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U . S . ENVIRONMENTAL PROTECTION AGENCY SCIENCE ADVISORY BOARD STAFF OFFICE CLEAN AIR SCIENTIFIC ADVISORY COMMITTEE (CASAC ) PARTICULATE MATTER REVIEW PANEL PUBLIC MEETING Marriott at Research Triangle Park 4700 Guardian Drive , Durham, North Carolina

Tuesday, July 27 , 2010 (Volume II ) ATTENDEES : CASAC Members : Dr . Jonathan M . Samet , Chair Dr . Joseph D . Brain Dr . H . Christopher Frey Dr . Armistead ( Ted) Russell Dr . Helen Suh Dr . Kathleen Weathers Consultants : Dr . Lowell Ashbaugh Prof . Ed Avol Dr . Wayne Cascio Dr . Joseph Helble Dr . Rogene Henderson Dr . Philip Hopke Dr . Morton Lippmann Dr . William Malm Mr . Charles Thomas ( Tom) Moore , Jr . Mr . Richard L . Poirot Dr . Frank Speizer ( Telephonically present ) Dr . Sverre Vedal Science Advisory Board Staff : Dr . Holly Stallworth Dr . Vanessa Vu Office of Air Quality and Planning Standards Ms . Lydia Wegman Ms . Vicki Sandiford Dr . Karen Martin Dr . Marc Pitchford Ms . Beth Hassett-Sipple Mr . Tim Hanley Dr . Scott Jenkins Ms . Joann Rice Dr . Pradeep Rajan Mr . Phil Lorang1

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I N D E X Page Proceedings 254

Discussion re : Charge Question No . 11 254 Charge Question No . 12 265 Charge Question No . 13 321 Charge Question No . 14 328

Closing Remarks by : Dr . Samet 347 Dr . Vu 350 Ms . Lydia Wegman 351 Dr . Karen Martin 3521

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P R O C E E D I N G S ( 8 : 30 a . m . )

DR . SAMET : Good morning . It ' s 8 : 30 a . m . , and the schedule says Reconvene Meeting so we ' re going to

move on now to the discussion of the Secondary

-- Secondary Standard . We ' ll see where we are and how much we may be able to get done , just looking at the text that was sent on to Holly overnight .

So let ' s see , Karen , does your team have comments ?

DR . MARTIN : No . We covered the overview yesterday, so we don ' t have anything to add right

now . DR . SAMET : Okay . So with that , then , let ' s go right on to discussion of Charge Question 11 . And, Rich, I guess you ' re in the lead here . COMMENTS ON CHARGE QUESTION NO . 11 :

MR . POIROT : I don ' t have very much to say about the approach . I think it ' s been a consistent approach that the staff has followed from the beginning .

From the first time we saw this Urban

-Focused Visibility Assessment , it seemed like a logical analysis of the relatively few available urban visibility preference studies that led to a1

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reasonable

-appearing selection of a range of levels considered unacceptable across a number of different study areas that didn ' t focus in on any one range , but suggested something , you know, between 20 to 30 deciviews would be a reasonable level to consider to be adverse . And then , using a variety of different methods to estimate particulate matter related to light extinction

-- actually, a fairly highly complex method that could be applied in 11 or 14 case study cities

-- and similar approaches are applied in this version of the Policy Assessment document with a lot of additions that were responsive to questions that

we had raised the last time .

You know, there are an awful lot of combinations of different indicators , levels

-- I guess we haven ' t argued much at all about the averaging time

-- but indicator , levels and forms .

So the information , just to present it and get it out there , is just inherently very complex ; and I think they ' ve done a really excellent job in illustrating what these various different combinations would translate to in terms of standards that would have different apparent levels of stringency across the different study areas . So , overall , I just thought the approach was quite1

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rational and well conceived, logically conceived and clearly illustrated .

I thought in terms of question B : Has staff appropriately applied this approach in reviewing the accuracy of the current standard and potential alternative standards , that ' s kind of a two-part question . I thought the first part is really easy to

answer . I think it seems clear , no matter which way you look at it , that the current standard is not adequate . The averaging time is too long , the level is too high, and it ' s less than directly responsive to the effects of particulate matter on visibility . So to me , that part ' s easy to insert .

In terms of the proposed alternative standards , several are discussed, including the preferable

-- preferable approach of using a direct

measure of light extinction , which would be ideal , but perhaps is currently impractical given the availability of current instrumentation , so on and so forth, on the one hand . And on the other hand, let ' s say the

-- simply using a fine mass indicator averaged over shorter averaging times , and so forth, would be kind of the other extreme .

And then they proposed an intermediate kind of

a combination , really, of those two things in which1

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extinction would be estimated from available continuous fine mass and speciation and relative humidity data . So I guess that ' s the approach . I think it ' s clearly illustrated and the options are reasonably laid out in front of us . I may have some

concerns or some suggestions about alternative ways of estimating extinction from the available data , but I think that will come up later .

So that ' s all I have on the approach, John . DR . SAMET : Thank you , Rich . Bill ? DR . MALM : I guess I could comment . The comments I might have

-- I guess the essential comments that I might have are similar for both 1 1 and the Discussion Charge Question Number 13 , which I ' m lead on , so let me say something

-- let me make the general comments now because they ' re sort of appropriate for 1 1 and 13 .

I guess the biggest concern that I have is that there ' s so many combinations of percentile levels and different metrics and maximum

-- you know, the one-hour maximum every day versus the one-hour maximum across all days . And you know, comparing and contrasting all these different approaches , I mean , I think you made a -- first of all , it ' s just amazing how much work it takes to get all this done and to1

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look at all these possibilities and so forth, so you ' re to be commended on doing that . It ' s a lot of work to get where you are . But I think the next step is to somehow quantify these different comparisons . The different approaches , come up with some way to quantify that so it ' s easily summarized and one can understand the advantages and disadvantages of making

one set of choices over another set of choices .

You ' ve talked about how the 90 th percentile all

-hour approach is similar , I believe , to the 98 th percentile max one hour every day . I think that ' s the combination that you emphasized, yeah . So , and you say that they compare reasonably well . Well , two points . What ' s reasonably well ? You know, everybody has different value judgments when it comes to statements like reasonably well . So somehow you should quantify what reasonably well means , and I think that

-- I think that somehow, maybe

-- somehow graphically showing that . I guess the bottom line is somehow to quantify those comparisons . There are probably other combinations that are reasonably well , too -- compare reasonably well , too ; but you know, so what ? What ' s the consequence of those comparisons ?

