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 U.S. ENVIRONMENTAL PROTECTION AGENCY

 + + + + +

 CLEAN AIR SCIENTIFIC ADVISORY COMMITTEE

 PARTICULATE MATTER REVIEW PANEL

 + + + + +

 PUBLIC MEETING

 + + + + +

 THURSDAY,

 MARCH 11, 2010

 + + + + +

 The meeting convened in Salon ABC

of the Marriott Research Triangle Park, 4700

Guardian Drive, Durham, North Carolina, at

8:00 a.m., Jonathan Samet, Chair, presiding.

 CASAC MEMBERS PRESENT:

 JONATHAN SAMET, Chair

 JOSEPH BRAIN

 H. CHRISTOPHER FREY

 ARMISTEAD RUSSELL

 HELEN SUH
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 PANEL MEMBERS PRESENT:

 LOWELL ASHBAUGH

 ED AVOL

 WAYNE CASCIO

 DAVID GRANTZ

 ROGENE HENDERSON

 MORTON LIPPMANN

 ROBERT PHALEN

 RICH POIROT

 FRANK SPEIZER

 SVERRE VEDAL

 SCIENCE ADVISORY BOARD STAFF:

 HOLLY STALLWORTH, Designated

 Federal Officer

Page 3

 TABLE OF CONTENTS

AGENDA ITEM PAGE

Overview of Policy Assessment . . . . . . . . .5

(Chapters 4-5)

Highlights of Urban-Focused Visibility. . . . 41

Assessment

 OAQPS:

 Dr. Karen Martin

 Ms. Vicki Sandiford

 Dr. Marc Pitchford

Public Comment on UFVA. . . . . . . . . . . . 72

Charge Question #1. . . . . . . . . . . . . .112

 Dr. Lowell Ashbaugh

 Dr. Philip Hopke

 Dr. David Grantz

Charge Question #2. . . . . . . . . . . . . .120

 Dr. Chris Frey

 Mr. Tom Moore

 Dr. Lowell Ashbaugh

Charge Question #3. . . . . . . . . . . . . .115

 Mr. Tom Moore

 Mr. Rich Poirot

Charge Question #4. . . . . . . . . . . . . .117

 Mr. Richard Poirot

 Mr. Tom Moore

 Dr. Lowell Ashbaugh

Highlights and Discussion of Charge . . . . .131

Questions for Upcoming Review of

Policy Assessment

 OAQPS:

 Dr. Karen Martin

 Ms. Beth Hassett-Sipple

Adjourn

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

2 (8:05 a.m.)

3 CHAIRMAN SAMET: So here's what

4 we're going to do. We are sticking with the

5 schedule in terms of times for public

6 comments. Remember, we have two public

7 commenters still on visibility. Tom is going

8 to call. And we need to hear from Tom.

9 So in the meantime, what we are

10 going to do is look at the draft letters to

11 the administrator. So remember that we have

12 been presenting our main comments in the body

13 of a relatively brief letter attaching

14 comments, then the responses to the charge

15 questions, and then the comments of the

16 individual panelists.

17 So we have draft letters to look

18 at that are in front of you in hard copy. So

19 what we would like to do is go over the main

20 points of these letters.

21 Let's try not to engage in group

22 wordsmithing. I know it's hard not to, but

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1 it's probably not what we need to do. In

2 fact, Holly and I would discourage it at any

3 time. I think we spent probably two months

4 sort of post-meeting time doing wordsmithing.

5 I recognize that these texts can

6 always be improved and our letters made ever

7 more splendid. However, there comes a time.

8 DR. STALLWORTH: And also the

9 conference code has changed this morning. 

10 It's 044B15.

11 CHAIRMAN SAMET: Although I don't

12 know why anybody would want to be doing their

13 e-mails when they could be wordsmithing the

14 letters.

15 OVERVIEW OF POLICY ASSESSMENT (CHAPTERS 4-5)

16 CHAIRMAN SAMET: Okay. So why

17 don't we start. The one that's labeled

18 "Samet," let's start with that. So this was

19 on the risk assessment.

20 Actually, when I wrote it, I was

21 -- you can ignore some of this because I was

22 thinking of a joint two letter on the two
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1 documents.

2 And what we have done, actually,

3 is at the moment, there would be two separate

4 letters. And, Holly, I don't know if it's

5 best to have one or two.

6 DR. STALLWORTH: Two.

7 CHAIRMAN SAMET: Two. Okay. So

8 consider this to be the letter on the risk

9 assessment. Okay. It's gone. There had been

10 a paragraph on the thing.

11 I had tried to put in here, I

12 think, beyond saying that we thought the

13 document was improved and with final revisions

14 would be ready to become final, then I thought

15 these were our main points. But if I have

16 missed something, sort of main points, in

17 part, that over-arch, that go beyond the

18 charge question, so they were this question

19 about the peak shaving proportional approach

20 and the hybrid approach and addressing the

21 fact that these were not well-explained, they

22 need to be explained better, and perhaps it

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1 was I think the hybrid approach findings that

2 we thought merited the greatest emphasis.

3 So there was that. There was the

4 point raised originally by Frank about chapter

5 5 and the discussion there to move that to an

6 appendix while keeping that one sort of risk

7 distribution graph that places the 15

8 communities on it.

9 The question about how low to go

10 -- and that had to do with going below 12 --

11 and then just making chapter 6 better, saying

12 it is important, but it just needed to be more

13 clearly written.

14 So if there are other main points

15 that the group thinks should be added, please

16 let's raise them now. And then let's also go

17 through what is said here.

18 So maybe the first point is, are

19 there other sort of big issues? Remember, we

20 have the responses to the charge questions as

21 well.

22 MR. AVOL: I think you have

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1 captured it.

2 CHAIRMAN SAMET: So we can

3 certainly revisit this. So then why don't we

4 if everybody is ready maybe take a look at the

5 bullets? So just the first bullet? And this

6 had to do with the presentation of these

7 approaches for the meeting, the suites of

8 standards.

9 DR. VEDAL: You know, there was a

10 point that was made yesterday about not

11 sufficient clarify. But I agree with Lowell

12 or someone yesterday said that they are

13 presented pretty clearly at one point,

14 well-defined, and about what they actually

15 mean or how they are actually done.

16 You don't think so, Ted?

17 DR. RUSSELL: No.

18 DR. VEDAL: I mean, I read it, but

19 I think I understood it. But you think they

20 need more detail?

21 DR. RUSSELL: Well, the peak

22 shaving approach is not well-described.

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1 DR. VEDAL: But I think what they

2 answered is what it says in the text.

3 DR. ASHBAUGH: I think part of the

4 problem is the name.

5 DR. VEDAL: Yes. Yes, that's

6 true.

7 DR. ASHBAUGH: And my first

8 thought when I saw the name was, yes, they

9 took Pete's off. And that's what Bill got

10 stuck on. But the text does explain that it

11 takes the top monitors and rolls them all

12 back.

13 DR. VEDAL: Yes.

14 DR. ASHBAUGH: But it probably

15 could be explained better and maybe with a

16 different name because that is confusing.

17 DR. RUSSELL: And the point I

18 think the three of us could have is if it did

19 show the mathematics of it, it would go a long

20 ways, either within the text or within

21 appendix B. Within appendix B, they don't

22 ever --
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1 DR. BRAIN: Can there be one data

2 set and then use the three approaches on a

3 single data set and show the outcome?

4 CHAIRMAN SAMET: That suggestion,

5 I mean, the --

6 DR. RUSSELL: That is in response

7 to one of the --

8 CHAIRMAN SAMET: Yes.

9 DR. RUSSELL: I think an example

10 would help. And they can put that in appendix

11 B.

12 CHAIRMAN SAMET: Yes. So I had

13 the sense here as CASAC founded these three

14 alternatives that were not defined in

15 sufficient clarity and recommended a

16 graphical, you would say graphical or

17 mathematical, approach along with the

18 inclusion of examples based on the 15 study

19 areas.

20 And I think that was -- I don't

21 think it is very clear. And I think if Phil

22 and Ted read it and don't find it clear and

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1 they're confused --

2 DR. ASHBAUGH: Yes. I agree. If

3 anyone finds that it's not clear, it's not

4 clear. I do think it was explained, but if

5 anybody doesn't get it right, it's not clear

6 enough.

7 CHAIRMAN SAMET: Ted, would you

8 like to recommend a graphical and/or

9 mathematical approach for definition?

10 DR. RUSSELL: Yes. Do you want to

11 put that in responses to the charge questions

12 or do you want it --

13 CHAIRMAN SAMET: Well, it's in my

14 letter, it's in the overall letter, right now. 

15 I can just modify it and say "graphical and/or

16 mathematical approach." I mean, it's just --

17 DR. RUSSELL: Yes. That would be

18 good.

19 CHAIRMAN SAMET: Okay. The text

20 does suggest a name besides "peak shaving"

21 because that was --

22 DR. VEDAL: Yes. That's good.

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1 CHAIRMAN SAMET: So then the next

2 bullet is on chapter 5. Between Frank and I,

3 we did all write something that will go into

4 the -- I guess it's not really a charge

5 question, but we would just add it as an

6 additional comment.

7 And this captures that, just

8 saying that we think the chapter should be an

9 appendix. And then this key part about

10 generalizability will just be brought into

11 chapter 6.

12 And then the third bullet I think

13 is an important one. This had to do with our

14 somewhat lengthy discussion yesterday about

15 extending the risk assessment counterfactuals

16 or scenarios to levels below 12.

17 What would be the basis for

18 deciding this how low to go question and that

19 the document didn't not make clear what was

20 the basis for picking the scenarios except, I

21 mean, I think we recognized that these were

22 put forward as potential 24-hour and annual

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1 standards. And then there was an expiration

2 of them. But that's perhaps not the right

3 logic.

4 So the key here is that this last

5 couple of sentences, "We recommended EPA

6 develop and apply specific criteria for

7 determining the exposure concentration values

8 to be considered in the risk assessment. 

9 Mounting uncertainty at lower concentrations

10 would be a reasonable basis for doing so. 

11 That was just a sort of a suggestion about how

12 to go. So the proposal is that they do

13 something and that it be explicit."

14 DR. LIPPMANN: You only talk about

15 the annual, 12. In the introduction, you

16 talked about 24-hour and annual. And perhaps

17 we need a few more words to say that as you

18 get down to 12 and below, the annual tends to

19 be controlling and is the most critical --

20 CHAIRMAN SAMET: Okay.

21 DR. LIPPMANN: -- or that using

22 the 24-hour leads to annual levels in peaking
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1 cities that are extraordinarily low.

2 DR. VEDAL: Well, that doesn't

3 need to be here. I mean, that's throughout --

4 CHAIRMAN SAMET: I think probably

5 I can see Mort's point that the discussion is

6 largely about the annual and not about --

7 DR. LIPPMANN: I mean, you need to

8 say a few words at least about why you're

9 concentrating on the annual.

10 DR. STALLWORTH: Because it's

11 controlling when you go down --

12 CHAIRMAN SAMET: Yes, yes, yes.

13 DR. STALLWORTH: Thank you. I'll

14 have to put a sentence in there.

15 DR. VEDAL: Well, not really. 

16 It's because, I mean, the argument in favor is

17 because it provides more consistent public

18 health protection. They both could be

19 controlling with enough lowering standard.

20 DR. LIPPMANN: Right. I think

21 just to make a note to expand on that a little

22 bit.

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1 DR. STALLWORTH: Thank you.

2 CHAIRMAN SAMET: And there

3 probably should be a sentence. I mean, we

4 should say recommend that EPA develop and

5 apply specific criteria. Maybe we should

6 probably have a third sentence that just says

7 the text should clearly specify the basis for

8 decision-making or something, something like

9 that at the very end.

10 DR. PHALEN: Jon, I hope that you

11 wouldn't think of this as wordsmithing. I

12 think of it as more concept-smithing, but on

13 the first line, the current risk assessment

14 explores the burden of disease that can be

15 avoided. And that is awfully confident for

16 me.

17 I would say it explores the

18 potential for avoiding disease burden because

19 it makes it sound like the risk assessment is

20 exploring disease burden.

21 CHAIRMAN SAMET: So why don't we

22 say explores the burden of disease estimated

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1 to be avoidable or something like that?

2 DR. PHALEN: Perfect. Thanks,

3 Jon. Thank you.

4 CHAIRMAN SAMET: Yes, yes. We

5 actually don't have a definition of

6 wordsmithing yet.

7 DR. PHALEN: Good. We will.

8 CHAIRMAN SAMET: But we will, sir. 

9 You can write it. So we had several

10 modifications this morning, just a little

11 balance around the 24-hour annual thing that

12 includes the last sentence in responding to

13 Bob's comment.

14 Okay. And then the last, it says

15 make chapter 6 as good as possible.

16 DR. STALLWORTH: And we can come

17 back to this after we go through the charge

18 questions.

19 CHAIRMAN SAMET: Yes, yes. Okay. 

20 So if these are roughly okay and no one has

21 any new bullets to add, let's maybe go on. 

22 Rich, do you want to sort of talk about the --

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1 DR. STALLWORTH: Do you want to

2 walk through this one?

3 CHAIRMAN SAMET: Do you want to do

4 that? I was thinking about giving them a

5 list. Okay. That's fine. So we'll do the

6 charge questions, then.

7 All right. So we're going to go. 

8 Turn the page. We're going to go on to the

9 risk assessment charge questions. Okay. So

10 we have for question 1A, we have comments from

11 Ted. So why don't we take a minute on this

12 first page?

13 So the first one really speaks to

14 the point we had already.

15 DR. RUSSELL: Making that

16 consistent with what we already have.

17 CHAIRMAN SAMET: Right.

18 DR. RUSSELL: So coming up with an

19 alternative label. I think it says pretty

20 much the same thing.

21 CHAIRMAN SAMET: Yes, it does. 

22 And so we might just add to come up with
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1 another name for it, too, how to get that. 

2 Okay. So those are mine. And then --

3 DR. SPEIZER: Can I ask a question

4 here? Do we need in this cover letter to hit

5 every charge question as though it's an

6 independent response to each one? I mean, is

7 that required of us? Do we want to do that

8 first?

9 CHAIRMAN SAMET: Well, we have

10 been doing it. I mean, we have been

11 responding to each charge question.

12 DR. SPEIZER: But we have got

13 those, all the individual responses.

14 DR. STALLWORTH: But this is

15 CASAC's consensus response --

16 CHAIRMAN SAMET: This is our

17 consensus. This is our response.

18 DR. STALLWORTH: -- to charge

19 questions.

20 DR. SPEIZER: Okay. So you want a

21 consensus response to the charge questions?

22 DR. STALLWORTH: That's correct.

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1 DR. LIPPMANN: Well, the names

2 here are the leader who --

3 DR. STALLWORTH: Yes. I inserted

4 names just to help.

5 CHAIRMAN SAMET: Yes.

6 DR. STALLWORTH: Obviously I'll

7 delete the names. I wanted to keep --

8 CHAIRMAN SAMET: Well

9 DR. SPEIZER: Yes. I don't have

10 to take exception to what we include. That's

11 all right. Go ahead. I just don't --

12 CHAIRMAN SAMET: This is no

13 different than what we have been doing.

14 DR. SPEIZER: Well, I guess maybe

15 my short-term memory is getting shorter.

16 CHAIRMAN SAMET: No. Because what

17 we have been doing is asking sort of the lead

18 person on each charge question to --

19 DR. SPEIZER: Well, I know, but

20 this is a letter to the administrator.

21 CHAIRMAN SAMET: Oh, no. We are

22 moving beyond the letter now.

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1 DR. SPEIZER: This is not the

2 letter to the administrator?

3 CHAIRMAN SAMET: No.

4 DR. STALLWORTH: This is the

5 attachment to the letter.

6 CHAIRMAN SAMET: This is the

7 attachment.

8 DR. SPEIZER: Okay. I'm sorry. 

9 I'm sorry.

10 CHAIRMAN SAMET: Okay. So the

11 four bullets we just went over would be the

12 letter plus the boilerplate stuff. Okay. So

13 these are the responses.

14 So we had done the first one,

15 which was actually the bullet in the -- same

16 as the bullet more or less. And then the next

17 is the response to B. And that's right. We

18 had the discussion about missing values.

19 Okay. So any comments here?

20 DR. LIPPMANN: On the second line,

21 I think "motivates" is not the right word,

22 something like "clarify the basis for,"

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1 instead of "to help motivate."

2 CHAIRMAN SAMET: That's the

3 meaning of it, Ted, right?

4 DR. BRAIN: To add confidence to

5 the analysis.

6 CHAIRMAN SAMET: Justify.

7 DR. BRAIN: To justify the

8 procedures.

9 CHAIRMAN SAMET: I think this

10 qualifies for wordsmithing, but I think we

11 will get rid of "motivate." Okay. "Explain"

12 or something. Anything else on this one?

13 (No response.)

14 CHAIRMAN SAMET: Okay. Then the

15 next, it's charge question 2, selection model

16 inputs. And here is a response developed by

17 Morton

18 DR. LIPPMANN: With wordsmith

19 taken from Wayne and Helen fit into what we

20 discussed in the background. I think you used

21 some edge words here and there, too.

22 CHAIRMAN SAMET: Okay. Good with
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1 this one? Then next.

2 DR. VEDAL: This wasn't the place

3 to comment about the socioeconomic status

4 issues.

5 CHAIRMAN SAMET: The adjustment

6 issue questions?

7 DR. VEDAL: Yes. Did that come

8 later?

9 DR. STALLWORTH: I think that's

10 later.

11 DR. VEDAL: All right. It's

12 really, I think, in 6.

13 DR. STALLWORTH: I think that's in

14 the next one.

15 CHAIRMAN SAMET: Okay. So charge

16 question 3 is uncertainty and variability. 

17 Chris is teaching and will be in a few hours. 

18 This is Chris' response.

19 DR. VEDAL: Should we wait on

20 that?

21 CHAIRMAN SAMET: No. I would

22 suggest that we look at it now because I think

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1 he's 10:30 plus to get here.

2 DR. STALLWORTH: And I

3 incorporated Chris'. This is his second

4 version that incorporates your comments.

5 DR. SUH: Thank you.

6 DR. STALLWORTH: There's a mention

7 of socioeconomic status here.

8 DR. BRAIN: It seems like some of

9 this should go into his own comments.

10 DR. STALLWORTH: Yes. Some of it

11 probably should.

12 DR. BRAIN: It needs to be

13 condensed and more focused on --

14 DR. VEDAL: And much of that third

15 paragraph is sort of specific comments about

16 infiltrations and --

17 DR. BRAIN: Yes. It doesn't

18 really tell them what they should do.

19 DR. STALLWORTH: Okay. I'll mark

20 that and discuss it.

21 CHAIRMAN SAMET: So yes. It's

22 overly long, too. Actually, Chris always

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1 writes a lot, which is useful, but in this

2 case, it might get pared down a bit.

3 DR. STALLWORTH: Right.

4 DR. PHALEN: Jon, this is the one

5 with infiltration rights, right?

