter dedicated to looking at 11 uncertainties and sensitivities can address a 12 number of these issues. 13 Particularly, you ask the question 14 here about characterizing -- (interference 15 from the microphones) -- things are going 16 weird. 17 You show that distribution of 18 protection in terms of percent of lakes 19 protected. Try to include that in your 20 uncertainty calculations. 21 (Interference from phone line.) 22 It might be break time. Page 351

1 (Laughter.) 2 But I think that would be good. 3 DR. HUBBELL: Yes, and if I could 4 finish just with one thought on that. In that 5 uncertainty chapter, just to get a better feel 6 for what you are looking for, does it make 7 sense, then, at the end to have sort of an 8 integrated uncertainty discussion with an 9 implications for protection provided?

10 CHAIRMAN RUSSELL: Yes. 11 DR. HUBBELL: Okay.

12 CHAIRMAN RUSSELL: That would be 13 exactly what we would be looking for. 14 DR. HUBBELL: Okay. 15 CHAIRMAN RUSSELL: Okay. So, I 16 think bad things have happened, and we will 17 take a 15-minute break. So, let's get back at 18 3:30, a 19-minute break. 19 (Whereupon, the foregoing matter 20 went off the record at 3:12 p.m. and went back 21 on the record at 3:28 p.m.) 22 CHAIRMAN RUSSELL: All right. I Page 352 1 think we are done with Question 16. 2 Question 17, we have already 3 answered, and that is no. 4 (Laughter.) 5 I think that became the 6 reverberating comment in terms of aggregating 7 them together, though in this case you are 8 talking about five bins based on the 9 geological classification scheme. So, I think 10 the answer is, no, just to aggregating them, 11 but now we get into the five-bin question. 12 So, Charlie, if you want to start 13 off with that? 14 MEMBER DRISCOLL: Well, we talked 15 previously about some of the challenges in 16 using the geological classes in the glaciated 17 areas. I had two things that I want to ask. 18 So, I am not really giving suggestions, but I 19 am actually asking questions. 20 I had mentioned in the morning 21 about covering how you address inputs of 22 organic acids and those effects on ANC. It Page 353 1 seems to me that that is something that is in 2 this background. Is that going to be added in 3 or how is that going to be handled in terms of 4 getting this background ANC value? Do you 5 understand what I am saying?

6 DR. HUBBELL: I do. The answer 7 is, if it is not in there, then, clearly, we 8 will need to add it in there. 9 I need to check with Jason as to 10 whether or not it actually includes that in 11 that BC zero term because I thought that it 12 included some of those. 13 DR. GREAVER: Yes, in the annex or 14 the appendix to Chapter 5, we have a technical 15 summary of the terms in the critical loads 16 model. I was looking at it after you made the 17 comment this morning, and I don't see that18 organic acid was included in our pre19 industrial buffering capacity terms. So, that 20 is something that we will have to look into 21 adding. 22 Do you know if there are extensive202-234-4433 Neal R. Gross & Co., Inc. Page 354

1 datasets?

2 MEMBER DRISCOLL: There are 3 models, actually, that have been developed. 4 There is a series of models that could be used 5 to estimate organic anion concentrations. So, 6 I think there are approaches that could be 7 used that would be reasonably defensible based 8 on land cover data. I mean it is largely 9 driven by wetlands and elevation and 10 vegetation type. 11 DR. HUBBELL: Okay. If you have 12 some references of those models, that would be 13 helpful because I don't -- I mean Jason may 14 know them already, but, if not, then -- 15 MEMBER DRISCOLL: I will write a 16 note, but if I don't send it, remember, my 17 memory is not very good. 18 DR. HUBBELL: We will make a note.

19 MEMBER DRISCOLL: And then a 20 related question -- 21 CHAIRMAN RUSSELL: Actually, 22 before you go on, Charlie, I just have a Page 355 1 question for the people on the Panel. When I 2 was thinking about this, most of your organic 3 acids are probably biogenic in nature, right? 4 So, they should be in the background since 5 they are already, you know, they are biogenic 6 decomposition of the BOCs being emitted. 7 MEMBER DRISCOLL: But they vary a 8 lot in space. 9 CHAIRMAN RUSSELL: They vary a lot 10 in space, but with this background ANC, at 11 least I would have thought that they would 12 already be in there. 13 DR. HUBBELL: Well, that is what 14 we are trying to figure out. We've got to 15 check with Jason. He is our expert on that, 16 and he is not here. So, we will check on 17 that. And if it is not in there, then maybe we 18 will get the models for you that can produce 19 those estimates. 20 CHAIRMAN RUSSELL: Okay. It was 21 just how you determine your background ANC. 22 If it is truly a background, it should be Page 356

1 there.

2 DR. HUBBELL: Yes. It would be 3 included in that G term. Whether it is 4 actually in there, I am not sure. But if it 5 is not, we will add it to that background

6 term.

7 MEMBER DRISCOLL: The other 8 question I had, and this is based on something 9 that Tara said this morning that I may have 10 misunderstood, if the ANC is less than 50, did 11 you say that you don't consider it, the site? 12 DR. GREAVER: Oh, in how we

13 excluded some of our catchments from our 14 population?

15 MEMBER DRISCOLL: Yes. 16 DR. GREAVER: So, the way that we 17 did that, we calculated critical loads for ANC 18 equals 50 for everybody. Then, if the 19 critical load was less than 10, I believe, we 20 excluded it, with the thinking that there was 21 probably that much uncertainty, maybe 10 22 milliequivalents, in our critical load Page 357

1 calculation. So, if the critical load could 2 possibly be zero, we took it out of our 3 population. 4 DR. HUBBELL: Thinking that if the 5 critical load was zero, then it must mean that 6 the natural acidification, the natural ANC was 7 below 50. Now, obviously, that would change. 8 If we want to do it on the 20, or if we went 9 up to 100, then the ones that are included 10 actually would change.

11 MEMBER DRISCOLL: Is that 12 description written somewhere in this

13 document? 14 DR. GREAVER: No, I'm sorry, it is 15 not in there. 16 DR. HUBBELL: If you want to 17 criticize that, that is fine. It is just 18 something that we didn't stop thinking when we 19 turned in our paper. We kept on thinking. 20 MEMBER DRISCOLL: No, no, that's 21 fine. It is just hard to criticize what you 22 can't -- you know, but I heard this in202-234-4433 Neal R. Gross & Co., Inc. Page 358 1 passing, and I was thinking I didn't see 2 anything on that. So, if that could be 3 developed, I think that would be -- because 4 people are going to be very interested in 5 those very low ANC systems. Those are the 6 systems that are actually showing the greatest 7 rate of response to decreases in deposition. 8 DR. GREAVER: Does that seem like 9 a reasonable way to you, to exclude some of 10 those that may have naturally ANC below 50? 11 MEMBER DRISCOLL: If I was king, I 12 would do it with trying to estimate the 13 organic acids. I think, then, it is more 14 transparent. But there are sites that will 15 have, I think either based on paleo data or 16 based on reconstructions, there are sites that 17 will have historical ANCs that will be below 18 50. There's no doubt in my mind. 19 DR. HUBBELL: But our point is 20 that, if we choose a standard based on a 21 target of an ANC of 50, and there's no way 22 they can reach it with any reductions in NOx Page 359 1 or SOy, it is not really going to be 2 appropriate to focus on those as a place to

3 set standards for NOx and NOx. 4 MEMBER DRISCOLL: No, I understand

5 that. I understand that --

6 MEMBER WEATHERS: But --

7 CHAIRMAN RUSSELL: Kathleen? 8 Well, keep going. Charlie, keep going.

9 MEMBER DRISCOLL: I understand 10 that, but it is also important, it seems to 11 me, to the managers, particularly the local 12 managers, to understand that those systems are 13 not recoverable at least from the standpoint 14 of the target that you are establishing. So, 15 maybe they have other ideas for those types of 16 systems. 17 So, it seems to me to make it 18 clear that there is a cutoff, so that can be 19 part of the discussion. 20 DR. HUBBELL: Yes, that would 21 definitely be part of the discussion with the 22 Administrator, as to what that level should Page 360

1 be. And also, the converse, we are also 2 talking about ways, if the natural ANC of an 3 area is 150, then, as Laurie was saying, it 4 would be very simple to come up with saying, 5 "Look, if your natural ANC is 150, you don't 6 need to worry about it. You are in 7 compliance. You don't need to monitor," or

8 whatever else. 9 So, we are trying to think of ways 10 to bound those conditions. 11 MEMBER DRISCOLL: Yes, yes. Okay. 12 CHAIRMAN RUSSELL: Kathleen, you 13 were saying something? 14 MEMBER WEATHERS: Well, yes, I was 15 first trying to get clarity, but I think I 16 just got it, which is the goal is to exclude 17 the organic acidity freshwaters, right, as 18 opposed to those that have been acidified from 19 strong mineral acids? 20 DR. GREAVER: Yes, exactly. 21 MEMBER WEATHERS: Yes. So, saying 22 that is the goal upfront I think is really Page 361 1 important, but I wonder if you can use other 2 chemical indicators, such as high DOC versus 3 high sulfate or nitrate. So, I wonder if 4 there is another way to do it, rather than 5 just ANC or ANC and a combination of things

6 that exclude those freshwaters from the

7 database or from the standard.