And then secondly, what are the implications of these different choices ? The choice of picking1

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the one-hour maximum every day versus the one-hour maximum for all days . You suggest in there some place that in one case they ' re similar , but in one

case you ' ve got two or three hours out of a day picked for the one approach and, obviously, if you only allow one hour per day you don ' t get that for the other . So that has implications , I would think, in the kinds of sources that might be emphasized for control .And I brought this comment up before . I think that would be

-- and you can ' t go back and do all the model runs all over again to explicitly tie this down ; but at least there should be some discussion about the potential implications of these different approaches . I mean , if you have one big episode in a year , I suspect that one big episode is going to be targeted more than it would be if you picked a

one-hour maximum every day . So the sources that might be addressed for

-- or the states might choose to address for meeting the standard could very well be different depending upon what standard you pick . I think having some discussion and, maybe , pointing out , if you can ' t point exactly what those sources might be , you could at least point out the implications of one approach over the other .1

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So within the context of all that , I think that some way of quantifying all these different combinations . And then ultimately, it seems to me , it would be helpful to have some recommendation as to what approach you guys think might be more appropriate because of such

-and

- such and such

-and

-such, and I didn ' t see anything approaching

a recommendation of why one approach might be better

over another approach . There ' s so much information , so much data , it would be hard for anybody to really read through all that stuff and form that conclusion

on their own . I think you have to help the reader along and at least point out why you might want to pick one approach over another and, again , the implications of that .

So I guess to sort of

-- I mean , this discussion is

-- I made similar comments under both this Charge Question 11 and 13 . So that ' s one , the

one issue .

The second issue , I think maybe it needs to be in the research section as opposed to being able to do something in the next go-around, but all these

scenes have something

-- people are responding to similar cues , and it would be helpful to come up with

a visibility

-- extinction , deciview, visual range ,1

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all that stuff isn ' t -- really aren ' t visibility indexes . They ' re another way of characterizing the stuff that ' s in the atmosphere . So if you came up with a -- you did a great job on developing a logit model , and it now allows for an easy and more direct intercomparison of all these different visual air quality

-- the preference studies . You probably also could come up with a visibility index, and there ' s

some numbers in the literature

-- a visibility index that would normal ize all these scenes such that they would all fall in the same curve , that these acceptability curves that are modelled with this logit model would basically lie on top of each other if they were plotted against a true visibility index which characterized the scenic quality or the quality of the landscape features that these folks are looking at .

That index obviously would be a -- have some sort of a nonlinear relationship with extinction and concentration and all this other stuff , but it would help if you could do that . Then you basically would have a metric that could be applied to any scene any place in the country, or probably the world, for that matter . And then you could relate that back to extinction and the kinds of other discussions that1

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you need to have in terms of preserving or getting to

some point where that scene is acceptable .

So you probably can ' t get that done in the next go-around, but you probably ought to include something like that in the

-- in things that need to be done because I think it ' s very do

-able and somebody should give some thought , and maybe I might

even give some thought to it . I think that would be

a big step forward and then a lot of these kinds of discussions that we ' re having would go away .

So I guess that ' s enough for now . Thank you . DR . SAMET : Okay . So your general comment , I

mean , in terms of , sort of , the number 11 , the current approach, which I think Rich took on in a

more constrained sense when he gave his answer , is okay; but I think what you ' re saying is it laid out this huge array that then becomes difficult to find your way through . And I think we ' re going to come back to it as we discuss 12 and 13 .

Lowell ? DR . ASHBAUGH : Yeah . I actually liked the rewrite very much . I thought you did a very good job of it . My primary interest in this was the ten-step process of calculating visibility reduction . It1

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seems to me there ' s going to be an awful lot of

uncertainty in that that hasn ' t been addressed, and in particular , taking the 24

-hour daily scaling fractions , scaling those down to -- averaging them for the months , scaling them down to the day, and then applying them to an hourly measurement based on

a continuous monitor . So it ' s going to wash out so much detail that I ' m not sure you ' re going to actually get what ' s providing viability reduction ; and this isn ' t even to mention the problems with using the hourly measured relative humidity, which we found in the IMPROVE program varies so much that it ' s also a difficult process . So I think I like the concept of this calculation ; but the uncertainties involved in it , I think you need to analyze very carefully before

-- before applying that process .

And I think, too , the direct measurement of light extinction is

-- one advantage that wasn ' t stated in the document is that you get immediate feedback on it . The process of collecting the filters and analyzing them for speciation and doing this other analysis takes a considerable amount of time . The advantage of a direct light extinction measurement is you ' ve got feedback right now . I think that needs to be brought out as well .1

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That ' s the main thing I wanted to bring up on this . DR . BRAIN : Can I ask a naive question? When you ' re directly measuring light extinction , how do you deal with fog , snow, rain? Just educate me .

DR . RUSSELL : Actually, the instrument would be designed such that when the relative humidity is

over 90 percent , you ' re not -- it wouldn ' t be measuring . So that immediately gets rid of the

-- I

mean , that ' s actually one of the considerations we ' ve had before in this group just because of the issues associated with that .

DR . BRAIN : Thank you . DR . SAMET : Okay . Other comments on Charge Question 11 , general approach? Tom?

MR . MOORE : I apologize because I wasn ' t able to participate in the discussions very well in March .

It seems like we really leapt forward here ; and there ' s roughly a page on direct measurement , indicator for optical , and many pages on this speciated mass and composition approach ; and I just wonder whether that ' s in balance considering the comments that Lowell just made about further developing the optical option .

And I want to second Bill ' s approach that1

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-1896 (FAX) 265 essentially there needs to be , kind of , what are you recommending , what are you choosing among the percentiles and the forms and the indicators and why . I mean , it seems like this standard, consideration of the standard, requires some staff direction as opposed to the more low

-key terms like , consideration should be given . I mean , this is really a very complicated set of choices to make and particularly when we get to the discussion of the level of the standard . So I ' d second Bill ' s and like to see a little bit more on the merits of the optical .

DR . SAMET : I wonder if we shouldn ' t go on . We ' re having a somewhat wandering discussion across these different charge questions , go on and take on the nature of the secondary indicator .

Ted? COMMENTS ON CHARGE QUESTION NO . 12 :

DR . RUSSELL : Actually, as I said to Rich , I think we ' re already getting there .

So on question 12 , it ' s the nature of the indicator , and staff has laid out three potential indicators . One , just using PM2 . 5 mass directly . Another one -- and this really came up from discussions of this group probably almost a year ago , I think it was , that we would just

-- that we ' d1

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recommend measuring PM2 . 5 light extinction directly . It ' s now quite possible to do that , and there ' s new instruments coming available . And the third was , as mentioned, that we would have a calculated light extinction using the method that has no shortened acronym or whatever . And so the question is what are the attributes of each one , or in terms of staff ' s considerations , do we think that they ' ve appropriately supported them .

And I would first state that my thoughts on the PM2 . 5 mass indicator for visibility, the only thing that it has going for it is it ' s simple , and given the

-- you know, probably the way to logically think of this is , first , PM2 . 5 mass indicator . Then go to the mass calculated light extinction . And the thing is , is that there ' s enough information out there already that using their mass calculated light extinction formula , that they can do a better job . So I think you can almost remove the thought of using the PM2 . 5 mass indicator without doing something to adjust for speciation .