6 CHAIRMAN SAMET: Right.

7 DR. PHALEN: Does anyone object to

8 talk about air exchange rates, rather than

9 infiltration rates, or using air exchange

10 rates, instead of infiltration? It's not a

11 one-way process.

12 CHAIRMAN SAMET: Good point. And

13 this probably is something that might be in

14 the specific comments. We can ask Chris to

15 pare this down a little bit.

16 Yes, sure. Air --

17 DR. PHALEN: Yes. Think about the

18 concept because it sounds like it's a one-way

19 process that, as opposed to air exchange --

20 MR. AVOL: Although the regulatory

21 premise here is outdoor.

22 DR. PHALEN: Pardon?

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1 MR. AVOL: The regulatory premise

2 here is outdoor. So it's outdoor --

3 DR. PHALEN: No. I understand. 

4 No. I know that. But, you know, as many

5 studies have shown, you know, when you're

6 talking about risk, you know, the x city

7 studies, for example, have shown that there

8 are indoor areas, too. And if we don't

9 consider that, we're not considering the full

10 range of risks.

11 Plus, it's just more accurate

12 scientifically if you're modeling air

13 exchange, rather than --

14 DR. STALLWORTH: Okay. I made a

15 note of that. And we'll ask Chris to tighten

16 this up, maybe shorten it and export some of

17 the more minor comments to --

18 CHAIRMAN SAMET: Yes, yes. I

19 mean, I think the major point is that, in

20 general, this was thought to have been done

21 well. That's probably his first paragraph and

22 then a few of the later --
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1 DR. VEDAL: I think that paragraph

2 on the low, medium, and high could probably do

3 that through the sentences.

4 DR. STALLWORTH: Which one is

5 that, Sverre?

6 DR. VEDAL: The third one on the

7 second page of this, --

8 DR. STALLWORTH: Okay.

9 DR. VEDAL: -- basically about

10 doing that and then how they achieve

11 consensus. I don't think that detail is

12 needed.

13 CHAIRMAN SAMET: Well, probably

14 this comment about staff consensus -- you

15 remember we had some discussion about that

16 yesterday -- is probably what is keeping it up

17 front. It should be probably defined.

18 Okay. Other things on Chris'

19 response?

20 DR. LIPPMANN: The last paragraph

21 that has a close bracket at the end, I don't

22 see where the bracket starts.

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1 DR. STALLWORTH: Take it off.

2 CHAIRMAN SAMET: Okay. So charge

3 question 4 was the sensitivity analysis.

4 DR. STALLWORTH: It's also Chris.

5 CHAIRMAN SAMET: It's also Chris.

6 MR. AVOL: There is another row

7 bracketed at the end of this.

8 CHAIRMAN SAMET: Again, I think

9 the main points are the right ones. And

10 perhaps it could be streamlined a little bit,

11 but --

12 DR. LIPPMANN: On the next page,

13 the last paragraph ends with "This might be

14 clarified." I don't think we want to say

15 "might." You know, we either say it should or

16 --

17 CHAIRMAN SAMET: He has a

18 question. I think we should just take it off. 

19 This might be clarified.

20 DR. STALLWORTH: Okay.

21 CHAIRMAN SAMET: Okay? Okay. So

22 move on to charge question 5. So, actually,

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1 we have this piece of Sverre. And, then,

2 Sverre, your piece there, is that in response

3 to A and B or --

4 DR. VEDAL: Yes. The discussion

5 of the second, yes, it is A and B because

6 recommendations are all largely B, things that

7 might be added.

8 DR. STALLWORTH: Okay.

9 DR. BRAIN: We kind of hint at it,

10 but do we want to be clear about wanting them

11 to put the 15 selected cities in the context

12 of the total topography of the U.S., you know,

13 to be a little clearer about that they're not

14 typical but that they're -- we talked about

15 that, but I don't see that really --

16 CHAIRMAN SAMET: What they have

17 done -- and this goes back to that chapter 5

18 to sort of place some cities in the spectrum

19 and other distribution of PM-related risk. 

20 With the BenMAP analysis, they have not

21 provided other demographics.

22 I guess the question, what would

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1 you want to do?

2 DR. BRAIN: Mike sort of hints at

3 it when he talks about the generalizability of

4 the findings from the 15 areas, but, I mean,

5 it seems to be really -- should be clear --

6 CHAIRMAN SAMET: For both?

7 DR. SUH: Well, this is where

8 Rogene had mentioned taking those pretty

9 graphs or pretty plots and adding a third

10 dimension --

11 DR. HENDERSON: Third dimension.

12 DR. SUH: -- for the health. And

13 perhaps you're right. Maybe that's where the

14 chapter 5 plot goes in to show how the 15

15 cities fit within the whole scheme.

16 CHAIRMAN SAMET: So maybe the --

17 and I think Helen goes on the same thing. The

18 question of establishing the generalizability

19 of the results in chapter 4, but that also has

20 to come back in chapter 6 because that is

21 still an important part of the integrated

22 summary.
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1 So maybe there should be comment

2 to this in chapter 4 and again in chapter 6. 

3 So maybe the comment there about chapter 5 is

4 probably correct, but we should suggest that

5 this be incorporated at the proper points in

6 both chapters 4 and 6.

7 And then the other question is,

8 should there be additional attempts to try and

9 place these 15 cities in the broader context

10 of U.S. cities and how would you usefully do

11 that? I mean, we know that cities are

12 different.

13 DR. VEDAL: I mean, what they have

14 done is put it in the context of air

15 pollution.

16 CHAIRMAN SAMET: Of air pollution

17 risk.

18 DR. VEDAL: I don't know how.

19 CHAIRMAN SAMET: Yes, which is a

20 reasonable thing to do, I think.

21 DR. VEDAL: Yes, yes, yes. But --

22 DR. SUH: But if you put it --

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1 DR. VEDAL: So you would have to

2 identify some criteria that you wanted to and

3 then place them in the district.

4 CHAIRMAN SAMET: Yes. I was

5 thinking about how you could construct the

6 table. I guess it was Joe who started this

7 conversation. But what would be in the table,

8 you would have the 15 cities. And then you

9 would have the other X cities that somehow fit

10 the same range of population or of something. 

11 I'm just not --

12 DR. BRAIN: Or that they represent

13 populations that during the top quartile of

14 exposure or something, you know, something

15 like that.

16 CHAIRMAN SAMET: They've done that

17 with the risk stuff. They've done that with

18 that figure 5.4 because that is sort of an

19 exposure-based figure.

20 DR. LIPPMANN: While you are

21 thinking, Jon, in the beginning we said areas. 

22 And now you're talking cities. And here it

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1 says urban areas. I think for consistency, we

2 always ought to use urban areas because city

3 is not quite the right word.

4 CHAIRMAN SAMET: Okay.

5 DR. LIPPMANN: They usually are

6 SMAs. And area could be confusing left alone.

7 CHAIRMAN SAMET: They're referred

8 to in the document, I think, as urban study

9 areas. I think that's where that terminology

10 came from.

11 DR. LIPPMANN: In any case, urban

12 area --

13 DR. VEDAL: Yes. I took it from

14 that text.

15 DR. LIPPMANN: You know -- Holly

16 go through and make sure that's uniformly

17 used.

18 CHAIRMAN SAMET: So good point. I

19 think what I would suggest is we use the EPA's

20 own terminology.

21 DR. LIPPMANN: Whatever term we

22 use should be used consistently.

Page 33

1 DR. STALLWORTH: Urban study

2 areas?

3 CHAIRMAN SAMET: Urban study

4 areas, yes. Yes.

5 DR. HENDERSON: Jon, didn't they

6 have a paragraph in there telling how they

7 chose these cities, but one of the main things

8 was that they had health data on them, right? 

9 I mean, you were talking about what delineated

10 the 15, but it was that we have information on

11 them concerning health effects, right?

12 CHAIRMAN SAMET: Yes, but I think

13 this text was largely having to do with the

14 representativeness, then, of those cities once

15 they were selected. And I'm not sure. They

16 were not selected to be "representative."

17 And maybe that would be helpful if

18 you were to add that the selection of these

19 cities was not made necessarily to assure

20 representativeness. And then the question

21 becomes what has been done to show how they

22 fit into the context of exposure risk. And
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Page 34

1 that's where this analysis in chapter 5 really

2 figures in as useful.

3 DR. SPEIZER: They're all NMAPS

4 cities, aren't they? And the ISA has a figure

5 on NMAPS. I wonder if it would be worth

6 pulling that figure in and highlighting these

7 cities in that context. That would actually

8 show where they fit in the figure of risk.

9 DR. LIPPMANN: And, pursuing

10 Rogene's point, how representative are they? 

11 Tacoma was selected as a Western city. It's

12 hardly representative of Seattle, which is

13 much bigger. But it was data where suitable

14 data were available.

15 So that's an example of where it

16 was a convenience sample that could be

17 described as reasonably representative, but it

18 doesn't really --

19 DR. SUH: I think the point was

20 that these 15 cities were representative. I

21 think it's just that they're not so anomalous

22 as compared to the rest of the other cities.

Page 35

1 DR. LIPPMANN: Right.

2 DR. SUH: So I think it's good

3 just to put them into some sort of context, I

4 think, but I don't think there was ever a

5 claim that they were representative, though.

6 CHAIRMAN SAMET: And I think,

7 actually, that is probably the best context,

8 what probably was done, which is to try to put

9 them in this sort of exposure distribution. 

10 I mean, it's exposure turned into risk by a

11 BenMAP, but I think --

12 DR. VEDAL: Well, yes. I mean, I

13 wasn't really as enthusiastic about Rogene's

14 suggestion before, but thinking about it, I

15 think I am because the risk estimates are

16 based on these cities.

17 And if the risk estimates are just

18 inordinately different, say, based on the

19 distribution from NMAPS or whatever

20 distribution we have, that might color our

21 view of them.

22 DR. LIPPMANN: I noticed that in

Page 36

1 these maps, these diagrams, Tacoma looks odd. 

2 And it seemed like --

3 DR. VEDAL: It is odd.

4 DR. LIPPMANN: -- not necessarily

5 the best choice.

6 CHAIRMAN SAMET: But we have to

7 remember that 15 cities aren't going to

8 change.

9 DR. LIPPMANN: No, no.

10 CHAIRMAN SAMET: And so the

11 question really is --

12 DR. LIPPMANN: How to describe

13 them.

14 CHAIRMAN SAMET: -- how to

15 describe them. And I think in terms of this

16 analysis and this purpose, the figure of

17 exposure/risk is probably exactly the right

18 one.

19 DR. VEDAL: Right. I just don't

20 think we can get the risk on the same -- we

21 can ask them to put them on the same plot as

22 the one we have. It really dilutes the

Page 37

1 message and just to complicate it, but

2 something to put it in the context of the risk

3 distribution would be.

4 CHAIRMAN SAMET: Well, that's

5 figure 5.4.

6 DR. SUH: Yes. To me, that is

7 actually perfect.

8 CHAIRMAN SAMET: Yes. It's done

9 in a different way. Well, that's the

10 suggestion that Frank and I made.

11 DR. VEDAL: Yes.

12 CHAIRMAN SAMET: I mean, figure

13 5.4, remember, is the BenMAP risk.

14 DR. VEDAL: Right.

15 CHAIRMAN SAMET: And they are

16 placed on this distribution.

17 DR. VEDAL: Right on the

18 distribution.

19 CHAIRMAN SAMET: Yes, yes.

20 DR. VEDAL: Right.

21 CHAIRMAN SAMET: So that's why I

22 think that is the right way to explain where
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Page 38

1 the --

2 DR. VEDAL: Yes.

3 CHAIRMAN SAMET: -- where they

4 sit, but I don't think demographics helps. 

5 And, you know, I mean, I agree you are always

6 going to get down to say, "Well, gee, Tacoma

7 is funny" or "Baltimore is funny" or --

8 MR. AVOL: So where are we going

9 to ask them to put that, again?

10 CHAIRMAN SAMET: Well, I think the

11 suggestion had been in chapter 6, but I think

12 both Helen and Ed have suggested that it would

13 also be and should probably be in chapter 4 as

14 well, which I think is --

15 MR. AVOL: I mean, it seems like

16 they make the case in chapter 4 and describe

17 it. And chapter 6 is sort of an integration

18 of the whole summary. So I think it has got

19 to be in chapter 4 to set the premise for why

20 you're using it.

21 DR. STALLWORTH: So is there a

22 specific here for the letter?

Page 39

1 CHAIRMAN SAMET: Well, I think

2 it's that it be included in both chapters 4

3 and 6 with more complete explanation in

4 chapter 4.

5 DR. HENDERSON: I think that would

6 be good.

7 DR. STALLWORTH: Okay.

8 CHAIRMAN SAMET: Okay. And then

9 we are going to make a small change in the

10 overall letter.

11 MR. AVOL: I think, Jon, though,

12 we do need to be a little careful about the

13 claim that it is representative of the 15.

14 CHAIRMAN SAMET: No, I don't think

15 we should claim representativeness.

16 MR. AVOL: Yes.

17 CHAIRMAN SAMET: The question is,

18 I don't think anyone is.

19 MR. AVOL: Well, right now in line

20 6 of Sverre's comments about the

21 representativeness of the 15 urban areas.

22 CHAIRMAN SAMET: Wait a minute. 

Page 40

1 Show me where. It would be helpful. That's

2 useful for understanding. I don't think he's

3 claiming representativeness.

4 MR. AVOL: I did.

5 CHAIRMAN SAMET: Sverre, we're

6 muttering about you over here.

7 DR. VEDAL: Oh, sorry.

8 CHAIRMAN SAMET: That's all right. 

9 So your first long sentence, where you talk

10 about the representativeness, you're not

11 trying to imply that there is

12 representativeness. You're just --

13 DR. VEDAL: No. That you assess

14 the representativeness.

15 CHAIRMAN SAMET: That you assess

16 the representativeness.

17 DR. VEDAL: I could clarify that,

18 but I thought that was the purpose of sort of

19 putting --

20 CHAIRMAN SAMET: That was my

21 reading as well. Okay. So, just to revisit

22 this, then, this chapter 5 goes away, should

Page 41

1 be moved to an appendix, to support a small

2 discussion where the 15 cities are discussed

3 in chapter 4 and also used in chapter 6 in the

4 integrated summary when it is a question of

5 where these 15 cities sit and the distribution

6 of population risk is addressed.

7 HIGHLIGHTS OF

8 URBAN-FOCUSED VISIBILITY ASSESSMENT

9 CHAIRMAN SAMET: Okay. And this,

10 we sort of have the piece that Frank and I

11 wrote, which can come here as sort of an

12 extension of the charge.

13 Okay. Then chapter charge

14 question 6 relating to chapter 6.

15 DR. SPEIZER: Can I comment here? 

16 I misunderstood the instructions. And so what

17 you see here that is marked "Speizer," the

18 first part of which I thought was a composite

19 answer to the whole thing --

20 DR. STALLWORTH: I'm sorry, Frank. 

21 What I did was --

22 DR. SPEIZER: All right. Tell me
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1 what you did.

2 DR. STALLWORTH: I interrupted

3 you. I didn't know whether you wanted your

4 old answers included. So I just put them in

5 there for A through E.

6 DR. SPEIZER: Yes. I figured we

7 could always take them out.

8 DR. SPEIZER: Okay. Fair enough. 

9 I didn't even look at those. I just sort of

10 wrote the first part and stopped because it --

11 DR. STALLWORTH: I went back to

12 your comments and just popped them in there

13 because I figured we could change it or take

14 them out.

15 DR. SPEIZER: Okay.

16 DR. STALLWORTH: So the first

17 paragraph called "Speizer," that's the new one

18 I got last night.

19 CHAIRMAN SAMET: Right. So is

20 that the right one?

21 DR. STALLWORTH: He did not answer

22 A through E last night.

Page 43

1 CHAIRMAN SAMET: I see.

2 DR. STALLWORTH: So these are

3 individual comments and --

4 DR. SPEIZER: Yes. The first two

5 paragraphs are what I wrote last night.

6 CHAIRMAN SAMET: I am so confused.

7 DR. STALLWORTH: Okay. The first

8 two paragraphs are sort of the overview answer

9 to --

10 CHAIRMAN SAMET: I see. Okay.

11 DR. STALLWORTH: -- charge

12 question 6.

13 CHAIRMAN SAMET: I see. Okay.

14 DR. STALLWORTH: The A through E

15 components are not something he sent me last

16 night --

17 CHAIRMAN SAMET: So you printed

18 this out. Okay.

19 DR. STALLWORTH: -- something I

20 pulled from his individual comments.

21 CHAIRMAN SAMET: Okay. Okay.

22 DR. PHALEN: In the second

Page 44

1 paragraph, the general agreement that the

2 current standards are not adequate bugs me a

3 little bit, as you all might guess. I think

4 maybe they are not adequate in all areas in

5 the United States, but I think they might be

6 adequate in some areas.

7 So I would like to see if the

8 Committee would agree to kind of soften that

9 a little bit.

10 DR. SPEIZER: Well, the problem is

11 we're dealing with national standards. We

12 can't regionalize the effects.

13 DR. SUH: Do we actually even talk

14 about it with the standards with --

15 CHAIRMAN SAMET: Yes. That's the

16 same. I mean, this is not really --

17 DR. SUH: I'm not sure we ever --

18 DR. BRAIN: We are not compelled

19 to do that here.

20 CHAIRMAN SAMET: Yes.

21 DR. STALLWORTH: Talk about what,

22 Helen?

Page 45

1 DR. SUH: Well, we didn't really

2 discuss what are the standards for --

3 DR. VEDAL: We will get there in

4 policy.

5 CHAIRMAN SAMET: Yes.

6 DR. SUH: And then also, I guess,

7 the other thing is we did discuss the risks

8 but not really their magnitude or their levels

9 of comparison, their relative value of

10 comparisons. So I guess I'm not sure that --

11 MR. POIROT: The second half of

12 that sentence is still relevant.

13 DR. VEDAL: Yes. So we can strike

14 the first half.

15 DR. SUH: Yes.

16 CHAIRMAN SAMET: I mean, the issue

17 is whether, at what levels of PM the risk

18 analysis points to disease burden; that is,

19 that is there and potentially avoidable.

20 That is really what this is about

21 and not -- so the discussion -- I mean, it

22 would be inappropriate, I think, in this sort
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Page 46

1 of point in the process to discuss adequacy of

2 standards.

3 DR. STALLWORTH: So you are going

4 to strike that?

5 CHAIRMAN SAMET: I think we'll

6 probably strike. Let's go back to the first

7 paragraph, though, first. We have high

8 praise. We have unanimously pleased.

9 DR. PHALEN: I don't think we took

10 a vote on it. I think everyone was pleased.

11 CHAIRMAN SAMET: Yes.

12 DR. PHALEN: Maybe you could take

13 out "unanimously" because we don't have

14 everybody here to take a vote.

15 CHAIRMAN SAMET: I think the panel

16 was pleased it indicates. That's fine. 