8 DR. HUBBELL: Let me make sure I 9 understand. You are suggesting that, in terms 10 of the exclusion indicator, the exclusion 11 indicator may be different than the ecological 12 indicator that we target for the standard? 13 MEMBER WEATHERS: Right, or maybe 14 an "and" function. 15 DR. HUBBELL: Okay. 16 MEMBER WEATHERS: So, it is low 17 ANC, but the reason is because it is organic 18 acidity. 19 DR. HUBBELL: So, it might be, if 20 ANC is below 50 or below 20, or whatever the 21 background ANC, it is below that, and this 22 other indicator?202-234-4433 Neal R. Gross & Co., Inc. Page 362 1 MEMBER WEATHERS: Right. 2 DR. HUBBELL: Okay. 3 CHAIRMAN RUSSELL: Andrzej? Are 4 you back on? 5 MEMBER BYTNEROWICZ: I don't think 6 I have a lot to add for Question 17. I 7 thought it was a good idea to introduce 8 fraction G. Too bad I missed the discussion 9 in the morning, so I would have a better 10 understanding of different points of view. 11 I think, in general, terms using 12 geologic clarification is a good idea, since 13 chemistry and weathering of geologic material 14 is a main factor affecting abilities of the 15 lakes and other aquatic ecosystems to cope 16 with acidification. 17 So, that is basically what I have. 18 CHAIRMAN RUSSELL: Ellis? 19 MEMBER COWLING: I just want to 20 say I -- 21 CHAIRMAN RUSSELL: Microphone. 22 MEMBER COWLING: Oh, yes. Page 363

1 (Laughter.) 2 I thought that this idea of making 3 bins, whether you have five or you might have 4 more, I don't know, but I developed a 5 practiced sentence to describe how little I 6 know about these things. You will find this 7 sentence repeated many times. 8 "I have no direct experience from 9 which to offer a well-informed, professional 10 judgment in response to this question." 11 (Laughter.) 12 I don't really know how the bins 13 would work, but it seems sensible to me. So, 14 carry on. 15 CHAIRMAN RUSSELL: Myron? 16 MEMBER MITCHELL: I think all my 17 comments I have already covered in other

18 statements. 19 CHAIRMAN RUSSELL: And Kathleen, 20 did you have any other comments on this 21 question? 22 MEMBER WEATHERS: No. Ditto to Page 364 1 Myron.

2 CHAIRMAN RUSSELL: Panel? 3 (No response.) 4 Question 18. Charlie, do you want

5 to start us off? 6 MEMBER DRISCOLL: This is one that 7 I have -- I don't know; you said it so 8 eloquently, Ellis -- no expertise. So, I am 9 going to punt. 10 (Laughter.) 11 So, I will pass it onto my 12 colleagues who have more experience in terms 13 of atmospheric deposition. 14 CHAIRMAN RUSSELL: Andrzej? 15 MEMBER BYTNEROWICZ: Well, maybe I 16 can add something. I have some comments. 17 One is it is kind of a question 18 related to a symbol of V used for describing 19 concentration-to-deposition ratios. For me, 20 it was quite misleading because normally V is 21 for deposition values, for deposition velocity 22 values. So, in that case, I don't know, maybe Page 365 1 another symbol could be considered. 2 In regard to CMAQ models, well, we 3 all know that there are some shortcomings of 4 those models, and especially, as I mentioned 5 before, in regard of nitrogen compound. So, 6 here I would like to make a comment that 7 recent EPA efforts to start measuring ammonia 8 with plastic samplers on a CASTNET network is 9 a really great thing which is going to help a 10 lot with understanding what real levels of 11 ammonia we have in remote areas. That would 12 help us not to be reliant on CMAQ values only. 13 And you have, on the other hand, 14 to maybe test the CMAQ output. 15 So, that's the basic comments I

16 have. 17 MEMBER MITCHELL: I guess in the 18 question itself, it seems like to me in terms 19 of looking at the relationship between 20 concentration-to-deposition ratio, a more 21 critical analysis would be the actual error 22 terms associated with the deposition202-234-4433 Neal R. Gross & Co., Inc. Page 366

1 velocities themselves. I mean that is what is 2 really going to drive it. 3 So, how, within the CMAQ model 4 applications, can you actually validate, 5 check, whatever you want to call it, the 6 deposition velocities? I mean that is a 7 critical issue. We all know, everybody that 8 deals with this issue knows that, but I think 9 at least to indicate some possible boundaries 10 on those would be helpful.

11 CHAIRMAN RUSSELL: Kathleen? 12 MEMBER WEATHERS: I agree with 13 Myron's comments. I think that there are some 14 discrepancies between CASTNET measurements and 15 CMAQ in that regard, where concentration and 16 deposition velocities vary enough so that 17 deposition estimates are similar. So, I agree 18 with Myron. 19 CHAIRMAN RUSSELL: Naresh, did you 20 want to add anything to this? 21 MEMBER KUMAR: I guess we have 22 talked about the uncertainties earlier. One Page 367 1 I can currently think of are definitely 2 emissions, both of ammonia and NOx. I think 3 there are a lot of uncertainties there. 4 One thing which has not been 5 talked about is inability of the models to 6 really predict clouds and liquid water 7 content. So, there is a lot of uncertainty. 8 There were some papers discussed 9 in the last CMAS meeting where you might get 10 the right answer for the wrong reasons because 11 you underpredict river water content and 12 overpredict clouds, or vice versa. I forgot 13 which one. But the combination of that might 14 give you the right ballpark figure, but that 15 is not going to work, depending on the control 16 strategies. So, I think that that uncertainty 17 is definitely there. 18 Of course, the cloud chemistry, 19 there are a lot of limitations of the cloud 20 chemistry. 21 So, what is the answer to 22 determining the implications, which we, I Page 368 1 think, talked about earlier? It is, again, 2 use different models, different ecological 3 models or different years and different air 4 quality models to draw a bound to your

5 numbers. 6 CHAIRMAN RUSSELL: Yes, I would 7 warn you that wouldn't be a bound necessarily, 8 since they are based on the same sort of 9 assumptions, but that would be an indication 10 of an uncertainty by taking the various model

11 results. 12 DR. HUBBELL: Can I ask just a 13 followup on that? I mean we talked just a 14 little bit about this, but is there any 15 benefit thinking about some type of a data 16 fusion approach? Because I know there's not 17 a lot of observations for ammonia or for some 18 of the other species, especially in areas that 19 we are most interested in. But is there any 20 benefit to thinking about data fusion? 21 MEMBER WEATHERS: Say what you 22 mean by data fusion. Page 369

1 DR. HUBBELL: I mean, you know, 2 either taking the monitors and adjusting them, 3 and adjusting the model outputs by some type 4 of an interpolated model field or other type 5 of data-matching approach, but, basically, 6 using the model in a relative sense, rather

7 than an absolute sense. 8 CHAIRMAN RUSSELL: There is a 9 danger here. That is one reason I wouldn't 10 necessarily go down this road. 11 Let's say you used data fusion on 12 the concentrations, which I think is a fine 13 thing to do if what you are interested in is 14 getting a best estimate of a concentration 15 away from a monitor at some other location. 16 But here what you want to do is you want to 17 get this deposition transmission ratio. So, 18 you would have to both use data fusion both in 19 terms of the observations on the 20 concentrations as well as the observations on 21 the deposition. 22 One of the problems there is you202-234-4433 Neal R. Gross & Co., Inc. Page 370 1 only have observations on the deposition in 2 terms of wet deposition, which that is a very 3 fine-scale thing. 4 And the dry deposition would be an 5 unknown that you couldn't really do. So, I 6 would be worried that what you would end up 7 with is very much a mixture of apples and 8 oranges when you do this division. 9 DR. HUBBELL: Okay. 10 CHAIRMAN RUSSELL: And given that 11 I think we know the dry deposition velocities 12 relatively well within these models, I think 13 that might just be opening up a whole new area 14 of uncertainty. 15 DR. HUBBELL: Okay. That makes

16 sense.

17 CHAIRMAN RUSSELL: At least that 18 is my take. Anyone else who has thought about 19 this? 20 MEMBER WEATHERS: Yes. Yes, I'm 21 not sure I agree with the statement that dry22 deposition velocities are relatively wellPage 371 1 known or constrained. So, can you say more 2 about that? Because I think that that is one 3 of the major uncertainties, as Myron pointed 4 to, and I agree with. 5 CHAIRMAN RUSSELL: Well, there is 6 the review by Wesley, probably in -- what was 7 it? -- 1993. I would say he was sort of was 8 the leader at the time. He really put that 9 constraint pretty tight compared to many of 10 the other things. 11 So, I just look at that as one of 12 the things we know better within the models. 13 I have people on my righthand side who are 14 grabbing their microphones to say no. 15 (Laughter.) 16 MEMBER WEATHERS: Yes, I'm doing

17 the same. 18 MEMBER BYTNEROWICZ: I would like 19 to say something, too. 20 Judging from what I know about 21 Western ecosystems, it is so variable, and we 22 know about deposition velocities of few Page 372 1 species to few ecosystems, that it is really 2 difficult to say that it is well-known. In my 3 understanding, it is still the area which has 4 to be developed. So, a high level of 5 uncertainty for me. 6 MEMBER MITCHELL: I would agree 7 there is a high level of uncertainty compared 8 to, for instance, I have seen, looking at the 9 CATMEN and the CASTNET sites, the Edmond site. 10 There is a gigantic amount of difference in 11 deposition and associated with which 12 deposition velocity you utilize. If you 13 compare the ARMS model and the CMAQ model, 14 there's differences there. It is my 15 understanding that those differences are 16 associated with how deposition velocities are

17 calculated. 18 So, I think it is really a major 19 unknown; plus, we don't even know in terms of 20 all the types of surpluses associated with 21 these different sites what actually deposition 22 velocities you would utilize across the actual Page 373 1 heterogeneous surfaces. 2 So, I think it is really one of 3 the major issues that we have to deal with. 4 CHAIRMAN RUSSELL: So, would you 5 be talking a factor of two? Ten? 6 MEMBER MITCHELL: Honestly, I 7 think there are people over here who could 8 answer this question better than I would. I 9 think it is highly dependent on the chemical 10 species. 11 MEMBER BYTNEROWICZ: And also, on 12 the environmental conditions. 13 CHAIRMAN RUSSELL: Rudy? 14 MEMBER HUSAR: Regarding the 15 chemical species, that to me is the 16 difference. In other words, for sulfur 17 dioxide, sulfate, it is pretty well 18 constrained, in particular, by the weather 19 position data as well as the overall mass 20 balances and everything. It has been pretty 21 well stabilized over the years? But nitrogen 22 compounds, the various mix of nitrogen202-234-4433 Neal R. Gross & Co., Inc. Page 374 1 compounds, all of a sudden, everything, the 2 variability is substantially higher. 3 So, whenever this uncertainty is 4 to be specified, it is in that area. That is 5 where, of course, Naresh's comment about where 6 does that uncertainty or inability of the 7 model to reproduce the observations come from, 8 is that the emissions or is it that it is in 9 the inside the guts of the model? 10 The lack of the ability to perform 11 these so-called closure experiments, closure 12 where you can mass balance out everything, it 13 is just not there. That is in the case of NOx 14 and, of course, in particular, for ammonia. 15 CHAIRMAN RUSSELL: Rich, you had a 16 point? 17 DR. SCHEFFE: Well, kind of a 18 little bit in response to some of these 19 things, and let me start with the velocity and 20 then go back to ammonia. Okay? There are a 21 couple of points. 22 I think Ted hit it really on the Page 375 1 nose. Deposition velocity is misnamed. I 2 mean it is a mass transfer process that is 3 governed in a large way, especially with 4 gases, by reaction considerations. Those 5 reactions, of course, have to do with a lot of 6 the plant physiology processes as well as 7 different things going on with surfaces and

8 stuff. 9 So, it is a model, in essence, it 10 is a model process. It is not really 11 something that is measurable.

