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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.
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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

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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

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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, 310
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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

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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

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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.

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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 their
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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.

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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

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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

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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.
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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

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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.

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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

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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,
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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.

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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. 

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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 to
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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 is

17 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,

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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

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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

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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.
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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

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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

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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,

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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. 
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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

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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

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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 that

17 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.

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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 our
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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, any
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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.
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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 indicators
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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.
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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.
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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 over
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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 12
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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 we
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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 the

20 parameters of the equation. All the non21 atmospheric concentration parameters, those

22 things, not NOx and SOy, but all those
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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 assumptions
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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 soils

11 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 in
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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 other

6 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 to

18 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 and
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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 we

22 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 Policy
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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 be

9 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 deposition
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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 way

7 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 be
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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. 
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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-reactive

20 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 are
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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?
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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.
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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 are

5 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 hard
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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 the
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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,
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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 interested
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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.
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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 the

14 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.
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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 you

14 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 or

4 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 mean
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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, all
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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 are
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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.
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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 not
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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 multiple
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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 to
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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,
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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 and

12 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 are
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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. And

7 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 to

18 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 higher

11 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?
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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 River
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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 and
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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 monitoring
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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 current

10 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 the
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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 of
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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 with
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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 can
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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?
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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 do
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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 current
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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 some

18 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 a
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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.)

18

19

20

21

22
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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?
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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 the

17 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 ecosystem
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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 prospective

20 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.
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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 with
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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. 
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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 -- but

2 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 more
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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 of

6 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 for
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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 uncertain
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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 out
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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 was

10 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 is

Page 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?
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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 those
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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 improve
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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 the
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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 area
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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 making

14 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 measured
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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 small
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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.
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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 surface
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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 moving

15 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 there

11 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-state
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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 way
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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't

13 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, the
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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, not
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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 the
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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 that
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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 wanted
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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 where
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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 of
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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 we

20 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 going
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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. 
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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 balance
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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 related

4 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 ammonia
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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 sometimes

21 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 CASTNET
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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 that

18 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 extensive
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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 in
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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?
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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 deposition
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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 you
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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 dry

22 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 nitrogen
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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,
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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 that
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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 dimensions
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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.
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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 for

7 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 be
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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, I
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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.
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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 have

4 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,
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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? 
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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.
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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 anyone
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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 both
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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 the

12 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.
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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.
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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 three
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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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222:4 244:22

257:15,19 258:6

271:14 273:18

279:2 317:5 340:4

340:7 351:17,20

362:4 374:20

378:19 379:2

405:7 406:11

430:15 432:10

434:21

background 3:10

15:16 42:22 44:10

46:6 72:14,17

157:9 259:14

282:20,21 302:3

336:19 353:2,4

355:4,10,21,22

356:5 361:21

386:8

backs 93:3

backstop 324:10

bad 156:12 163:6

163:13 173:2,19

195:13,16,17,19

219:10 255:6

281:3,6 351:16

362:8 390:7

balance 43:20 64:2

64:8 220:5 236:10

239:18 244:20

246:9,10,11 249:4

249:21 301:14

341:22 342:5

374:12

balanced 183:13

228:7

balances 245:4

247:3 339:17

373:20

balancing 58:18

ball 198:8

ballpark 367:14

barebones 393:9

Barry 2:12 3:3 8:3

8:4 13:5 18:8

20:9,12,16 85:12

108:13,18,21

109:3,7 226:14

333:6 395:13

435:1

base 44:12 217:4

244:9 305:5,8

307:15 325:8

327:19 339:1

341:15 398:2,19

based 27:13 30:7

33:3 40:7 42:8

66:4,14 77:18

103:22 114:7

128:3 148:15

158:3 180:15

196:17 212:7

224:12 225:18,21

229:10 231:11

240:7,10 259:5

272:3 273:15

302:16 324:9

327:21 329:12

352:8 354:7 356:8

358:15,16,20

368:8 376:10

388:8 429:9

baseline 81:19

111:10 307:6

335:7 386:16

base-cation-to-al...

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base-flow 327:21

base-level 190:9

base-year 312:18

basic 53:13 150:5

307:16 365:15

basically 41:12

44:10,15 46:3

56:1 57:1,9 61:8

66:2,7 74:20

93:16 94:5 95:14

101:19 105:10

106:2 110:13,15

110:15,17 111:16

156:17 175:21

209:5 231:8 243:5

297:21 331:3

334:14 362:17

369:5 400:18

basis 39:13 70:15

87:3,3 147:18

154:19 157:1

276:18 349:22

404:9 414:13

433:6

Bay 179:1 290:16

BC 67:19 73:10

291:7 353:11

BC-to-AL 292:18

beans 195:6

bear 168:12 256:9

342:9

bearing 102:6

beast 216:17

Beautiful 394:5

beauty 45:18

341:13

bedrock 63:4 88:22

89:6 234:6,13

235:10 236:15

275:17 276:6

283:13 286:15,19

287:22 288:5

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beefed-up 393:17

befalling 128:2

began 32:5

beginning 53:15

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beginnings 30:3

begins 144:14

270:6

behalf 9:12

behavior 87:14

256:12

behavioral 148:9

behaviors 243:3

beings 168:19

belabor 124:16

belaboring 144:22

believe 30:1 113:11

116:19 119:9

125:22 153:15

158:9,18 209:8

246:7,14 302:1

356:19 384:22

398:10

believes 125:21

belong 132:22

236:16 261:19

benchmark 66:8

benchmarks

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beneficial 167:22

170:6 181:18

336:3 415:13

benefit 66:17

150:20 151:4

212:3 301:15,22

302:18 338:1

368:15,20

benefits 21:21

76:19 153:11

166:9,10 169:13

218:21 411:6

best 36:13 47:2

132:16 133:10,16

198:1 202:5

217:18 220:5

234:10 235:11

328:2 369:14

375:12 410:16

411:7 413:17

431:8

bet 179:2

better 18:15 33:5

51:20 78:9 94:1

94:19 109:14

114:4 143:16

145:7 187:18

193:17 195:3

200:5 202:6

205:18 209:11

226:7 227:8 232:2

232:6 234:19

250:10 279:19

290:18 291:9

316:1 322:14

327:20 346:13,17

351:5 362:9

371:12 373:8

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382:10 387:12

388:10 408:3

beyond 82:6 97:14

101:20 103:9,10

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131:11 185:19

204:1 218:19

234:13 287:8

344:8 422:6

bias 77:15 206:14

247:16 248:14

biased 72:15 163:5

165:13

biases 75:7,15

273:21

bidirectional 30:22

377:5

big 68:4 79:12 81:7

143:9 144:4 147:4

166:4 201:20

308:1 319:12

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bigger 58:22

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billion 152:20

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biodiversity 157:6

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biogenic 355:3,5

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biologically-reac...