17 Frank, the sentence, "However, the results

18 presented could be summarized more

19 effectively, and, rather than being presented,

20 details should have warranted a more

21 integrative discussion," do you think there is

22 too much detail in chapter 6? I'm not sure

Page 47

1 there is.

2 DR. SPEIZER: I think there is.

3 CHAIRMAN SAMET: You do?

4 DR. SPEIZER: Yes.

5 DR. BRAIN: Is chapter 6 where we

6 also had the -- was the text talking about 100

7 percent reduction in risk?

8 CHAIRMAN SAMET: Yes. That was

9 one of them down to the lowest measured level.

10 DR. BRAIN: The assumptions need

11 to be very clear or that should be eliminated. 

12 I am still uncomfortable --

13 CHAIRMAN SAMET: Yes. There is

14 some of that. I mean, there is the second

15 paragraph. Much of it is about the issue that

16 we highlighted in one of the bullets in the

17 letter, this issue of how do you set how low

18 the risk analysis should be extended? And I

19 guess that represents the ultimate extension.

20 So in a sense, it's covered, but

21 we may want to suggest that --

22 DR. BRAIN: I would like a more

Page 48

1 direct statement because that conflicts with

2 the third line, "a no threshold linear

3 effect." So to the extent that's true, then

4 just dropping it down another --

5 DR. SUH: But weren't you also

6 talking about -- when you talked about the

7 different approaches and then there's the

8 peakiness and then there was the 100 percent

9 reduction in certain cities? Isn't that the

10 chapter you're referring to?

11 DR. BRAIN: Yes. I mean, there is

12 the nice --

13 DR. SUH: There are a couple of

14 tables that had 100 percent reduction in risk.

15 DR. BRAIN: Right. And I guess I

16 am uncomfortable with that because it seems --

17 DR. HENDERSON: I think that the

18 bottom paragraph does a good job of describing

19 what we discussed as far as having criteria

20 for determining how low you go. I thought

21 this paragraph was well-written.

22 DR. STALLWORTH: Joe, did you have

Page 49

1 an edit to propose where it says, "no

2 threshold linear effect"?

3 DR. BRAIN: No. I mean, I agree

4 with that.

5 DR. STALLWORTH: Okay.

6 DR. BRAIN: But if you buy into

7 that, then it seems to me a scenario that

8 eliminates risk completely. It's inconsistent

9 with that.

10 DR. SPEIZER: Yes. I tried to

11 modify that, by this last part of this

12 paragraph says, "Pick a criteria and use

13 that."

14 DR. VEDAL: Well, I don't

15 understand what you mean by the lowest levels

16 at which reported results are in the U.S. Is

17 that the lowest measured value of a

18 distribution in which a study was done?

19 DR. SPEIZER: Well, I guess it

20 would have to be a study done for it to have

21 a reported result.

22 DR. VEDAL: Yes. But what value
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1 do you --

2 CHAIRMAN SAMET: Well, Sverre,

3 that's this LML is the lowered measured level,

4 lowest measured level.

5 DR. VEDAL: Yes. But that's where

6 you put the standard.

7 CHAIRMAN SAMET: No, no, no, not

8 the standard, but that was used for the

9 extension of the risk analysis.

10 DR. VEDAL: Yes.

11 CHAIRMAN SAMET: I mean, that's

12 what we're talking about. This paragraph

13 should not have the word "standard" in it. 

14 This is actually about how to do the risk

15 analysis.

16 DR. BRAIN: That's sort of my

17 point. The absence of data doesn't

18 necessarily equal the absence of an effect.

19 CHAIRMAN SAMET: Yes. But this is

20 how you develop the risk analysis tools that

21 will be used in the policy assessment.

22 DR. VEDAL: Yes, but that's what

Page 51

1 these are, standards 25 and 10.

2 CHAIRMAN SAMET: No, no, no. 

3 They're values that have been used in the risk

4 analysis. They're not standards.

5 DR. VEDAL: All right. Have it

6 your way. That's all right.

7 CHAIRMAN SAMET: I mean, I think

8 in terms of process, they should not be

9 designated as standards at this point.

10 DR. VEDAL: All right. All right. 

11 Nevertheless, I mean, the issue --

12 CHAIRMAN SAMET: They might become

13 standards.

14 DR. VEDAL: The issue is I'm not

15 sure this gives them the guidance that they

16 need. The lowest levels at which reported

17 results are in the U.S. --

18 CHAIRMAN SAMET: Well, but this is

19 the same. This goes back to the bullet we

20 have in the overall letter, which was to say

21 -- and, remember, we ended the discussion

22 yesterday without doing anything more than

Page 52

1 saying there needs to be something explicit. 

2 It needs to be written. And uncertainty is

3 one basis for --

4 DR. VEDAL: I'm not arguing that. 

5 I think that's a very good point. I am just

6 saying that this does not provide them that

7 guidance. This is ambiguous.

8 Is this saying that we look at the

9 lowest value in this cohort study that has

10 been done and we choose that to do a risk

11 analysis on, like 4?

12 CHAIRMAN SAMET: No. A different

13 issue is -- well, first, this should be

14 consistent with what is in the cover letter.

15 DR. VEDAL: Yes.

16 CHAIRMAN SAMET: So that should

17 be. And what the cover letter is saying there

18 has to be an explicit statement. And the

19 basis for that statement should be clear.

20 One basis would be that at some

21 point uncertainty is judged to be too great to

22 further extend. Another might be that you

Page 53

1 have gone outside a range of values at which

2 observations have been made of risk in

3 populations. And I think that is where Frank

4 was going here in suggesting some

5 alternatives.

6 We are not -- so I think we need

7 to align this with what is in the letter. I

8 mean, it's not unreasonable to list out some

9 of the possibilities for doing this.

10 DR. VEDAL: I like your MAP.

11 CHAIRMAN SAMET: So what are you

12 arguing?

13 DR. VEDAL: The specific

14 recommendation here, which doesn't provide

15 them the proper guidance, I don't know. How

16 do you --

17 DR. SPEIZER: I think I provided

18 two alternatives. One is to put the lowest

19 study value as the value that you go down to. 

20 The alternative was to pick one in which there

21 was more than one study and pick some fraction

22 of that to be the lowest value to go down to
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1 to avoid the problem of the outlier study.

2 DR. LIPPMANN: Is this the right

3 place to put the words "margin of safety"?

4 DR. SPEIZER: Well, I put it in

5 quotes. I put it in quotes because I wanted

6 to suggest that whatever the lowest value of

7 multiple studies is, that they take some

8 fraction of that as the value to do the risk

9 assessment on.

10 You know, maybe that's the wrong

11 word to use there, but I put it in quotes

12 purposely because I didn't believe it was a

13 real margin of safety.

14 DR. LIPPMANN: Well, we heard some

15 sensitivity from Karen yesterday about

16 introducing those words at this point, not

17 that they don't come in at some other point.

18 DR. SPEIZER: Fair enough. 

19 Another set of words that would imply the same

20 thing, that you could go below multiple

21 studies, would be fine.

22 CHAIRMAN SAMET: But, you know,

Page 55

1 this speaks back to the issue that I raised. 

2 I mean, in my mind, the risk analysis would be

3 a tool in which you explore burden of

4 attributable disease and how that burden could

5 be avoided at different levels. And then you

6 use that information in the policy analysis to

7 make judgments.

8 What is backwards here is that

9 already the idea that has come that what might

10 be standards is the basis for setting these

11 numerical boundaries in the risk analysis.

12 And I can understand why and how

13 that happened, but in terms of sort of

14 thinking about the process, what we would like

15 to do is do the risk analysis, look at the

16 burden of disease, avoidable different points,

17 look at these distributions, and then make

18 some judgments as to where standards would

19 fall.

20 And I think now this sort of trap

21 that has come up is so now the question is,

22 well, gee, we stopped the trouble. Well, if

Page 56

1 we go down to lowest measured level, then we

2 can eliminate potentially that much more

3 attributable disease, which happens because

4 you have a linear no threshold model, which

5 has been assumed. And its validity is hard to

6 judge as one goes lower and lower.

7 So the question then is it might

8 be appropriate for us to point out that the

9 setting of these limits should be guided by

10 understanding of the science, how certain it

11 is, how low one can go, and not necessarily

12 where you think in a later document you are

13 going to propose alternative standards.

14 And I think to me suggesting how

15 this should be done we should do here.

16 DR. SUH: Jon, can I ask you a

17 question? So in the risk assessment itself,

18 it talks about these alternative standards.

19 CHAIRMAN SAMET: Right.

20 DR. SUH: So one of the things

21 maybe we might want to suggest based on your

22 comments, which made sense, is that they

Page 57

1 choose a different way of presenting those

2 scenarios in terms of --

3 CHAIRMAN SAMET: Yes. They could

4 become alternative standards.

5 DR. SUH: Right, but that perhaps

6 we would want to suggest some overarching --

7 perhaps maybe that is not how they are

8 presented in --

9 CHAIRMAN SAMET: Right. I mean,

10 exposure scenarios. What we really want for

11 the risk analysis is the most valid model that

12 can be developed. And then it's used for

13 developing various scenarios for policy

14 purposes that then can become. Then those

15 scenarios drive the development of alternative

16 sets of standards. I mean, it --

17 DR. SUH: I agree that the way it

18 is set up now that those are the ones we are

19 thinking about. Those words are in our head

20 about those are the possibilities.

21 CHAIRMAN SAMET: Right, right. 

22 Right.
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1 DR. SUH: And so perhaps that gets

2 into much more of an overarching comment about

3 how these different exposure, annual and

4 24-hour exposure, levels want to be thought

5 about, just as an introduction to it.

6 CHAIRMAN SAMET: So maybe, I mean,

7 if you thought about this -- and maybe we need

8 another bullet in the letter -- sequence from

9 going from a research workshop to ISA to risk

10 analysis to the policy assessment document at

11 the time you begin the risk analysis in a

12 sense, you might or might not know what the

13 alternative suites of standards are going to

14 be. Ideally you don't know because you, in

15 fact, are going to base them on the risk

16 analysis.

17 So, again, I think it might be

18 worth perhaps a more general comment to talk

19 about what we think about the overall flow,

20 whether it's here or somewhere else, but I

21 think it -- does what I am suggesting here

22 about sort of the ordering make sense to

Page 59

1 everyone?

2 DR. VEDAL: Yes, it does. I think

3 that part of the confusion, at least for me,

4 here -- and it may not be confusing for others

5 is this issue of the distinction between these

6 -- I don't know what else to call them -- mock

7 standards that are used for the risk analysis

8 and the lowest measured level down to which

9 risk is estimated in this.

10 CHAIRMAN SAMET: Right.

11 DR. VEDAL: And they're different.

12 DR. LIPPMANN: They are two

13 different issues.

14 CHAIRMAN SAMET: Right, yes, yes.

15 DR. VEDAL: Those are different.

16 CHAIRMAN SAMET: Right.

17 DR. VEDAL: And what is being

18 talked about here are the mock standards, not

19 the lowest measured level to which risk is --

20 CHAIRMAN SAMET: Right. And then

21 our discussion there yesterday led us there

22 when this question came up, Well, gee, whet

Page 60

1 we've modeled. Remember, the table that led

2 us to this was the one with these additional

3 going down.

4 DR. VEDAL: Yes, but, I mean,

5 that's what gets me hung up. at least when we

6 start talking about to the lowest level of

7 which reported results are in the ISA, that to

8 me smacks of lowest measured level, not a mock

9 standard.

10 DR. HENDERSON: To me what Frank

11 has said is -- I mean, this is a big problem,

12 how you go down on -- how far down do you go

13 with a no threshold level.

14 I mean, to me what this says is

15 you take the lowest level at which any effect

16 has been observed and some fraction of it for

17 a margin of safety.

18 DR. VEDAL: But what is that level

19 in a study? I mean, I don't understand that. 

20 The lowest level at which an effect has been

21 observed? I don't know how you even get that

22 number.

Page 61

1 DR. HENDERSON: Well, if you can't

2 observe it --

3 DR. SPEIZER: I guess I was

4 thinking more of the average reported level in

5 a study.

6 DR. HENDERSON: Yes, in a cohort.

7 DR. SPEIZER: In a cohort study or

8 in some kind of study --

9 DR. HENDERSON: Yes.

10 DR. SPEIZER: -- not the ten

11 percent outlier of that study.

12 DR. VEDAL: All right. So you

13 pick some assessment of sort of the mean of

14 the distribution --

15 DR. SPEIZER: Mean of the

16 distribution, yes.

17 DR. VEDAL: -- that's used for

18 calculating the annual average.

19 DR. SPEIZER: Right. That's what

20 I would use, --

21 DR. VEDAL: Yes.

22 DR. SPEIZER: -- something like
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1 that. And if that's comfortable for you -- I

2 mean, that's really what I meant. I may not

3 use the right words for that, but that's what

4 I meant. So if we can wordsmith that

5 properly, that would be okay.

6 Now, Rogene, I would not go with

7 the lowest level in a fraction of that because

8 that gets us down to zero, I'm afraid.

9 DR. HENDERSON: I was using your

10 second suggestion with --

11 DR. SPEIZER: The second was a

12 multiple study. After there, I would say you

13 have to have more than one observation at the

14 lowest level, so whatever level it would be.

15 DR. HENDERSON: I said it too

16 briefly. I mean imprecisely.

17 DR. SPEIZER: There may be other

18 alternatives.

19 CHAIRMAN SAMET: Let's go back. I

20 think we should, one, escalate a bullet out of

21 this up to the cover letter. And I think it's

22 going to address the process question, which

Page 63

1 is, is the risk analysis about alternative

2 "standards."

3 And maybe we won't engage our

4 colleagues behind us in this dialogue or is it

5 about having the most valid model possible in

6 which any number of population exposure

7 scenarios are explored.

8 And then the drawing out of

9 alternative standards takes place in the

10 policy assessment document. I mean, that to

11 me makes sense.

12 Please? Have a seat right at the

13 table.

14 DR. MARTIN: I'm sitting here

15 trying to put into context the nature of your

16 discussion with how we are thinking about it

17 and how it will be meaningful to us in moving

18 forward. I guess I would just make a couple

19 of observations.

20 We have if you go back to all the

21 staff papers that you all have seen over time

22 done risk assessments that focused on

Page 64

1 characterizing risk remaining upon just

2 meeting current standards and upon just

3 meeting a series of alternative standards.

4 And that helped inform judgments

5 about if you believe the standard needs to be

6 revised, what alternative standard might be

7 appropriate to consider.

8 Clearly the risk assessment was

9 targeted on simulating risks remaining upon

10 just meeting a set of alternative standards

11 because that's what most directly helps inform

12 judgments about standards. And so, too, does

13 this risk assessment.

14 And so the question before us is

15 what set of alternative standards should we

16 use, should we simulate in the risk assessment

17 that will be informative?

18 Well, to simulate sets of

19 standards that are way outside the range that

20 we think are plausibly reasonable to consider

21 wouldn't be a useful exercise.

22 So we are, of course, trying to

Page 65

1 target on simulating alternatives that are

2 within what we understand to be the general

3 range that we will be thinking about.

4 CHAIRMAN SAMET: Yes. I think you

5 came at this with pretty strong priors, which

6 is really my point. And then what I found

7 that we heard yesterday was some questioning

8 by your own staff of whether your priors were

9 the right ones or not and why not go lower.

10 DR. MARTIN: Well, but, of course,

11 you can see this is an evolving process, which

12 is one of the benefits of doing multiple

13 drafts of a document.

14 In order to do the risk

15 assessment, you have to be completely

16 definitively about what alternative sets of

17 standards you are assessing. You have to

18 specify those numbers.

19 And if upon seeing those results

20 we decide, as in this case we did, that it

21 would be more informative, additionally

22 informative, to look at other sets of
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1 standards, then we proceed to do that.

2 CHAIRMAN SAMET: Right. Yes.

3 DR. MARTIN: We're not trying to

4 be all omniscient at the beginning.

5 CHAIRMAN SAMET: Well, yes.

6 DR. MARTIN: But you do have to

7 lay out some choices to proceed.

8 CHAIRMAN SAMET: Right. So I

9 think, in fact, maybe the problem was, to use

10 your words, that there was perhaps too much

11 all omniscience in this instance. And, rather

12 than using considerations other than what you

13 think the standards might be, the suite of

14 standards that might be proposed, you have

15 some other basis for making the determination

16 of what scenarios you are going to --

17 DR. MARTIN: That's what we are

18 understanding --

19 CHAIRMAN SAMET: Right.

20 DR. MARTIN: -- you are discussing

21 --

22 CHAIRMAN SAMET: Right.

Page 67

1 DR. MARTIN: -- and your advice

2 is. And I understand that. And that's --

3 CHAIRMAN SAMET: Yes. And I think

4 our advice is that you have something beyond

5 here's at the moment we started the risk

6 analysis of what alterative suites of

7 standards might be considered out in the

8 future. I mean, I think that is perhaps too

9 much prejudging.

10 DR. MARTIN: Okay. And the other

11 observation I would like to make gets at that

12 point. And it gets at the process point you

13 were just making. The way the discussion

14 seems to be going is the implication is that

15 the risk assessment is a filter between the

16 ISA and the policy assessment.

17 And that is not at all the way our

18 process is defined in our minds. In our

19 minds, we have an ISA that evaluates the

20 science. We then take that science, and we do

21 two things with it. One thing is we say,

22 okay. If we believe there is sufficient

Page 68

1 information, appropriate information to

2 conduct a quantitative risk assessment, we'll

3 draw from that science assessment document as

4 a basis for doing risk assessment.

5 In addition and as a separate

6 matter, we also look at the evidence in the

7 ISA directly and ask the question, even if we

8 were never to do a quantitative risk

9 assessment, what does that evidence tell us

10 about the adequacy of the current standard and

11 potential alternative standards?

12 So we are using two lines of

13 reasoning to get to the discussions that are

14 presented in the --

15 CHAIRMAN SAMET: Yes. I think

16 that is clear. And I don't think I view the

17 --

18 DR. MARTIN: Okay. It wasn't

19 clear to me that it was clear to everyone.

20 CHAIRMAN SAMET: No. I don't

21 think I view these as so linear. And I think

22 the way you have posed the questions in the

Page 69

1 policy analysis makes clear that there's sort

2 of one box to another box to another box kind

3 of thing.

4 DR. MARTIN: Okay.

5 CHAIRMAN SAMET: But I do think in

6 terms of the discussion we're having at the

7 moment, what would be helpful, I think, is if

8 you were able to describe how you select the

9 exposure scenarios for the risk analysis in

10 some way that, yes, you would probably have to

11 be realistic.

12 It does reflect some of the

13 potential scenarios, but there ought to be

14 other reasons as well because I am going to

15 think you found yourself yesterday. Well,

16 this could go lower, and it could go lower. 

17 Those scenarios might be useful. And those

18 scenarios might be useful.