12 The reason we feel that the best 13 approach to this is through modeling is 14 because the models, really, they are 15 inventories of all of the salient information 16 that goes into modeling those processes, 17 whether it be the surfaces, whether it be the 18 vegetation types, whether it be the 19 meteorological variables, and, in turn, the 20 thermodynamic processes that control all of 21 that. We really don't see any other way of 22 doing it. Page 376 1 The idea of trying to do kind of 2 uncertainty on kind of a term like deposition 3 velocity, it is just hard to get a handle on 4 it. I think we can get a better handle on 5 trying to improve, you know, all of the inputs 6 to those models that deal with characterizing 7 deposition velocity. 8 Remember, in CASTNET, that CASTNET 9 models, I mean there is a model that goes in 10 the CASTNET. It is based on you have simply 11 an ambient concentration. Then, that is 12 modeled in terms of what is the so-called, I 13 will call it mass transient rate from the 14 concentration to surfaces. So, really, I am 15 not sure how we can go about doing that. 16 Now the other thing on ammonia, 17 and I keep hearing CMAQ doesn't do a good job 18 with ammonia. So a few things. 19 Largely, the ammonia emissions 20 characterization is an area that needs 21 improvement. Probably, in that area, as an 22 input to CMAQ, that is probably one of the Page 377 1 areas of greatest uncertainty. I think we 2 have to probably be a little clear about that. 3 There also is a lot of work that 4 needs to be done, that is being done, in sort 5 of the bidirectional transfer of nitrogen in 6 general and ammonia in particular between the 7 soil and the atmosphere, and how that has 8 worked. There is a lot of work in terms of 9 coupling that to the meteorological models 10 because that is driven, of course, by soil 11 temperatures and ambient temperatures. That 12 is another mass transfer process. There's a

13 lot of work there. 14 But one thing to think about with 15 ammonia, ammonia will become of increasing 16 importance as we start kind of moving towards 17 the area of ammonia sources. As we move 18 towards more and more remote areas, ammonia -- 19 because remember the gradients, that the 20 levels of ammonia are highly correlated with 21 the sources themselves because ammonia does 22 come out very quickly in the atmosphere. So,202-234-4433 Neal R. Gross & Co., Inc. Page 378 1 there are some of those things. 2 So, in terms of an aquatic 3 acidification standard, the focus here, 4 ammonia itself probably isn't quite as 5 important as the consideration of ammonia

6 would be for other effects. 7 So, those are just a few points, 8 and two other things. The other great area in 9 terms of model improvement is in getting the 10 wet deposition fields better. I think we have 11 a general feeling in the modeling community 12 that the model handles dry deposition as well 13 as any other process we can put, but in terms 14 of wet deposition, because of kind of the cast 15 nature of precipitation events, it is really 16 hard to kind of get a handle on that with 17 modeling processes. 18 Now this isn't fusion, getting 19 back to Bryan's point, but there is a lot of 20 work now because there are so many 21 measurements of precipitation, and there are 22 ways of going about taking those measurements Page 379 1 of precipitation and kind of relating that to 2 scaling that back to the modeling fields and 3 doing a lot of interpolation with these PRISM 4 techniques, and so forth. There is a lot of 5 promise there in terms of improving the wet 6 deposition estimates. So, there is a lot of 7 hope there. 8 And finally, lightning NOx, which 9 is another area of big improvement in the

10 models. 11 So, those are three or four 12 general areas where you will have to comment 13 in terms of uncertainties and improvements. 14 MEMBER WEATHERS: Well, let me put 15 it in context, maybe in a different way. 16 So, one of the concerns I have is 17 that, let's say for a grid cell size of 12 18 kilometers for CMAQ, there are deposition 19 velocities that are part of the model that 20 have to do with land use, land cover, and also 21 are influenced by chemical species. Correct?

22 DR. SCHEFFE: Yes. Page 380 1 MEMBER WEATHERS: And this gets to 2 the point of drawing boundaries around the 3 areas of interest. So, if the areas of 4 interest are much smaller than that or 5 sensitive systems are at, say, high-elevation 6 exposed ecosystems, the deposition velocities 7 are going to be likely quite different. So, 8 that is a level of uncertainty that I think is 9 important that drives deposition and this 10 ratio as well, that may turn out to be the 11 wrong ratio or the wrong deposition velocity 12 for the area of interest for looking at ANC.

13 Does that make sense? 14 DR. SCHEFFE: Yes, I think that 15 makes sense. I think if we were looking at 16 micro-scale receptors, I think the problem 17 would be much more complex than it is. But I 18 think since we are actually thinking the other 19 way, that we are expanding out, and we are 20 looking at grouping many, many catchments into 21 much larger kind of grid-celled domains, that 22 the issue of the subgrid scale variability is Page 381 1 less. So, that is one thing that is going on.

2 There also are some more 3 treatments because I think a little of the 4 land use and the vegetation features and a lot 5 of those, you know, the information sources 6 are coming at finer and finer scale. We are 7 able to start using some of that information 8 in the model for some of the 9 parameterizations. Granted, of course, that 10 the concentration fields are still limited by 11 the grid cell. 12 MEMBER WEATHERS: Yes. Right. 13 So, right, if those boundaries, the watersheds 14 or the bedrock areas accumulate, so that they 15 map onto the CMAQ grid cell size, then, yes, 16 I agree with you. But if they don't, I think 17 it is a huge issue. 18 CHAIRMAN RUSSELL: So, you got 19 some mixed information there. We will see

20 what we can do on the letter. 21 Question 19. Well, first, were 22 there any more comments from the Panel on that202-234-4433 Neal R. Gross & Co., Inc. Page 382

1 one, on 18? 2 (No response.) 3 Nineteen, Charlie? 4 MEMBER DRISCOLL: I'm going to let 5 Ellis keep his own microphone for the future. 6 (Laughter.) 7 I actually like this tradeoff 8 curve. I think it sets the ideas out there, 9 although I think it could be described a 10 little bit better. I had to read it several 11 times. But I think once I got it, I think I 12 like it. 13 Just for your information, we have 14 been doing some critical loads work in the 15 Adirondacks. We have been developing similar 16 curves using a dynamic model. They look very 17 different than your theoretical steady-state, 18 as you might imagine. So, I think it is quite 19 interesting. 20 But I think it is a good idea the 21 way it is framed. I think it helps sort of 22 set that out to look at the tradeoffs. So, I Page 383 1 would endorse this approach. 2 CHAIRMAN RUSSELL: Other people on

3 the Panel? 4 MEMBER WEATHERS: I agree. 5 MEMBER BYTNEROWICZ: I agree. I 6 see one level of quite high uncertainty, which 7 would be final calculation of NO2 and SO2 8 concentrations, but that is another issue. 9 DR. HUBBELL: One of the things we 10 are grappling with is, when we get to this 11 point -- and obviously, we have several more 12 drafts that we can work through this in -- but 13 we can present the standards in terms of 14 directly the AAPI equation; we can present 15 them in terms of these tradeoff curves. We 16 can talk about compliance in terms of just 17 match these NOx and SOy concentrations with 18 these tradeoff curves and you're done. 19 That is what Tara was trying to 20 show. You can just say, if you are down here 21 in this region of the graph, you are in 22 compliance; if you are up here, you're not. Page 384 1 So, one of the things, as we go 2 through this process, and I think this gets at 3 Ellis' concern, is in terms of which method 4 both most clearly represents the concept we 5 are trying to do in terms of protection and 6 the level of the standard, but also allows us 7 to make sure we carry through the 8 uncertainties. That is something we can use 9 some thoughts on, because you do get some 10 simplification when you go to these tradeoff 11 curves. They look nice. They are easy to 12 present. But there is the concern that, do 13 they lose too much in translation? Do they 14 simplify it too much? 15 That is something that we, 16 obviously, want your opinion on. It doesn't 17 have to be, again, in necessarily this 18 reaction, although it would be great, but as 19 we move forward, and you see further examples 20 of these and how they play out, and we use 21 different terms, getting your reaction on 22 those will be valuable, I believe. Page 385

1 CHAIRMAN RUSSELL: Ellis?

2 MEMBER COWLING: These tradeoff 3 curves, of course, it was presented as a 4 NOx/SOy comparison, but it never occurred to 5 me until this afternoon that you could apply 6 this to the reduced/oxidized forms of 7 nitrogen, too. You have a tradeoff between 8 those. And every time Charlie mentions 9 organic acids, I think, well, why not have a 10 tradeoff between organic acids and inorganic 11 constituents of nitrogen? So, I think the 12 tradeoff idea is a good one. 13 Why not develop in the second 14 draft a way to deal with tradeoffs between 15 oxidized and chemically-reduced forms of 16 nitrogen as well? 17 DR. HUBBELL: Yes, we actually 18 were discussing that at lunchtime. That is 19 one of the things we want to do. I threatened 20 to start putting in 3D contour plots, and my 21 team members get all nervous. But there are 22 ways that we can display three dimensions202-234-4433 Neal R. Gross & Co., Inc. Page 386 1 without making everybody unhappy. I know the 2 modelers will like them. They like to see 3 three-dimensional plots, but the public has a 4 hard time understanding them. 5 DR. SCHEFFE: We ought to be 6 careful with organic nitrogen there. I think 7 we are thinking of that more in the context of 8 background ANC and how that plays in. So, I 9 don't think that leads itself into a tradeoff 10 discussion necessarily. 11 DR. HUBBELL: Right, but the 12 reduced forms of nitrogen it does. In other 13 words, if we are talking about allowing people 14 to dynamically adjust their reduced nitrogen 15 as we go through time to reflect the changes 16 in their baseline buffering capacity because 17 of what is being used up by reduced nitrogen, 18 then, yes, you would want to know, how would 19 my curve shift as I change ammonia? That is 20 what you would really be looking at, is shifts 21 in the curves. 22 CHAIRMAN RUSSELL: Question 20. Page 387 1 MEMBER DRISCOLL: So, I like the 2 three-year averaging idea -- I think I 3 mentioned that previously -- because there is 4 a lot of year-to-year variation in data and, 5 presumably, CMAQ simulations that are driven 6 by climatic. So, I think it makes a lot of 7 sense in my mind. So, I would endorse that. 8 DR. HUBBELL: One of the things we 9 didn't really say here, which we should have 10 asked, is, yes, three years is, I think, a 11 reasonable period. But is it long enough? Is 12 five years better or six years? Or, do we 13 have a specific window of time that makes the