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biology 142:1

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bit 24:19 28:17

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46:3 49:3 59:10

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black 232:18

blow 77:22 78:13

blows 80:4

blue 30:14 35:20

37:22,22

BOARD 2:11

BOCs 355:6

bodies 59:2,14

238:16 306:16

bonus 412:10

bottom 164:12

285:5

bound 302:16

344:13 360:10

368:4,7

boundaries 59:17

366:9 380:2

381:13

bounded 284:10

bounding 299:12

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411:3,20

bounds 299:20

box 232:18 270:17

313:11

Boy 314:3

breaches 269:16

break 140:3,18

187:2 221:12

324:6 336:2

350:22 351:17,18

breaking 108:10

breakthrough

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Brewer 4:4 9:13

85:16,16 90:5

bridge 26:4

bridging 40:18

brief 12:13 112:13

113:5

briefly 12:19 104:4

bring 22:1,22 26:3

128:14 171:7,14

171:17 172:9

182:22 202:20

208:3 209:14

235:8,9 298:11

301:20 340:6

bringing 23:9 63:6

168:12 297:21

300:2

brings 343:7

broad 77:18 92:5

142:6 288:1

315:20

broader 141:13

236:12 292:19

broad-ranging

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brook 133:14,15,18

256:9

brought 118:21

144:1 145:13,17

209:18 230:20

406:4 407:3 426:7

Bryan 3:14 11:13

23:19,22 28:11,12

30:4 54:2 129:2

201:8 314:11

412:14 428:12

Bryan's 378:19

budget 103:5,20

283:5

budgets 250:18

buffering 56:8,11

57:10 182:12

353:19 386:16

Buhr 100:17

build 77:15 279:6

413:15

builds 30:11

336:17

built 75:8 77:8

bullet 408:14

bullets 17:1 408:2

bunch 180:3 196:1

buoyant 99:9

burning 106:20

business 224:11

busy 15:11

button 328:21

buy 100:16

Bye-bye 109:2

Bytnerowicz 1:21

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329:7 331:9

343:15,18,22

344:20 345:1

362:5 364:15

371:18 373:11

383:5 388:12

394:14 396:3,6

C

C 1:13 30:16

222:13 234:6

283:13 310:8

430:4,18,19

436:14

calcium 217:3

297:20

calculate 31:5,10

35:5 36:13 39:17

222:21 390:19

423:13

calculated 34:4,7

37:7 39:8,13 40:9

40:11 44:4 152:16

251:5 356:17

372:17

calculating 58:14

230:18 277:3

347:13

calculation 153:8

266:17,20 267:19

357:1 383:7

calculations 216:19

224:12 225:12

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278:14 296:6

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calibration 94:17

224:3

California 87:11

158:20

Californians

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call 3:2 46:11 67:5

111:9 136:13

238:19,20 366:5

376:13

called 11:17 98:21

calling 32:19

CAM 349:15

Camp 123:8

CAMx 312:9,13,19

canceling 341:20

capabilities 100:3

capacity 56:8,11

57:10 88:9 182:12

353:19 386:16

405:21

caption 126:5,6

captions 191:2,21

capture 135:14

196:11,18 399:1

captured 197:1

carbon 165:21,22

171:11 173:8

253:16,17

care 125:22 137:3

142:21 144:19

145:10 147:5

149:5 227:4 243:7

315:1 395:17

406:9

careful 131:9 160:5

160:21 161:3

235:7 280:17

386:6

carefully 136:20

Carolina 1:15 19:4

123:3,5,12,17

carry 122:8 363:14

384:7

Cary 20:14

CASAC 1:4 8:9,18

9:22 11:2 14:15

18:12 23:4 27:9

33:4 36:11 171:18

212:13

CASAC's 13:1

36:12 170:14

cascade 197:20

case 22:5,9 25:20

37:7 38:3 84:1,1

89:14 95:10

112:18 125:8,20

132:17 151:10

157:13 158:17

161:12 167:9

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170:7 181:13

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cast 378:14

CASTNET 201:8

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catalytic 94:11

catastrophe 128:2

catcher's 178:18

catchment 32:8,10

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catchments 32:16

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categorical 51:16

categories 32:22

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categorization

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category 33:11,13

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cation 243:16

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cations 44:12 256:3

cation-to 297:11

cation-to-alumin...

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cation/aluminum

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CATMEN 372:9

causal 272:6

causality 260:15

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cause 83:1 176:21

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caused 210:12

causes 83:1 271:5,5

causing 301:12

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caution 281:9

cautious 405:15

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cavity 100:21

CCE 396:8

cell 61:7 347:13

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cells 47:13,13

center 180:4

centimeters 99:9

central 141:8

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cents 142:5,8

certain 61:18 66:9

66:12 72:18 190:7

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63:17 70:11 75:6

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88:13 96:1,19

97:4 103:1,14

118:3,14,19 119:3

130:3,8 147:3

157:6 158:16

167:6,14,18

171:17 172:9

176:17 205:14

211:19 239:20

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275:10 285:22

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413:10 415:19

428:13

certified 9:18

cetera 71:17 75:15

118:18 184:20

215:16 260:4,13

262:19 263:7

265:2 304:12

319:3 339:2 411:6

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Chair 1:17,19 4:8

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chaired 11:20

Chairman 3:8 13:9

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64:11 68:22 69:6

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78:22 79:4,7

80:22 84:6 85:1

90:4 91:4 96:9

97:11 98:13 102:2

106:7 107:4,9,13

111:18,22 114:18

115:16 121:10

124:10 127:9

128:5 130:10

131:3 132:6

133:20 134:2,5,18

137:18 138:2,5,10

140:2,15 141:2

149:21 151:21

155:14 159:7

162:9 166:5

173:21 174:10,13

174:16,20 176:12

177:4 179:11

180:10 183:3,19

184:1 185:14

187:14 196:5

198:6 204:7,13,15

204:21 205:2,12

205:17,21 206:22

209:17 210:13

212:9 213:1,10,13

213:17 216:10

220:19 221:11

222:3 228:8 234:4

238:5 241:5,8

254:15 255:16,19

255:22 256:14

259:2 265:10

270:2 272:22

281:11 286:10

287:20 289:16

291:14 292:4,7

296:9 300:16

302:22 304:21

308:22 310:18

312:22 313:14

314:7 315:17

316:9 318:7

319:15 328:5,8,12

328:18 329:1

331:5,10,13 334:4

334:22 335:15,19

338:11,18 343:7

343:12,17,20

344:2,19,22 346:8

347:2 349:3 350:8

351:10,12,15,22

354:21 355:9,20

359:7 360:12

362:3,18,21

363:15,19 364:2

364:14 366:11,19

368:6 369:8

370:10,17 371:5

373:4,13 374:15

381:18 383:2

385:1 386:22

390:9,16 391:2,9

391:14,17 392:1,6

392:9,12,17 394:6

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396:5 397:8 399:4

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436:1,17

challenge 124:6

282:17 320:6

333:2 347:6

challenges 352:15

challenging 216:14

403:18

chance 397:21

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change 50:12 55:8

57:20 69:9,9

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97:10 133:17

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157:6 171:3,5

219:19 222:20

246:13 256:18

271:5 280:12,19

281:1 297:15

333:13 357:7,10

386:19 388:16

426:11

changed 186:15

219:22

changes 60:16

84:15 94:11 124:2

157:11 186:14

191:20 215:2

220:16,16 244:3

318:3 333:17

334:3 386:15

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changing 99:18

217:10 257:1,3

258:12 263:2
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chapter 4:11,18 5:2

5:10 6:2,7 7:2,9

16:22 18:4 28:22

29:2 30:3 64:15

85:8 110:7,9,12

112:9,11,16 113:1

113:7 114:6,12

116:1,15 118:12

124:15,19 125:17

127:11,13 133:12

141:6,17 149:20

149:22 150:2

152:4,9,15 153:6

154:16,18 155:20

156:3 162:12,22

163:1 164:19

174:21 181:16

183:21 185:15,16

185:21 193:11

194:8,9,15 199:2

207:12 210:14,16

213:15 222:5,9

251:3,3 259:4,10

259:18 266:11

290:7 310:1,3,7

316:17,22 319:19

320:5 329:6 350:9

350:10 351:5

353:14 396:1,18

397:3,9,12 399:8

403:15 407:13,16

429:12,17,18

431:5 433:18

chapters 15:9 29:6

29:7,8,18 64:16

65:14,16,17,19

112:8 114:14

155:1 183:1

428:22 429:1,7,13

characteristic 81:6

characteristics

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62:11 63:5,13

81:10,20 184:15

184:22 190:16

239:21 285:18

characterization

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376:20 404:12

characterize 25:15

60:12 68:9 205:13

characterized

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170:16 190:17

233:1

characterizing

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350:14 376:6

charge 4:13,14,20

4:21 5:4,5,6,12,13

5:14,15,17,18,19

5:20,21,22 6:10

6:11,12,13,14,15

6:17,18 7:5,6,12

7:13 15:10 16:18

26:20 29:7 36:12

103:10 106:18

112:8,11,13,21

113:1 134:8 186:3

187:12,16 331:7

396:9 415:11

416:21 417:21

418:2,4,6,9 429:8

429:11 435:20

Charles 1:24 6:5,8

256:21 258:4

Charlie 19:5 72:8

77:1 78:21 79:10

80:13 122:14

130:11 174:21

177:5 179:11

188:9 220:19

230:20 243:1,7

256:17 281:11

296:9 317:15

319:20 320:3

329:8 330:6 334:8

343:14,22 344:6

352:12 354:22

359:8 364:4 382:3

385:8 392:18

398:12 399:19

401:2,3 430:2

431:6 436:6

Charlie's 80:8

392:13

chartered 9:22

charts 209:1

cheaper 301:10

cheapest 103:5

check 257:22 353:9

355:15,16 366:5

checked 123:18

chemical 97:14

104:1 220:16

330:1 361:2 373:9

373:15 379:21

chemically 51:1

136:14,15 137:4

chemically-oxidi...