19 DR. MARTIN: And clearly we're

20 understanding the advice you're grappling with

21 how to word as saying that we really should be

22 thinking about how to describe our selection
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Page 70

1 of an array of alternatives to look at in

2 terms of where we have confidence in the

3 evidence and where we lose confidence that the

4 evidence will provide credible estimates that

5 would meaningfully inform the process and to

6 characterize that and create criteria for

7 that.

8 DR. SPEIZER: I think we were

9 getting a little comfortable coming into the

10 meeting yesterday at 12. You added some

11 information to show some effect at 10.

12 The real question that comes up

13 is, why not seven and a half? So you need to

14 have criteria for stopping. I mean, that's --

15 CHAIRMAN SAMET: Okay. Thank you.

16 So I think, just going back

17 through this, I think that we will write

18 something additional. And the overall letter

19 will align that with what is here.

20 Let's see. I'll just turn the

21 page. We are scheduled for our public

22 comments previously. And I wonder if we can

Page 71

1 just try and finish this up in the next few

2 minutes.

3 DR. SPEIZER: Jon, I think it is

4 going to be hard because this really primarily

5 comments from me. And other people will want

6 to have some input into it. I would suggest

7 that we might give people a chance to read all

8 of this over and modify it.

9 CHAIRMAN SAMET: Okay. That's

10 fine. We were scheduled -- it's about now, I

11 think, Holly --

12 DR. STALLWORTH: Yes.

13 CHAIRMAN SAMET: -- to do our

14 public comments on the visibility document. 

15 And, if I understand, we have --

16 DR. STALLWORTH: Dave Heinold,

17 American Petroleum Institute. Do we have your

18 handouts?

19 MR. HEINOLD: Yes.

20 DR. STALLWORTH: I've got so much

21 paper I don't know if I have it.

22 MR. HEINOLD: You should.

Page 72

1 DR. STALLWORTH: Okay. Thank you.

2 CHAIRMAN SAMET: Thank you. I

3 think that's fine. Wherever you are most

4 comfortable, I think. And if you could limit

5 your comments to five minutes, please?

6 PUBLIC COMMENT ON UFVA

7 MR. HEINOLD: Okay. My name is

8 Dave Heinold. I'm with AECOM Technology

9 Corporation on behalf of American Petroleum

10 Institute.

11 Again I would like to pass on some

12 of our comments, interpretation regarding the

13 urban visibility issue and how it was reviewed

14 in second external review draft.

15 The main issue that I would like

16 to bring up is that urban visual air quality

17 has been characterized in the studies thus far

18 as being associated with extinction of either

19 550 nanometers or possibly related to PM2.5

20 concentrations.

21 And, again, I would like to

22 reiterate that what we know about urban

Page 73

1 visibility is that is a lot more complicated

2 and varies from city to city. And the issues

3 are probably a lot more complex than has been

4 characterized.

5 Specifically I would like to point

6 out that extinction measurement at a single

7 location over a one-hour period doesn't

8 adequately characterize persons experienced in

9 urban visibility. And it depends on a lot of

10 other factors.

11 Among those factors are how far

12 you're looking; where your scenic vista is;

13 and, most importantly for urban visibility,

14 the contribution of nitrogen dioxide, not in

15 the extinction at 550 nanometers but the

16 effect of nitrogen dioxide and the

17 carbonaceous particulate in reformulating the

18 ratios of light that people see so that you

19 have discoloration resulting in that.

20 And while the studies identify,

21 talk about the relationship of NO2 to

22 extinction and correctly say that NO2 does not
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1 contribute to extinction very much more than

2 like 5 percent, even in urban areas, it does

3 have a large effect on the discoloration.

4 And to pretend that it doesn't and

5 also pretend that all particles scatter light

6 in the same way, whether carbonaceous or

7 non-carbonaceous, that kind of does a

8 disservice to the whole science of urban

9 visibility.

10 Another issue is that the hourly

11 point extinction measurements are too variable

12 to properly characterize urban visibility

13 because it is a path-integrated effect. And

14 so that one needs to look at perhaps other

15 ways of characterizing visibility than have

16 thus far been reviewed.

17 Another shortcoming of the data

18 that we have thus far is that we have very

19 limited and, as acknowledged in the studies,

20 a very limited number of studies relating how

21 people perceive urban visibility and what

22 ranges of extinction specifically are

Page 75

1 interpreted as being meaningful in terms of

2 their welfare.

3 The limitations of the studies are

4 well-discussed in the study, but what it

5 doesn't seem to point out is that there are

6 such profound differences, regional

7 differences, and differences of contribution

8 of different particulate types. That would

9 make it very difficult to hang your hat on a

10 single measure of visibility that is going to

11 adequately protect visibility in urban areas.

12 And because we found that there

13 are such large variabilities, it is going to

14 be difficult to establish a single standard

15 that is going to adequately protect all of the

16 areas, urban areas, of the country.

17 Another thing that has been

18 discussed and will be brought out in the

19 policy document is, well, can now we use

20 24-hour PM2.5 mass, which is already being

21 measured for health effects to also relate to

22 visibility issues?

Page 76

1 And I think a discussion of all

2 these steps one needs to take to transform

3 PM2.5 mass, even just to extinction,

4 regardless of the other issues related to

5 urban visibility, it's a very tall task to do.

6 And there are many limitations in

7 doing so and a great deal of variation among

8 weather patterns in various cities and the

9 contribution of primary and secondary

10 particulates of various types that is going to

11 make it very difficult to relate particulate

12 mass, especially averaged over a period to

13 relate that directly to one's experience in

14 terms of visibility in urban areas.

15 Finally, to summarize the

16 comments, we feel that there are an

17 insufficient number of studies right now to

18 define what urban visibility impairment is and

19 that the measures for urban visibility that we

20 are considering are probably not going to be

21 adequate going forward in terms of actually

22 protecting visibility. And so that, indeed,

Page 77

1 more study should be done and to evaluate

2 whether there really is a threshold of

3 extinction or other parameters that need to be

4 evaluated to protect urban visibility.

5 And the information thus far

6 presented does not provide a compelling case

7 in which to create an ambient air quality

8 standard. And that's a summary.

9 Thank you.

10 CHAIRMAN SAMET: Okay. Thank you.

11 Questions for Mr. Heinold?

12 DR. BRAIN: I have a question.

13 CHAIRMAN SAMET: Joe?

14 DR. BRAIN: Sure. It seems to me

15 you are better at pointing out the problems

16 than offering a solution. We care about

17 visual air quality.

18 MR. HEINOLD: Yes.

19 DR. BRAIN: PM2.5 isn't perfect.

20 MR. HEINOLD: Yes. Okay.

21 DR. BRAIN: It's not perfect for

22 health either. Is there another criterion
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1 pollutant that is a better surrogate for the

2 VAQ? How --

3 MR. HEINOLD: Well, my background

4 has been in plume visibility study, visible

5 plumes from power plants, et cetera, over the

6 years. And I think some of those techniques

7 need to be brought forward into looking at

8 this.

9 The way I see what has been

10 studied thus far has been based on what we

11 have learned about class one areas, where we

12 have a really good idea in class one areas

13 that extinction of 550 nanometers is a very

14 good indicator of the reduction in visual

15 range. In the urban settings, there are other

16 things involved.

17 So I would suggest if we are going

18 to do measurements, we need to take

19 measurements that account for the variability

20 of extinction over wavelengths, perhaps using

21 transmissometers or other techniques that

22 account for discoloration in addition to

Page 79

1 extinction.

2 And so I don't think there is a

3 perfect answer, I think something that more

4 directly measures that people are seeing. And

5 some of the suggestions that you'll see here

6 are that it is only just a point source at a

7 single location that one distributes over an

8 urban setting and take averages, rather than

9 using a single location and things like that.

10 So I think there are a lot of

11 areas of refinement that could be pursued. 

12 Thank you.

13 CHAIRMAN SAMET: Okay. Thank you.

14 Next commenter is Anne Smith.

15 DR. SMITH: I'm Anne Smith,

16 Charles River Associates. I'm speaking on

17 behalf of UARG today. I want to focus my

18 comments on the statistical basis and some

19 issues in the statistics underlying the

20 candidate protection level range of 20 to 30

21 deciviews that EPA is using in UFVA.

22 These are based on logistic curves

Page 80

1 and statistically estimated recently and to

2 justify the candidate level range from 20 to

3 30. With 20, it comes from a Denver study. 

4 The 30 comes from a, one, Washington, D.C.

5 analysis.

6 However, in the document, that

7 memo from Strauss Consulting that conveyed

8 these logistic recurrences to EPA, it reported

9 a number of other EPA findings that are being

10 ignored in UFVA but are relevant.

11 These are, in particular, that

12 there is strong heterogeneity across the

13 cities in the preferences, that the preference

14 malleability that was shown in Smith and

15 Howell is statistically significant, and that

16 there is a statistically significant estimate

17 above 30 deciviews that is relevant.

18 All of these undermine several

19 points that are being used in the UFVA,

20 undermines the ability to set a uniform

21 national standard, undermines the ability for

22 these kinds of preference studies to be used

Page 81

1 for setting any VAQ standard at all, and

2 undermines the setting of the upper bound of

3 the standard protection levels at 30

4 deciviews.

5 On the first point on the

6 heterogeneity, Stratus concludes that the

7 results are heterogeneous across cities. They

8 say the hypothesis test of the means across

9 the cities, that is, are the same. It's

10 strongly rejected for all pairs of cities,

11 indicating that the mean 50 percent criteria

12 deciview levels differ for all 4 cities.

13 This heterogeneity undercuts the

14 support for setting a uniform national

15 visibility standard. For instance, instead of

16 being able to say we have a national

17 distribution with some uncertainty on what the

18 preference level is from which all of these

19 cities are randomly drawn sets, the Stratus

20 statistical results are saying that we have

21 statistically significant differences in the

22 acceptable VAQ level from city to city.
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1 As you can see here, the

2 confidence intervals for each city do not

3 overlap at all. For those of you who prefer

4 to look at t statistics, this is taken

5 straight from the memo.

6 And what is most important to see

7 here is these are the t statistics supporting

8 the data on the previous slide. They're

9 extremely high, suggesting a very strong

10 rejection of the possibility that these are

11 random draws off of one uniform national

12 distribution. In fact, they are separate

13 distributions. They're not due to variants.

14 On the point about preference

15 malleability, Smith and Howell did three tests

16 all of the Washington, D.C., all of the same

17 Washington, D.C., vista. And it found that

18 the preference response that you get from

19 these surveys is very malleable.

20 What the Stratus survey does,

21 statistical analysis does, is show that these

22 test differences are not due to variance. 

Page 83

1 They are statistically significant. And this

2 means that these preference studies cannot be

3 used as a basis. They are not a robust

4 scientific basis for setting a preference

5 standard.

6 This is what Smith and Howell

7 said, but this is the Stratus results are

8 confirming that through their own independent

9 analysis.

10 Again on the left here, I am

11 showing the results that support this

12 statement. And I have drawn the confidence

13 intervals in that table for it to help on

14 visually seeing what is going on here.

15 The confidence intervals are the

16 three blue bars for test one, test two, and

17 test three on what their preference levels

18 were. These are the 95 percent confidence

19 intervals.

20 You can see they do not overlap. 

21 They are very strongly different from each

22 other. And, importantly, you will notice test

Page 84

1 three is statistically significant and well

2 above 30 deciviews. It has a deciview level

3 of a mean of 32.3.

4 So while we feel that these tests

5 really can't be used to set a standard, if EPA

6 is going to persist in using these preference

7 studies to set a standard, they need to at

8 least use the test three result for the range. 

9 And that would bring the range up into well

10 above 30 to 32 or 33.

11 Test three from the D.C. study --

12 and this is acknowledged in the UFVA -- did

13 encompass the most complete range of photos of

14 visibility conditions in Washington, D.C. So

15 it is actually the better of all the tests if

16 one has to choose one of those three tests to

17 pick a number for Washington, D.C.

18 Thank you.

19 CHAIRMAN SAMET: Okay. Thank you.

20 Are there questions for Dr. Smith?

21 (No response.)

22 CHAIRMAN SAMET: Okay. Thank you. 

Page 85

1 So thank you to our two commenters.

2 At this point we I think should

3 probably return to where we were. We will

4 come back to our visibility discussion,

5 hopefully joined by Tom and having heard the

6 public comments, and continue our work on that

7 document.

8 So I think what I would suggest is

9 that we go back to where we were when Frank

10 suggested we need a little more time because

11 the group has not had a chance to interact

12 around developing the specific responses to

13 the A, B, C components or whatever of question

14 6.

15 So we had that general discussion

16 about question 6. Now if we could go on,

17 then, to A. And we can see both, Frank, how

18 you feel about what you wrote before the

19 meeting and whether others want to chime in. 

20 And we can at least perhaps make sure the

21 general points are there absent sort of

22 wordsmithing these responses.
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1 So A is to what extent does the

2 panel believe that we have captured the key

3 policy-relevant questions that can be

4 addressed by this risk assessment.

5 DR. VEDAL: Just to clarify the

6 first sentence after "questions" on the

7 beginning of line 2, which would be 4 PM2.5,

8 then it goes on to say it doesn't do a trip

9 and other particles.

10 DR. SPEIZER: Yes. Now, you know,

11 I think we've got now a brief review of the

12 policy assessment, which is a chapter on 10

13 minus 2.5 although it needs to be fleshed out,

14 I think, considerably.

15 I actually put this in sort of

16 hopefully if it was necessary to push, that

17 the PA would have something in it. So given

18 that that has occurred, I am not sure that we

19 need to have it in here. How other people

20 feel about it I don't know.

21 DR. LIPPMANN: I see nothing wrong

22 with indicating the scientific concern that's

Page 87

1 adequate, commendable even, for PM2.5. It

2 overlooks an important area of public health

3 concern.

4 DR. SPEIZER: Okay. We can leave

5 it in.

6 CHAIRMAN SAMET: I think that's

7 fine. So, I mean, certainly doing a risk

8 assessment for PM10-2.5 or coarse mass PM

9 would have been useful for policy purposes. 

10 It simply was not here.

11 So I think if you want to offer

12 the reminder that it wasn't done, which I

13 think is what Mort said, that I think we could

14 reduce the text here otherwise.

15 DR. LIPPMANN: Yes. And maybe the

16 last sentence is necessary.

17 CHAIRMAN SAMET: I think there

18 could be two sentences here to get a sense of

19 that. So it would be one says good job, and

20 the next one says but.

21 Okay. B.

22 DR. VEDAL: Regarding A again, I

Page 88

1 mean, so this is only relevant to the coarse. 

2 I missed the discussion as to whether there's

3 a thing about these other less than other

4 causal things is also relevant to fine PM,

5 right?

6 DR. SPEIZER: Yes. I don't

7 remember whether I put that in specifically. 

8 Again, that does come out in the PA. There

9 was a place I did write something about those

10 other factors.

11 CHAIRMAN SAMET: You know,

12 actually, Sverre, just to challenge you, the

13 word is key, policy-relevant. And I think if

14 you are proposing that a quantitative risk

15 assessment should have been done for some of

16 these other --

17 DR. VEDAL: No, I'm not proposing

18 that, no. I'm saying I think this is just

19 saying there is some parenthetical stuff here

20 that's saying we're --

21 CHAIRMAN SAMET: But this refers

22 to this risk assessment. I mean, I think in

Page 89

1 a sense --

2 DR. VEDAL: Yes. This is a risk

3 assessment for fine PM, right?

4 CHAIRMAN SAMET: So what is your

5 point? I mean, I think the point is that if

6 you think that the risk assessment should have

7 been done for these other health outcomes,

8 then we should say that. I don't personally

9 think that we should. So I'm not sure what

10 you would want to mention here.

11 DR. BRAIN: We just want them to

12 be mentioned to be acknowledged as emerging

13 concerns.

14 CHAIRMAN SAMET: Well, we've done

15 that. We've done that in our prior --

16 DR. BRAIN: Actually, it's in this

17 sentence here.

18 CHAIRMAN SAMET: We actually did. 

19 We made a fairly strong point of that in our

20 prior comments that we, in fact, said

21 something like there may be health outcomes.

22 So the level of causal, of
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1 strength of causal inference has not reached

2 that of likely causal or causal but which may

3 be of such importance for public health and

4 risk assessment. We have already said that.

5 DR. VEDAL: What I'm saying is

6 this seems to be a confusing point about

7 coarse and a point about these other issues.

8 DR. SPEIZER: Yes, yes. You're

9 right. I mean, it's in here. That really

10 applies to fine. And so maybe a modifier of

11 that second sentence.

12 CHAIRMAN SAMET: I think we have

13 actually made the point already about -- that

14 was very clear in our prior letter.

15 DR. VEDAL: I would be happy not

16 saying anything.

17 CHAIRMAN SAMET: Okay. And we

18 made the point about coarse mass PM before.

19 DR. SPEIZER: I mean, I think

20 Sverre is saying that this looks like I'm

21 worried about the suggested health findings as

22 applied to coarse. And they really apply to

Page 91

1 fine. So you might need to have another

2 qualifier in that sentence or to both, yes, or

3 to both.

4 DR. STALLWORTH: Okay. I made

5 note of that. We can wordsmith.

6 DR. SPEIZER: It's just wordsmith

7 that.

8 CHAIRMAN SAMET: Okay. So on to

9 B, which is actually one of those pretty long

10 questions.

11 DR. SPEIZER: Yes. I'm afraid

12 here I was confused as to how the national --

13 well, first, I was confused on two scores. 

14 One, understanding the peakiness of the peak

15 shaving issue and how -- I didn't understand

16 the shift. I think I've been dealt with, how

17 it shifts the whole distribution.

18 And then, secondly, I somehow

19 combined how the 15 sites played a role in the

20 national estimates.

21 So I don't know that anything I

22 have said here makes a lot of sense. So we

Page 92

1 need some new words, I think.

2 CHAIRMAN SAMET: Total

3 wordsmithing.

4 DR. SPEIZER: And if I look at

5 what Sverre said, I think he said yes.

6 DR. VEDAL: Yes. There's nothing

7 else.

8 DR. STALLWORTH: Rich, do you want

9 to call Tom Moore? I've e-mailed him twice

10 this morning.

11 CHAIRMAN SAMET: So section 6.2,

12 just to remind everybody, is called

13 Interpretation of Urban Study Area Results.

14 And so this is sort of about the heart of the

15 analysis in going through just meeting these

16 alternative standards and so on.

17 So there's a lot of detail here. 

18 And the question is, so to what extent do the

19 panel members believe that the observations

20 presented in section 6.2 are well-supported by

21 the results of the analysis? I mean, what

22 they have done, what is done here is a lot of

Page 93

1 the analysis from chapter 4 is brought

2 forward.

3 DR. SPEIZER: Is brought forward. 

4 And I think it probably was fine.

5 CHAIRMAN SAMET: So the question

6 is, how well were things brought forward? 

7 That's one thing. I mean, I guess the

8 question in the end is, how well does 6.2 do

9 its job of summarizing key points out of

10 chapter 4?