So then you come to the mass calculated light extinction , and as Lowell has already indicated, there ' s , I think, a number of problems with this , is that it doesn ' t -- there ' s so many biases and1

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uncertainties in the measurements to begin with . Then when you start taking these monthly averages and trying to figure out or apply monthly averages to what would become one-hour averages , it has some real problems associated with it ; in part , is that the time of the greatest visibility degradation is when the relative humidities are high . And it ' s also when the relative humidities are high is when you ' re going to have the more soluble components , the nitrate and

some of the organic carbon , that would also correlate with the water content of the aerosol ; but those are also the components that you lose in some of the filter

-based measurements . So you ' re going to have this real problem there , is that some of the most important

-- more important species are the ones you wouldn ' t be measuring to try to apply in your mass calculated light extinction . So I think there ' s just

a lot of issues with the mass calculated light extinction .

And then when we get to the using directly measured PM2 . 5 light extinction , I think the real pushback there is that people are afraid to use -- you know, that they don ' t want a new instrument , or at least I think that ' s the only

-- only reason I ' ve heard so far that makes any sense . And I would say1

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that the instrument technology is there . I think it ' s going to be one of the better instruments , more stable instruments , to have out there , one of the easiest to use and it ' s going to give us some wonderful new information . It ' s -- and it ' s going to be continuous . I think there ' s just a tremendous number of reasons to use , to deploy these new instruments , plus it is measuring exactly what you want to predict .

So I look at those three and just say of the three different indicators that have been proposed, I think there ' s just so much

-- so many reasons to go for direct measurement , and I think there ' s enough

reasons to go against the other two that I would rule those out . Of course , Rich has another idea on that

one . DR . BRAIN : And the document is not now explicit enough in making your recommendation ; right ? You really want to modify it so it ' s clear?

DR . RUSSELL : I would be more explicit , yes . DR . BRAIN : Thank you . DR . MARTIN : If I could ask a point of clarification here . In your comments that the instrumentation is there now, I think we all remember the AAMM Subcommittee meeting where this was very1

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-1896 (FAX) 269 explicitly discussed . And the conclusions that came from that , from my understanding , were that , while there is developing instrumentation , we ' re talking about some years before it could be sufficiently tested and developed to provide a basis for a standard .

DR . RUSSELL : You ' re talking about the cavity ringdown approaches , which would be better .

DR . HOPKE : Well , which would get you PM10 . The difference is PM10 versus PM2 . 5 . If we want light

--

DR . SAMET : Phil , use your mic . DR . HOPKE : -- PM10 then

-- DR . SAMET : Microphone , Phil , microphone . DR . RUSSELL : Speak to your mic . DR . HOPKE : Okay . If we want light extinction from PM10 then the instrumentation is not here now . If we want light extinction from PM2 . 5 , yes , there are certainly capable instruments that are available on the shelf now .

DR . RUSSELL : And it would be two different instruments right now that we would use in tandem, one doing scattering and one doing absorption .

DR . MARTIN : Okay . DR . HOPKE : Right .1

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DR . RUSSELL : I think that may be what you ' re --

DR . MARTIN : To put a finer point on the point I was trying to make , while you ' ve identified instruments that are available right now, the Agency doesn ' t have established reference methods for

-- that have been evaluated and tested for their use as

a reference method for a standard . It was my understanding that we were projecting that was a multi

-years ' effort in order to do the evaluation work necessary to establish it as an FRM and that that was a primary issue in this draft in terms of coming up with an alternative approach because of that limitation in having an FRM for the purpose of directly measuring light extinction .

DR . SAMET : So I think we should hear from the remaining discussants on this point and then circle back as we need to , to this question .

Joe ? DR . HELBLE : I actually don ' t have much to add to what Ted said based on my reading of the document . I thought it was clear . I thought the three potential indicators that were discussed were the appropriate ones . I thought

-- and maybe Ted didn ' t make this point quite as directly, but I thought1

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staff did a nice job of talking about PM2 . 5 mass as an indicator and then essentially dismissing it , saying here is why it ' s not the ideal choice . So I thought given that the discussion then became one of direct measurement versus measurement based on speciated concentrations , I would

-- without commenting on availability of instrumentation and the time it takes to develop an FRM -- second the point that any time you can make a direct measurement , it ' s preferable . The time issue that Lowell pointed out , meaning you get direct feedback here , is certainly a strong positive ; so I would encourage the Agency to move in that direction .

Having said that , I think there are other

reasons to get better speciated PM2 . 5 data that will

-- came out yesterday in discussing some of the research needs , will come out again later today when

we talk about the research needs . So if this could help develop a more extensive network of speciation monitoring , I think that would be a positive and have ancillary benefits . Still , having said that , I think when the opportunity to make direct measurement is available , I would strongly urge movement in that direction . Otherwise , I simply would echo what Ted said .1

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DR . SAMET : Okay . Tom? Tom, yeah . MR . MOORE : I think it ' s Bill . DR . SAMET : No . MR . MOORE : Okay . DR . SAMET : You ' re welcome to comment or not . MR . MOORE : Oh, I was going to comment , but I didn ' t keep track of this one on my list here .

Well , I would like to come at this from kind of an operational point of view . People have already made the point about timeliness , and I ' m sympathetic to the issues that Karen has raised . I think in practice people are running these instruments already for the direct measurement , and I think that favors that indicator because I think one thing that happens in the speciated mass calculation approach is that you have all these uncertainties and possible different approaches that folks will use and I ' m just wondering whether that , kind of , anticipates the air quality planning needs a little bit ; and perhaps that could be dealt with in that step where we have a simple black

-and

-white measurement of are you over a standard or not and then there ' s a speciated mass approach to derive what you do about it .

So the objective standard would be simple , direct measurement , timely . You wouldn ' t be telling1

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-1896 (FAX) 273 people three months later what happened, which is kind of a less

-than

-optimum situation . And you know, you could save all the speciated analyses for the implementation and do that when you -- for the areas that required that .

I do want to give credit to the idea of this , kind of , integrated assessment that was done because it was nicely written up . It definitely should be laid out in such a way as an option so that the Administrator can consider it ; and I think that also could inform this research agenda issue that Joe started to raise here , too , what do we need to know if this indicator were selected . So just knowing that we ' re over an optical level is nice to know and

so that ' s a protective effort there ; but we ' re going to need a methodology that contributes to the

over-all body of knowledge , say, in five years when the next review is underway .

DR . SAMET : Okay . Bill ? DR . MALM : Question , Karen , is the

-- the method of reconstructed extinction is based on continuous mass measurements . Is there a federal reference method for continuous mass ?

DR . MARTIN : I ' m going to ask our monitoring folks , or if one of you want to speak to it . Phil ?1

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MR . LORANG : Since I ' m here , let me try . Phil Lorang from the EPA .

There is a procedure for qualifying continuous instruments as equivalent and there are a number of models that have been approved as continuous , but the criteria for approval is on their 24

-hour average performance . There ' s no system to ensure that

one-hour values are online

-- or in line with what they might actually be .