14 most sense? 15 I mean we looked at variability in 16 our deposition ratios, those transformation 17 ratios, or our transmission ratios I guess we 18 are saying that they are now, but we looked at 19 those, and they were, over a four-year period, 20 they were fairly stable. That is one of the 21 questions: are there other things that we 22 should be looking at in terms of stability? Page 388

1 MEMBER DRISCOLL: Well, the more 2 you do, the more stable it will be, right? 3 DR. HUBBELL: Yes, that is right. 4 MEMBER DRISCOLL: Because you are 5 diluting out extremes. So, I think if you 6 could do, you know, additional years, but I 7 think three years would be a minimum, I think, 8 based on both field observations and model 9 calculations, from my experience. But if you 10 could extend it to five, all the better. 11 MEMBER WEATHERS: Agreed. 12 MEMBER BYTNEROWICZ: Yes, I agree 13 with that. I would go a little bit further 14 even. With the increasing use of green energy 15 and changes in energy consumption and climate 16 change, I think year-to-year information on 17 annual values, and possibly like a three-year 18 run, I mean would probably be something which 19 I would try to suggest maybe for that 20 exercise. 21 MEMBER COWLING: I got the 22 impression that you were intending to do for Page 389 1 the same geographical area a comparison 2 between how it would work with the one-year or 3 three-year or five-year. Is that true? 4 DR. HUBBELL: We can do that, yes. 5 We have not done it yet, but I think that 6 makes perfect sense --

7 MEMBER COWLING: Yes. 8 DR. HUBBELL: -- to look at how it 9 would work with the different averaging times.10 I think we have, as Rich said, we have a five11 year modeling period that we think we can look 12 at. So, that will allow us to look at those 13 windows. 14 MEMBER MITCHELL: Because in doing 15 that, it gives a real opportunity to look at 16 how those different years result in different 17 -- the different results from those years. It 18 shows that these are relatively robust and 19 conservative estimates, especially if you 20 actually had years with quite different 21 climatic components. That would be a powerful 22 test of the system.202-234-4433 Neal R. Gross & Co., Inc. Page 390

1 DR. HUBBELL: I think that is 2 something we can look at for sure. 3 And one other thing on that is 4 some of the reasons why these model years were 5 run was to look at differences in the 6 meteorology. So, there are some years that 7 are bad years meteorologically and some that 8 are good years. 9 CHAIRMAN RUSSELL: So, actually, 10 that is what you have done in figure 5.7, 11 isn't it? 12 DR. HUBBELL: Yes, that is what we 13 looked at, but that is just for the deposition 14 ratios. It is not for looking at like ammonia 15 or other things. 16 CHAIRMAN RUSSELL: Right. 17 DR. HUBBELL: Yes. So, if we want 18 to look at the full range of -- in other 19 words, if we were to calculate what those 20 tradeoff curves would look like for a one-year 21 average versus three-year versus five, they 22 would probably be somewhat different, and we Page 391

1 can look at that.

2 CHAIRMAN RUSSELL: Yes. I was 3 just encouraged by figure 5.7 in that the 4 coefficient of variation is very low. 5 DR. HUBBELL: Yes, especially in 6 the East it is very low. There is an area for7 sulfur towards Texas that was kind of weird8 looking. 9 CHAIRMAN RUSSELL: Right.

10 DR. HUBBELL: And we need to 11 understand why. But it may have to do with 12 the precipitation and the relatively-low 13 deposition rates there.

14 CHAIRMAN RUSSELL: Yes. 15 DR. HUBBELL: But these are things 16 that we want to explore more. 17 CHAIRMAN RUSSELL: And when you do 18 that, keep in mind, my guess is that the 19 actual deposition of sulfate in that part of 20 Texas is not a biggie. 21 DR. HUBBELL: Yes, I think that is 22 part of it, the small numbers, yes. Page 392 1 CHAIRMAN RUSSELL: So, it is a 2 small number. Even though it is a high 3 coefficient of variation, it is not a major 4 issue.

5 DR. HUBBELL: Yes. Yes. 6 CHAIRMAN RUSSELL: So, you want to 7 keep those two things in mind --

8 DR. HUBBELL: Yes. 9 CHAIRMAN RUSSELL: -- when you 10 communicate these results. 11 DR. HUBBELL: Okay. Good point.

12 CHAIRMAN RUSSELL: The next two 13 questions are actually somewhat not Charlie's 14 gig, as you might put it. 15 MEMBER DRISCOLL: No, I want to 16 take a shot at the first one. 17 CHAIRMAN RUSSELL: Oh, yes, that's 18 right, Charlie wanted to add something to 19 this. He wanted to make it more complex. 20 MEMBER DRISCOLL: Right. I really 21 want to take the answerer's prerogative and 22 modify the question because you just addressed Page 393 1 monitoring of air. I think that I would argue 2 an as critical, if not more critical, 3 component of that are the ecosystem 4 measurements. They are always under siege. 5 I spent a fair amount of time writing to 6 Congress and going down there about monitoring 7 programs for NADP and CASTNET and LTM. 8 So, I think that the ecosystem 9 measurements are really barebones. They are 10 really, I would argue, inadequate to do a true 11 assessment. There is virtually no biological 12 monitoring going on. There is virtually no 13 soils monitoring going on, and there is really 14 very limited surface water monitoring. 15 So, I think that the watershed 16 side and the biology side really need to be 17 beefed-up. I will leave it to one of my 18 atmospheric colleagues to lobby on the air

19 measurements. 20 DR. SCHEFFE: Just before we move, 21 it would be really helpful in your comments to 22 kind of lay these out. That would be202-234-4433 Neal R. Gross & Co., Inc. Page 394 1 extremely -- 2 MEMBER DRISCOLL: I've got tons of 3 text. Don't worry. 4 (Laughter.) 5 DR. SCHEFFE: Beautiful. 6 CHAIRMAN RUSSELL: And on the air 7 side, I would imagine you are going to take 8 this to AAMM at some point.

9 DR. HUBBELL: That's correct. 10 CHAIRMAN RUSSELL: And in some 11 ways, I would just say for now this looks 12 fine, and that would be, I think, the 13 appropriate way to do it.

14 MEMBER BYTNEROWICZ: And I have 15 some written comments on that, too. So, 16 probably no sense to repeat that. 17 DR. HUBBELL: Yes, and Nealson, do 18 you know when, has the AMS or the modeling 19 subcommittee been scheduled yet? 20 MR. WATKINS: We actually have not 21 put ourselves on the AAMM schedule for 22 secondary. We will look to do that soon. So, Page 395 1 I would imagine that would put us -- I'm 2 looking at Kyndall -- maybe early next year 3 would probably be the next time we would have 4 that opportunity. But we are talking about 5 doing that, certainly. 6 DR. HUBBELL: So, if this Panel 7 has some comments, as we go through the next 8 review of the second draft, as we try to 9 develop more of this, the more comments you 10 have on that that you want to pass through to 11 the other Panel, I think Kyndall can make sure 12 that happens through Ted. 13 MS. BARRY: And also, Ted is the 14 Chair. 15 (Laughter.) 16 DR. HUBBELL: Yes, well, that will 17 take care of that problem for us. Ted will 18 absorb all these comments and repeat them. 19 CHAIRMAN RUSSELL: And Question 22 20 is very similar, and I think the response is 21 pretty much the same. For now, this looks -- 22 it is a fine placeholder. Page 396 1 So, any other questions on Chapter

2 6?

3 MEMBER BYTNEROWICZ: I have a 4 comment, if I could. 5 CHAIRMAN RUSSELL: Oh, certainly. 6 MEMBER BYTNEROWICZ: Yes, I don't 7 know if EPA staff is primarily aware of the 8 most recent CCE Status Report 2009 from the 9 ICP effort from the long-range charge for the 10 pollutants from Europe. I just got it. 11 First, also, it is Jean-Paul 12 Hettelingh, and it is also Posch and Slootweg 13 are the co-authors. There is an excellent 14 section on ecosystem services. Would you want 15 to probably read it? Because I think it may 16 help in your approach to the particular 17 question. 18 Recall there was a whole Chapter 4 19 on quantifying relationships between N 20 deposition and impact on forest ecosystem 21 services. So, I would like to just recommend

22 that. Page 397

1 If you don't have it, please let 2 me know and I can send you maybe a PDF version 3 of that chapter. 4 DR. HUBBELL: Okay. Thank you 5 very much. I think we can probably get the 6 electronic report. So, that is very helpful, 7 though. 8 CHAIRMAN RUSSELL: So, moving on 9 to Chapter 7, Paul? 10 MEMBER HANSON: We've got two 11 questions to deal with. My initial reaction 12 to Chapter 7 was that there isn't much here; 13 why are we talking about it? And that is true 14 for Section 7.2. It is stated that it is not

15 there. 16 But my personal comment on Section 17 7.1, which deals with the first question. It 18 is that I couldn't imagine from my perspective 19 a more confusing set of paragraphs. I just 20 didn't get it. Now other people did, and they 21 will have their chance to speak. 22 But when I read Section 7.1, I202-234-4433 Neal R. Gross & Co., Inc. Page 398 1 said, why don't I have an X-Y graph here 2 showing me the base cation/aluminum ratio of 3 an upland system plotted against the ANC 4 component of its aquatic pair? That is what 5 I was thinking I was reading about, but that 6 is not what was there. What I got was a 7 discussion of numbers of lakes and things, and 8 I was just totally lost. 9 But, Kathleen, you are still on 10 the phone, I believe, and you have some good 11 thoughts and some good text that I can draw 12 from. Both Myron and Charlie have weighed-in 13 on this issue in their comments as well. So, 14 hopefully, they will jump in. 15 Now on the second question, I 16 think it is a consistent response to 17 everybody, including my own opinion, that, 18 yes, the aquatic system seems to be the more 19 sensitive of the two, and if you did base a 20 standard on it, there would be protection for 21 the upland terrestrial system. 22 That is really all I want to say. Page 399 1 I will listen and try to capture everybody 2 else's thoughts and work on the text that I

3 need to work on. 4 CHAIRMAN RUSSELL: Rudy? And I 5 assume Dale is now off? Then, Kathleen? 6 MEMBER WEATHERS: Yes, I'm here. 7 CHAIRMAN RUSSELL: So, anything 8 else on Questions 23 or 24 on Chapter 7?