11 DR. SUH: Can I ask, isn't this

12 the section that we had a lot of problems

13 about the risk reductions and what that means? 

14 And so in response to this part of that, the

15 charge, are we supposed to just reference back

16 to chapter 4 in those questions we have on

17 those comments or --

18 CHAIRMAN SAMET: You mean those

19 questions, those issues we have just gone

20 through?

21 DR. SUH: Yes.

22 CHAIRMAN SAMET: I think those are
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1 going to be in the sort of general piece that

2 would be written response to question 6 that

3 Frank has. So I think that is covered.

4 DR. VEDAL: That is the main

5 issue, yes.

6 DR. SUH: Well, I guess I am

7 wondering if we should just reference, just

8 say, you know, "As we discussed earlier" or

9 something like that.

10 CHAIRMAN SAMET: I mean, reduced

11 to a literal read of this question, it says

12 how well does section 6.2 do at representing

13 stuff that came before. And a simple answer

14 is it's okay. I mean --

15 DR. SUH: That's not maybe the

16 most useful answer.

17 DR. VEDAL: Well, yes, but, I

18 mean, it is basically referring to the

19 discussion of chapter 4, then, that we --

20 CHAIRMAN SAMET: Which we have

21 gone over. I mean, in a sense in chapter 6,

22 we should not be bringing up new conceptual

Page 95

1 issues because it's an integrative summary of

2 what came before it.

3 DR. SUH: I agree. I totally

4 agree with that. I'm just wondering if we

5 should just say, notwithstanding the issues

6 that have been discussed before, this summary

7 presents -- whatever is fine.

8 MR. AVOL: Well, but it wasn't

9 fine because we gave them a clear indication

10 of chapter 6, that chapter 6 needed to be

11 clarified.

12 DR. SUH: That's the problem. In

13 some ways a response like a "Yes" would be

14 irrelevant because if you're suggesting they

15 change it a lot, then it doesn't really matter

16 what we thought the summary that they did --

17 DR. SPEIZER: I hate to bring up

18 something that might cause a long discussion,

19 but I am going to do it anyway. I don't know

20 how easy it is for people to get to the

21 appendices, but there is a series of tables,

22 E-24 to E-34, which show the percent

Page 96

1 reductions at the various scenarios that are

2 looked at.

3 I actually struggled with those

4 tables because the first column in the tables,

5 first column in the tables, is generally

6 recent PM concentrations. The second column

7 is the 15, 35 and then the various

8 alternatives.

9 Now, the minus numbers -- and

10 these are generally in the recent PM

11 concentrations, they pick a year -- are

12 generally minus numbers, which I interpret --

13 maybe Zach can help us here -- as meaning that

14 if you like those standards, you would have an

15 excess risk compared to the others, which are

16 positive numbers, which would be a reduction

17 in risk. Am I wrong?

18 DR. PEKAR: So basically on those

19 tables, what they are doing is they are

20 comparing risk relative to the current

21 standard. So it's saying let's take current

22 standard as sort of the level, and under

Page 97

1 recent conditions, most places have higher

2 risk.

3 Now, it's risk reduction relative

4 to the current standards. Let me stop for a

5 second and say if we look at the alternate

6 standard levels, we have a positive reduction

7 in risk.

8 Sort of the corollary of that is

9 then if under recent conditions you have

10 higher risk, in terms of a risk reduction,

11 that is actually negative because you can

12 either do it the other way -- we could have

13 said that, which might have been more

14 intuitive, under recent conditions, it is

15 positive. It is a higher risk. And then you

16 have percent reduction. It could have been a

17 negative.

18 DR. SPEIZER: But all of these

19 reductions are back to LML. Is that correct?

20 DR. PEKAR: All of those are

21 modeled. Well, the risk is estimated down to

22 LML.
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1 DR. SPEIZER: Yes.

2 DR. PEKAR: But, just to be clear,

3 those percent reductions are often dealing

4 with PM levels. You know, you're talking

5 about incremental reductions from 15 down to

6 14 down to 13 down to 12. The absolute risk

7 numbers are modeled down to LML.

8 DR. SPEIZER: That's where I have

9 a problem, is that -- and this is where Joe

10 has a problem in the sense that this is where

11 you get these 100 percent reductions.

12 DR. PEKAR: Right.

13 DR. SPEIZER: Would it not be

14 better that these were modeled to the delta

15 from the current standard, rather than down to

16 LML, just to give a more realistic estimate of

17 what the effects would be? That's the concern

18 I have about how that's done. I'm sorry.

19 CHAIRMAN SAMET: No. But isn't

20 this the point we have been discussing

21 generally, which is how are you going to say

22 where you're going, how well you're going to

Page 99

1 go? I mean, I think this is the same general

2 point we have been speaking to but now in

3 particular.

4 DR. PEKAR: There are different

5 risk metrics that can be done. We can

6 certainly talk about the reduction, the

7 reduction in the percent of mortality

8 attributable to PM2.5.

9 And in that case, you're talking

10 about the degree of step-down in going from 15

11 to 14 to 13 to 12. And you don't have to

12 worry about how far down you're modeling

13 because you're only looking at the incremental

14 change. That is certainly one of the risk

15 metrics that we talk about in there.

16 But this particular one depending

17 on the risk metrics, some of them are very

18 responsive to the lower bound of the risk

19 estimation. Some of them only deal with the

20 incremental step-down.

21 And if there is a sense that the

22 risk metrics that deal with the incremental

Page 100

1 reduction in a sense are better because we

2 have better confidence in that statement, I

3 think we even say that in the document, to the

4 benefit of the incremental risk reduction is

5 you're only talking about the magnitude of

6 risk associated with sort of stepping down

7 from 15 to 14 to 13 to 12. And you're not

8 focusing on how far down you have to go.

9 I'm not sure if that's clarifying.

10 DR. SPEIZER: So it seems to be

11 more intuitive to me --

12 DR. PEKAR: Right.

13 DR. SPEIZER: -- to discuss it

14 that way than to take it down to 5.8.

15 CHAIRMAN SAMET: But I think this

16 is the same general discussion we have been

17 having. And maybe this goes back to whether

18 those tables stay in or go. If you can

19 specify something, I mean, I think, as you

20 said, it is very reasonable to go down

21 15-14-13, et cetera -- you happened to go

22 15-12, whatever.

Page 101

1 But the question of how low you

2 go, as we have said, should be based on some

3 specified criteria. And I think, Frank, this

4 is for EPA to make a clear specification.

5 DR. SPEIZER: At this stage I

6 think we just need to say something about

7 that.

8 CHAIRMAN SAMET: No. We will. I

9 think we --

10 DR. PEKAR: The absolute risk in

11 terms of how far down you go and then the

12 second issue that certain risk metrics don't

13 depend on that and really focus on the

14 incremental change -- and we may feel that we

15 have greater confidence -- and we do -- in

16 making those statements. And maybe those risk

17 metrics should be emphasized from a policy

18 standpoint.

19 I think we agree. And we could

20 strengthen that point.

21 CHAIRMAN SAMET: So let's go back. 

22 We're somewhere at 6B. Let's see. Who else
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1 was on this? Let me pull this out. So other

2 6B discussants were Sverre, Joe, Mort, and

3 Rogene.

4 DR. VEDAL: Yes. My observations

5 were well-supported, no other observations are

6 apparent was my contribution.

7 CHAIRMAN SAMET: Okay. So maybe

8 if the literal answer is has chapter 4 been

9 dealt with appropriately in chapter 6, the

10 easy thing is to say yes. But there are a

11 bunch of more difficult general issues around

12 chapter 4-6 that we have dealt with in

13 general. And I think Frank just came back to

14 it again.

15 DR. SPEIZER: Okay.

16 CHAIRMAN SAMET: All right. So 6B

17 is okay.

18 DR. BRAIN: But it's a good chance

19 to underline our concerns.

20 CHAIRMAN SAMET: All right. And

21 then 6C. This has to do with the descriptors

22 of levels of confidence and so on. I think

Page 103

1 Frank is saying this looks also --

2 DR. VEDAL: At this point I would

3 interject this observation on ischemic heart

4 disease.

5 CHAIRMAN SAMET: Yes. The IHD CBD

6 thing. Okay.

7 DR. VEDAL: Yes.

8 DR. STALLWORTH: Should we add a

9 sentence about that?

10 DR. VEDAL: I would like to,

11 although, again --

12 CHAIRMAN SAMET: The point should

13 be made somewhere, I think.

14 DR. VEDAL: Yes, for sure.

15 DR. SPEIZER: I think that's good.

16 DR. STALLWORTH: I'll make a note

17 of it.

18 DR. VEDAL: I think it was brought

19 up. Someone brought it up earlier today,

20 actually, in the actual -- it may be

21 repetitious. Anyway --

22 DR. STALLWORTH: We'll figure it

Page 104

1 out.

2 CHAIRMAN SAMET: Okay. And then

3 D.

4 DR. SUH: Is this where you want

5 to put the comment in about the table --

6 CHAIRMAN SAMET: Table 5.4.

7 DR. SPEIZER: 5.4. And maybe even

8 here this little discussion that we just had

9 about perhaps focusing more on the deltas

10 across the range, rather than down to a lowest

11 measured level.

12 DR. VEDAL: Yes. I mean, I think

13 the two are complementary. I mean, I think

14 down to the lowest measured level gives you

15 some notion of absolute risk and what's

16 remaining and the impact. The others, this

17 relative measure, it doesn't really give you

18 the full picture. Even though you're more

19 confident, it doesn't give you the full

20 picture, really.

21 DR. SPEIZER: Well, but it also is

22 I think more realistic as to what can be

Page 105

1 anticipated to be expected to be accomplished. 

2 I mean, I am concerned.

3 I guess, if you go down to the

4 lowest measured level, you are going to see

5 headlines in half the newspapers in the United

6 States anyway that say the EPA is not setting

7 the standard sufficient to protect the public. 

8 And that's just not appropriate.

9 DR. VEDAL: Yes. I see that.

10 DR. LIPPMANN: Well, assuming that

11 there will be some tightening of the standard,

12 the lowest measured level would be a moving

13 target because there will be some efforts to

14 comply with the reduced standards. And then

15 the lowest measured level next round will be

16 25-30 percent lower than it is now.

17 So it's a poor frame of reference

18 to use lowest measured level. It depends on

19 how many epi studies they are and what the

20 ranges will be.

21 DR. VEDAL: It won't depend on the

22 standards.
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1 DR. SPEIZER: We're talking about

2 economics.

3 DR. LIPPMANN: We're talking about

4 risk, not the standard here. And if the risks

5 are above and below our lowest measured level,

6 then the risks will shift and be hard to

7 explain.

8 CHAIRMAN SAMET: Okay. So I think

9 that looking at 6D-E, again, this relates to

10 some of the process stuff around the summary

11 and other issues.

12 DR. LIPPMANN: 6D?

13 CHAIRMAN SAMET: Well, 6D I think

14 we had just passed through. I've gone to 6E.

15 DR. LIPPMANN: E.

16 CHAIRMAN SAMET: This is that long

17 list of items at the end of the chapter.

18 DR. STALLWORTH: D or E?

19 CHAIRMAN SAMET: E.

20 DR. SPEIZER: Yes. I think this,

21 the long response, has kind of a little

22 politics in it that should probably come out.

Page 107

1 DR. VEDAL: I mean, the issue here

2 is whether or not it's basic --

3 CHAIRMAN SAMET: Yes, yes.

4 DR. VEDAL: They pretty much are.

5 CHAIRMAN SAMET: They pretty much

6 are. I mean, this is --

7 DR. VEDAL: Again, that issue is

8 about the 12, the lower limit of the risk

9 assessment. That's all --

10 CHAIRMAN SAMET: Which we have

11 addressed.

12 DR. LIPPMANN: This needs to be

13 revised. And I'm not sure it makes sense to

14 talk about the risk estimates from 2006

15 because the document goes into the better

16 database that we have now and supersedes what

17 the database was in 2006.

18 CHAIRMAN SAMET: I mean, again,

19 taking this straightforward, this one says,

20 "Have we listed the right stuff in the

21 bullets?"

22 DR. LIPPMANN: Yes.

Page 108

1 CHAIRMAN SAMET: Yes. Okay. So

2 there's work to be done. I think we've gotten

3 the general shaping of it. And probably the

4 comments on chapter 6 are the most,

5 potentially the most, demanding. Let me make

6 a suggestion that if we want a short break,

7 now would probably be the right time to --

8 DR. STALLWORTH: Let me ask, do we

9 have anybody on the line yet? Tom Moore?

10 (No response.)

11 DR. STALLWORTH: Okay.

12 CHAIRMAN SAMET: Okay. And then

13 we come back and look at the visibility

14 letter. Okay. Good. So let's reconvene by

15 10:00, which gives a generous 12-minute break.

16 (Whereupon, the foregoing matter

17 went off the record at 9:48 a.m. and resumed

18 at 9:59 a.m.)

19 CHAIRMAN SAMET: So everybody has

20 the visibility letter in front of you. And

21 thanks to the visibility team for working on

22 this.

Page 109

1 DR. LIPPMANN: Yes. Thank you.

2 MR. POIROT: Well, so those first

3 three paragraphs were sort of intended to go

4 in the summary letter. And I wrote them kind

5 of blandly.

6 I think we really liked the first

7 urban visibility, urban focus visibility

8 assessment. We asked for a number of things. 

9 And they delivered all of them in the second

10 draft.

11 So generally we were supportive of

12 it, had some relatively minor recommendations

13 in several sections and no major

14 recommendations. So that was intended just to

15 those first three paragraphs.

16 CHAIRMAN SAMET: And, actually,

17 Rich, maybe this would be the place. There's

18 one comment. We did think that there should

19 be a summary chapter to the document. And

20 that should go somewhere.

21 In fact, in the text that I had

22 written that Holly could maybe find again, I
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1 had written something about the need for

2 either an executive summary or a sort of

3 integrative chapter at the end.

4 So, Holly, you could just put that

5 text in.

6 MR. POIROT: Good point.

7 DR. STALLWORTH: So Jon's

8 paragraph is "With regard to the visibility

9 assessment, CASAC welcomed the additional

10 analyses of the urban visibility preference

11 studies. This unified analysis provided

12 useful insights into the variation and

13 visibility preferences among the study panels. 

14 This completed analysis should now be folded

15 into the document.

16 "CASAC also recommends the

17 addition of an integrated summary chapter. At

18 present, it lacks a summary that brings main

19 findings and their implications together. The

20 chapter might be included in the summary as a

21 first chapter or at its conclusion.

22 "There is also a need for further

Page 111

1 research on the topics related to visibility

2 need to be assembled in" --

3 CHAIRMAN SAMET: Yes. I said

4 there might be a compilation of research needs

5 in this, so the mention of that, too. Those

6 are --

7 MR. POIROT: Yes.

8 CHAIRMAN SAMET: So we'll put that

9 in.

10 MR. POIROT: Yes. I like that

11 better than mine.

12 DR. STALLWORTH: Do we have anyone

13 on the line?

14 (No response.)

15 CHAIRMAN SAMET: Okay. So that

16 would be sort of the draft cover letter, the

17 main points. And then the charge questions,

18 should we go there?

19 MR. POIROT: I guess Lowell had

20 the first one.

21 CHARGE QUESTION #1

22 DR. ASHBAUGH: Yes. I think

Page 112

1 there's too much in here. I put in a lot that

2 I had in mind.

3 DR. STALLWORTH: We need to export

4 some of the minor comments, too.

5 DR. ASHBAUGH: Yes. I think those

6 should remain, perhaps with some changes. 

7 Practically everything else can be moved. I

8 don't know if there's anything there that

9 needs to be kept in response to the charge

10 question.

11 DR. STALLWORTH: I didn't know. 

12 And the reason I didn't remove it myself is I

13 didn't know whether this comment about sea

14 salt we wanted to leave.

15 DR. ASHBAUGH: Yes. Well, yes. I

16 do have that in my individual comments, but I

17 wasn't -- I am not sure that the panel wants

18 to have it in in the panel comments or not. 

19 So that's up to the panel.

20 DR. GRANTZ: I think it ought to

21 remain in the general comments because I think

22 it is an important point.

Page 113

1 MR. POIROT: I guess I will take

2 the other view. Especially in the context of

3 this assessment and in the specific urban

4 areas used, I'm not sure I see it making it a

5 big difference --

6 DR. GRANTZ: That's true.

7 MR. POIROT: -- in this

8 assessment. Maybe if we don't look, we don't

9 -- I think let's leave it in. I think it

10 doesn't hurt anything.

11 DR. STALLWORTH: And extract all

12 of the other paragraphs.

13 MR. POIROT: I don't want to be

14 telling them they need to redo the whole

15 assessment to have sea salt. They might

16 mention it at some point, finding out that it

17 could be a contributor in some of the near

18 coastal areas.

19 DR. ASHBAUGH: I can work with you

20 on a revision of that.

21 DR. STALLWORTH: Okay. I'm going

22 to go ahead and delete all but the first --
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1 what was it -- three paragraphs and the sea

2 salt.

3 DR. ASHBAUGH: The first two --

4 DR. STALLWORTH: First two.

5 DR. ASHBAUGH: -- and the sea

6 salt.

7 DR. STALLWORTH: Okay. And then

8 you can --

9 DR. ASHBAUGH: I think a lot of

10 this actually stays on the definition of

11 haziness, the last paragraph on that page. 

12 Did you want that in the comments?

13 DR. GRANTZ: I think that is

14 something, too, that they might look at. I

15 don't think it needs to be in this letter.

16 DR. ASHBAUGH: Okay. So we can

17 just leave it back in your individual

18 comments.

19 DR. GRANTZ: Yes. I think we can

20 take that out here.

21 DR. ASHBAUGH: Yes. Okay.

22 DR. STALLWORTH: Okay.

Page 115

1 CHAIRMAN SAMET: So on to question

2 2?

3 DR. STALLWORTH: Yes.

4 CHAIRMAN SAMET: Question 2. This

5 is Chris. Actually, why don't we go to

6 question 3. Hopefully Chris may be here soon,

7 and, Rich, we're going to run out of time on

8 --

9 DR. STALLWORTH: Do we have

10 someone on the line?

11 (No response.)

12 CHARGE QUESTION #3

13 MR. POIROT: So question 3 was

14 asking about our take on the newly added

15 discussion of the 90 percent RH screen and its

16 specific application in removing influences of

17 natural weather, removing periods where

18 natural weather was likely to be an overriding

19 influence on visibility, rather than air

20 pollution.

21 I think we generally found it to

22 be a fairly well-presented analysis,

Page 116

1 especially as modified by the memo that we

2 only discovered yesterday that actually made

3 some of the statements that weren't correct,

4 made them correct.

5 I wanted to also add the

6 additional comment that this use of a 90

7 percent RH screen would also for other reasons

8 be beneficial in characterizing the secondary

9 standard itself.