DR . MALM : So I guess , I mean , I sort of agree with Phil in the sense that if it ' s possible , I mean , any direct measurement -- there ' s a number of instruments out there and any direct measurement is going to be more accurate than a reconstructed extinction , period . I mean , that ' s a slam dunk . I

mean , I think the reconstructed extinction is adequate for what you want to achieve , but the instrumentation is there right now to make a direct measurement more accurately than you could ever reconstruct it even if you had continuous mass measurements every hour , so .

DR . SAMET : Okay . Phil , do you want to weigh in ? DR . HOPKE : Yeah . Again , I ' ll just chime in again .1

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I mean , we have a lot of experience with measuring

-- with these measurement techniques . I

mean , they ' ve been running nephelometers for a long time . In IMPROVE network, there ' s a lot of experience with nephelometers .

I mean , you know, I don ' t understand what it is you ' re going to try and quantify because how are you going to generate a known standard atmosphere with a known standard extinction or absorbance . I

mean , if we could do that , we could actually test the accuracy of an FRM and discover that it ' s crap , you know . So I don ' t see what the problem is with years to get to an FRM . You define it by design like you have in the past and then develop some equivalence , I

mean , you know . I think you have to get something going and the simplest straightforward approach is to have a reasonable nephelometer and absorbance measurements out there . And again , we can come and

revisit this in the not too distant future if you want to start moving to , again , more single instruments , PM10 instead of 2 . 5 . These things may well be available in five years ; but if we think it ' s important to start with visibility, it seems to me that there are opportunities to do that fairly1

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-1896 (FAX) 276 effectively and efficiently in the near term .

DR . MARTIN : The reason I ' m raising these points of clarification is , as you all know, in the first draft of this Policy Assessment this hybrid type of approach was not discussed . We ' re talking about either aggregated mass or light extinction . The thing that happened between the first draft and the second draft that caused us to develop this alternative approach was the meeting with the AAMM Subcommittee and the discussion that took place there and the recognition of

-- I was not at that meeting, but my understanding

-- and these folks were , so I ' ll let others speak more directly to it

-- was the recognition that , while there was instrumentation that was available and had been used in the past , there were new methods coming along, that there was time needed to do some pilot work that would feed into , and the type of evaluation that the Agency needs to do to establish an FRM and that we weren ' t talking about a year or so . We were talking about many years . And it was that outcome of that AAMMS meeting that caused us to come back and say, okay, right now we have two alternatives , neither of which for different reasons look like something we can move forward with in this review . How can we sort of1

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-1896 (FAX) 277 split the difference and develop something that we could move forward with in this review . And your comments now seem to be somewhat at odds and surprising relative to what we heard when we met with the monitoring subcommittee . And I ' m sort of

-- sort of wondering what to do with this discussion in light of that difference .

DR . SAMET : Well , I think Vanessa ' s going to comment . Then we might get the other Ted Russell to comment .DR . VU : I think Karen did portray correctly . And Ted

-- I know, Phil , you did not participate at that meeting of the AAMMS .

You did . Oh, that ' s right , Phil , you did . DR . HOPKE : I was there , pitching for the same thing I ' m pitching for now .

DR . VU : So maybe what we could do is pull that report and make it available to everyone to refresh everybody ' s memory .

DR . SAMET : Let ' s see , Ted and then Kathleen . DR . RUSSELL : I think what we came out of the AAMMS meeting was saying in the meanwhile you could

use as a bridging approach the essentially reconstructed visibility, and the recommendation was you would go to direct measurement and in the1

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meanwhile use a reconstructed approach . But the endpoint was to direct measure it , and that would give you time to do it .

Now, I can try to pull up the report , but I think that was our recommendation .

DR . BRAIN : As a bystander , it certainly sounds like there ' s less and less confidence in the reconstruction approach . That ' s sort of what I hear , is that it ' s not a bridge you ' d want to walk across .

DR . RUSSELL : Oh, I would actually in the near future have

-- say that it ' s a reasonable bridge . It ' s better than using PM2 . 5 mass and it ' s something that can be done relatively quickly . So I don ' t have

a problem with that bridge in the meantime . I just don ' t want that bridge to be the one that goes on forever .DR . SAMET : Okay . Kathleen .

DR . WEATHERS : So this is a very useful discussion to explain why it is that I was confused in reading through these indicators . And from 35 , 000 feet , one of the things that really heightened my interest in trying to sort these out was the comment that the choice of the indicator versus the form is probably more important . So the indicator , what gets chosen here seems to have a huge influence on the1

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outcome looking at the forms and levels and potential standard .

So it was not clear to me for the second two choices how many of these variables can be measured

now; so we ' re discussing that right now . It sounds

as if light extinction , it can ' t be measured currently; is that

-- that correct , in the field is not being measured currently .

It was not clear to me from one of the

-- the modeling approach which pieces of information exist

now or whether there has to be some additional monitoring data , so if you can answer that before I go on . DR . PITCHFORD : Okay . I ' m not sure I understood exactly what you were saying , but let me

answer what I think you said and then you can tell me if I ' m right .

DR . WEATHERS : Yeah . DR . PITCHFORD : Okay . People do direct optical measurements now, but they don ' t do them in the context of any regulatory framework . It ' s more to gather different kinds of information or for scientific things , and they ' ve been doing that for several decades . So it isn ' t novel , new things that

are currently available that could be used . But EPA1

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does not have

-- has not gone through any process . We ' ve never had this as an indicator , so we had no

reason to do that . So there would be

-- even if everything else was perfect , there would have to be

some effort and whatnot put forward to make it so , but there ' s also technical issues that in a regulatory framework would have to be looked at .

So what AAMMS -- what we thought we heard from AAMMS was , don ' t think that you can just take what ' s

on the shelf now and put it out in the field and use it . There ' s a fair amount of work that needs to be done . And I agree with what Ted said . They did talk about using some sort of a calculated extinction as a bridging technique , and that ' s our leaping off point for what we did in the Policy Assessment with our third indicator , so ; and everything we need for that indicator is available .

DR . WEATHERS : Okay . So that ' s helpful , and it would be helpful to have that be clearer in this document as well .

DR . PITCHFORD : Sure . DR . WEATHERS : What ' s also not clear is what the sensitivity of this modeling approach is from a parsimony standpoint . This is a pretty complicated model that seems to me rules in a lot of1

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uncertainties that aren ' t identified here , so it would be really useful to know something about those

uncertainties .

DR . SAMET : Okay . Rich? MR . POIROT : So I ' d like to disagree with all of my colleagues to a point and start with the reflecting back on the Urban

-Focused Visibility Assessment where there ' s a series of the scatter plots in one of the appendices that compare just plain old stupid fine mass with the most elaborately reconstructed extinction . If you look across those and throw out the St . Louis site

-- which had, I think everyone acknowledges , bad data

-- the average R2 is point 7 . And as a starting point , I ' d like to suggest that there ' s never been a NAAQS indicator that related to any effect , primary or secondary anywhere , that ' s anywhere in the ballpark of point 7 . That ' s an incredible relationship right there to start with .