9 MEMBER WEATHERS: Just an 10 observation that has evolved over the time 11 period that we have talked today, which is -- 12 and I mentioned this before -- actually, in 13 looking at the AAPI, the terrestrial system is 14 taken into account. So, while there isn't a 15 standard, an endpoint set, terrestrial 16 ecosystem processes are central to the ANC 17 term. So, it may not be too much of a jump to 18 move toward the terrestrial system as well. 19 I think Charlie has had some comments earlier 20 about what that might look like. 21 DR. HUBBELL: Can I ask one quick 22 clarification on that? Page 400

1 MEMBER WEATHERS: Yes. 2 DR. HUBBELL: So, I understand 3 your point, and I think it is one that we have 4 tried to take into account, is that you are 5 depositing it on terrestrial systems, and that 6 is what determines leaching, and so forth. 7 But in areas that don't have a lot of aquatic 8 resources, one of the questions is, what do we 9 do for terrestrial acidification in those

10 areas? 11 You could just say, well, that 12 means your ANC standard needs to apply there 13 as well, but that doesn't seem very targeted. 14 So, the question is, are you just referring to 15 terrestrial because this is co-located with 16 aquatic ecosystems? 17 MEMBER WEATHERS: Yes, I guess I 18 was. Basically, understanding what is going 19 on with, say, soil acidification requires 20 often at least some measurement of soil water. 21 So, even though it is not targeted to aquatic 22 systems, looking at soil water chemistry is, Page 401 1 I think, one of the standards or a possible 2 standard that Charlie was pointing to. 3 Charlie, if that is not what you 4 were talking about -- 5 CHAIRMAN RUSSELL: Anything else? 6 Any other questions from EPA? 7 DR. HUBBELL: No, I'm not sure I 8 am quite understanding that, but --

9 CHAIRMAN RUSSELL: I know. You 10 looked quizzical. 11 DR. HUBBELL: Yes, I'm just not. 12 Maybe if you could, in your comments, maybe 13 that is something that will come out more. I 14 am just not quite sure what, if you are 15 talking about they have measuring ANC in soil 16 water and using that as a critical factor or

17 not? 18 MEMBER WEATHERS: No, no, no, no, 19 I wasn't. I wasn't thinking about ANC. I was 20 thinking more about looking at aluminum, 21 looking at flow-water chemistry. So, I can 22 try to be clearer in the comments I pass on.202-234-4433 Neal R. Gross & Co., Inc. Page 402 1 DR. HUBBELL: That would be really 2 great. Thank you. 3 CHAIRMAN RUSSELL: Rich? 4 MEMBER POIROT: Well, I guess I 5 had made this point earlier, but it appears as 6 though the least-stringent end of the range 7 for a product is roughly as protective as the 8 more stringent end for the terrestrial. 9 Therefore, if the more stringent end of the 10 terrestrial is actually a valid consideration, 11 then, you know, you might think of that in 12 terms of using a slightly higher ANC to 13 accommodate those systems that you would 14 otherwise miss, if you were going to just go 15 with a single indicator. 16 DR. HUBBELL: Right. And like I 17 said, I just want to clarify that the analysis 18 that we have done so far really only tells you 19 about terrestrial systems that are near 20 aquatic systems. So, I think all these 21 statements are quite valid and useful in terms 22 of thinking about those types of terrestrial Page 403 1 systems, but we still have a long way to go to 2 think about how this type of a standard would 3 protect terrestrial systems that don't have4 those kinds of aquatic systems that are co5 located. 6 So, I don't want to overemphasize 7 what we have developed here, but I think your 8 point and the other points are well-taken, and 9 that you are seeing a level of protection that 10 is dominated by the aquatic system at this 11 point. 12 CHAIRMAN RUSSELL: Anything else

13 from the Panel? 14 (No response.) 15 Okay. Chapter 9, and, Myron, you 16 get to lead us off. Two important questions. 17 MEMBER MITCHELL: So, I found this 18 to be a challenging task because this is a 19 summary of everything that we talked about 20 already. So, all of the issues that we have 21 talked about during the day would have to be 22 recast in terms of the conclusions. To go Page 404 1 through all those again would be a waste of 2 time. 3 On the other hand, Question 25, in 4 terms of looking at the reviewing of the 5 preliminary staff conclusions regarding the 6 adequacy of the current standards and the need 7 for developing the multi-pollutant structure, 8 I think that is well-developed. I think that 9 basis is there. 10 Then, we get down to Question 26, 11 "What are the views of the Panel on the 12 overall characterization of uncertainty?" I 13 think we have had a clear discussion during 14 the day of there's a lot of areas of 15 uncertainty that still need to be developed. 16 I think we have gotten, from the other 17 questions, some specific ideas of where those 18 major areas of uncertainty are. 19 So, I think there is no reason for 20 me to go through all the details of all those 21 previous discussions, but I think you have 22 some more details in terms of your own Page 405

1 conclusions, on the conclusions.

2 MEMBER CHESTNUT: I have to wake 3 up. 4 (Laughter.) 5 I'm just joking. 6 Well, yes, a lot of the discussion 7 today. So, I am just trying to look back and 8 see what. I mean, this section, obviously, 9 was not really written yet. So, it is a 10 little hard to comment. 11 But just trying to think about 12 what are the big uncertainties that need to be 13 addressed, the first thing that I noted, 14 actually, was that I thought something was 15 being too cautious, which was the connections 16 between, the relationship between ANC levels 17 and ecosystem services. I mean it is true 18 that they can't necessarily be quantified in 19 some sort of units, but the fact that there is 20 such a clear relationship between ANC levels 21 and the capacity of the lakes to support 22 species that are native to that is, I think,202-234-4433 Neal R. Gross & Co., Inc. Page 406 1 very strong evidence that services are being 2 lost. So, it doesn't need to be so cautious.

3 Whenever those numbers from the 4 New York studies are brought forward, it needs 5 to be said it is limited to New York. It

6 talks about the Northeast and then talks about 7 the numbers from the New York study. I know 8 New York has a big population, but they are 9 not the only ones who care. 10 Then, I guess I just was trying to 11 think back over the whole thing of what, to my 12 non-ecologist mind, seemed like the dominant 13 uncertainties. There's the extrapolations 14 from the catchments that you can model to the 15 rest of the group in that category. 16 How are you going to help the 17 Administrator make a decision about what's an 18 adverse effect? You know, this distance

19 between an ANC of 50 and 100. It even seems 20 more fuzzy to me on the terrestrial side of 21 what are the things to consider in thinking 22 about when this effect is actually detrimental Page 407 1 to public welfare. 2 I think there have been some other 3 things brought up here. We have talked a lot 4 about the reduced nitrogen or I'm not sure, 5 the stuff that comes from the ammonium, but I 6 think we have addressed that today. I mean, 7 that was a major concern, too, the idea of 8 holding that constant in the standard-setting. 9 And there have been some other things I think 10 that have been talked about today that need to 11 be addressed for uncertainties.

12 CHAIRMAN RUSSELL: The Panel? 13 Other comments on Chapter 9? 14 Except I think that we have asked 15 that the whole uncertainty discussion probably 16 gets its own chapter with the sensitivity 17 analysis.

18 Paul? 19 MEMBER HANSON: Just a couple of 20 things within 9.2.1, where you talk about 21 research needs. I don't know that there will 22 be complete agreement or any agreement Page 408 1 necessarily with this comment, but the third 2 and fourth bullets down use critical loads in 3 place of what I think would be better 4 substituted a phrase that talks about 5 uncertainty in the response of ecosystem 6 processes or organisms to acidity. 7 That is, I think the research 8 would do well to give us a fully flexible 9 response surface from which the decisions and 10 the thresholds, if you will, could be decided 11 for critical loads. That is, I am a real fan 12 of understanding the full response surface, as 13 opposed to just trying to target a value, and 14 that applies to the other bullet down as well.

15 I don't know. What do other 16 people on the Panel think? 17 DR. HUBBELL: Just to be clear, we 18 are in agreement. That is one of the things, 19 actually, that we have been trying to develop 20 ways to do even in this timeframe, is come up 21 with those more complete understandings of 22 dose/response. But it is something that I Page 409 1 have already communicated to our Office of 2 Research and Development, that that is a need, 3 is dose/response curves that are associated 4 with different ecological indicators that are 5 associated with different types of atmospheric 6 metrics. So, I think it is the right way to 7 go. 8 CHAIRMAN RUSSELL: Myron? 9 MEMBER MITCHELL: It might be 10 helpful to have some clarification, at least 11 from my viewpoint, where EPA is looking to go 12 forward with this document with respect to the 13 acidification component, but the actual 14 nutrient-loading part is not fully developed. 15 I guess we want this to be a successful

16 endeavor. 17 My question is, and maybe we will 18 have some discussion on this tomorrow, would 19 be, should you kind of focus on the 20 acidification thing and do a really good job 21 on that or is it really important to also 22 expand into the nutrient enrichment component?202-234-4433 Neal R. Gross & Co., Inc. Page 410 1 Because we don't want it to push you guys into 2 doing something which you really can't do 3 well. I guess some response from where you 4 feel that you could be successful would be 5 helpful. 6 DR. HUBBELL: Okay. So, I have 7 had this talk with our team as well. 8 Everybody wants to cover everything. I mean 9 that would be great if we could come up with