10 That is, it's one question to use

11 it in the risk assessment, but there are other

12 good reasons, some of which Ted alluded to

13 that came out of the discussions from the

14 Monitoring Subcommittee for using it as a

15 filter in making measurements as well. So

16 that was the tone of the second.

17 CHAIRMAN SAMET: Okay. Other

18 comments? Everybody is okay? It's to the

19 point and focused?

20 (No response.)

21 CHAIRMAN SAMET: Sverre, any

22 comments on --

Page 117

1 DR. VEDAL: Silence.

2 CHAIRMAN SAMET: Okay. So

3 question 4. Again, Rich, this is you.

4 CHARGE QUESTION #4

5 MR. POIROT: This question was

6 asking about our take on the, largely, I

7 think, on the, graphic presentations and some

8 of the tabular information that was presenting

9 some of the requested alternative analyses and

10 so forth that we were asking for; for example,

11 the influence of this RH screen, looking at

12 other percentiles, including the 98th

13 percentile, and so forth and the comparisons

14 between using the single worst hour of the day

15 and then calculating percentile versus

16 calculating the percentile across all the

17 daylight hours.

18 So, again, I think generally we

19 found these graphic presentations to be very

20 useful and informative. I think everybody who

21 commented especially liked the tile plots. 

22 There's a lot of information there that's
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1 really nicely summarized.

2 I thought we did have an issue

3 with the sort of apples versus apples

4 comparability of selecting the single worst

5 hour versus using all of the hours and that we

6 would like to see a more direct sort of a

7 one-to-one kind of a comparison.

8 I don't push any specificity in

9 there, largely because I felt like the staff

10 was sort of nodding its head as if it had good

11 ideas of how to address that. And I thought

12 it was maybe better to not be too specific of

13 exactly how to do that. So I didn't put any

14 specificity in here.

15 We could think about, talk about

16 adding that, that it would be probably a

17 detailed discussion and emphasizing that that

18 choice of whether to do it one way or the

19 other might actually be very important. Maybe

20 it isn't. We just don't know because we can't

21 see it.

22 So let's take a close look at

Page 119

1 that, see what kinds of different maybe

2 species or sources or neurological conditions

3 or whatever come into play and get emphasized

4 by using one approach versus the other

5 approach.

6 And then the last point was

7 emphasizing the comments that some of us had

8 on apparently illogically high it seemed

9 contributions of the coarse mass in some cases

10 that, again, nobody is saying we do all of

11 this but, rather, just put a pointer to this

12 in the text that encourages some caution

13 interpreting some of those results.

14 CHAIRMAN SAMET: Okay. Any

15 additions to this, Lowell?

16 (No response.)

17 CHAIRMAN SAMET: So you're

18 comfortable with this. Okay. Good. So that

19 leaves us, I guess, with the piece from Chris. 

20 And we do expect him --

21 DR. STALLWORTH: He said 10:30. 

22 Probably --

Page 120

1 CHAIRMAN SAMET: 10:30. So maybe

2 we can hang on. Anything else on visibility? 

3 I know you are going off soon, Rich. So --

4 MR. POIROT: So what were we going

5 to do about question 2?

6 CHAIRMAN SAMET: Well, we can

7 either go through it or we can wait until

8 Chris comes in or do both.

9 CHARGE QUESTION #2

10 CHAIRMAN SAMET: Do you have

11 comments to the response as it is written now?

12 MR. POIROT: My tendency would be

13 to defer to Chris' opinion on the topic. I

14 thought he did a good job explaining yesterday

15 and so forth.

16 DR. STALLWORTH: He had comments

17 on the budget analysis, which I just stuck in

18 there. And this will have to be smoothed out.

19 MR. POIROT: I think looking at

20 the whole of the comments put all together,

21 it's probably more detailed than we want. I

22 wonder, though. David really had some

Page 121

1 concerns.

2 DR. GRANTZ: Yes. I would like to

3 address the middle paragraph on page 4. While

4 I strongly support the use of logit and I

5 think that takes those data just about as far

6 as they can go, the data remain quite limited.

7 And I think this letter should

8 reflect the fact -- well, reflect an opinion

9 of mine anyway that we may really not be

10 looking at data that have a central tendency,

11 that these may be real regional differences

12 which will be borne out by future research.

13 DR. STALLWORTH: So you would

14 soften the sentence that says, "The overall"

15 --

16 DR. GRANTZ: I would add in it an

17 explicit sentence that says that not only is

18 further research to be recommended but that it

19 is reasonable, a reasonable interpretation of

20 the available data is that there are regional

21 differences. I don't know how far to take

22 that, that logic, but I think my personal
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1 opinion is that we're getting ahead of

2 ourselves with those data.

3 CHAIRMAN SAMET: And I think it

4 did come up in our discussion yesterday. When

5 you're talking about the need to explore the

6 sort of settling multiple factors in some

7 organized way to try and understand the

8 difference between sort of place, person, et

9 cetera, and we --

10 DR. GRANTZ: Yes. Well, there are

11 regional differences, even with health

12 responses and whatnot.

13 CHAIRMAN SAMET: Right.

14 DR. GRANTZ: But in this case,

15 we're basing -- and it becomes even more

16 critical when you look at the policy

17 assessment, that we're starting to base the

18 entire standard now on visibility. And that

19 is based on these limited preference studies.

20 So I say in my written comments

21 that it's probably appropriate to move forward

22 on the basis of available data, but I don't

Page 123

1 think this panel should endorse the

2 comprehensiveness, let's say, of those data.

3 They remain -- the logit analysis,

4 which is the question to be answered here,

5 contributed a lot.

6 CHAIRMAN SAMET: No.

7 DR. GRANTZ: But it doesn't add

8 any more data to the field as far as --

9 CHAIRMAN SAMET: Right. But there

10 are research needs that come out of this. I

11 think the logit analysis shows clearly and I

12 think our public comment or comment on this

13 that there is heterogeneity confirmed by the

14 statistical analysis.

15 DR. GRANTZ: My main point is that

16 that is not reflected in here.

17 CHAIRMAN SAMET: Right, right. 

18 And then I think where the implications come

19 is really in the next step, in the policy

20 analysis, like you do when you have the data

21 you have at hand show heterogeneity. And then

22 --

Page 124

1 DR. GRANTZ: But these comments

2 have to show our take on looking at the graphs

3 in this visibility analysis. And my take on

4 those graphs is that you can draw a line

5 through the middle of the distribution. It

6 doesn't necessarily mean that's a very good

7 thing to do.

8 CHAIRMAN SAMET: Right.

9 DR. GRANTZ: And it's certainly

10 not in --

11 CHAIRMAN SAMET: Right, right.

12 DR. GRANTZ: I mean, I would like

13 this panel to endorse that we're done with

14 that.

15 CHAIRMAN SAMET: Yes, yes. And I

16 think, actually, the part we'll see in the

17 next step, which is if these are all of the

18 data you have at hand and you are going to use

19 them and you have heterogeneity, then you have

20 to interpret it.

21 DR. GRANTZ: Yes. I mean, in a

22 way, it is a funny thing, having seen the

Page 125

1 policy assessment because I think I can make

2 these comments based only on having seen that

3 graph.

4 You know, I see four separate

5 lines. And there is a line drawn through the

6 middle, which is a reasonable thing to do with

7 limited data. But it's by no means a robust

8 answer.

9 So I would like that paragraph to

10 reflect that while it's in some ways

11 reasonable to move forward with looking for a

12 central pendency, the data don't strongly

13 support that. And further research is

14 strongly recommended, something along those

15 lines.

16 CHAIRMAN SAMET: Okay. Yes?

17 MR. POIROT: I think it's a very

18 important issue that I would like to see us

19 carefully craft the language because, on the

20 one hand, you know, an extreme critique of it

21 would make it a kind of a game-breaker. And

22 I don't believe that it's a game-breaker
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1 necessarily. So I would --

2 DR. STALLWORTH: How about this

3 compromise I was just trying to figure out? 

4 While it's appropriate to move forward on the

5 basis of available data, the panel believes

6 the data suggest some heterogeneity that

7 should be explored with further research.

8 MR. POIROT: That works for me.

9 DR. GRANTZ: I think the

10 game-breaker problem is addressed in the next

11 step. You know, I just think as we move

12 along, we would present an analysis. And we

13 have to give our opinion about that analysis,

14 not where it is going to go.

15 Technically we shouldn't have seen

16 the PA yet, really, when we're done with

17 events. But since we are heading for a

18 visibility standard, it becomes that much

19 longer.

20 So I'm fine with that wording. 

21 Thank you.

22 CHAIRMAN SAMET: Okay. Good. 

Page 127

1 Okay. And anything else, I mean, we have to

2 be in -- and we can get Chris or Joe to do

3 this, some combination of what has been

4 written. You know, the analyses are useful. 

5 They're straightforward. They're presented

6 well. And I think that we can say. And I

7 think both Chris and Joe say that, perhaps in

8 too much length, but we can edit that.

9 Okay. Anything else on

10 visibility?

11 (No response.)

12 DR. GRANTZ: I know Chris and Joe

13 have comments. Are you going to combine those

14 or --

15 DR. RUSSELL: Yes, yes. We'll

16 take care of it.

17 DR. STALLWORTH: I'll probably ask

18 Rich Poirot to smooth it out.

19 CHAIRMAN SAMET: Okay. So let's

20 talk about the process for moving forward on

21 these two letters. So, Frank, you need to

22 work on responses to 6 with your colleagues.

Page 128

1 DR. SPEIZER: I actually thought

2 that we had worked that down to something that

3 you have been keeping track of, Holly.

4 DR. STALLWORTH: I made pretty

5 good notes. John, I thought you would take a

6 risk assessment letter and give it a good --

7 CHAIRMAN SAMET: All right. 

8 That's fine. I was just trying to be gentle. 

9 All right. Okay.

10 DR. STALLWORTH: And, likewise,

11 Rich, I can send you my most recent file. If

12 you could take that and smooth it out based on

13 the comments?

14 CHAIRMAN SAMET: Okay. But we

15 will need to bring these letters to closure. 

16 And so that --

17 DR. STALLWORTH: We'll do that

18 soon.

19 CHAIRMAN SAMET: So, as I say,

20 what we would like to do, then, is circulate

21 and --

22 DR. STALLWORTH: A draft that you

Page 129

1 have edited.

2 CHAIRMAN SAMET: A draft that Rich

3 has edited and then I guess any last

4 discussion on our April 8th call.

5 DR. STALLWORTH: Right, right. 

6 I'll incorporate all comments by e-mail. And

7 then we'll post it and discuss both of these

8 letters on April 8th, but hopefully that will

9 be a short discussion.

10 CHAIRMAN SAMET: Okay.

11 DR. STALLWORTH: So maybe next

12 week we'll send these letters out, Monday.

13 CHAIRMAN SAMET: I would think so. 

14 Yes. So you'll send texts to me, texts to

15 Rich with --

16 DR. STALLWORTH: I just sent you

17 that, right?

18 CHAIRMAN SAMET: You just did. 

19 Okay. All right. I'll send it to Frank. No. 

20 So, anyway, we will do that. Chris.

21 DR. STALLWORTH: Just in the nick

22 of time.
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1 CHAIRMAN SAMET: Just in the nick

2 of time. We're almost getting to the end, but

3 don't worry. But thanks. Actually, just to

4 update you, we have gone through drafts, which

5 are sitting there, of the two letters.

6 And so there is both sort of the

7 overall letter, the main messages, and then

8 there is for each response to the charge

9 questions.

10 I think on the pieces that you had

11 written, there was general agreement that you

12 had covered the right stuff and the feeling

13 that some of the material was too long.

14 On the charge question, I think it

15 was two on visibility. Both you and Joe had

16 written something. And it will need to be

17 amalgamated. And Rich is going to do that.

18 DR. FREY: Okay.

19 CHAIRMAN SAMET: So that you don't

20 have to worry about doing.

21 DR. FREY: All right. HIGHLIGHTS

22 AND DISCUSSION OF CHARGE QUESTIONS FOR

Page 131

1 UPCOMING REVIEW OF POLICY ASSESSMENT

2 CHAIRMAN SAMET: I think that is

3 where we are. We are talking about the

4 process now for finishing off these letters.

5 DR. FREY: Okay.

6 CHAIRMAN SAMET: Yes. And so

7 we'll circulate comments, try and minimize

8 wordsmithing. Concept-smithing is okay. And

9 that gets to final discussion April 8th. So

10 that's where we want to be.

11 Okay. So then the other issue is

12 the review of the policy assessment. And, you

13 know, as of now, we are scheduled to have I

14 guess 4 hours on the 8th and 4 hours on the

15 9th --

16 DR. STALLWORTH: If needed.

17 CHAIRMAN SAMET: -- if needed to

18 discuss the policy assessment. We are going

19 to get reworked charge questions, although

20 presumably the general areas will be roughly

21 the same.

22 DR. STALLWORTH: The coverage will

Page 132

1 be the same.

2 CHAIRMAN SAMET: Will be the same. 

3 And, you know, we might spend a few moments. 

4 I mean, in a way we have been sort of making

5 the assignments is that Holly sort of does

6 what seems logical and appropriate. And I

7 usually say, "Yes, it looks fine." And then

8 we send it out. And every now and then

9 somebody wants to take on one or another --

10 DR. STALLWORTH: Right. Well, I

11 can --

12 CHAIRMAN SAMET: -- charge

13 question, makes a movement. But we can do

14 that. We can go to the charge questions that

15 we have now and see if the people want to take

16 on any particular --

17 DR. STALLWORTH: It would be great

18 if people want to volunteer for --

19 CHAIRMAN SAMET: -- volunteer for

20 --

21 DR. STALLWORTH: It makes my life

22 easier.

Page 133

1 CHAIRMAN SAMET: So if we actually

2 pull up yesterday's -- and, you know, I think

3 we'll have some challenge in discussing these

4 by phone simply because of the scope of the

5 document and the difficulty of the concepts we

6 are going to cover. 

7 So, just to go through real quick,

8 there was this first set of over-arching

9 questions that related to things like

10 organizational structure and technical

11 content. This is probably one no one

12 particularly wants to volunteer for.

13 DR. BRAIN: I'll volunteer for

14 one.

15 DR. STALLWORTH: Are you going to

16 write notes?

17 CHAIRMAN SAMET: Yes, I'll make

18 notes. Okay. So, Joe, maybe if you took on

19 these two? I think they go together in any

20 case.

21 And we'll put you down as leader

22 on organizational structure and technical
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Page 134

1 content. And we'll give you Sverre.

2 DR. BRAIN: Or he can do two and

3 I'll do one or we can work together.

4 DR. VEDAL: I've got some meatier

5 things here, guys.

6 CHAIRMAN SAMET: Okay. We'll

7 figure it out. If Joe takes the lead on those

8 two, then it would be okay.

9 Then the next batch relates to the

10 primary standard for fine particles. And

11 there is one on approach and this referring to

12 how information is used in addressing the

13 development of the standards and use of the

14 epidemiological information.

15 It kind of sounds like you,

16 Sverre. Was this --

17 DR. VEDAL: I didn't X it, but

18 I'll do it.

19 CHAIRMAN SAMET: So you'd be

20 three. And then the next is four, adequacy of

21 the current suite of standards. So we're

22 going to essentially go through the whole

Page 135

1 thing.

2 We have a lot. I mean, there is

3 going to be a lot of work to do because we

4 have fine particle, coarse particle, and then

5 invisibility, and welfare. So it's a lot to

6 cover.

7 DR. LIPPMANN: There are plenty of

8 questions, --

9 CHAIRMAN SAMET: Yes.

10 DR. LIPPMANN: -- which is more

11 than the number of members.

12 CHAIRMAN SAMET: Right. No. Some

13 people are going to have to repeat. And I

14 think it makes sense to --

15 DR. LIPPMANN: No. Maybe the

16 approach if it's in both, one person can

17 handle the approach on both.

18 CHAIRMAN SAMET: Although I will

19 say they are quite distinct in the approaches

20 given the different amount of evidence

21 available.

22 DR. STALLWORTH: Karen had a

Page 136

1 comment.

2 CHAIRMAN SAMET: Karen, go ahead.

3 DR. MARTIN: I just had a point of

4 clarification that these questions are by

5 chapter.

6 CHAIRMAN SAMET: Yes.

7 DR. MARTIN: So question 3 is

8 about the approach we use for looking at the

9 fine particle --

10 CHAIRMAN SAMET: Right. Which is

11 different, right.

12 DR. MARTIN: And question 4 is

13 only about adequacy of the fine particle

14 primary standards.

15 CHAIRMAN SAMET: Right.

16 DR. MARTIN: Those questions will

17 come up again in the other chapters. So these

18 aren't all-encompassing questions.

19 CHAIRMAN SAMET: Right.

20 DR. MARTIN: Okay.

21 CHAIRMAN SAMET: Thanks. So I

22 think the approach here, that's where we -- I

Page 137

1 think that would work. Okay. And then

2 there's this adequacy of the current suite of

3 standards.

4 DR. SPEIZER: I'm willing, but I

5 also would like to be on the coarse particles

6 as well.

7 CHAIRMAN SAMET: You can have two.

8 DR. SPEIZER: Okay.

9 CHAIRMAN SAMET: Okay. So Frank. 

10 Then the --

11 DR. CASCIO: I'll work with Frank

12 on that one as well.

13 CHAIRMAN SAMET: Okay.

14 DR. STALLWORTH: On number 4? 

15 Okay.

16 DR. CASCIO: Also on coarse

17 particles as well.

18 CHAIRMAN SAMET: Okay. And then

19 indicator?

20 DR. LIPPMANN: I'll volunteer for

21 that.

22 DR. PHALEN: Yes. I'll volunteer
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1 with Mort also.

2 CHAIRMAN SAMET: Okay.**DR. PHALEN: 

3 Thanks.

4 CHAIRMAN SAMET: Okay. And do you

5 potentially want to take what comes with

6 indicator, or the averaging time in the form,

7 or, Helen, do you want to do the form?

8 DR. SUH: Yes, that's fine.

9 CHAIRMAN SAMET: Ted? Okay.

10 DR. STALLWORTH: So we're putting

11 Mort and Bob on --

12 CHAIRMAN SAMET: Would you take

13 the averaging time, too, Mort? Would you take

14 the averaging time, too, for --

15 DR. LIPPMANN: Okay. And I'm on

16 5, not as confident on 6.

17 DR. STALLWORTH: That's okay.

18 CHAIRMAN SAMET: That's okay. All

19 right. And then 8 is levels.

20 PARTICIPANT: Have I got forms?

21 CHAIRMAN SAMET: Helen is going to

22 do forms.

Page 139

1 PARTICIPANT: Okay.

2 CHAIRMAN SAMET: And then 8 is

3 levels.

4 DR. HENDERSON: I have a conflict

5 and can't be on the call, but I would be glad

6 to help anybody writing up.

7 CHAIRMAN SAMET: So we probably

8 should have somebody. So we put you by it,

9 but I think we probably should have somebody

10 who will be on the call.

11 DR. SUH: Well, do you want me to

12 do it? And then I can work with Rogene, then.