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chemically-reduc...

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119:13 122:13

136:5 256:19

257:4 385:15

chemiluminescen...

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chemistry 89:3

97:17 141:22

148:18 234:21

247:13 269:3

294:15,17 323:7

362:13 367:18,20

400:22 401:21

Chesapeake 179:1

290:16

Chestnut 1:22 4:19

7:14 19:13,14

141:4 143:17

150:1 159:5,9

180:11 181:7,11

183:22 185:6,13

210:15 300:18

318:8,14 335:1

405:2

chime 105:2

choice 66:20 81:16

81:17 104:9,16

173:13 185:12

choices 35:18

147:22 148:9,16

choose 151:17

160:12 235:2

240:6 358:20

choosing 119:11

128:9 148:10

chorus 303:3

chose 65:17

chosen 120:4 234:9

Chris 24:2 124:12

Christmas 215:7,7

215:8

chronic 322:2,12

churn 233:14

churned 210:5,6

circle 340:4

circular 157:2

citation 88:22

157:16

cited 85:22 90:3

City 95:9

clarification

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213:5 228:12

242:15 265:22

362:12 399:22

409:10

clarifications

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clarified 159:11

clarify 117:20

160:6 166:20

184:5 235:17

236:20 264:20

402:17 426:18

clarifying 139:13

clarity 81:2 113:18

360:15

class 89:16 142:20

classes 174:2

236:14 307:13

352:16

classification 33:14

286:19,22 308:10

352:9

classifications

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classify 319:1

Clean 1:3 8:5,10

10:19 121:3 212:1

cleaned 416:7

clear 50:10 54:5

87:7,16 105:20

115:7 132:5 140:5

146:2,7 150:10

203:5,7 242:11

299:6 302:20

313:21 314:5

319:2 326:9

334:14 336:8

338:6 359:18

377:2 404:13

405:20 408:17

416:4,5 417:10

cleared 428:13

clearer 29:20 132:4

316:1 401:22

clearly 63:14 66:20

75:18 86:9 109:12

125:8 130:5 156:8

186:11 190:5

199:1 210:17

244:5,8 246:20

260:5 261:20

300:11 305:21

335:4,11 336:16

337:8,9 339:16

340:2 353:7 384:4

418:17

clever 103:18

119:15 278:19

climate 323:22

333:13,17 334:3

388:15

climatic 282:13

387:6 389:21

clipped 270:6

close 90:15 112:6

251:18 315:3

412:4

closely 129:6

230:14

closer 108:9
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cloud 367:18,19

clouds 367:6,12

CMAQ 37:6 47:5

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62:2 90:1,2

154:19 198:4

199:6,7,7,8,10,12

199:14,17 200:4

200:10 201:10,14

201:20 203:1,9,17

206:7,15,16 207:5

208:18 213:8

224:5 312:1,9,17

340:18 345:19,21

347:7 348:10,17

349:20 365:2,12

365:14 366:3,15

372:13 376:17,22

379:18 381:15

387:5

CMAS 367:9

coastal 87:22

123:10 291:11

coefficient 391:4

392:3

cognizant 423:3

collaboration

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colleagues 345:21

364:12 393:18

413:6

collect 176:6 335:9

color 117:4

Colorado 100:17

combination 38:1

40:3 109:22 188:6

311:14 361:5

367:13

combinations 38:6

combine 109:20

232:8,11 277:1

341:4,20

combined 188:3

193:22 422:5

combining 67:21

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24:6 60:15 86:17

87:2 89:13 90:21

111:20 115:4

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237:22 238:1

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307:21 360:4

374:7 377:22

401:13 408:20

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139:8 148:20

157:9 159:22

160:8 197:6 205:2

227:2,2 239:8

246:10 270:15

276:2 334:17

342:1 407:5

comfortable 214:7

429:3 434:2

coming 21:8 53:11

60:3,4 83:2 91:1

97:9 136:5 197:19

228:19 236:11

252:3,8 262:18

270:16 290:20

302:2 319:2 381:6

421:8

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153:20 183:6

comment 4:2 9:9

9:10 16:2 28:5,6

70:11 71:11 79:9

84:8 85:3 90:7

113:14 114:5

115:14 116:14

119:9 122:12

127:18 130:12

131:6 134:16

147:10 149:14

152:6,11 153:12

153:18 155:8

160:3 170:13

207:2,3 208:1,17

223:20 243:8

254:3,6 257:9

262:1 268:3

275:16 286:18

290:13 296:11

298:13 321:12

331:6 339:7

344:14 346:15

349:5 352:6

353:17 365:6

374:5 379:12

396:4 397:16

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418:1 423:7

425:12

commented 42:6

77:7 281:13

commenters 13:3

comments 7:21

9:12 13:2 18:5

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50:9 53:3 57:18

76:1 106:14

109:10 112:22

113:5,18,21 114:2

115:8 119:7

124:14,19 127:7

127:11 149:18

152:2 169:10

170:10 174:21

188:9 208:13

209:19 210:13

213:7 241:4,11

243:2 248:20

259:13 264:16,19

264:21 267:8

269:9 286:13

289:16 291:6,13

310:16 319:17

320:2 331:4

335:17 346:6

347:5 363:17,20

364:16 365:15

366:13 381:22

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commercial 94:9

94:10 100:13

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committee 1:3 4:6

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committees 303:21

Committee's 109:1

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communicated

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communication

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communities

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community 93:10

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171:6 204:3

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207:11 208:15

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compelling 187:1

compellingly-logi...

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complementary

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completed 24:16

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109:19 173:1

189:20 196:7

298:21 320:21

complex 86:22

200:11 260:19

265:4 340:9,14

380:17 392:19

complexities 63:20

200:10 261:5

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67:20 261:2

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compliance 10:4

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93:20 335:5,10

360:7 383:16,22

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compounds 95:13

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comprehensive

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concepts 150:6

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conceptual 29:1,16

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39:22 67:9 107:17

110:11 222:10

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215:20 218:14

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conducted 9:4

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confidence 115:3,5

131:12 207:20

266:7,22 267:4

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341:22 342:6,7

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200:6,8 293:22

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configured 93:19

conflict-of-interest

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confused 320:21

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confusion 137:13

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229:7 326:13

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Congress 393:6

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259:22 319:9

Connecticut 92:18

177:22 178:8,11

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connectivity

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consecutive 47:6

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72:13 88:19 99:17

124:18 125:10

129:14 180:7

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constraining

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constraints 128:19

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consultants 183:17

Consulting 19:14

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context 62:19

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converted 39:1

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convinced 189:20

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Coordinator 85:18

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copies 434:12,13

correct 55:7 74:2,3

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correctly 171:10

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corresponding

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cost 98:3 271:10

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cost-effectively

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count 121:13 187:4

country 73:17

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296:22 306:5,6,14

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243:14 347:5

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coupling 255:1

298:6 377:9

course 23:9 25:11

26:18 27:10,16

45:15 57:20 65:6

95:19 136:17

209:2 210:4

230:12 233:7

234:15 241:11

242:6 250:18

260:14 262:3

274:22 280:9

285:14 287:9

295:7 303:5 313:5

313:6 345:6

367:18 374:5,14

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381:9 385:3

court 198:9

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cover 16:19 49:15

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coverage 97:22

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185:2,2 326:1

333:12 338:2

363:17 410:10

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covers 60:6 150:2

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Cowling 1:23 4:15

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102:4 104:6

115:20 116:21

118:5 119:1

121:12 135:16

136:1 139:15

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256:15 258:2,9

331:11,15 346:10

362:19,22 385:2

388:21 389:7

425:11,22 428:7

co-authors 396:13

co-located 400:15

co-variant 235:1

created 116:16,18

118:1

creation 121:13

criteria 8:14 33:1,4

33:5 37:8 40:8

90:14 95:18 96:3

96:14 97:2,5

119:12 120:6

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critical 24:3 32:15

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35:7 45:4 59:7

116:2 121:7 150:9

156:15,16,18,21

156:22 159:10,14

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160:16,17,22

161:3,7,8,13,20

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236:1,4,19,22

237:8,9,18 238:3

239:17 240:16

263:17 303:14

330:12 353:15

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366:7 382:14

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critically 206:18

225:2

criticisms 311:5

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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