10 a standard that covered all the effects and 11 all the pollutants. 12 I think we've got a really good 13 case that, hopefully, we are presenting to 14 you. Obviously, there's details we all want 15 to work out and uncertainties. 16 But I think our best case is still 17 for aquatic acidification. I think we can 18 extend this to terrestrial acidification if we 19 can deal with some of these issues of 20 sensitivity that we have talked about. 21 I have asked the team, because 22 they are very interested in doing this, to Page 411 1 provide a proposal of how we would deal with 2 this question of can we use nitrogen as a 3 bounding criteria on the tradeoff curves. It 4 is not a full incorporation of nitrogen in any 5 means. It doesn't account for these multiple 6 benefits, et cetera. But I think that is our 7 best shot at incorporating nutrients in the 8 aquatic acidification for freshwater. 9 For estuarian systems, I am not 10 sure how we are going to deal with that at 11 this point. I think the Committee, I mean the 12 Panel has already expressed their own concerns 13 about being able to move forward with 14 estuarian impacts. So, I don't think we are 15 really going to move much further than we are 16 now on the estuarian impacts. 17 I think that by the next draft we 18 hope to at least have an idea of whether we 19 think it is worth moving forward on using the 20 nutrient loadings as a bounding condition. 21 But I do hope by the next draft that we will 22 have developed at least a proposal or an Page 412 1 alternative that might incorporate the 2 terrestrial acidification effects. Our team 3 feels like we've got enough information, very 4 close to enough information to be able to do 5 something similar to what we have done for 6 aquatic. 7 So, I hope that gives you an idea 8 that we expect to get terrestrial in there for 9 the next round. If we get nutrients in, it 10 will be a bonus, but it is not something that 11 I am anticipating putting a lot of weight on 12 right now. 13 MEMBER MITCHELL: Obviously, 14 Bryan, there is obviously a tradeoff between 15 the more regions that can be covered by this 16 standard, more likely that it is going to have 17 great interest and support in the community 18 versus a more narrow focus, but that is a very 19 difficult tradeoff to figure out in terms of 20 how to proceed with this. 21 DR. HUBBELL: That is right. Our 22 hope is, again, if we cover terrestrial and Page 413 1 aquatic, that reaches a lot of different 2 systems. That reaches places in the East and 3 the West. It covers a lot of communities. 4 We are hoping that will be a good 5 start, again, with acknowledgment, as our Park 6 Service colleagues pointed out, with 7 acknowledgment that that is not going to give 8 you coverage in all areas for dealing with the 9 nutrient sufficiency over the high elevation 10 areas. It is certainly not going to get you 11 protection in the estuarian areas where there 12 is a significant contribution. But it at 13 least starts us down a path of thinking about 14 ecologically-relevant standards that, 15 hopefully, we can build on as we go through 16 the following reviews. 17 But we feel like our best chance 18 for a success right now is going where we have 19 the most solid connections from both a 20 scientific standpoint and a modeling 21 standpoint. That is why we are focusing on 22 the acidification parts.202-234-4433 Neal R. Gross & Co., Inc. Page 414

1 CHAIRMAN RUSSELL: Praveen? 2 MEMBER AMAR: Just a quick 3 question. Conclusions would be read by many 4 people without even reading this text. So, 5 the No. 6 conclusion on page 221, you kind of 6 start with acidification and nutrient 7 enrichment. You mention both and then go on 8 to say the NAAQS are inadequate to protect the 9 public welfare. But then you only mention 10 acidification and you don't say anything about 11 nutrient enrichment. Is that by design? 12 It is the beginning of conclusion 13 No. 6 on the basis for acidification. 14 DR. HUBBELL: Yes, I don't think 15 we want to conclude that that is not the case. 16 I think that may be just an omission on my 17 part. 18 MEMBER AMAR: Yes, I had a 19 feeling; it got my attention. I said a word 20 is missing. 21 DR. HUBBELL: Yes. Yes, we will 22 make sure, we try to make sure, if we do make Page 415 1 that statement, that it is on purpose rather 2 than an oversight. 3 MEMBER AMAR: Yes, exactly. So, I 4 would be sure, but it was missing.

5 DR. HUBBELL: I have one other 6 question for you. As you mentioned right 7 here, the conclusions are likely to be read by 8 lots of people. Well, we also submitted to 9 you late, admittedly late, we submitted to you 10 an executive summary, which we don't have a 11 charge question for. But I just wanted to put 12 that out there, that it would also be 13 beneficial to us to hear from you any comments 14 you wish to provide on an executive summary, 15 recognizing that we didn't give you time to 16 adequately review that. 17 I know Dale Johnson had put a few 18 comments on the executive summary. If others 19 have those, we certainly would welcome those. 20 CHAIRMAN RUSSELL: Actually, I 21 will ask that question. I have gone through 22 it and I've got some thoughts. I mean, Page 416 1 actually, I thought it did a pretty good job 2 summarizing what was in the rest of the Policy 3 Assessment. Actually, the places that aren't 4 clear in the executive summary very much match 5 the places that aren't clear in the Policy 6 Assessment. So, I think the two will get 7 cleaned up together. 8 But what do other people have to 9 say about the executive summary? 10 MEMBER AMAR: I know I read it 11 first before reading this whole thing. It 12 was, yes, more readable. I think it is -- 13 what? -- 14 pages, and it gets the big 14 picture. 15 MEMBER HUSAR: And no question, 16 cutting through a lot of the text has helped 17 considerably in getting the bigger picture as 18 to what is the content. 19 CHAIRMAN RUSSELL: So, what I 20 would say to the Panel, in fact, let's see, 21 who isn't in charge of something right now? 22 (Laughter.) Page 417

1 Rudy, you're not leading an 2 assignment? Guess what you're going to do. 3 (Laughter.) 4 So, if you can provide some 5 comments, and if anyone can get comments on 6 the executive summary to Rudy, that would be 7 good. 8 I really thought that the 9 executive summary, it helped. There were some 10 places where it was not quite so clear. 11 But I will try to get those 12 comments to Rudy and anyone else, if they can

13 as well. 14 DR. HUBBELL: That would be very, 15 very helpful. Thank you. 16 CHAIRMAN RUSSELL: Other questions

17 from EPA for the Panel? 18 (No response.) 19 And hearing none, I was also going 20 to -- I mean we have pretty much gone through 21 the charge questions. One of the things I was 22 interested in is just an overall, if anyone202-234-4433 Neal R. Gross & Co., Inc. Page 418 1 just wanted to comment on the overall concepts 2 being put out. I think the charge questions 3 address that. But anything that we have 4 missed so far? We have addressed the charge 5 questions, but were there any issues that were 6 not addressed by the charge questions that we

7 should talk about now? 8 To me, one of the big ones was, 9 and they were in the charge questions, but 10 just how uncertainty is addressed. I really 11 think that that is going to be a real key. 12 I will assume that we are going to 13 see a lot more definition on the size of these 14 areas and things next time around. 15 DR. HUBBELL: Yes. In fact, we 16 tried to put a note to that extent, that that 17 was something that was clearly gap and that we 18 are wrestling with both the categories and the 19 spatial areas and how we will be dealing with

20 both of those. 21 CHAIRMAN RUSSELL: Oh, you told us

22 that that was -- Page 419

1 DR. HUBBELL: Yes. 2 CHAIRMAN RUSSELL: And I was just 3 wondering, actually, do you have any thoughts 4 right now? 5 DR. HUBBELL: Well, I mentioned a 6 couple of them. One of them was looking at 7 the homogeneity in the air quality 8 concentrations and deposition fields. 9 CHAIRMAN RUSSELL: But you have 10 said what you are going to look at, but in 11 terms of having -- 12 DR. HUBBELL: No. No, we have 13 nothing for you on that yet. 14 CHAIRMAN RUSSELL: Okay. 15 DR. HUBBELL: I would like to, but

16 we don't. 17 CHAIRMAN RUSSELL: Rich? 18 MEMBER POIROT: You know, I was 19 thinking it was a very interesting contrast 20 with the new primary NO2 and SO2 standards, 21 which are very, very much focused on local 22 sources, near roadways and near specific SO2 Page 420 1 emission sources. This is in some ways almost 2 the opposite of that.

3 I know that we don't talk about 4 the implementation phase in advance, but, on 5 the other hand, let's just imagine for a 6 moment what happens. If we have these 7 standards set at certain levels, they end up 8 being exceeded perhaps in the Adirondacks, 9 Vermont, New Hampshire, and the Shenandoah 10 Mountains. Then, what do we do? Then, it 11 strikes me that it doesn't fit so conveniently 12 into the traditional SIP process perhaps. 13 You know, it kind of got me 14 thinking about the area for which an 15 exceedance is observed compared to the area 16 for which the air quality indicator might be 17 observed or be considered to be out of 18 compliance could be an interesting topic to 19 pick up. 20 DR. HUBBELL: Let me just take off 21 my standard-setting hat for a moment and talk 22 about this issue of what different types of Page 421 1 programs would do, and just remind you that, 2 as you are well aware, the SO2 and NO2 3 standards are not the only way to control NOx 4 and then SOy, nor are the secondary standards 5 for NOx and SOy. They are also precursors for 6 ozone and PM. They are going to be addressed 7 by a number of these large-scale programs that 8 we have coming up already. 9 So, the picture now, if you were 10 to do a picture of what areas that are 11 exceeding any type of alternative standards 12 might look like, the picture that it would 13 look like in 2020 or 2025 would be very 14 different. Remember that secondary standards 15 are different in their implementation than 16 primary standards. You have a lot more 17 flexibility. 18 So, the pictures that we would 19 paint in terms of what non-attainment would 20 look like or what future situations would look 21 like would be very different when you are 22 looking at a secondary standard that has both202-234-4433 Neal R. Gross & Co., Inc. Page 422 1 primary standards that are addressing the same 2 pollutants, but, also, other primary and 3 secondary standards that are affecting NOx and 4 SOy as precursors to those. So, there is a 5 combined multi-pollutant kind of picture. 6 Beyond simply the multi-pollutant we are 7 talking about here, there is a multi-pollutant 8 management picture. 9 As you are aware, EPA is very much 10 trying to move towards that multi-pollutant 11 approach. These will simply strengthen the12 case for thinking about things in a multi13 pollutant management and framework. But, 14 again, that is not really part of setting the 15 standards, but it is something to be aware of

16 as we move forward. 17 MEMBER POIROT: You know, this 18 becomes essentially thinking just like, for 19 example, in terms of nitrogen, this becomes 20 one of the six or eight good reasons to 21 control nitrogen.