13 CHAIRMAN SAMET: Okay. That's

14 fine. Thanks. So we've got Helen and Rogene

15 for that.

16 DR. STALLWORTH: And, Helen,

17 you're also taking number 7?

18 CHAIRMAN SAMET: Yes, she's taking

19 form.

20 DR. STALLWORTH: All right.

21 CHAIRMAN SAMET: Okay. And then

22 primary standard for thoracic coarse. Let's

Page 140

1 see, Wayne, you were -- is that Wayne and

2 Frank? Okay. Let's see. This is Frank and

3 Wayne.

4 Indicator?

5 DR. LIPPMANN: I'm doing indicator

6 on the fine. I'll be happy to do it on the

7 coarse, too.

8 CHAIRMAN SAMET: Okay.

9 DR. VEDAL: It's more challenging,

10 Mort.

11 CHAIRMAN SAMET: Ted, should you

12 be on indicator for coarse?

13 DR. RUSSELL: I could be.

14 CHAIRMAN SAMET: You could be?

15 DR. RUSSELL: Should and could

16 are two different words.

17 CHAIRMAN SAMET: Do you want to

18 be?

19 DR. RUSSELL: That's fine.

20 CHAIRMAN SAMET: Okay.

21 DR. HENDERSON: It's much more

22 complicated.

Page 141

1 CHAIRMAN SAMET: I think you would

2 be helpful on that one. So we have averaging

3 time, form, and levels. All right. Well, the

4 averaging time is probably a relatively

5 straightforward discussion. Can I just put

6 that on, add that on, for you? I'll put you

7 and Ted.

8 DR. SPEIZER: I guess because I

9 can read the whole thing, I'll probably make

10 comments on the whole thing.

11 CHAIRMAN SAMET: Was that

12 volunteering for something?

13 DR. SPEIZER: It's volunteering,

14 but I don't know for what.

15 CHAIRMAN SAMET: For which one,

16 Frank?

17 DR. SPEIZER: For all the factors

18 in the coarse.

19 CHAIRMAN SAMET: On the coarse. 

20 Oh, okay. Okay. So maybe --

21 DR. STALLWORTH: Which number is

22 that, Frank?
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1 DR. SPEIZER: Well, it's --

2 CHAIRMAN SAMET: Well, you're

3 talking about 10, 11, 12, and 13.

4 DR. SPEIZER: Yes, 10 to 13.

5 DR. STALLWORTH: Okay.

6 CHAIRMAN SAMET: So do you want to

7 take the lead on the level, Frank?

8 DR. SPEIZER: If you'd like.

9 CHAIRMAN SAMET: Okay.

10 MR. AVOL: So, Jon, we're coming

11 to the end of the health part, and I've not

12 been assigned anything.

13 CHAIRMAN SAMET: Oh, I've missed

14 you. You've been too quiet.

15 MR. AVOL: I've worked with Rogene

16 and Helen on the -- and I'll get in on the --

17 CHAIRMAN SAMET: No. We're going

18 to go back and fill in so I haven't -- we

19 haven't assigned 12. That's the form. So,

20 Ed, why don't you take the lead on it since

21 you're --

22 MR. AVOL: Form on coarse?

Page 143

1 CHAIRMAN SAMET: Yes, form on

2 coarse.

3 MR. AVOL: Okay.

4 DR. LIPPMANN: Jon, on health,

5 before we move on to visibility, I had sent a

6 brief paragraph to Holly overnight about a

7 charge question which isn't there and should

8 be. It's only a paragraph. Why don't I read

9 it?

10 CHAIRMAN SAMET: Okay.

11 DR. LIPPMANN: "The policy

12 implications of reliance on the core CR

13 functions or annual mortality associated with

14 long-term PM 2.5 exposures in the face of the

15 core CRB well below the lower end of the

16 alternative risk mile specifications needs to

17 be discussed within this VA document,

18 especially in terms of the magnitude of the

19 most likely mortality in it.

20 "It is not sufficient to say, as

21 on page 2-48, that 'These considerations

22 increase our overall confidence that we did

Page 144

1 not overstate risk with the core risk

2 estimates.'

3 "There should be a discussion of

4 the policy implications of underestimating the

5 true risks and a charge to the CASAC PM panel

6 to discuss this issue at its next meeting. It

7 will certainly be an important consideration

8 when margin of safety is considered."

9 DR. VEDAL: So let me ask this. 

10 So this has to do with coarse and the

11 long-term?

12 DR. LIPPMANN: It's strictly fine

13 --

14 DR. VEDAL: I misunderstood.

15 DR. LIPPMANN: -- related to the

16 annual CR for fine being at the low end by a

17 factor of about three of the alternative

18 models which were judged to be scientifically

19 credible, including University of Washington.

20 So there are policy implications

21 in the estimate of the risks when relying on

22 a CR, the extreme low end.

Page 145

1 CHAIRMAN SAMET: Okay.

2 DR. VEDAL: I mean, this was grist

3 for the mill for our risk assessment

4 discussion.

5 CHAIRMAN SAMET: Yes.

6 DR. LIPPMANN: Well, but its

7 character will be carried over from the risk

8 assessment as the base core model. And what

9 are the policy implications of that?

10 DR. VEDAL: Well, I mean, there

11 are a lot of reasons. Well, there is no point

12 discussing it now. But no sensitivity

13 analysis and those other cohorts that even

14 come close to those that were done in ACS.

15 DR. LIPPMANN: That doesn't mean

16 that they are necessarily far along.

17 DR. VEDAL: No.

18 DR. LIPPMANN: No. I think due

19 attention and respect needs to be shown for

20 that. But I think there are policy

21 implications which need to be discussed. We

22 need to be charged with discussing the policy
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1 implications.

2 CHAIRMAN SAMET: Well, in

3 addition, I would just note that I think we

4 are free to, as we have always done, make

5 comments that extend beyond the charge

6 questions.

7 So I think we can either keep

8 this, your note, with us and flag it for

9 discussion on April 8th or we can forward it

10 and have it incorporated into --

11 DR. STALLWORTH: Into the RA? 

12 Into the --

13 CHAIRMAN SAMET: Well, I mean, I

14 think we can --

15 DR. STALLWORTH: Into the PA?

16 CHAIRMAN SAMET: Yes, PA. Yes.

17 DR. STALLWORTH: Okay.

18 DR. LIPPMANN: Well, Holly has my

19 next --

20 CHAIRMAN SAMET: Okay.

21 DR. LIPPMANN: If you want to use

22 it, it's available to you.

Page 147

1 CHAIRMAN SAMET: Let me look at

2 it. And I'll --

3 DR. STALLWORTH: Okay.

4 CHAIRMAN SAMET: And we have a

5 note from Tom. He would like to be with

6 question 1 and then 14-17, which we're getting

7 to now, of course, the visibility.

8 So I think we covered the

9 health-related questions. So then we are on

10 to the visibility, where we have adequacy

11 indicator averaging times and levels and form.

12 And we're missing a lot of our

13 team.

14 DR. ASHBAUGH: Jon, before we go

15 on, I just noticed that chapter 4 has only an

16 odd number of pages.

17 CHAIRMAN SAMET: Okay.

18 DR. ASHBAUGH: It's double-sided

19 and then copied single-sided and double-sided,

20 but all of the even-numbered pages are missing

21 throughout chapter 4.

22 DR. STALLWORTH: Of?

Page 148

1 DR. ASHBAUGH: Of the PA.

2 CHAIRMAN SAMET: Of the PA?

3 DR. ASHBAUGH: At least in my

4 copy. I just have odd-numbered pages.

5 DR. BRAIN: And my copy as well. 

6 It's double-sided, but, again, it's missing

7 even pages.

8 DR. ASHBAUGH: Yes. It looks like

9 the other chapters are okay, but chapter 4 is

10 missing --

11 DR. SUH: My chapter 4 is okay.

12 PARTICIPANT: Yes. Mine is okay.

13 DR. ASHBAUGH: I was trying to

14 look at some of it, but I was missing a page.

15 CHAIRMAN SAMET: Okay. So,

16 anyway, we're going to get a new chapter 4.

17 DR. ASHBAUGH: With that, I will

18 take --

19 CHAIRMAN SAMET: Well, what is the

20 amongst the visibility -- so do you want to

21 take on 14? And 15. So this is the

22 indicator. So this is a major discussion, of

Page 149

1 course.

2 DR. GRANTZ: I think Rich should

3 do that.

4 CHAIRMAN SAMET: So you're

5 suggesting Rich?

6 DR. GRANTZ: Yes.

7 CHAIRMAN SAMET: This is what

8 happens when you leave.

9 DR. GRANTZ: I'll help him, but --

10 PARTICIPANT: Well, I'll be happy

11 to help him, too.

12 CHAIRMAN SAMET: Okay. And

13 averaging time? This goes with it, doesn't

14 it?

15 DR. GRANTZ: It does. Rich isn't

16 here.

17 CHAIRMAN SAMET: All right. So

18 Rich. So this is the lead person. All right. 

19 Levels and form. Let's give Rich a break.

20 DR. RUSSELL: Actually, is Bill

21 going to be back for our meetings, too? He

22 may be.
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1 DR. STALLWORTH: He will be back

2 in time for the April 8th discussion, yes.

3 DR. RUSSELL: You may want to --

4 CHAIRMAN SAMET: Who did we want

5 to save him for?

6 DR. RUSSELL: He may want to take

7 some of this as well.

8 DR. STALLWORTH: Which one? Which

9 one would you give to Bill? I'm sorry?

10 MR. AVOL: Let's give Bill 17. He

11 could easily do 15 as well.

12 DR. RUSSELL: Yes. That's what I

13 was thinking.

14 CHAIRMAN SAMET: And then we have

15 other welfare-related effects. So we have

16 climate.

17 DR. GRANTZ: I think I could

18 probably take 19 and 20. Climate I'm not --

19 CHAIRMAN SAMET: Okay. That's

20 probably right. Thanks. Do you want to do

21 climate?

22 DR. FREY: Sure.

Page 151

1 CHAIRMAN SAMET: Chris will do

2 climate.

3 DR. STALLWORTH: So this means in

4 your revision, you've got to stick to the same

5 structure.

6 CHAIRMAN SAMET: And Ted? So I

7 put both of you.

8 DR. RUSSELL: And Phil also makes

9 sense on -- Phil also makes --

10 CHAIRMAN SAMET: Actually, Phil we

11 should have had -- we have not gotten him into

12 some of the --

13 DR. RUSSELL: Yes. He hasn't

14 gotten anything.

15 CHAIRMAN SAMET: -- PM issues. 

16 This is a good tactic. You leave, and then

17 you are forgotten.

18 DR. RUSSELL: Usually it works the

19 other way.

20 CHAIRMAN SAMET: I know. I know. 

21 So, actually, let's go back and think about --

22 well, would he be good for the indicator on

Page 152

1 visibility discussion?

2 DR. STALLWORTH: Which one is

3 that?

4 CHAIRMAN SAMET: Fifteen.

5 DR. ASHBAUGH: I think we can

6 split 15 and 16.

7 DR. STALLWORTH: Okay. Right now

8 I have them together with Poirot, Grantz, and

9 Ashbaugh. Should we split off? What was it,

10 15, Hopke and Malm?

11 DR. ASHBAUGH: Sure.

12 DR. STALLWORTH: Yes?

13 DR. ASHBAUGH: Yes.

14 DR. STALLWORTH: Okay.

15 CHAIRMAN SAMET: Yes. And we'll

16 get at least two or more discussants under

17 each of these. So we'll do that. I mean, I

18 think the initial will be -- and let's talk a

19 little bit about process.

20 DR. RUSSELL: Actually, I think

21 Phil makes sense pretty much on all of the

22 indicator ones. It might be useful to have

Page 153

1 one person --

2 CHAIRMAN SAMET: It goes across

3 all of the indicators.

4 DR. VEDAL: Maybe even form.

5 DR. STALLWORTH: So number 10 as

6 well?

7 DR. PHALEN: I was thinking of the

8 health as well.

9 DR. RUSSELL: Yes.

10 DR. STALLWORTH: Number 10 is the

11 indicator question for the risk assessment?

12 DR. ASHBAUGH: There's a separate

13 indicator question.

14 DR. PHALEN: Yes, also was

15 indicator. I think he would be good on 5.

16 DR. STALLWORTH: Okay.

17 DR. PHALEN: Would his comments on

18 the overall organizational structure be

19 helpful? Who is on that now?

20 DR. STALLWORTH: Joe Brain.

21 CHAIRMAN SAMET: Joe, we'll put

22 others on, I mean, for sure. Now, we'll end
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1 up with three or four people on each of these. 

2 It's just really a question of who it will be,

3 make sure we have somebody who is in the lead

4 and wants to be.

5 Frank?

6 DR. SPEIZER: And, Holly, you are

7 going to send around a list?

8 DR. STALLWORTH: Yes.

9 DR. SPEIZER: Can we legally

10 communicate within the subgroups?

11 DR. STALLWORTH: Yes.

12 DR. SPEIZER: And that seems to me

13 what we should do because that way we can come

14 up presumably with one presenter at the --

15 DR. STALLWORTH: Yes. That

16 actually works better, Frank. That's what we

17 did for the last meeting.

18 PARTICIPANT: And who was on 17?

19 CHAIRMAN SAMET: Seventeen is

20 Bill.

21 PARTICIPANT: Thank you.

22 CHAIRMAN SAMET: We'll get more. 

Page 155

1 And that actually will be the -- with 20

2 questions, that is a lot of subgroups. So

3 people will end up on multiple subgroups. And

4 just the communications will be a little bit

5 of a --

6 DR. STALLWORTH: Messy.

7 CHAIRMAN SAMET: -- messy. So

8 maybe if you can sort of call yourselves the

9 question 1 subgroup, et cetera, or something

10 so you can keep track of the e-mail flow,

11 which sometimes is challenging? And so if the

12 designated leaders could take charge of this?

13 The call -- let's see. We will

14 have public comment.

15 DR. STALLWORTH: Probably.

16 CHAIRMAN SAMET: We will probably

17 have public commenters. When we have our

18 call, are you planning on making any more

19 remarks?

20 DR. MARTIN: I think we might want

21 to make some short remarks.

22 CHAIRMAN SAMET: I'm just trying

Page 156

1 to think about the time. Okay. We will have

2 to see how many public commenters we have. If

3 we set aside a half-hour and reduce the time

4 to three minutes, that would be -- it is still

5 going to take us probably 30 or 40 minutes to

6 get started with getting to a point where we

7 move to Committee discussions, which means if

8 we have 20 items, I mean, even if we take 10

9 minutes each, it's a lot of time. And some of

10 these, of course, need substantial discussion.

11 DR. STALLWORTH: And we're asking

12 for preliminary written comments.

13 CHAIRMAN SAMET: So I think if we

14 have preliminary written comments, we have to

15 see how this does. I mean, we will have to

16 keep track of time. But if we went on for 15

17 minutes each and we're heading up towards --

18 it's a lot of time.

19 So it is likely that we will need

20 both. I can't imagine we won't need both days

21 of time that you should have set aside in your

22 calendars.

Page 157

1 DR. STALLWORTH: Let me suggest

2 with the visibility questions, this is such a

3 small subgroup that everybody can be on 14

4 through 19.

5 CHAIRMAN SAMET: Yes. I agree.

6 DR. STALLWORTH: Okay.

7 DR. HENDERSON: Will we see a copy

8 of what is preliminary before the call coming

9 if you combine every? That should shorten it

10 up.

11 DR. STALLWORTH: Yes. That does

12 help to shorten the discussion.

13 DR. ASHBAUGH: So will you send us

14 some timeline on when we need to get those in

15 to --

16 DR. STALLWORTH: Well, we can

17 discuss it right now. I will send out the

18 assignment. A week from today? Two weeks

19 from today?

20 CHAIRMAN SAMET: To get the

21 comments in?

22 DR. STALLWORTH: Preliminary
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1 written comments to me on --

2 CHAIRMAN SAMET: Oh, I think we

3 should give more time

4 DR. STALLWORTH: We need revised

5 charge questions.

6 CHAIRMAN SAMET: We need revised

7 charge questions. And I think people need a

8 couple of weeks to wade through this.

9 DR. STALLWORTH: Two weeks?

10 CHAIRMAN SAMET: I think if you

11 had, even by the end of the month, Holly,

12 because, remember, our call is April 8th and

13 9th. I think we just need to have this in

14 front of us. So I would say by month's end

15 should be the goal.

16 DR. ASHBAUGH: So the process here

17 is to give comments on something we are not

18 assigned to, just communicate with the lead

19 person on that?

20 CHAIRMAN SAMET: Yes.

21 DR. ASHBAUGH: You know, if I have

22 comments on overall structure and --

Page 159

1 CHAIRMAN SAMET: Sure, sure. Just

2 send them to the lead.

3 DR. ASHBAUGH: Okay.

4 CHAIRMAN SAMET: And you'll get

5 new charge questions revised, a list of who is

6 on what. And we'll fill things out in some

7 logical way so that there are at least three

8 or four people per question.

9 DR. ASHBAUGH: Okay.

10 CHAIRMAN SAMET: Okay?

11 DR. PHALEN: A comment. It seems

12 like it would be helpful if those three or

13 four people would communicate also and work

14 out some of their differences so that we don't

15 have extended --

16 CHAIRMAN SAMET: That was the

17 suggestion, actually.

18 DR. STALLWORTH: That was the

19 idea.

20 CHAIRMAN SAMET: That was the

21 idea, right, the fact that the leader on each

22 would --

Page 160

1 DR. ASHBAUGH: Together in one set

2 of written comments.

3 DR. PHALEN: In advance of the

4 call?

5 DR. ASHBAUGH: Yes.

6 DR. PHALEN: Okay.

7 DR. ASHBAUGH: And then I guess

8 the lead will send them to Holly, and Holly

9 will combine everything.

10 DR. RUSSELL: So at the time of

11 the call, only the leader will present that

12 subcommittee's opinion?

13 CHAIRMAN SAMET: Well, yes,

14 preferably the discussion will be led by the

15 leader. I mean, I think others will feel free

16 to chime in as needed or if they have other

17 view or whatever, but I think I the leader for

18 such streamlining things could do this, --

19 DR. RUSSELL: Yes.

20 CHAIRMAN SAMET: -- I think that

21 would be helpful.

22 DR. SUH: So I'm sorry. You might

Page 161

1 have mentioned this. Are we expected to have

2 a conference call with our group prior? No?

3 CHAIRMAN SAMET: No. E-mail.

4 DR. GRANTZ: That's not precluded,

5 is it, legally? I think that might be useful,

6 actually.

7 CHAIRMAN SAMET: Well, sure, I

8 mean, if you think that would be --

9 DR. GRANTZ: That's okay to do?

10 DR. SUH: Well, one other thing is

11 that it might be useful to have somebody who

12 spans. I don't know if that is useful. I

13 mean, I guess if there is no conference

14 calling, then maybe it doesn't matter.