current 25:19

26:10 38:8 49:9

53:6 69:4,12,16

69:18 86:10 94:13

97:1,20 127:3

167:17 185:18

186:1 187:9 188:2

188:3,6,13,15,21

192:9,10,17 193:6

194:4 196:9

210:17 211:11,12

212:7 213:22

214:6,21,22 215:1

215:3,10,18,19

217:9 218:8,14

219:2,16 220:2

228:18 240:7

329:12 404:6

currently 11:20

57:16 93:18

141:16 367:1

curve 35:16 36:2

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109:18 151:5

299:17 302:8

382:8 386:19

curves 31:18 35:13

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111:3 299:13

302:4 382:16

383:15,18 384:11
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danger 369:9

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days 425:1

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133:9 141:8

175:19 293:12

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decisionmaking

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decisions 142:3

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declination 162:22

decline 66:11 308:2

decomposition

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decreased 51:1

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decreases 43:17

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decreasing 55:13

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dedicated 350:10

deep 323:8

defensible 323:1

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86:18 137:21

156:21 162:3

239:5,22 337:2

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defining 37:9 50:17

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433:7

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98:19 134:18

171:7 287:5

328:13,19 339:4

359:21 367:1,17

definition 156:19

156:21 284:11,18

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definitions 42:5

degradation 239:8

degree 62:12 74:2

266:6,22 267:4

316:19 319:11

degrees 70:14

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deleterious 163:9

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deliberation 13:1

deliberations 9:3,7

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delicate 64:8

delighted 12:10

116:4

demands 331:22

demonstrate 31:15

demonstrated

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demonstrating

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denitrification

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depend 233:16

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dependence 200:12

dependent 21:15

47:20 373:9

depending 31:2

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deploy 100:4

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86:4,20 87:13,17

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98:20 99:7 103:21

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145:4 149:3 150:8

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lead 23:22 60:15

62:13 63:20

112:12,14 134:7

148:14 169:2

188:1 211:16

222:6 339:12

403:16 429:22

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leading 28:6 417:1

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leads 16:21 17:6

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leakage 228:19

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18:12 21:20

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114:18 124:12,13

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222:7 225:1 252:6

261:8,9 274:16

280:6 286:5 313:4

319:15 344:5

351:17 369:11

379:17 416:20

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level 31:5 32:18

34:7,17,19,22

35:21 38:12 39:6

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43:4 44:6 46:9

66:4 67:1,11,12

81:22 82:8 88:15

111:5 115:5

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184:7 190:2

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335:8 342:17,19

345:2,5,14 359:22

372:4,7 380:8

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levels 51:9 53:16

65:6,9,11,13 67:5

67:10 89:17 115:3

151:6 172:18

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306:3 319:4,6

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363:5 368:14

374:18 377:2

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388:13 405:10

424:20 427:18

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54:18 63:3 64:8

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353:16 365:19

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Luckily 14:5 211:7

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Lydia 3:12 11:13

15:18 21:1,4

163:14 166:5,7

425:18 426:12

Lynch 40:20 73:5

218:13

M

MAGIC 89:2,5

194:10 216:21

223:21 246:8,15

246:17 247:9

magnesium 297:20

magnitude 25:15

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71:7,8 77:20

79:16 80:19 117:8

127:16 129:8

136:13 137:22

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141:21 143:4

147:20 151:4

154:1 155:10

157:22 160:6

167:20 176:10

180:15 181:11

204:21 205:12

207:11 208:11

209:22 211:19

223:9 225:4

230:12,21 232:2

234:14 235:2,8

241:18 242:11

257:22 264:7

265:15,20,21

266:12 268:6,8

273:17 285:12

287:11 307:9,22

310:13 313:20

323:4 324:1

325:13,17 329:4

331:21 335:10

337:16 342:8

354:8,13 357:5

366:1,6 368:13,22

369:1 375:2 376:9

387:15 388:18

405:8,17 407:6

410:8 411:11

415:22 417:20

423:19 426:7

434:1 436:3

meaning 35:10

137:11 160:11

270:15

meaningful 220:3

meaningless

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means 15:10 50:22

51:2 57:2 153:17

155:12 224:17

252:9 262:3

289:13 337:1

400:12 411:5

423:13

meant 189:18

216:8 249:16

295:21

measurable 41:20

334:12 375:11

measure 31:8

48:10,13 71:16

93:14,22 97:15,22

99:4,12 100:14

102:15 139:6,7

186:18 195:8

222:19 274:17

280:6,8 306:17

330:16 424:5,6,6

424:15

measured 57:14

71:15 94:20 97:17

98:5 195:15 201:9

207:15 225:19

229:18 230:1,10

254:7 273:16

281:22 321:18

measurement 48:5

93:9 95:3 100:2

139:3 203:13

225:22 228:16

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measurements

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198:18,20 199:9

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249:22 269:12

273:15 275:13

320:14 341:7

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393:19

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146:1

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member 12:12 19:3

19:5,7,9,11,13,15

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20:13 54:7,13,17

54:21,22 58:3

60:20 61:1,3,14

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364:6,15 365:17

366:12,21 368:21

370:20 371:16,18

372:6 373:6,11,14

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381:12 382:4

383:4,5 385:2

387:1 388:1,4,11

388:12,21 389:7

389:14 392:15,20

394:2,14 396:3,6

397:10 399:6,9

400:1,17 401:18

402:4 403:17

405:2 407:19

409:9 412:13

414:2,18 415:3

416:10,15 419:18

422:17 423:1,7,17

424:21 425:4,11

425:22 428:7

430:6,17,20 431:9

431:14,19 432:2,7

432:11,14 433:2,4

433:14,16,20

434:8,10 435:14

435:21 436:13

members 1:18 2:1

10:4 11:2 24:4

50:8 113:10

385:21

memory 354:17

mention 54:18

120:4 169:12,22

175:6 220:22

317:17 330:4,5

414:7,9

mentioned 30:5

33:13 58:6 79:2

88:5 128:9 145:5

145:17 154:17

155:10 170:9

177:6 189:21

222:16 249:6

252:2 268:4,14

279:9 281:17

295:21 296:11

347:11 352:20

365:4 387:3

399:12 415:6

419:5

mentioning 50:2

mentions 385:8

message 168:7,15

268:19 436:4

met 23:12 104:1

meteorological

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meteorologically

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meteorologists

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meter 34:12 191:13

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226:21 227:6

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methodology 49:4

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409:6

Mexico 95:8

micro 103:18

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microequivalents

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micrograms

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microphone 85:12

112:3 115:18

286:17 331:14

346:9 362:21

382:5

microphones

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micro-meteorolo...