So I think all of this concern about the

uncertainties , well , they ' re really not huge , even if

we start in the simple terms of thinking of the fine

mass indicator . If you can bring in the humidity associated with the aerosols in a reasonable way, you

can improve that point 7 to point 8 5 or something1

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like that . The uncertainties in this reconstructed extinction calculation , frankly, are not large and it ' s not possible for them to be large . So I ' m not anywhere near as concerned that

-- as some others

are , that this is going to be fraught with errors and

so on and so forth .

What I ' d really like to get us to as an endpoint of a recommendation , if we could, would be the idea of pushing as hard as we can for the need for optical instrumentation as the preferred way to go , but without pushing so hard that it breaks the thing and everybody says , oh , then we can ' t have any secondary standard this time around . So that ' s why I thought that the , sort of , interim use , the mass data enhanced by speciation , or whatever , kind of a recommendation that came out of the AAMMS subcommittee as an interim approach was a good idea . And I think also , this committee itself said the same thing in its letter the last time around, that we recommended as an interim approach using the mass enhanced with the speciation and humidity data in whatever ways were feasible , and that ' s what they did . So I don ' t understand why we should be all upset about them doing what we asked them to do .

So I just would like to try, though , to reduce1

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some of the concerns that this reconstructed approach is going to be way, way out in left field . No , it isn ' t . No , it isn ' t .

And beyond that , I would also like to suggest that I think you could utilize your speciation data

on an historical basis to come up with either a site specific or preferably regional composition that you could do on a seasonal basis and use that in advance

so that you can then combine that historical seasonal average speciation information with your realtime fine mass and humidity data to come up with your estimated extinction . It ' s a simpler version of what ' s been proposed . It would have higher

uncertainties , but they ' re not going to be that great ; and the advantage would be that you wouldn ' t have to wait three or four months after this instantaneous visibility effect to know what you thought it was . You ' d have it right there . You could use it in realtime . You could be pointing it out in your mass calculations and so on and so forth .

Again , what I would really like us to be able to do is to come out pushing as hard as we can for the need to move to the optical indicators because I think if we don ' t push pretty hard it ' s not going to happen . It ' s too easy to say, oh, we ' ve got other1

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issues to work on ; but at the same time being supportive of this reconstructive extinction as an alternative approach . And as I say, I think it could be done in a simpler way that would be more timely and that the uncertainties would not be that large , and I think that some calculations could probably be done that would demonstrate that .

DR . SAMET : So just a comment , Karen , you ' re going to finalize this Policy Assessment document in the next three months , four months ?

DR . MARTIN : Yes . DR . SAMET : So we ' re pretty far down in reviewing the second draft with a still , sort of , undetermined

-- a broad set of options with I think still unclear preferences on the part of the committee . I think I ' ve heard three possibilities . One is the view that the instruments that measure light extinction , regardless of whether there ' s an FRM or not , are at least ready enough .

Second, that they may not be ready enough ; and if not ready enough , there are two bridges . One is , I think, the Rich option , which is , you use PM2 . 5 in

as informative a way as possible , possibly modified by knowledge of the region in some way . And the other is your proposal for this speciated index .1

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So it seems to me that in having this discussion and trying to reach an outcome that indicates some preference , the first point of the discussion is , in fact , whether the instruments are ready for prime time , the light extinction instruments ready for prime time , and can be recommended . I don ' t understand the vagaries in the development of

-- the issues of developing the FRM for this ; but it seems like the first point is , in fact , whether those instruments are ready and should be given preference . And if not , then there

are some alternatives that would follow, so if we can try to be a little bit orderly about this . I know that ' s a challenge .

Let ' s start with that point . So maybe we ' ll circle back to Ted, Phil , Joe , and anybody else who wants to weigh in on -- yes , even , Sverre .

DR . SPEIZER : John , could I throw another two -- DR . SAMET : So who wants to lead off

-- or Lowell . DR . SPEIZER : This is Frank .

DR . SAMET : So let ' s just stick to this one question and try and resolve it . Lowell ?

DR . SPEIZER : Yeah . But I wanted to ask

--1

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DR . ASHBAUGH : Well

-- DR . SPEIZER : -- which is , is there a difference in data captured that ' s related to humidity or rain that would relate to each of these differently or are they all affected the same way?

DR . SAMET : Okay . I ' ll take that as a modification of the question on the table .

So Lowell , go ahead . DR . ASHBAUGH : I didn ' t get the sense that this approach being proposed, to do light extinction

-- and I think that ' s what ' s missing in this document . I ' m happy with it being used as a bridge , but not as the final approach, so .

DR . SAMET : Okay . So that fits with the way I ' ve constructed

-- so let ' s just first stick with this point .

MR . MOORE : You ' re doing a good job on trying to get us to focus .

DR . SAMET : It ' s hard . DR . MOORE : Can you restate ? DR . SAMET : The first choice is whether light extinction is ready to be given preference or not . And if not , I think we referred to there are two bridges , and I gather they are bridges on the part of the Agency while awaiting the determination as to1

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whether the light

-- or the light extinction is ready . And I think it was Rich who was saying maybe PM2 . 5 by itself is not so bad and that it could be

re fined, I think we were suggesting on a regional basis using

-- bring in knowledge of speciation and then perhaps humidity, whatever else , and then the proposal for the speciated approach that ' s included in the PA . So I still would like us -- and I think that ' s a --

DR . MOORE : There remain three choices , just

as the document outlines , measure it directly, use PM2 . 5 mass , and do Rich ' s approach, or do a more complicated

--

DR . SAMET : Right . But we ' re putting them in this sort of decision

-making algorithm of what this committee would like to do . So let ' s just stick to the first point I started with , and that I think is this question on where the light extinction instrumentation stands . And I think I ' ve heard divergent

-- somewhat divergent views . So I want to circle the table of everybody who might have an opinion , so anybody who has an opinion on this . I ' ll sort of go around .

Helen , do you have thoughts about this , or knowledge ?1

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DR . SUH : No . DR . SAMET : Okay . Kathleen? DR . WEATHERS : Yeah . It seems to me that if light extinction can be measured, that ' s the primary choice ; and if not , doing the bridging approach , it ' s the simplest , is the next . And I think that ' s what Rich outlined .

DR . SAMET : And Ted, your view on where the instrumentation stands ? I think you ' ve been clear .

DR . RUSSELL : Yes . So it ' s available . There ' s better stuff coming .

It would have to -- as we lined out in the AAMMS report , I ' m pretty sure -- and I hope someone is bringing it up faster than I ' ve been able to bring it up . For some reason my computer is just not doing it quite so quickly

-- that that instrumentation for PM2 . 5 does exist now . There are some better technologies coming along .

What we suggested was that it be tested and, essentially, the modification made such that it could be used in network form, for one , taking into account relative humidity less than 90 percent . If all of that stuff could be readily done , you would perform

some type of field experiment to assess that it is appropriately used in the network and get it out ,1

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-1896 (FAX) 289 recognizing that that would take a little amount of time until we would have a bridging technique . Actually, you know, what Rich suggested is probably fine . I ' m somewhat compelled by his argument that if

we ' re looking just for a bridging approach, something simple is probably good .