15 I am wondering if there is some

16 way of -- Phil would be on maybe all of the

17 indicator groups or something like that. I

18 don't know if that's -- I'm not sure. So

19 scratch that comment.

20 CHAIRMAN SAMET: Okay.

21 DR. GRANTZ: Yes. I think we have

22 to be a little careful not to wipe out all
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1 heterogeneity of opinion before we get to the

2 conference.

3 DR. STALLWORTH: That's true.

4 CHAIRMAN SAMET: I can't imagine

5 that happening.

6 DR. GRANTZ: We are drifting in

7 that direction.

8 CHAIRMAN SAMET: Okay. Anything

9 else?

10 DR. STALLWORTH: I can't think of

11 anything. So we should finish the subgroups.

12 CHAIRMAN SAMET: Yes, yes. Sure. 

13 You mean with people?

14 DR. STALLWORTH: I will send out

15 the assignments for the policy assessment

16 charge questions. We will get a revised

17 visibility letter from Rich Poirot.

18 DR. SPEIZER: When will we get the

19 revised charge questions?

20 DR. STALLWORTH: Karen is saying

21 this afternoon she will send it to me.

22 DR. MARTIN: Yes.

Page 163

1 DR. STALLWORTH: So I'll check my

2 e-mail tomorrow or this afternoon and send it

3 out.

4 CHAIRMAN SAMET: Okay. I think we

5 are done. We still have an awful lot of work

6 ahead. And then, Karen, just to remind us, I

7 don't have the timetable right in front. The

8 second complete draft --

9 DR. MARTIN: The second complete

10 draft will be available the end of May for our

11 late June meeting.

12 DR. SPEIZER: Will that be a

13 face-to-face meeting or will that be --

14 CHAIRMAN SAMET: That's a --

15 DR. MARTIN: We always welcome a

16 face-to-face meeting, especially on policy.

17 CHAIRMAN SAMET: I think we'll

18 discuss that. We'll figure that out, Frank. 

19 I mean, it's unfortunate we're not having this

20 next meeting face to face, but we aren't. And

21 it could be that the second meeting, we will

22 look for a way to have that face-to-face.

Page 164

1 DR. STALLWORTH: I mean, depending

2 on the heterogeneity of opinion about the

3 policy assessment. If it's a lot of the

4 discussion that needs to take place, it should

5 be face-to-face.

6 CHAIRMAN SAMET: Okay. Well, I

7 think we are done. I want to thank everybody

8 for the hard work working into the night last

9 night and getting things done.

10 Good trip home. And we'll talk

11 soon, April 8th and 9th. This will be, of

12 course, a no-e-mail/texting conference call,

13 absolutely focused on what you're doing. So

14 we'll be talking then. Thanks.

15 (Whereupon, the foregoing matter

16 was concluded at 10:51 a.m.)

17

18

19

20

21

22
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A

ABC 1:12

ability 80:20,21

able 69:8 81:16

absence 50:17,18

absent 85:21

absolute 98:6

101:10 104:15

absolutely 164:13

acceptable 81:22

accomplished

105:1

account 78:19,22

accurate 25:11

achieve 26:10

acknowledged

74:19 84:12 89:12

ACS 145:14

actual 103:20

add 12:5 16:21

17:22 21:4 33:18

103:8 116:5

121:16 123:7

141:6

added 7:15 28:7

70:10 115:14

adding 29:9 118:16

addition 68:5 78:22

110:17 146:3

additional 12:6

30:8 60:2 70:18

110:9 116:6

additionally 65:21

additions 119:15

address 62:22

118:11 121:3

addressed 41:6

86:4 107:11

126:10

addressing 6:20

134:12

adequacy 46:1

68:10 134:20

136:13 137:2

147:10

adequate 44:2,4,6

76:21 87:1

adequately 73:8

75:11,15

Adjourn 3:24

adjustment 22:5

administrator 4:11

19:20 20:2

advance 160:3

advice 67:1,4 69:20

ADVISORY 1:3

2:19

AECOM 72:8

afraid 62:8 91:11

afternoon 162:21

163:2

AGENCY 1:1

AGENDA 3:1

agree 8:11 11:2

38:5 44:8 49:3

57:17 95:3,4

101:19 157:5

agreement 44:1

130:11

ahead 19:11 113:22

122:1 136:2 163:6

air 1:3 24:8,9,16,19

25:12 30:14,16

72:16 77:7,17

115:19

align 53:7 70:19

alluded 116:12

all-encompassing

136:18

alterative 67:6

alternate 97:5

alternative 17:19

53:20 56:13,18

57:4,15 58:13

63:1,9 64:3,6,10

64:15 65:16 68:11

92:16 117:9

143:16 144:17

alternatives 10:14

53:5,18 62:18

65:1 70:1 96:8

amalgamated

130:17

ambient 77:7

ambiguous 52:7

American 71:17

72:9

amount 135:20

analyses 110:10

117:9 127:4

analysis 21:5 27:3

28:20 34:1 36:16

45:18 47:18 50:9

50:15,20 51:4

52:11 55:2,6,11

55:15 57:11 58:10

58:11,16 59:7

63:1 67:6 69:1,9

80:5 82:21 83:9

92:15,21 93:1

110:11,14 115:22

120:17 123:3,11

123:14,20 124:3

126:12,13 145:13

and/or 11:8,15

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annual 12:22 13:15

13:16,18,22 14:6

14:9 16:11 58:3

61:18 143:13

144:16

anomalous 34:21

answer 41:19 42:21

43:8 79:3 94:13

94:16 102:8 125:8

answered 9:2 123:4

answers 42:4

anticipated 105:1

anybody 5:12 11:5

108:9 139:6

anyway 95:19

103:21 105:6

121:9 129:20

148:16

apparent 102:6

apparently 119:8

appendices 95:21

appendix 7:6 9:21

9:21 10:10 12:9

41:1

apples 118:3,3

application 115:16

applied 90:22

applies 90:10

apply 13:6 15:5

90:22

approach 6:19,20

7:1 8:22 10:17

11:9,16 119:4,5

134:11 135:16,17

136:8,22

approaches 8:7

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appropriate 56:8

64:7 68:1 105:8

122:21 126:4

132:6

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102:9

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146:9 150:2

158:12 164:11

area 32:6,12 87:2

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areas 10:19 25:8

29:4 31:21 32:1,2

32:9 33:2,4 39:21

44:4,6 74:2 75:11

75:16,16 76:14

78:11,12 79:11

113:4,18 131:20

arguing 52:4 53:12

argument 14:16

ARMISTEAD 1:21

array 70:1

Ashbaugh 2:6 3:10

3:14,19 9:3,7,14

11:2 111:22 112:5

112:15 113:19

114:3,5,9,16,21

147:14,18 148:1,3

148:8,13,17 152:5

152:9,11,13

153:12 157:13

158:16,21 159:3,9

160:1,5,7

aside 156:3,21

asked 109:8

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115:14 117:6,10

156:11

assembled 111:2

assess 40:13,15

assessing 65:17

assessment 3:2,5

3:21 5:15,19 6:9

12:15 13:8 15:13

15:19 17:9 41:8

50:21 54:9 56:17

58:10 61:13 63:10

64:8,13,16 65:15

67:15,16 68:2,3,4

68:9 86:4,12 87:8

88:15,22 89:3,6

90:4 107:9 109:8

110:9 113:3,8,15

116:11 122:17

125:1 128:6 131:1

131:12,18 145:3,8

153:11 162:15

164:3

assessments 63:22

assigned 142:12,19

158:18

assignment 157:18

assignments 132:5

162:15

associated 72:18

100:6 143:13

Associates 79:16

assumed 56:5

assuming 105:10

assumptions 47:10

assure 33:19

attaching 4:13

attachment 20:5,7

attempts 30:8

attention 145:19

attributable 55:4

56:3 99:8

available 34:14

121:20 122:22

126:5 135:21

146:22 163:10

average 61:4,18
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averaged 76:12

averages 79:8

averaging 138:6,13

138:14 141:2,4

147:11 149:13

avoid 54:1

avoidable 16:1

45:19 55:16

avoided 15:15 55:5

avoiding 15:18

AVOL 2:7 7:22

24:20 25:1 27:6

38:8,15 39:11,16

39:19 40:4 95:8

142:10,15,22

143:3 150:10

awful 163:5

awfully 15:15

a.m 1:14 4:2

108:17,18 164:16

B

B 9:21,21 10:11

20:17 28:3,5,6

85:13 87:21 91:9

back 9:12 16:17

28:17 29:20 42:11

46:6 51:19 55:1

62:19 63:20 70:16

85:4,9 93:15

97:19 100:17

101:21 102:13

108:13 114:17

142:18 149:21

150:1 151:21

background 21:20

78:3

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balance 16:11

Baltimore 38:7

bars 83:16

base 58:15 122:17

145:8

based 10:18 35:16

35:18 56:21 78:10

79:22 101:2

122:19 125:2

128:12

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basically 26:9

94:18 96:18

basing 122:15

basis 12:17,20

13:10 15:7 20:22

52:3,19,20 55:10

66:15 68:4 79:18

83:3,4 122:22

126:5

batch 134:9

beginning 31:21

66:4 86:7

behalf 72:9 79:17

believe 54:12 64:5

67:22 86:2 92:19

125:22

believes 126:5

beneficial 116:8

benefit 100:4

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35:11 37:13

best 6:5 35:7 36:5

Beth 3:23

better 6:22 7:11

9:15 77:15 78:1

84:15 98:14 100:1

100:2 107:15

111:11 118:12

154:16

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big 7:19 60:11

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Bill 9:9 149:20

150:9,10 154:20

bit 14:22 24:2,15

27:10 44:3,9

152:19 155:4

blandly 109:5

blue 83:16

BOARD 2:19

Bob 138:11

Bob's 16:13

body 4:12

boilerplate 20:12

borne 121:12

bottom 48:18

bound 81:2 99:18

boundaries 55:11

box 69:2,2,2

bracket 26:21,22

bracketed 27:7

Brain 1:19 10:1

21:4,7 23:8,12,17

28:9 29:2 31:12

44:18 47:5,10,22

48:11,15 49:3,6

50:16 77:12,14,19

77:21 89:11,16

102:18 133:13

134:2 148:5

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brief 4:13 86:11

143:6

briefly 62:16

bring 72:16 84:9

95:17 128:15

bringing 94:22

brings 110:18

broader 30:9

brought 12:10

75:18 78:7 93:1,3

93:6 103:18,19

budget 120:17

bugs 44:2

bullet 8:5 12:2,12

20:15,16 51:19

58:8 62:20

bullets 8:5 16:21

20:11 47:16

107:21

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burden 15:14,18,20

15:22 45:18 55:3

55:4,16

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C

C 85:13

calculating 61:18

117:15,16

calendars 156:22

call 4:8 59:6 92:9

129:4 139:5,10

155:8,13,18 157:8

158:12 160:4,11

161:2 164:12

called 42:17 92:12

calling 161:14

candidate 79:20

80:2

captured 8:1 86:2

captures 12:7

carbonaceous

73:17 74:6

care 77:16 127:16

careful 39:12

161:22

carefully 125:19

Carolina 1:13

carried 145:7

CASAC 1:15 10:13

110:9,16 144:5

CASAC's 18:15

CASCIO 2:8

137:11,16

case 24:2 32:11

38:16 65:20 77:6

99:9 122:14

133:20

cases 119:9

causal 88:4 89:22

90:1,2,2

cause 95:18

caution 119:12

CBD 103:5

central 121:10

125:12

certain 48:9 56:10

101:12

certainly 8:3 87:7

99:6,14 124:9

144:7

cetera 78:5 100:21

122:9 155:9

Chair 1:14,18

CHAIRMAN 4:3

5:11,16 6:7 8:2

10:4,8,12 11:7,13

11:19 12:1 13:20

14:4,12 15:2,21

16:4,8,19 17:3,17

17:21 18:9,16

19:5,8,12,16,21

20:3,6,10 21:2,6,9

21:14,22 22:5,15

22:21 23:21 24:6

24:12 25:18 26:13

27:2,5,8,17,21

28:16 29:6,16

30:16,19 31:4,16

32:4,7,18 33:3,12

35:6 36:6,10,14

37:4,8,12,15,19

37:21 38:3,10

39:1,8,14,17,22

40:5,8,15,20 41:9

42:19 43:1,6,10

43:13,17,21 44:15

44:20 45:5,16

46:5,11,15 47:3,8

47:13 50:2,7,11

50:19 51:2,7,12

51:18 52:12,16

53:11 54:22 56:19

57:3,9,21 58:6

59:10,14,16,20

62:19 65:4 66:2,5

66:8,19,22 67:3

68:15,20 69:5

70:15 71:9,13

72:2 77:10,13

79:13 84:19,22

87:6,17 88:11,21

89:4,14,18 90:12

90:17 91:8 92:2

92:11 93:5,18,22

94:10,20 98:19

100:15 101:8,21

102:7,16,20 103:5

103:12 104:2,6

106:8,13,16,19
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107:3,5,10,18

108:1,12,19

109:16 111:3,8,15

115:1,4 116:17,21

117:2 119:14,17

120:1,6,10 122:3

122:13 123:6,9,17

124:8,11,15

125:16 126:22

127:19 128:7,14

128:19 129:2,10

129:13,18 130:1

130:19 131:2,6,17

132:2,12,19 133:1

133:17 134:6,19

135:9,12,18 136:2

136:6,10,15,19,21

137:7,9,13,18

138:2,4,9,12,18

138:21 139:2,7,13

139:18,21 140:8

140:11,14,17,20

141:1,11,15,19

142:2,6,9,13,17

143:1,10 145:1,5

146:2,13,16,20

147:1,4,17 148:2

148:15,19 149:4,7

149:12,17 150:4

150:14,19 151:1,6

151:10,15,20

152:4,15 153:2,21

154:19,22 155:7

155:16,22 156:13

157:5,20 158:2,6

158:10,20 159:1,4

159:10,16,20

160:13,20 161:3,7

161:20 162:4,8,12

163:4,14,17 164:6

challenge 88:12

133:3

challenging 140:9

155:11

chance 71:7 85:11

102:18

change 36:8 39:9

42:13 95:15 99:14

101:14

changed 5:9

changes 112:6

chapter 7:4,11 12:2

12:8,11 16:15

28:17 29:14,19,20

30:2,2,3 34:1

38:11,13,16,17,19

39:4 40:22 41:3,3

41:13,14 46:22

47:5 48:10 86:12

93:1,10,16 94:19

94:21 95:10,10

102:8,9,12 106:17

108:4 109:19

110:3,17,20,21

136:5 147:15,21

148:9,11,16

chapters 3:3 5:15

30:6 39:2 136:17

148:9

character 145:7

characterize 70:6

73:8 74:12

characterized

72:17 73:4

characterizing

64:1 74:15 116:8

charge 3:9,12,15

3:17,20 4:14 6:18

7:20 11:11 12:4

16:17 17:6,9 18:5

18:11,18,21 19:18

21:15 22:15 27:2

27:22 41:12,13

43:11 93:15

111:17,21 112:9

115:12 117:4

120:9 130:8,14,22

131:19 132:12,14

143:7 144:5 146:5

155:12 158:5,7

159:5 162:16,19

charged 145:22

Charles 79:16

check 163:1

chime 85:19 160:16

choice 36:5 118:18

choices 66:7

choose 52:10 57:1

84:16

chose 33:7

Chris 3:13 22:17

22:18 23:3,22

24:14 25:15 26:18

27:4,5 115:5,6

119:19 120:8,13

127:2,7,12 129:20

151:1

CHRISTOPHER

1:20

circulate 128:20

131:7

cities 14:1 28:11,18

29:15 30:9,10,11

31:8,9,22 33:7,14

33:19 34:4,7,20

34:22 35:16 36:7

41:2,5 48:9 76:8

80:13 81:7,9,10

81:12,19

city 25:6 32:2 34:11

73:2,2 81:22,22

82:2

claim 35:5 39:13,15

claiming 40:3

clarification 136:4

clarified 27:14,19

95:11

clarify 8:11 20:22

40:17 86:5

clarifying 100:9

clarity 10:15

class 78:11,12

CLEAN 1:3

clear 10:21,22 11:3

11:4,5 12:19

28:10 29:5 47:11

52:19 68:16,19,19

69:1 90:14 95:9

98:2 101:4

clearer 28:13

clearly 7:13 8:13

15:7 64:8 69:19

123:11

climate 150:16,18

150:21 151:2

close 26:21 118:22

145:14

closure 128:15

coarse 87:8 88:1

90:7,18,22 119:9

135:4 137:5,16

139:22 140:7,12

141:18,19 142:22

143:2 144:10

coastal 113:18

code 5:9

cohort 52:9 61:6,7

cohorts 145:13

colleagues 63:4

127:22

color 35:20

column 96:4,5,6

combination 127:3

combine 127:13

157:9 160:9

combined 91:19

come 16:16 17:22

22:7 29:20 41:11

54:17 55:9,21

85:4 88:8 106:22

108:13 119:3

122:4 123:10,18

136:17 145:14

154:13

comes 5:7 70:12

80:3,4 120:8

138:5

comfortable 62:1

70:9 72:4 119:18

coming 17:18 70:9

142:10 157:8

commendable 87:1

comment 3:8 12:6

16:13 22:3 26:14

30:1,3 41:15 58:2

58:18 72:6 104:5

109:18 112:13

116:6 123:12,12

136:1 155:14

159:11 161:19

commented 117:21

commenter 79:14

commenters 4:7

85:1 155:17 156:2

comments 4:6,12

4:14,15 17:10

20:19 23:4,9,15

24:14 25:17 39:20

42:12 43:3,20

56:22 70:22 71:5

71:14 72:5,12

76:16 79:18 85:6

89:20 93:17 108:4

112:4,16,18,21

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pleased 46:8,10,16

plenty 135:7

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plots 29:9 117:21

plume 78:4

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PM 45:17 87:8 88:4

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PM10-2.5 87:8

PM2.5 72:19 75:20

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points 4:20 6:15,16

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policy-relevant

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politics 106:22

pollutant 78:1

pollution 30:15,16

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poor 105:17

popped 42:12

population 31:10

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populations 31:13

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positive 96:16 97:6

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possibilities 53:9

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post 129:7

post-meeting 5:4

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prefer 82:3

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priors 65:5,8

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procedures 21:8

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reached 90:1

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ready 6:14 8:4

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really 12:4 14:15

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resulting 73:19

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Samet 1:14,18 4:3

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Sandiford 3:6

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80:16 81:21 83:1

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simple 94:13

simply 87:10 133:4

simulate 64:16,18

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117:14 118:4

single-sided 147:19

sir 16:8

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sitting 63:14 130:5

slide 82:8

smacks 60:8

small 39:9 41:1

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smooth 127:18

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socioeconomic 22:3

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somebody 132:9

139:8,9 154:3

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55:20 58:22 61:13

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spend 132:3

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stage 101:5

STALLWORTH

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8:05 4:2

9

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Neal R. Gross & Co., Inc.

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