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micro-scale 380:16

middle 110:8

mid-eighties/early

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mid-September

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miles 60:21 61:2

milliequivalents

34:12 251:10

356:22

million 145:18,18

million/billion

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mimic 80:1

mind 15:1,17 74:5

102:7 236:12

276:2 329:4

342:10 358:18

387:7 391:18

392:7 406:12

428:14

mindful 85:14

109:9

minds 50:22

Mine 198:10

mineral 360:19

mineralized 258:21

minimize 326:12

minimized 327:8

minimum 298:1

388:7

minor 132:7

133:18 155:8

174:22 195:9

196:2

minus 38:20 42:22

43:2 195:3 231:8

233:12 251:9

minute 24:19 90:4

160:4 256:17

430:7

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misinterpretation

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254:17 255:12

287:21 288:16,22

289:6,10 304:22

307:13,22 308:15

333:8 347:4 348:8

363:16 365:17

372:6 373:6

389:14 403:17

409:9 412:13

mitigation 82:22

mitt 178:18

mix 201:16 373:22

mixed 139:11

381:19

mixing 145:19,21

mixture 370:7

mobile 211:21

258:22

mobilization 282:8

model 29:16 30:18

32:10 35:3,4 47:5

57:8 61:16,17

62:2 64:7 76:20

78:7,8 79:22

83:18 90:2 94:2

94:21 95:1 101:2

188:10 194:21

195:1 200:11

205:7 206:6,7,7

207:15,16,18,20

208:2 209:7

216:19 225:9,12

226:10 227:18

230:14,15 231:1

232:2,17,18

246:22 247:2

248:14 257:16

260:8 270:15

281:19 283:10

317:7 318:2 319:3

341:9 353:16

366:3 368:10

369:3,4,6 372:13

372:13 374:7,9

375:9,10 376:9

378:9,12 379:19

381:8 382:16

388:8 390:4

406:14 424:7

modeled 51:15

127:14 178:3

228:21 230:2,22

233:21 317:12

376:12

modelers 386:2

modeling 41:1 45:4

47:4,7,10 48:16

62:13 139:4

203:11 204:12

229:17 235:20

236:1 237:1,13,18

238:3 246:3

251:13 272:4,4,21

290:21 317:19

323:3 335:10

348:18 375:13,16

378:11,17 379:2

389:11 394:18

413:20

models 32:6,7

79:16 83:12,14

114:7,9,10 115:4

154:20 190:21

209:12 223:19

224:2,8 231:1

246:19 257:21

258:6 266:15,17

276:5 281:21

283:8 296:12,16

298:9,10 312:8

320:13 321:19

344:12 349:15,16

354:3,4,12 355:18

365:2,4 367:5

368:2,3,4 370:12

371:12 375:14

376:6,9 377:9

379:10 424:14

modest 195:21

modifies 191:3

modify 277:16

278:16 392:22

mole 105:5,20,21

244:1,1

moment 28:14 81:2

97:9 420:6,21

monetized 153:10

monitor 60:6,10

94:9,10,16 269:13

269:18 360:7

369:15

monitored 95:20

98:6

monitoring 41:22

48:17 49:4 90:17

91:22 92:9 95:16

97:16 98:12 100:5

101:4,18 103:11

104:4 185:22

193:1 206:11,17

327:12,15 341:4

393:1,6,12,13,14

432:19

monitors 93:13,18

94:5,6,13,14

99:18 369:2

Montane 87:11

month 27:10

months 107:7

123:21

morning 8:3 10:15

11:11 16:16 17:7

17:13 20:12,17

21:3 93:7 113:4

174:3,9 238:14

266:14 268:5,14

278:22 281:17

300:10 352:20

353:17 356:9

362:9 434:22

435:3 436:22

mountain 305:22

Mountains 85:19

420:10

move 24:22 25:4

46:2 50:18 55:6

69:1 70:18 101:7

112:7 114:15

139:14 181:15

183:1 220:9,12

241:9 259:5 276:5

295:13 343:11

344:5 377:17

384:19 393:20

399:18 411:13,15

422:10,16 423:21

427:10

moves 258:18

moving 41:5 55:21

179:14 185:15

264:15 269:12

296:14 377:16

397:8 411:19

muddle 220:7

multi 22:17 110:5

295:14 303:4

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multidimensional

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multiple 33:4 62:4

112:11 157:22

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304:1,2,14 341:12

411:5

multiple-pollutant

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multitude 83:8

multi-media

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multi-pollutant

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110:6 295:14

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301:15 321:10

404:7 422:5,6,7

422:10

mute 328:9,21

Myron 2:6 6:22

7:10 19:15 159:8

162:9 165:15

166:11 197:10

198:8 206:21

254:16 287:20

303:1 304:21

363:15 364:1

366:18 371:3

398:12 403:15

409:8

Myron's 366:13

N

N 37:14 254:19,20

255:7,12,14

396:19

NAAQS 1:5 3:10

8:7,16,20 11:8

24:12 90:11

128:16 179:6

190:18 414:8

NADP 90:1 138:21

199:9 349:20

393:7

name 117:15

121:20

Naresh 2:5 4:12

5:24 19:17 112:20

115:17 134:7

206:22 265:11

274:7 292:4

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432:9

Naresh's 374:5

narrow 412:18

nation 97:18
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necessity 426:8