DR . SAMET : So , but actually, back to this point , I thought you had answered the question .

DR . RUSSELL : Then I didn ' t . DR . SAMET : Do we need a bridging approach or not if the instrument is ready; yes or no ?

DR . RUSSELL : I think we do . It would be useful . So I ' m going to equivocate . Sorry about that , John .

I do believe that this is the sort of thing that there should be some sort of field experimentation first before we say this is the technology, give it FRM status and send it out . So you know, this will take a couple of

-- a few years , a couple years , but I think we do want a bridging approach in the meanwhile .

DR . SAMET : Okay . Rich? MR . POIROT : Oh , I forgot the question . DR . SAMET : So the question is : Are the instruments ready? Are the light extinction1

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instruments ready or do we need a bridging approach; yes or no ? Well , not yes or no , but bridge or not bridge ? MR . POIROT : Bridge .

DR . SAMET : Bridge . Okay . Kent passes . Tom? MR . MOORE : So I think I have some evidence , but I rely upon the folks at the EPA to straighten me out on this ; but I think a number of state and local agencies use nephelometry to report hourly PM2 . 5 for the AIRNow program . So that what they ' re doing is they ' re pulling air through a PM2 . 5 cutpoint and measuring light scattering and then back

-calculating

on an hourly basis what PM2 . 5 is . I believe that ' s correct ; but I mean , that ' s an operational question . But the point is the instruments have been in use for

a number of years in exactly this mode . The absorption is probably a different , more complicated issue . I ' m torn because of

-- in terms of being ready to go , I ' m, you know, reminded of Voltaire , that the better is the enemy of the good . And so Rich has proposed a nice , you know, good approach . So I would just for the purposes of this discussion say let ' s go all the way to optical and not try and do the bridge .

DR . SAMET : So you ' re a non-bridger .1

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MR . MOORE : I ' m a non -- well , I ' m for optical . I ' m not a non-bridger . I mean , that ' s a different . . . .

DR . SAMET : Bill ? DR . MALM : There isn ' t a federal reference method for nephelometry right now even though there is instrumentation that could do the job . So I guess what I would like to see is that it be clearly

-- extinction should be used as the indicator . That ' s a slam dunk . I think we all agree on that , but maybe EPA could propose a timeline . I think if you can ' t go out with something that doesn ' t have some sort of blessing by EPA, then what ' s the timeline to get that blessing? What is the timeline to get to a point where you have a federal reference method that applies for nephelometry? And in the interim, the techniques that you guys have proposed, I think, would work just fine . As Rich pointed out , they ' re far better than any other relationship between health endpoints that we haven ' t asked for right now . So maybe just a timeline is all that ' s needed, is to say that we ' re going to use this interim approach up until now and then we anticipate that we ' ll have a federal reference method for

--

DR . SAMET : And don ' t answer timeline yet .1

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We ' re going to complete our round of the table .

Let ' s see , Mort ? DR . LIPPMAN : No , I pass . DR . SAMET : Phil ? DR . HOPKE : Okay . The question is , what mass ? Are we going to use the FRM mass ? Are we going to

use the continuous monitors so they ' re adjusted to get the wrong mass and wind up with the FRM? Are we going to get a full FDMS where we get something probably closer to a real mass ?

DR . SAMET : You ' re talking about on the bridging?

DR . HOPKE : What ? DR . SAMET : You ' re talking about on the bridging?

DR . HOPKE : Right . So the problem is that , you know, at this point we don ' t have all of the sites we would want with continuous mass monitors . Now, I think that would be a great idea . I mean , that ' s obviously something I ' ve been pushing for for

a long time . So I think we should be getting rid of all of our filter units and putting continuous mass monitors out there . But if we ' re going to have it relate then effectively to the visibility, it has to be a more effective measure of mass and not a measure1

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of mass that ' s trying to meet the FRM; and I think there ' s a problem there that needs to be looked at and addressed .

DR . SAMET : Okay . Phil , in your view on the light extinction measurement ; is it now?

DR . HOPKE : I would, yeah . Light extinction measurements , you know, that would be my preferred

- - if I had my druthers , I ' d have a continuous mass measurement , I ' d have a nephelometer , and I ' d have an absorption measurement system at every site . Then

we ' d have good mass measurements . We ' d have good extinction measurements , and we can go forward .

DR . SAMET : Okay . Joe ? DR . HELBLE : I ' m in Tom ' s camp . I ' m a non -- I guess I wouldn ' t characterize myself as a

non-bridger , but I would be in favor of moving directly towards an optical measurement . I guess , maybe , I ' m missing something . Because this is a secondary standard, I don ' t see the need for a bridge to get us there . Why not simply establish the standard, establish optical measurements as the method used to meet the standard, figure out what the timeline is to get there , and then implement the standard on that timeline ? So rather than doing something intermediate , say, this is where we want to1

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be and just move towards it as quickly as we can .

DR . SAMET : Okay . Chris , any views here ? DR . FREY : ( Shakes head from side to side . ) DR . SAMET : Wayne ? DR . CASCIO : No . DR . SAMET : Joe ? DR . BRAIN : I agree with what Joe said . You know, let ' s just endorse the direct light extinction but recognize that it will take a little time to make it an operational system . But so I think I ' m a

no-bridger . I agree with what Joe said .

DR . SAMET : Okay . Ed? PROF . AVOL : ( Shakes head from side to side . ) DR . SAMET : Lowell , do you want to weigh back in ? DR . ASHBAUGH : Yeah , I ' d like to come back in again after Joe spoke .

I was thinking of the bridge as something that might be necessary; but as a secondary standard, it ' s probably not necessary . We could go directly to a light extinction measurement and have the EPA just go ahead and develop that approach . I would also like to see some development of an approach for continuous speciation measurement as much as possible because that ' s going to tell you where the visibility1

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reduction ' s coming from .

DR . SAMET : Okay . Karen ? DR . MARTIN : Stepping back from what you all said, I guess the one point I would really like to offer is , thinking about the statute and what we ' re legally required to do , while secondary standards don ' t have a specific timeline to be met , neither are they promissory notes .

In setting a standard, one part of the definition of the standard is what you are going to

measure and how you are going to measure it in order to compare to the level of the standard you set . It ' s not a fully defined standard to say this is our standard in terms of X level of light extinction and in the coming years under this timetable we plan to develop an FRM that would be used to determine attainment with that standard . That ' s a plan for a future standard, but it ' s not a fully developed standard in and of itself . So while I think everybody here would agree conceptually with that approach , that doesn ' t get us to a fully defined standard in this review; and so we still need to grapple with , and so what do we do now .

DR . SAMET : So let me just

-- DR . MARTIN : In essence , you can ' t commit the1

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Agency to do a research effort in terms of developing

an FRM today and say that ' s embedded as our standard

as though it will necessarily happen under that time frame . DR . SAMET : Right . And I guess that hinges on whether the current instrumentation is viewed as adequate and your reference method could be developed around that or whether this phase of research is needed that would preclude such development , as I understand what you have said .

