Fw: SOx/NOx NAAQS: would you send a copy of ISA ?--for the docket

Jan King to: Sherry Russell 07/12/2011 09:14 AM

Jan King

Regulatory Development and Policy Analysis Group

phone: (919) 541-5665

fax: (919) 541-2664

Mailcode: C404-05

----- Forwarded by Jan King/RTP/USEPA/US on 07/12/2011 09:09 AM -----

From: Lydia Wegman/RTP/USEPA/US

To: Jan King/RTP/USEPA/US@EPA

Date: 07/11/2011 02:52 PM

Subject: Fw: SOx/NOx NAAQS: would you send a copy of ISA?--for the docket

----- Forwarded by Lydia Wegman/RTP/USEPA/US on 07/11/2011 02:52 PM -----

From: Rich Scheffe/RTP/USEPA/US

To: "Lee, Amanda I." <Amanda_I._Lee@omb.eop.gov>

Cc: Ginger Tennant/RTP/USEPA/US@EPA, "Laity, Jim" <James_A._Laity@omb.eop.gov>, Karen 

Martin/RTP/USEPA/US@EPA, Lydia Wegman/RTP/USEPA/US@EPA, Mary 

Ross/RTP/USEPA/US@EPA, Randy Waite/RTP/USEPA/US@EPA, Tara 

Greaver/RTP/USEPA/US@EPA

Date: 07/11/2011 02:03 PM

Subject: RE: SOx/NOx NAAQS: would you send a copy of ISA?

Amanda,

You hit on some semantics that are in play. In some ways the framework is an overall model; but in 

includes multiple models and other components. It's probably best to consider the AAI equation as the 

result of an overarching framework that links ecosystem and atmospheric modeling together, maintaining 

scientific integrity, but applicable to regulatory application. In a sense, the terms "framework" and 

"model" are interchangeable. However, a specific ecosystem model and atmospheric model are used to 

calculate F1, and a specific atmospheric model is used to calculate F2, F3 and F4. A combination of 

models is a model, and it also can be referred to as a framework.

On linearity - clearly the AAI expression appears linear; however, there are several nonlinearities 

imbedded in the individual terms. So, it is not incorrect to call the framework linear, but the terms linear 

and nonlinear are better thought of as relating to specific models, and perhaps even limited to describing 

the relationship of a single dependent variable on one independent variable.

Again, it boils down to semantics. Hope this useful.

Rich

. Richard Scheffe

(919) 541-4650

(919) 541-4511 (Fax)

scheffe.rich@epa.gov

"Lee, Amanda I." Rich, thanks for sending the link. You're right. I... 07/11/2011 10:12:27 AM
From: "Lee, Amanda I." <Amanda_I._Lee@omb.eop.gov>

To: Rich Scheffe/RTP/USEPA/US@EPA, Lydia Wegman/RTP/USEPA/US@EPA

Cc: "Laity, Jim" <James_A._Laity@omb.eop.gov>, Randy Waite/RTP/USEPA/US@EPA, Mary 

Ross/RTP/USEPA/US@EPA, Tara Greaver/RTP/USEPA/US@EPA, Karen 

Martin/RTP/USEPA/US@EPA, Ginger Tennant/RTP/USEPA/US@EPA

Date: 07/11/2011 10:12 AM

Subject: RE: SOx/NOx NAAQS: would you send a copy of ISA?

Rich, thanks for sending the link.  You’re right.  I could not find the answer, and I think you nailed the

issue at hand (what is framework vs. what is modeling).

I’m confused about what is considered “framework” vs what is considered “modeling” in the AAI

equation given on p. 13 of the briefing:  AAI=F1‐F2‐F3(NOy)‐F4(SOx).

Are the parameters to be estimated (F1, F2, F3, F4) and the linearity of the equation considered

“framework” or “model?”

Thank you very much for your help!

All the best,

Amanda

From: Rich Scheffe [mailto:Scheffe.Rich@epamail.epa.gov] 

Sent: Friday, July 08, 2011 7:22 PM

To: Lydia Wegman

Cc: Lee, Amanda I.; Laity, Jim; Randy Waite; Mary Ross; greaver.tara@epa.gov; Karen Martin; 

tennant.ginger@epa.gov

Subject: Re: SOx/NOx NAAQS: would you send a copy of ISA?

Amanda,

use this link (below) to download the ISA. You will not easily find an answer to your 

question. I gave the briefing. The framework is not uncertain. There are relatively higher 

uncertainties with regard to data (and modeling) that is used to apply the framework.

Rich

http://epa.gov/ncea/isa/soxnox.htm

Richard Scheffe

(919) 541-4650

(919) 541-4511 (Fax)

scheffe.rich@epa.gov

-----Lydia Wegman/RTP/USEPA/US wrote: -----

To: "Lee, Amanda I." <Amanda_I._Lee@omb.eop.gov>

From: Lydia Wegman/RTP/USEPA/US

Date: 07/08/2011 07:09PM

cc: "James_A ._Laity" <James_A._Laity@omb.eop.gov>, "Randy Waite" 

<waite.randy@epa.gov>, "Rich Scheffe" <Scheffe.Rich@epamail.epa.gov>, "Mary Ross" 
<ross.mary@epa.gov>, greaver.tara@epa.gov, "Karen Martin" <martin.karen@epa.gov>,

tennant.ginger@epa.gov

Subject: Re: SOx/NOx NAAQS: would you send a copy of ISA?

I don't have a copy of the ISA Amanda at the ready but I'm forwarding your message to a 

couple of folks via this response. The other possibility is to go to EPA's website, then to 

ORD, then to NCEA, which produced the document. We often also use Google to find EPA 

documents--whatever works. Hopefully someone can point you to where to find it if these 

approaches don't work. 

 From: "Lee, Amanda I." [Amanda_I._Lee@omb.eop.gov]

 Sent: 07/08/2011 06:44 PM AST

 To: Lydia Wegman

 Cc: "Laity, Jim" <James_A._Laity@omb.eop.gov>

 Subject: SOx/NOx NAAQS: would you send a copy of ISA?

Hi Lydia,

I’m confused about a sentence in the preamble about the structure of the multi-pollutant 

standard. Your very helpful briefing on the rule seem to suggest that while the concept of 

multi-pollutant standard is sound, the current framework is uncertain. I’m hoping that the 2008 

ISA would clarify my confusion. Would you mind sending a copy of the ISA? Better yet, if it is 

publicly available, would you send a link?

Thanks and have a good weekend.

Amanda