22 DR. HUBBELL: Yes. Page 423

1 MEMBER POIROT: And it may be the 2 reason to control it, to be especially 3 cognizant of nitrogen in the winter, for 4 example, where we've got other programs that 5 say only the summer matters.

6 DR. HUBBELL: Yes. 7 MEMBER AMAR: A comment I have, 8 what Ellis had said earlier, which did make an 9 impression on me, about the educational part 10 of this, I think when you are doing the next 11 draft, it is going to be complicated for 12 people in the states trying to figure out what 13 this means, how to calculate. It might be 14 helpful, even in the second draft, something 15 in the appendix, how is it going to work.

16 DR. HUBBELL: Yes. 17 MEMBER AMAR: You know, like in 18 question/answer form almost. What does this 19 mean? How would you do it? 20 DR. HUBBELL: Yes, and the 21 examples are, hopefully, going to move us in 22 that direction. That is, again, one of the Page 424 1 reasons why I like the tradeoff curves, is 2 because I think it is sometimes easier to show 3 people the picture and say we understand we 4 have got complicated equations underneath all 5 this, but if you measure your NOx and if you 6 measure your SOy and you measure your ammonia, 7 if we decide to do that or model it, and you 8 give us those pieces of information, here's 9 the picture. Here are the standards expressed 10 as these tradeoff curves that show you whether 11 you are in attainment or not. 12 Rather than starting with this 13 process of getting into all the details of the 14 underlying models, instead start with here's 15 how you measure your attainment or not. That 16 is what we are trying to think through, and we 17 think that maybe that will be an easier way to 18 communicate the process, not ignoring the 19 complexities, but just trying to paint a 20 little bit simpler picture for them. 21 MEMBER AMAR: And also in a 22 question-and-answer form, and the EPA does a Page 425 1 very good job these days of question/answer of

2 a lot of fact sheets.

3 DR. HUBBELL: Yes. 4 MEMBER AMAR: I think that is the 5 way people would learn. 6 DR. HUBBELL: Sure, and maybe that 7 is part of the way we would think about the 8 executive summary, too.

9 CHAIRMAN RUSSELL: Good. It 10 sounds -- oh, Ellis? 11 MEMBER COWLING: Rich made a 12 comment earlier in this day about we are not 13 supposed to be thinking about implementation. 14 Those of you who were present in the last 15 discussions that we had about the 16 implementation of the visibility, which is a 17 secondary standard relating to particulate 18 matter, I don't know if Lydia and Martin are

19 here -- 20 DR. HUBBELL: Yes, I think they

21 have left. 22 MEMBER COWLING: No? Okay.202-234-4433 Neal R. Gross & Co., Inc. Page 426 1 But there was a significant 2 pushback against the suggestion that both Rich 3 and I suggested, that the rate of progress or 4 a progress way of approaching improvement of 5 air quality and, in that case, visibility. 6 You seem more open to the idea. I 7 mean, when I brought up education, there will 8 be a necessity for dealing with the 9 implementation of whatever rules and 10 regulations are an outcome of this. I am very 11 hopeful that that will make a change. 12 But the extent to which both Lydia 13 and Karen resisted our encouragement to think 14 about implementation in doing a policy 15 analysis of the initiation of a new set of 16 standards, I wondered has there been some 17 rethinking? 18 DR. HUBBELL: No. Let me clarify. 19 What I was referring to, rather than 20 implementation of the standards themselves in 21 terms of what kind of controls and other 22 things they are putting on, what I was Page 427

1 referring to was providing to the states a way

2 to understand the standards. 3 We are talking about the same 4 standard. The AAPI in its equation form and 5 the AAPI reflected in these tradeoff curves 6 are the same thing. They are just simply two 7 ways of expressing or showing what compliance 8 with the standard might look like. 9 What I am saying is that I think I 10 want to move toward an approach that is as 11 easy to comprehend as possible, so that states

12 understand what we want them to do. How we 13 want them to do it is a whole different 14 question, but what we want them to do in terms 15 of achieving a particular level of protection 16 represented by an AAPI, that is what I am 17 trying to get at. 18 It is a little different than the 19 visibility situation where they are concerned 20 that the form of the standard would be driven 21 by concerns about implementation. Here we are 22 saying the form of the standard is the same; Page 428 1 it is just the expression of that form through 2 a graphic or through an equation that I am 3 referring to. 4 There's still some lines that are 5 drawn between the implementation and the 6 setting of the standard. 7 MEMBER COWLING: Okay. Thanks. 8 CHAIRMAN RUSSELL: Any other 9 questions from the Panel? 10 (No response.) 11 All right. It has been a long 12 day. First, thank you very much to Bryan, 13 Rich, Tara, et al. Certainly, this cleared up 14 some things in my mind that I came in with. 15 So, in terms of writing 16 assignments, the idea has been to have the 17 leads that have been identified on each of 18 these draft something this evening and get it 19 to Kyndall and me late tonight, so we can 20 start putting together the letter. 21 One thing that has come up is that 22 on Chapters 5 and 6 -- those were the two big Page 429 1 chapters -- that the leads wouldn't 2 necessarily be able to or wouldn't feel 3 comfortable with doing it all themselves, 4 since they go across media, go across ideas,

5 et cetera. 6 So, what I have done for both 7 Chapters 5 and 6 is identified subleads for 8 different charge questions. These are 9 somewhat based upon how people have been 10 participating in the discussion. 11 So, if you look at your charge 12 questions and start with Chapter 5, though I 13 will tell you the leads on the other chapters, 14 if they also want particular help from 15 somebody else who is not already listed in 16 their group, let's talk about that as well. 17 So, in Chapter 5, Question 10, so 18 this is the chapter that Praveen is leading. 19 I have discussed this with Praveen. So, I 20 will just go down it. 21 So, Question 10, Praveen would

22 lead.202-234-4433 Neal R. Gross & Co., Inc. Page 430 1 Question 11A -- and now we even 2 get to subquestions -- Charlie, if you can

3 take 11A? 4 And 11B and C, Kathleen. That's 5 why we didn't want you to leave. 6 MEMBER WEATHERS: So, wait a 7 minute. 8 (Laughter.)

9 Yes. 10 CHAIRMAN RUSSELL: So, if you can 11 just email, if you can respond to those or 12 provide input, and look at what the other 13 people on the Panel have said and sort of 14 summarize -- and hopefully, you are up to 15 this. If not, you can dump it back on 16 Praveen, who doesn't want it. 17 MEMBER WEATHERS: So, again, this 18 is 11B and C?

19 CHAIRMAN RUSSELL: Eleven B and C.

20 MEMBER WEATHERS: Yes. 21 CHAIRMAN RUSSELL: And then 11D, 22 Rich. Page 431

1 Eleven E, Praveen. 2 Twelve, Praveen. 3 Thirteen, Naresh. 4 And 14, Praveen. 5 Then, we get to Chapter 6. 6 Charlie, do you have some? We have talked 7 about it some. Do you have a list of who you 8 think would do it, would be best? 9 MEMBER DRISCOLL: So, I would do 10 15. It would be good if somebody would 11 volunteer to do 16. That is uncertainty. 12 CHAIRMAN RUSSELL: I was thinking 13 Andrzej on that one. 14 MEMBER DRISCOLL: Okay. 15 CHAIRMAN RUSSELL: And again, 16 since Naresh is already doing some 17 uncertainty, if you could also contribute to

18 that one? 19 MEMBER DRISCOLL: So, I can do -- 20 CHAIRMAN RUSSELL: But, Andrzej, 21 if you can take the lead? Is that okay? 22 Andrzej, are you there? Page 432 1 (Laughter.) 2 MEMBER WEATHERS: He conveniently 3 signed off. 4 (Laughter.) 5 CHAIRMAN RUSSELL: I thought I 6 told him to stay on. 7 MEMBER WEATHERS: You did. 8 CHAIRMAN RUSSELL: Well, in that 9 case, Naresh, we will dump it, okay to dump it 10 back in your lap? 11 MEMBER KUMAR: Well, 16 has a lot 12 of stuff going on. And obviously 18 --

13 CHAIRMAN RUSSELL: Yes. 14 MEMBER DRISCOLL: Well, I was 15 going to suggest you do 18. If you want, I 16 can try to do something on 16. I can do 17.

17 I could do 19. I can do 20. I can do the eco 18 part of 21, but if somebody has something, 19 maybe Rich, about monitoring atmospheric, and 20 then we talked also about tapping you for 22, 21 which is on using surrogates, I think, to 22 judge compliance. Can you handle that? You Page 433

1 look reluctant. 2 MEMBER POIROT: Yes, I'm trying to 3 remember what the surrogate point was.

4 MEMBER DRISCOLL: "What are the 5 views of the Panel on using existing NOy PM 6 2.5 sulfate measurement techniques as a basis 7 for defining federal reference methods to 8 judge compliance with" -- and I think there is 9 a word missing -- something "standards". 10 That's Question 22. 11 CHAIRMAN RUSSELL: And I can help 12 on 21 and 22 as well because I think, 13 ultimately, those go to A. 14 MEMBER DRISCOLL: So, you are okay 15 with that, Rich?

16 MEMBER POIROT: Yes. 17 CHAIRMAN RUSSELL: So, any of the 18 other chapter leads want to draft some help on 19 specific questions? 20 MEMBER AMAR: I think I would need 21 some help on 12. It says the extension of 22 this concept being talked to other three202-234-4433 Neal R. Gross & Co., Inc. Page 434 1 systems. I mean I wrote something. I don't 2 think I felt comfortable. I know Rich had 3 some comments which I understood. But if 4 there are others who want to contribute to how 5 this approach is going to work for the other 6 three, I am happy to take input.