DR . MARTIN : And to speak to that specific point , I would like to ask Tim Hanley, who was here yesterday talking about monitoring , to speak a little bit to our further understanding of the AAMMS discussion on this point .

MR . HANLEY : Thanks , Karen . So one of the things that has been mentioned in the last ten minutes that was pretty much unanimous when we met in February with the AAMMS was with regard to whether the Agency should consider a design

-based approach or performance

-based approach .

The reason why I bring that up is because it ' s been mentioned that the technology ' s available today . We agree with that , but there ' s multiple technologies available today . And the Agency coming out of that1

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-1896 (FAX) 297 February meeting read the AAMMS report , which , again , was approved by the full CASAC , as , whatever you do , do not pick one method more or less as the winner . And I think the subcommittee was pretty clear , in the long run we ' re going to be much better off if we have

a performance

-based approach that allows cavity ringdown and other options that might be developed down the road to enter into the market and be used for a light extinction standard .

So I mention that because I think the subcommittee were telling us -- and there are subcommittee members here if I get it wrong -- that you know what , we recognize that we want to get to the right place ; but let ' s make sure we get to the truly right place , which is , again , using a performance

-based approach .

If the Agency were to go with a design

-based approach , meaning , pick one method, work with that instrument company and select it and publish that method, we ' d have that ; but then we would sort of stifle innovation for anything further down the road . So yes , we could short

-circuit this process ; but again , the subcommittee and CASAC members signed off

on that letter saying , no , do it the right way . That right way requires that field testing, that even1

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-1896 (FAX) 298 though the technology is available , ORD would need to go through over a few years and work in ; and then that also buys some time for the innovators out there to bring their products in .

DR . SAMET : So Kathleen and then Ted . DR . WEATHERS : So is it possible from a policy perspective to say that while direct measurements of light is the goal , we ' re proposing to do a bridging approach and as those methods become available , will be compared against this bridging approach? Is that acceptable to point to the need for a direct measurement , but make the recommendation that a bridge modelling approach be used?

DR . MARTIN : We could certainly as part of setting a standard defined in terms of calculated light extinction indicate that is the Agency ' s goal , to work to develop something ; but we can ' t commit the Agency in the future to actually accomplish that , and the standard would be what the standard was . And if there was not funding to do the work we all agree is appropriate to do , the standard would remain what the standard was until and unless we changed it . So we

can all say it ' s a goal to do a bridging approach, but whatever standard we put in place will be the standard until we change it .1

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DR . WEATHERS : I guess what I was asking was , if you do that , if you say the bridging approach

-- this is the approach, this is the indicator , but also saying that in the future

-- this may be just a message . It ' s not a -- you know, it ' s not a policy agreement . In the future direct measurements would be ideal .

DR . SAMET : Yeah . What Karen is actually saying is that a bridging approach becomes the approach until it ' s replaced by something else when the science supports it . And in fact , if for whatever reason the money needed to develop the methods for measuring light extinction to the standard required were not developed, then things might remain

--

DR . WEATHERS : Right . DR . SAMET : I think she ' s saying we can make a recommendation that , yes , light extinction should be the target , that in the

-- apparently, in the view of this committee that there ' s still design issues to be dealt with and in preparing a method that might be suitable for development of a federal reference method, not there , but that work should be done , money should be invested and so on , and if that doesn ' t happen , then it doesn ' t happen . But I don ' t1

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think

-- Karen ' s not signing a note here .

Ted? DR . RUSSELL : And I think what Karen just said and what the committee has discussed, I ' d probably become a non-bridger . And then when I look back at the AAMM, I mean , we didn ' t -- we looked at it and said in the meanwhile this would be an appropriate approach with very much the view that that wouldn ' t become the rule , that that would be something that ' s viable to be used meanwhile , while you do this other work with the thought that the other work was pretty much going to get done and you would have an FRM set of instrument or set of instruments .

So looking at that , if you ' re sort of giving

us the choice that it becomes , do the instrument , you know, come up with an FRM versus saying that , okay, we can use this bridging approach, but it may not -- but that bridging approach becomes law, I think I quickly become one who just says , let ' s just go directly to the instrumentation and you do what you need to do to get the instruments out there in whatever time that takes because I don ' t want to see

us -- see the bridging approach, which we had recommended with the idea that the instruments would be there . It would go through the appropriate steps1

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to essentially develop the performance

-based standards to have an FRM set of instruments .

So , but what you ' re telling us now is that you really can ' t have a bridging approach and a promissory note down the way, which is the AAMM . It ' s saying, okay, this is our endpoint , but we recognize maybe you want to do something in three years -- for the first three years .

DR . MARTIN : We can set a standard using an intermediate approach on the premise that we anticipate the work will be done to provide for the next review moving to a direct

-measurement approach, but we can ' t promise that ' s going to happen . How could we ? And until you change it , the standard is the standard . It ' s -- you can ' t be half pregnant with the standard . You either have one or you don ' t because the standard, of course , triggers a massive amount of effort on the part of the states to implement that standard; and we either mean it or we don ' t . DR . SAMET : Congratulations on the pregnancy analogy .Phil ?

DR . MARTIN : You pushed me into it . DR . HOPKE : We could do

-- at least for1

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extinction , it ' s fairly easy to do a standard sodium sulfate spherical aerosol . Okay . We can generate that . They ' re good

-size chambers . We could line up the nephelometers and set a standard for what their response needs to be .

DR . MALM : It ' s already been done . DR . HOPKE : What ? DR . MALM : That ' s already been done . DR . HOPKE : I understand . But it hasn ' t been done by EPA, so it ' s not approved; okay?

But the point is that that ' s technologically feasible and that would get us off the ground pretty quick with respect to extinction , with regards to defining the FRM as anybody who could make that

measurement within some reasonably defined error bounds . Extinction becomes a little bit trickier because the question is extinction on the fly or extinction on a filter , and those are not quite the

same things . But again , we could still define one or the other as the standard for the time being .

There are instruments that do absorption on the fly . There are instruments that do absorption on

a filter . We can certainly measure the absorption

on -- we can make filters with known absorption ,1

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which we can measure independently integrating spheres or things like that . So there ' s some absolute ways we could calibrate what that filter absorption is and, again , compare the instruments .

Bill looks quizzical , so have I said something

untoward here ?

DR . MALM : That ' s fine . DR . HOPKE : Okay . So I think that within a fairly reasonable amount of time one could fundamentally calibrate or check nephelometers , fundamentally check light absorbing systems on filters , and that ' s a lot easier than doing it on the fly . So let ' s define our absorption as absorption collected on a filter and move on .

DR . SAMET : But isn ' t Karen ' s problem that in three or four months this PA needs to be done and it has to have a clear

-- lead to a clear recommendation? I mean , there ' s no time

-- this is all work that comes -- that supports the next go-around . So I mean , I agree there ' s work to be done , but that doesn ' t solve our dilemma for the next hour or 45 minutes .