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66:21 69:19 70:1

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237:19 241:15

248:13 269:11,13

272:19 276:9

281:18 291:4

300:11 307:7

308:18,20 321:7

326:5 332:15

333:10 335:8

337:4,6 338:4

348:4,7,15,17

349:10 353:8,9

360:6,7 391:10

393:16 399:3

404:6,15 405:12

406:2 407:10

409:2 433:20

needed 10:7 29:9

90:18 271:20

291:17 307:17

needing 196:1

needs 12:5 60:5

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142:4,6 145:4,16

146:1,4,6 150:21

151:3 169:21

173:14 201:15

376:20 377:4

400:12 406:4

407:21

negative 182:1,4,10

280:22

neither 93:22

nervous 385:21

NESCAUM 19:10

net 247:19

network 46:18,21

49:5 97:16,21

100:5 138:22

201:14 365:8

networks 41:22

49:17 186:10,18

192:9 194:4

195:21 198:15,17

206:17

neutralize 43:8

never 79:17,18

117:2 269:5 278:7

321:4 327:3 385:4

Nevertheless

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new 22:11,11,21

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100:4 107:20

109:21 123:3

128:15 145:3

146:3 154:2

179:18 193:1

194:5 195:18

196:1 237:13

286:1 323:15

345:11 370:13

406:4,5,7,8

419:20 420:9

426:15

NHx 40:5 44:14

97:6 104:4 130:4

268:15 279:5

NH3 104:4 345:13

nice 142:18 210:1

302:9 335:22

384:11

nicely 102:17 183:7

287:17

Nineteen 382:3

nitrate 139:8

195:16 243:16,16

244:2 245:7 246:3

247:3,10,18 256:7

256:8 257:17

275:4,6 282:11

314:22 325:7

361:3

nitric 94:12 98:21

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195:15 341:1,16

nitrification 231:5

243:19

nitrified 258:21

nitritified 248:4

nitrogen 4:5 11:18

12:4 16:4 34:11

35:17 36:9,16,22

37:12 38:21 41:12

43:1,3,10,15,20

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46:17,19 47:3,16

48:20 53:4,9 55:2

55:8,15,17,20

56:3,4,6,9,12,15

56:16,16,20 57:2

57:4 62:17 68:2,9

69:7,8,12 72:2

83:20 86:4 87:9

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135:4,12 136:4,6

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137:21 138:1,7,7

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165:20 167:2,12

167:13 168:5,14

168:18 170:17,18

171:11,15 172:2,4

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173:4,7,18 178:4

180:3 182:14,17

186:18 192:1,4

193:18,19 195:14

195:20 197:21

224:11 228:19

236:15 241:12

242:7,8,17 243:3

243:4,12 246:9,16

249:2,3,6,8,8,11

249:12 250:1

251:11 252:1,8,10

252:16,21 253:6

253:18,19 254:2,8

254:9,9 256:5,10

256:19,20 257:5

257:11,13 258:13

258:15,21 268:3,6

269:10 274:12,19

275:2 278:18

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NNS 158:8

noise 309:1

nomenclature

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non 69:20 92:7

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non-attainment

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non-ecologist

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non-linearity

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normal 303:12

normalized 289:12

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North 1:15 19:4

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Notwithstanding

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November 27:22

NOx 1:5 3:10 8:6

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211:19,22 212:4

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NOy 37:13 38:1

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42:3 43:18 44:1

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91:22 93:22 94:5

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97:5 98:3,18 99:3

100:7 139:8

192:13 193:6,18

195:3,4,8,18

341:13 433:5

NO2 49:9,14 93:11

93:14,20 95:19

96:1 100:2,5,14

100:18,22 101:8

105:13,21 171:15

193:20 197:18

208:7 341:15

383:7 419:20

421:2

number 36:17 51:5

57:18 58:6 66:3

66:18 88:20

101:15 104:21

118:10,10,15

143:2 144:3,6

151:7 152:18

168:4 182:7

229:22 236:4

279:1 282:11

283:10 317:17

349:17 350:12

392:2 421:7

numbers 145:6,11

145:15,21,22

146:5 148:22

149:11 152:10,12

152:12,14 153:5

153:13 199:14

266:20,22 267:20

268:1 274:8

284:20 368:5

391:22 398:7

406:3,7

numerate 153:16

nutrient 52:3

157:13 181:18

182:9 290:5 296:1

337:21 409:22

411:20 413:9

414:6,11

nutrients 182:3

295:5 300:9 339:9

339:11 411:7

412:9

nutrient-enrich...