7 CHAIRMAN RUSSELL: Paul? 8 MEMBER HANSON: I'll try some 9 stuff on parts of this understanding.

10 MEMBER HUSAR: And about the 11 summary, there was no specific request. So, 12 if anyone has scribbled copies, annotated 13 copies, I would be happy just to take it and 14 then make something out of that. Or else if 15 you would just send me an email, it would be 16 helpful. 17 CHAIRMAN RUSSELL: Thank you. 18 Any other comments from the Panel? 19 (No response.) 20 And given that I hear none, we are 21 going to get back together again at, what was 22 it, 8:15, 8:30 in the morning? Page 435

1 MS. BARRY: Yes, 8:30. 2 CHAIRMAN RUSSELL: 8:30 in the 3 morning. 4 DR. HUBBELL: Yes, and I just 5 wanted, also, to express EPA's appreciation to 6 the Panel. I was just talking to Tara. This 7 has been really a remarkable day for us in 8 terms of getting an amazing amount of good 9 feedback already, before we even get your 10 final comments. So, we really appreciate the 11 level of engagement and appreciate just the 12 very detailed comments that you all have put 13 together individually. Thank you. 14 MEMBER AMAR: Ted, one more 15 question. How long are we writing here? 16 Pages, paragraphs? 17 CHAIRMAN RUSSELL: My preference 18 is to have something very pointed and not 19 overly verbose. So, in terms of response to 20 any charge question, if you start -- 21 MEMBER AMAR: That is 26 pages I 22 know. So, that's not what you want. Page 436

1 CHAIRMAN RUSSELL: So, no, I would 2 be looking for one to two paragraphs to any 3 one question. I mean if it must be more than 4 that, it must be, but I think the message gets 5 lost if that happens. 6 Charlie, Andrzej said that he did 7 sign off, but we can email writing assignments 8 to him. So, in terms of Question 16. 9 And anyone else who wants to give 10 Andrzej a writing assignment, now is your 11 opening. 12 (Laughter.) 13 MEMBER WEATHERS: How do you feel

14 about 11B and C? 15 (Laughter.) 16 Kidding. 17 CHAIRMAN RUSSELL: So, actually, 18 you can talk to Kyndall. 19 So, email him about Question 16. 20 With that, thank you very much. 21 Have a good evening, and we will see you in 22 the morning. Page 437

1 I think you just amazed Kyndall 2 because she thought we had no chance to make 3 it by 5:00. 4 (Laughter.) 5 And thank you to the people on the 6 line, too. 7 (Whereupon, at 4:47 p.m., the 8 proceedings in the foregoing matter were 9 adjourned for the day, to reconvene Friday, 10 April 2, 2010 at 8:30 a.m.)

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362:14 ability43:8 44:12

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54:5 98:4 106:20 118:4 173:6 209:10 338:15 absorb 395:18 absorbed 217:4 absorption 80:3,3 abstract 183:16

277:10 accept 82:1 acceptable 135:13

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40:7 43:9 58:8 63:8 87:17 94:12 98:21 99:8,12,15 103:22 133:14 141:18 145:4 177:6 195:15 244:9 337:21 341:1,16 353:18 acidification 30:9

30:18 31:21 32:6 32:7 33:19 35:3 36:11 39:15 42:15 52:1,7 56:14 57:5 87:5,6 88:8,14 117:9 156:10 157:13 180:2 189:21 223:17,19 246:3 248:5 275:9 277:20 290:2,4,9 295:6 296:13,21 297:9,19 298:7,17 300:5,7 301:7 302:15 307:1,8,12 308:12 311:22 321:6 322:3,9 325:6 327:14,17 328:1 330:8,19 333:20 339:14,15 344:11,12 357:6 362:16 378:3 400:9,19 409:13 409:20 410:17,18 411:8 412:2 413:22 414:6,10 414:13 acidified 132:13

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77:11,12 243:18 246:5 248:2 331:2 acidity 175:4

240:19 326:19 330:8,16 360:17 361:18 408:6 acids 72:13,21 73:9

73:11 352:22 355:3 358:13 360:19 385:9,10 acid-based 247:7

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242:18 acting 208:8 action 9:16 175:11 175:17,21 176:2 178:22 281:1 actions 176:22 actively 126:15 activities 149:1

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closure 374:11,11 cloud 367:18,19 clouds 367:6,12 CMAQ 37:6 47:5

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392:3 cognizant423:3 collaboration 116:19 colleagues 345:21

364:12 393:18 413:6 collect 176:6 335:9 color 117:4 Colorado 100:17 combination 38:1

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225:2 criticisms 311:5 criticize 357:17,21 criticized 163:12 critiques 156:6 critters 293:11 crop 49:13 crucial 23:9 148:6 150:11 151:19 crumbles 148:4 cubed 209:22 cubic 191:13 cumulative 34:6 197:10 curious 74:20 194:12 195:11 274:8 current25:19

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5:24 19:17,17 113:3 114:20 134:15 207:1 265:13 292:5 310:22 311:20 366:21 432:11 Kyndall 2:12 3:3

8:4 10:16 13:5 17:8,22 108:14 395:2,11 428:19 436:18 437:1 L L 2:8 labeling 64:18 labile 258:17,18 Laboratory 19:8 lack 247:6 374:10 lag 188:4,8 220:17

259:1 laid 22:19 lake 177:6 284:11

284:14,16,19 285:9 294:15 lakes 36:1,4 64:19

64:20 65:1 87:10 132:13 144:11 184:22 238:16,22 239:3,4,6 240:6 276:14,19 277:9 277:17,18 278:1,3 278:7 284:9 286:1 291:9 295:22 330:20 350:18 362:15 398:7 405:21 land 168:2 182:12

209:5 219:17 354:8 379:20,20 381:4 lands 167:4 182:9 182:20 landscape 33:15

284:1 327:18 language 125:17 136:17 140:1 142:13 163:18 166:20,21,22 167:11 177:10 lap 432:10 large72:22 74:13

95:6 182:8 211:20 219:11 244:4 257:13 270:13 291:2 335:4 375:3 largely46:22 123:13 325:7 354:8 376:19 larger 33:17 46:13

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lasers 101:10 lasts 57:10 late 17:7 27:15 140:19 415:9,9 428:19 latitude 279:15 Laughter 107:12 117:5 121:16 134:1 135:20 155:18 178:12 181:9 193:3 210:10 213:19 214:12 216:9 234:2 251:19 258:7 273:5,8,11 279:13 320:7 328:17,22 347:1 351:1 352:4 363:1 363:11 364:10 371:15 382:6 394:4 395:15 405:4 416:22 417:3 430:8 432:1 432:4 436:12,15 437:4 launch 141:9 Laura 141:2 Lauraine 1:22 4:19

7:14 19:13 152:2 159:7 180:10 183:19 210:14 318:7 Laurie 360:3 Laurie's 335:22 law219:17 278:21 laws 10:5 lawyer 177:20 lay71:14 209:5

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429:18 leads 16:21 17:6

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65:6,9,11,13 67:5 67:10 89:17 115:3 151:6 172:18 176:20 180:13 211:10 219:6 244:4 278:15 330:2 339:11 349:1 365:10 377:20 405:16,20 420:7 life 80:19 137:17 light26:13 150:17 lightning 379:8 liked 159:9 191:22 193:8 273:22 likes 126:4 234:1 limit 31:11 39:10

39:13 40:4 45:11 143:20 160:12 161:8,18 323:18 limitation 233:15 limitations 114:9 146:6 151:2 161:14 269:20 282:2 367:19 limited 46:21 64:5

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37:22 55:6,21 171:7 176:4 183:4 305:2 309:1 349:18 350:21 437:6 linear 110:3,14,18 111:1,14 lines 156:14 169:16 197:13 300:1 428:4 link 26:6 176:20

260:1 330:10 linkage 265:17 linkages 260:6

265:20 266:1,2 311:21 linked 15:3 links 262:20 liquid 367:6 list 118:11 310:19

431:7 listed429:15 listen 399:1 listening 81:2 lists 126:8 liter 323:14 literally 62:19 literature 66:15 117:12 119:5 153:10 204:3 246:2 250:16,21 254:18 255:21 317:22 323:13 344:17 lithology 308:8 litigants 22:5,8 little 24:18 33:20

36:2 42:3 46:3 52:4 56:11 72:20 76:16 89:19 91:19 100:16 135:4 138:18 141:7 142:19 145:16 149:10 155:12 176:5 179:5 180:5 189:8,9,16 192:15 194:7,16 200:7,20 209:13 214:16,16 219:13 227:3 240:1 242:14 243:8 249:1 254:21 261:3 274:5 278:21 284:5 298:15 299:1,8 302:2 306:3 319:4,6 334:20 340:4,7 363:5 368:14 374:18 377:2 381:3 382:10 388:13 405:10 424:20 427:18 live 293:12 livestock 182:14 load 34:4,10,16

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237:18 238:3 263:17 356:19,22 357:1,5 loading44:14

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51:13 52:11,12 62:7,9 76:4 77:8 113:20 114:2,6 125:17 138:19 143:6,13,18,22 145:9 147:7 149:15 153:5 155:9 156:9 160:7 171:1 172:2,12 175:12 196:15 199:6,16,22 206:2 206:10 209:15 230:10 231:15 237:7,11,17 245:3 246:2 250:16 256:9 258:15 268:11 269:1 271:7 273:1 282:15 283:16 285:8 287:6 289:13 297:6 298:5 305:8 320:18 326:10 329:18 340:18 341:5,8,11,20,21 342:6 343:3 346:2 348:1 349:10 355:8,9 362:6 365:10 367:3,7,19 368:17 375:5 377:3,8,13 378:19 379:3,4,6 381:4 387:4,6 400:7 404:14 405:6 407:3 412:11 413:1,3 416:16 418:13 421:16 425:2 432:11 lots 53:2 60:10 122:11 299:17 415:8 Louis 19:20 love 195:18 low 115:6 240:16

310:3 336:22 358:5 361:16 391:4,6 lower 88:18 240:20

284:14,17 287:15 287:15 339:11 lowered 225:2 lowering 297:18 lowest 345:2 LTM 186:10 393:7 Luckily 14:5 211:7 lunch 17:18,19

221:13,16 298:15 lunchtime 385:18 Lydia 3:12 11:13 15:18 21:1,4 163:14 166:5,7 425:18 426:12 Lynch40:20 73:5

218:13M MAGIC 89:2,5 194:10 216:21 223:21 246:8,15 246:17 247:9 magnesium 297:20 magnitude 25:15 144:15 152:22 245:12 247:16 257:20 316:14 327:17 main 147:6 152:6

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41:20 Posch 396:12 posing 108:15 position 94:10

329:21 345:12 373:19 positive 93:21 163:1,3,8,10 164:15 181:22 182:4,10,19 280:22 possibilities 101:9

255:4 343:4 possibility 100:19 179:6,7 277:6 283:6 286:20 possible 13:6 41:17

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