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nutrient-loading

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N2O 105:18,20

O

Oak 19:7

OAQPS 11:12

13:13 15:16 21:6

106:11

OAR 106:12

objective 173:15,16

observation 68:21

94:21 209:12

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observational

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observations 48:3

99:15 123:9 249:7

317:11 368:17

369:19,20 370:1

374:7 388:8

observed 126:7

186:21 204:16

207:7 420:15,17

obviously 14:1 50:6

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60:5 65:13 66:13

72:7 75:9 88:1

89:7 133:5 162:4

162:7 165:2

198:22 199:16

201:1,12 204:17

236:13 260:7

284:6 288:1 295:2

302:2 307:14

308:1 311:7,9

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384:16 405:8

410:14 412:13,14

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occasions 132:14

133:13 189:22

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occur 164:5,7

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occurred 186:13

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occurring 65:12

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167:1,11 186:12

215:12 216:4

229:3 330:21

occurs 190:6

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offer 117:17 363:9

offering 102:14

office 2:13 3:6,15

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11:14 40:21,21

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Officer 2:12 8:5

official 3:4 85:11

off-track 158:6

oftentimes 172:1

OGC 71:10 129:13

oh 54:13 107:4

108:17 115:20

131:20 139:18

149:21 151:15

193:14 205:21

213:16 234:3

238:6 251:21

255:22 262:17

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285:15 328:16,20

331:15 343:20

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Ohio 178:10,11

okay 19:3 20:4,19

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91:18 106:7 107:9

108:12,17,19

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one-year 389:2

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Ontario 122:21

on-the-fly 50:12

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opinions 135:21

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organic 72:13,21

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137:3 138:8,11,16

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253:6,15,17,18

254:2,7,9,20

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organisms 408:6

organization 85:21

oriented 14:16

origin 55:22

originally 117:21

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106:21 108:13

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outcome 260:8

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outline 314:2

output 199:6,8,8

365:14

outputs 78:7 203:1

205:8 233:5,21

252:21,22 369:3

outside 83:9 270:17

overall 24:11 43:20

52:15 60:12

112:22 127:19

128:2 219:4 220:1

247:13 254:14

289:8 294:9 304:4

310:1 373:19

404:12 417:22

418:1

overemphasize

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overlap 348:10

overlay 338:17

overlays 143:15

overly 435:19

overpredict 367:12

overpredicting

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overprotect 82:2

oversight 415:2

oversimplying 87:1

overview 28:22

overwhelming

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oxide 119:17

oxides 94:12

oxidized 41:12,13

41:14 43:3,16,21

44:17 49:15 56:6

56:9,15,20 57:3

93:13 96:6 104:12

104:18 135:6,9

136:3,16 192:4

193:19 195:14

242:17 243:4

246:15 252:8

256:18 257:4

258:12 385:15

ozone 128:11

168:22 210:20

211:16 301:17

421:6

o'clock 221:13

P

PA 4:11,18 5:2,10

6:2,7 7:2,9

Pacific 132:20

pack 195:22

package 212:19

packs 103:6,13

Paerl 122:17

Paerl's 123:2

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pages 116:15

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paint 421:19

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pair 398:4

paleo 216:18

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paleo-calculation

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404:11 407:12

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panelists 10:8

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Panel's 9:20

paper 93:16 357:19

papers 99:14 218:3

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paragraph 100:10

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paragraphs 397:19

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parallel 74:7,9,16

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parameter 109:22

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systems 12:7 40:19

40:19 68:9 73:21

77:17,22 86:20

87:9 127:15 154:4

168:6 172:10

182:18 190:7

196:21 197:2

217:8,9 218:5

221:3,4 230:5

257:12 259:15

274:18 275:8

290:6,12 293:3,14

294:2 295:10

297:2,2,5 298:2

298:12 304:4

305:18 319:14

323:15 334:12,15

358:5,6 359:12,16

380:5 400:5,22

402:13,19,20

403:1,3,4 411:9

413:2 434:1

S-E-S-S-I-O-N

222:1

T

T 1:24

table 58:13 153:7

155:22 169:12

262:14,16

tables 277:14

tails 184:13 285:5

take 36:10 55:17,19

68:2 70:11 84:3

89:9 96:8 99:19

100:9 119:16

120:15 122:12

143:9 157:20

170:21 173:12

175:21 178:22

212:5 219:10

225:9 230:16

242:10 254:17

301:2 302:7 308:3

315:1 347:14

351:17 370:18

392:16,21 394:7

395:17 400:4

420:20 430:3

431:21 434:6,13

taken 9:15 44:2

108:1 142:13

175:17 227:16

242:21 247:19

248:2,3 399:14

takes 43:7 182:11

334:14 336:18

talk 12:19 16:4

29:17 31:21 33:20

35:15 41:6,16,18

42:11 52:17 58:14

110:9 125:18,20

129:13 138:16,22

144:16 160:10

161:10 164:20

166:9,12 170:1,5

217:10 224:15

250:7 310:7,8

311:21 319:6

321:5 383:16

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tapping 432:20

Tara 3:18 24:2

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30:2 40:16 42:14

44:2 45:2 55:21

83:14 135:1

137:18 234:1

356:9 383:19

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Tara's 160:21

target 31:5,8,11

38:2 39:5,10,19

40:4 43:18 161:11

161:18 196:12

231:21 296:15

358:21 359:14

361:12 408:13

targeted 89:15

400:13,21

targeting 297:16

targets 57:5

task 403:18

team 23:21 24:4,4

24:7 40:20 385:21

410:7,21 412:2

tease 215:12

Tech 18:22

technical 8:14

85:18 130:17

353:14

technically 92:22

techniques 48:6

101:10 103:2,11

139:10 202:12

379:4 433:6

technology 195:22

Ted 3:7 7:22 9:18

10:12 11:3 12:18

13:8 18:21 20:7

21:2,13 73:14

115:21 128:22

154:16 187:13

194:20 205:7

206:21 300:18

335:1 374:22

395:12,13,17

435:14

Ted's 22:6 72:11

teleconference 2:22

10:2 16:11

telephone 18:7

tell 64:22 65:1

71:20 118:6

146:15,21 153:16

159:18 250:2

429:13

telling 146:8

tells 402:18

temperatures

377:11,11

temporal 88:13

275:1 319:7

324:16 346:14

347:8 349:11

temporally 350:6

ten 172:20 266:10

292:19 373:5

tend 130:18

tends 125:3 254:20

255:13

tens 60:21

term 36:13 44:5,9

44:14,15 45:10

46:5 67:18,19,19

69:9,15 72:2,13

73:2,10 81:6

110:17 111:1,7,11

130:4 133:14

135:3,5,11 136:11

159:14 160:8

225:10,11 230:18

249:13 258:11

262:17,17 264:12

268:15,15,21

269:6 270:21,22

300:14 334:20

353:11 356:3,6

376:2 399:17

terminology 264:1

terms 14:12 17:5

33:11 37:4,4 40:6

42:2,4 44:9,21,22

45:9,9,10 46:7

47:8 49:3 51:8

54:11 55:2 62:17

66:10,16 68:8,12

68:18 71:2,16

72:17 74:13 75:19

76:6,13,17,18

77:20 81:12 82:8

82:22 91:21 96:21

101:13,16,20

105:7,21 110:3,19

113:21 116:11

117:13 118:17

121:1 129:3

134:11,13 137:11

146:12 150:9

152:10 164:16

180:11,13 181:21

182:5 184:5 189:6

200:2 201:10

202:14 204:4

209:6,21 213:5

217:6 220:22

221:5 227:3

231:16 239:17

242:16 243:9

247:12 253:10

256:8 261:19

269:12,12,13

271:12 275:1

293:5,15 298:5

301:6 305:3,20

306:7 317:19

318:2,3 324:16

329:6 331:21

332:5 334:12

337:22 339:7,15

342:21 349:6

350:18 352:6

353:3,15,19 361:9

362:11 364:12

365:18,22 369:19

370:2 372:19

376:12 377:8

378:2,9,13 379:5

379:13 383:13,15

383:16 384:3,5,21

387:22 402:12,21

403:22 404:4,22

412:19 419:11

421:19 422:19

426:21 427:14

428:15 435:8,19

436:8

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terrestrial 40:19

52:1,6 64:22 77:6

77:16,22 78:10,14

104:8 148:21

197:2 217:2 287:4

290:4,6,9,12

291:18 292:11,18

293:2 294:2 295:4

298:6 300:5,7

307:1,8 330:7

334:15,18 345:15

398:21 399:13,15

399:18 400:5,9,15

402:8,10,19,22

403:3 406:20

410:18 412:2,8,22

terrestrial-related

291:19 292:2

test 74:21 365:14

389:22

testing 224:4

321:17

tests 200:22

Texas 391:7,20

text 72:20 74:15

158:18 224:21

265:1,6 320:21

394:3 398:11

399:2 414:4

416:16

thank 10:9,14,16

13:9,11 21:2,7,18

23:4 40:16 54:1

58:3 85:15 91:3,4

93:6 96:9 106:7

107:4 108:18,21

112:4 115:16,20

124:10 127:9

128:5 130:10

140:15 151:21

155:14 174:14
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thermodynamic

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29:20 50:3,14

51:14 57:13 63:11

65:20 69:22 75:8

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244:2 245:5,19

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271:16,20 280:10

280:12,20 281:2

281:13 285:3

287:1 288:21

290:4 293:18

296:7,20 301:3

304:15 307:5

308:9,14,17

312:11 316:16

318:22 321:19,21

324:6 344:16

346:20 349:1

350:15 351:16

352:17 361:5

363:6 371:10,12

374:19 375:7

376:18 378:1,8

383:9 384:1

385:19 387:8,21

390:15 391:15

392:7 398:7

406:21 407:3,9,20

408:18 417:21

418:14 422:12

426:22 428:14

think 13:14 14:6,7

14:22 15:7,12

16:7 17:1 21:22

22:3 25:7 26:11

26:21 27:1 48:17

50:22 51:21 52:2

53:9,19 56:19

58:7,10,21 59:15

59:16 60:14 67:21

68:17 70:10 71:1

73:13 75:1,13,20

78:1,5 79:13 80:9

80:17 82:5,13,14

83:12,15 86:16

89:12 92:11 93:1

96:18 97:2,5

99:11 101:2,12,19

101:22 102:21

103:3 104:15

105:17 106:15

110:12 111:7

112:18 113:6,10

113:17,20 114:10

115:10 118:16

121:2,4,18 122:18

126:5,10 128:22

129:11,12 130:1,9

131:11 134:8,13

134:21 136:1

138:15,17 139:12

140:5,10 141:7,10

141:17,19 142:19

143:7 144:2 145:1

145:12,19 146:11

146:21 147:2,6,11

147:13,13,13,17

149:12,15 150:2,5

151:15,19 152:6,8

152:21 153:1,4,20

153:21 154:12,13

155:9,11,20

156:15 157:8,10

159:11 161:5

163:7,11 164:12

166:3,4,11 167:8

167:14,18 168:16

170:8 171:20

173:9,14,16 175:5

176:4 179:13,16

179:18 180:5,8,14

180:18 181:8

183:13,20,22

186:6 187:1,8

188:1 189:14,17

191:15 192:5

195:5 197:15

198:3,8 199:2,18

200:1,5 201:1,15

201:20 202:2,6,21

204:8 206:4,8,12

206:16 207:4,8,22

208:13,17 209:14

213:8 216:11,15

216:20,22 218:6

219:1,15,20

220:10,15 222:18

223:11,18 224:5,6

224:9,14 226:22

227:11,12,14

228:5 230:7,15

231:4,9,10 232:4

232:10 233:13

235:5,16 238:12

238:19 239:8,10

241:13,14,15

242:5,12 244:7

246:17 248:16

249:6,14 250:21

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257:10 267:1,8

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276:9,12 278:18

279:14,19 281:15

281:16,18,19

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283:7,13,14,16,17

283:19,21 284:6

284:18 285:21

286:5 287:22

290:15 291:8

292:9 293:18

294:5 295:1

297:10,15 298:3,7

298:8 302:5

304:17,19 305:1

305:18,19 308:5

309:6,14,22 310:4

311:12,16,19,20

312:14 313:15

314:8,11 315:3,15

315:19,21 316:2

316:10,20 317:12

318:4,21 319:4

320:8,10,15,16,17

321:1,7,9,11,15

321:16 322:22

323:2,10,15,21

325:12 326:8,8,11

326:21 327:2,10

327:16,19 328:1

329:8,10,16 331:6

331:18,20 332:4

332:14 333:13,15

334:7,20 336:9

337:4,13,15 338:6

339:4 343:3

344:12,16 345:2

345:17 346:18

348:19 349:12

350:4,9 351:2,16

352:1,5,9 354:6

358:3,13,15 360:9

360:15,22 362:5

362:11 363:16

366:8,13 367:1,2

367:16 368:1
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387:2,6,10 388:5

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389:10,11 390:1

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394:12 395:11,20

396:15 397:5

398:16 399:19

400:3 401:1

402:11,20 403:2,7

404:8,8,13,16,19

404:21 405:11,22

406:11 407:2,6,9

407:14 408:3,7,16

409:6 410:12,16

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414:14,16 416:6

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424:17 425:4,7,20

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433:8,12,20 434:2

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50:3,4 53:1 55:3

58:16 62:3,18

69:5,16 74:6

82:17,20 102:9

120:15 122:22

136:22 171:8

176:5 179:6

192:20 195:2

218:2,10 225:15

225:20 229:7

238:22 256:17,22

258:10 268:17

269:9 271:17

272:20 280:17

293:8 294:22

296:17 298:5

299:10,11 300:1,4

300:8 301:5 302:1

304:9 346:11

349:8 355:2

356:20 357:4,18

357:19 358:1

368:15,20 380:18

386:7 398:5

401:19,20 402:22

406:21 413:13

419:19 420:14

422:12,18 425:13

431:12

third 92:3 114:21

123:3 134:8,17

139:19 167:21

171:20 224:15,22

408:1

Thirteen 431:3

thorough 53:12

186:5

thoroughly 102:10

103:10

thought 69:14

74:19 91:19 95:4

112:2,10 114:22

126:21 138:6

189:13 190:18

192:14 225:4

227:21 234:11

237:8 250:10

251:21 260:10

279:10,16 291:2

319:17 351:4

353:11 355:11

362:7 363:2

370:18 405:14

416:1 417:8 432:5

437:2

thoughts 62:16

175:15 180:6

197:13 232:12

294:20 335:16

384:9 398:11

399:2 415:22

419:3

threatened 385:19

three 11:22 47:6

114:19 127:15

224:19 225:5,7

257:2 290:3

313:22 350:6

379:11 385:22

387:10 388:7

433:22 434:6

three-dimensional

386:3

three-year 320:19

322:8 387:2

388:17 389:3

390:21

threshold 110:15

110:20 146:21

160:2

thresholds 339:3

408:10

throwing 82:21

THURSDAY 1:9

tie 161:3

tiger 133:3

tight 371:9

tightening 265:3

till 276:4

timber 83:19

169:13,18 170:1

timber-producing

170:3

time 11:4 14:5

17:17 21:20,22

22:5,10,17 23:7,8

23:12,13 42:7,9

52:8 57:20 58:1

70:1 71:20 86:22

88:12 91:1 112:6

113:2 116:3 121:5

121:19 122:5

125:4,4 129:2

155:5,6 171:14

174:4,8 179:20

186:10 187:5,16

188:5 189:10,10

195:11 196:19

208:3,12 209:20

218:17,17,21

220:1 221:12

224:3 227:5

228:18 229:1

230:9 233:3,8,10

233:14 235:9,9

239:14 246:12

249:19 257:11,12

268:10 272:20

280:13,21 282:5

294:4,7 300:12

310:9 320:13,15

320:17 321:2,13

321:20 322:11

325:14 327:12

336:10 342:14,16

350:22 371:8

385:8 386:4,15

387:13 393:5

395:3 399:10

404:2 415:15

418:14

timeframe 187:21

197:8 213:21

408:20

timeframes 322:20

times 58:6 95:12

118:15 171:1

220:17 246:2

259:1 274:13

344:15 363:7

382:11 389:9

timespans 200:16

timing 71:3,4 76:6

76:18 129:2

189:17

tiny 178:14

tip 301:14

TMDL 175:2,18

177:8,21 179:6

183:10 295:22

TMDLs 175:3

177:6,17

today 9:11 13:13

15:8 23:10,15

26:19 27:1 65:9

86:16 89:13

155:22 174:12

215:12,21 216:2

218:16,19 219:3

219:19 399:11

405:7 407:6,10

today's 27:10 216:5

told 418:21 432:6

tolerated 159:17

Tom 11:19

tomorrow 16:16

17:6,10,13 174:2

174:5,9,17 409:18

tonight 17:7 428:19

tons 394:2

tools 147:8

top 257:18

topic 43:11 49:21

157:21 194:19

420:18

topics 176:15

topography 59:21

total 41:11 47:15

93:12 96:3 102:7

103:14 105:21

119:18,22 120:3

122:16 123:4

135:3,12 137:21

138:1,7,12 139:2

139:16 140:7

148:22 191:6,8,9

191:10,16 192:1,3

192:12 193:18,22

195:4,14 208:21

341:6 342:5

349:21

totally 70:22 82:20

165:15 276:15

398:8

touching 52:13

track 95:21 243:22

282:1

tracking 245:4

tradeoff 31:17

35:13,16 37:14,16
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tradeoffs 239:14

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tradeover 40:2

trading 105:18

traditional 201:2

420:12

traditionally 99:4

trail 152:21

transfer 235:22

236:18 237:19,21

375:2 377:5,12

transferring 238:2

transformation

30:20 37:5 44:20

47:8 48:21 264:4

264:13,14 314:21

332:15 387:16

transformations

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transformed

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transient 376:13

transition 44:7

translation 384:13

transmission

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transparent 358:14

transpired 15:19

transport 211:22

263:6 269:17

travel 73:7

treasured 86:2

treat 182:20 314:15

315:9

treating 56:21,22

68:19 81:20 268:9

treatment 51:18

139:12 165:3

167:5 189:20

203:8,10 242:16

268:5

treatments 381:3

trees 149:4 307:14

307:17

tremendous 67:21

101:16

tremendously

261:1

trend 233:19

triangle 1:14 38:8

tricky 162:5 302:2

302:20

tried 25:15 101:13

120:6 133:8

160:20 208:20

337:5 400:4

418:16

tries 109:21 349:16

tropical 79:20

trout 133:14,15,18

true 109:5 122:18

146:16 172:17

226:10 246:2

324:14 326:8

349:19 389:3

393:10 397:13

405:17

truly 355:22

try 52:14 59:1 60:7

60:10 65:21 74:21

75:20 89:3,7

131:1 135:13

158:11 176:5

184:8,21 187:18

192:7 202:19

211:2 216:22

231:2,3 236:17

264:22 280:21

281:14 282:1

283:8 291:22

295:16 312:4

318:1,22 319:4,6

327:8 337:1,14

338:5,8,16 350:19

388:19 395:8

399:1 401:22

414:22 417:11

432:16 434:8

trying 29:5,14

59:13 64:1 68:8

86:18 99:4 100:4

103:4 104:7

127:19,21 128:19

129:16 130:6

143:13 154:6

158:15 160:6,14

161:2,4,13,16,22

165:18 180:22

181:2 184:18

189:7 192:21

197:18 198:4

205:22 209:11

215:9,22 218:10

219:20 220:4

222:13 227:17

236:11 239:7,10

253:4 255:9

268:11 271:17

282:5 285:3

288:19 293:20

295:1,13,15 302:6

302:17 304:22

309:20 322:10,17

339:4 355:14

358:12 360:9,15

376:1,5 383:19

384:5 405:7,11

406:10 408:13,19

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424:16,19 427:17

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309 5:11,21

31 132:10

310 5:24

317 6:5

318 6:6

319 5:22 6:7

320 6:8,10

328 6:19

33rd 120:21

331 6:21

333 6:22

334 6:23,25

34th 121:9

344 6:8,11,19

346 6:21

347 6:22

349 6:23

352 6:8,12

362 6:19,21

363 6:22

364 6:8,13,19,23

365 6:22

366 6:23,25

382 6:9,14

383 6:23,25

383,394 6:19

385 6:21

387 6:9,15,25

39 13:18

392 6:9,17

395 6:18

396 6:25

397 7:2,4,5

398 7:6

399 7:7

4

4 4:20 5:2 39:11

64:16 65:14

145:18 149:18

150:2 164:19

181:16 185:15,16

194:15 396:18

4.10 207:3,4

4.11 207:4

4.12 207:3

4.13 207:4

4:47 437:7

40 3:21 291:2

40th 121:11

400 34:22

402 7:8

403 7:9,10,12

404 7:13

405 7:14

407 7:15

41 116:15

415 7:18

417 7:21

42 116:15,22 117:7
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Neal R. Gross & Co., Inc.

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5

5 4:21 5:10 6:2

28:22 30:3 64:15

110:12 150:3

184:16 194:9

222:5,9 251:3,3

259:4 290:7

353:14 428:22

429:7,12,17

5-5 194:9

5.7 390:10 391:3

5:00 437:3

50 3:14 34:7,17

35:21,22 38:3,10

38:13 39:4,6 66:8

99:12 150:18,20

151:9 160:17,22

238:18 240:20

249:10 252:2

253:7,8 292:16,22

306:14 323:14

356:10,18 357:7

358:10,18,21

361:20 406:19

500 48:11

54 3:23

6

6 6:7 29:2 110:7,9

319:19 320:5

396:2 414:5,13

428:22 429:7

431:5

67 121:14

68 156:14

7

7 5:4 7:2 186:3

187:12 196:9

397:9,12 399:8

7.1 397:17,22

7.2 397:14

7:00 174:7

76 146:14

8

8 3:2 5:5 187:16

196:13,20 213:12

213:15

8:00 174:7

8:15 434:22

8:30 1:12 8:2

434:22 435:1,2

437:10

83 34:18 64:17

84 164:12

85 4:2,4

88 158:7

9

9 5:6 7:9 190:15

197:12,13 198:12

403:15 407:13

9.2.1 407:20

9:30 9:11 85:2

90-day 28:6

91 4:5,7

93 4:9

95 36:4 38:7,11

161:1 184:13

238:18

96 4:10