Tom? MR . MOORE : I ' ll try and be quick, John . I think what Phil just said, if I could boil1

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it down , is that this is not a scientific issue with respect to the instrumentation . It ' s just a technical process issue and so -- but that may stop it from moving forward . I mean , EPA struggled for the last 20 years about design specification versus performance and we pendulum back and forth . So maybe this goes to Vanessa ' s idea about what should be the research approach going forward . You know, what are the specific recommendations about tying together implementation of these standards with the research agenda , which I feel is kind of separate right now .

So as I was trying to say, I ' m an optical advocate ; but I ' m not a non-bridger . So there are tremendous advantages to doing the bridging approach . You know, the health folks will get a lot more data than they have now . So I mean , I ' d be willing to facilitate some kind of a solution that includes starting with the bridging , but there has to be a clearly defined objective to get to the real variable

we ' re trying to measure .

DR . SAMET : So one issue

-- and I don ' t know, maybe , Karen , you can respond to this

-- as I heard the bridging options , if one were to use PM2 . 5 alone , that is the simplest bridging option I would

-- you know, for obvious reasons . The question of1

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-1896 (FAX) 305 developing this speciation approach, while it might have benefits in expanding our , sort of , knowledge of variation of PM species across the country, would involve

-- I mean , I don ' t know what ' s involved there in terms of creating new, quote , reference method and how much effort putting that bridge in place is . If the work to get to a direct light extinction measure could be done relatively quickly, you know, how fancy

a bridge is needed . And I think we heard Rich saying that maybe PM2 . 5 is not so bad .

DR . MALM : Well , I agree basically with what Phil has said, but there ' s no way -- I don ' t think, Phil , you ' re going to get all that . I mean , it takes time to generate aerosols and set these studies up and all that kind of thing . So I don ' t think all that can get done in the time frame that they need to get it done in here if they ' re going to get it

-- you know, come up with a proposal for a standard within the time frame of this go-around .

So I don ' t think that there ' s -- I don ' t think there ' s any alternative other than

-- if we ' re going to get it done now -- any other alternative than to accept a bridge with the idea that they ' ve made some commitment to move toward an optical measurement down the road . But if you ' re going to get it done this1

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go-around, I think the bridge is it ; and all we need from them is a timeline and some sort of

-- you know, if Congress cuts their budget and they can ' t afford it , they can ' t afford it ; but it ' s better to get something out there now with a bridge than to do nothing at all .

DR . SAMET : Joe , did you have a comment ? Oh, that Joe . The other Joe , okay .

DR . HELBLE : I was just going to ask for clarification because what I ' m understanding what Karen is saying is that , while we may all be in agreement that a bridge should be a bridge and here ' s the goal that we ' re moving towards , in the end a bridge is not a bridge . It ' s simply a promise that

we ' ll think about it and we ' ll try, that when we set

a standard, the standard ' s set and moving to something new depends upon budget , it depends upon research , it depends upon the next review, it depends upon changing the standard .

So what I ' m hearing you say is that we can call it a bridge ; but we should recognize that if we make the choice to go down this path , we ' re really setting a standard . And we all have to , I think in varying degrees , individually assess what the probability is if we move towards an optical1

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measurement and in terms of a time frame ; and my

sense is that probability is not very high .

DR . SAMET : Okay . Chris ? DR . FREY : Yeah . I guess I ' ll sort of clarify the flip side of that is my understanding from the discussion , is that with regard to using optical instrumentation , given the , I guess , the bureaucratic hurdles , for lack of a better term, to establish that

as an FRM, that there ' s not a way in this five

-year cycle to see a standard develop . That ' s sort of delayed until such time that the FRM is successful and that process is completed . So that , really, I just want to clarify, that our option or the Agency ' s option , really, is either , A, create a standard based

on the so-called bridging approach or , B , do nothing .

And then the other aspect of that is that five years hence , it seems pretty clear that CASAC would like to see that the optical methods have been established as an FRM such that then it ' s ready for prime time ; but there isn ' t going to be an interim possibility that , say, two or three years from now the Agency could establish an optical

-based standard . That ' s my understanding from the discussion . I just want to clarify that .

DR . SAMET : Karen --1

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DR . SPEIZER : I just want to throw a question out . What would be wrong with a bridge for five years ? DR . SAMET : Well , that , Frank, that might happen ; but it might not . I mean , I think that really depends on , sort of , what happens in the next review . Karen , is that correct ?

DR . MARTIN : Yes . DR . SAMET : And I think Chris did say it right , didn ' t he ?

DR . MARTIN : Yes . DR . SAMET : Mort ? DR . MALM : Whether you monitor visibility directly, extinction directly, you ' re doing it by reconstructing the extinction . I would bet you that the same endpoint

-- that the endpoint is going to be the same no matter how you do it . If our goal is to improve visibility, this interim technique , this reconstructed extinction will accomplish that just as well as a direct measurement . I agree that direct measurement is better and all that sort of stuff and certainly would be my first choice . But if our endpoint is to improve visibility, reconstructed extinction will get the job done .

DR . SAMET : Okay . Mort ?1

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DR . LIPPMAN : Well , the question then is do we need to reconstruct it or would a humidity corrected PM2 . 5 serve that purpose as well . The simpler one that Rich has proposed may be adequate also .

DR . SAMET : Okay . DR . HOPKE : Again , we have the problem of speciation data is only going to be collected every third day for 24 hours , and what we ' re clearly interested in is short

-term high levels of visibility degradation . So I think, you know, we really need to be looking at the mass -- continuous mass measurements rather than something with respect to speciation at this point .

DR . MALM : Well , the proposals use continuous

mass and weight it some way such that you end up being closer to reconstructed extinction and you don ' t need an instantaneous readout . The states are going to make decisions . They ' re going to create plans to meet the standard over long periods of time . It ' s nice to have instantaneous data and to be able to understand it , you know, as it ' s being measured; but you don ' t need it . You don ' t need that kind of a measurement if your goal is to create some sort -- is to create a plan that allows you to reduce certain

- - you know, to improve visibility . You don ' t need that1

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instantaneous feedback, although I agree it ' s awful nice to have .

DR . SAMET : So let me just read a sentence from a CASAC letter April 29th , 2010 , signed by Ted and myself . So just to remind us that here it ' s talking about the different

-- sort of , the preamble is talking about these different light extinction methods promising alternatives . As these devices are not currently commercially available , costs are less certain and they would have to be thoroughly tested for use in a network . This is promising future things . Data from existing continuous PM2 . 5 federal equipment method monitors could be used as a surrogate for fine

-mode visibility assessment until data from extinction monitoring methods are more widely available . Subcommittee members use such

mass -based methods as a practical interim approach or bridge to extinction monitoring .

So this seems quite clear and consistent with the discussion here , and I think I ' ve heard, possibly with the exception of Ted, who I think was responding in part to , sort of , the possibility that light extinction methods would not necessarily be implemented, that we should not have a bridging option , but otherwise that the , quote , "bridging1

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-1896 (FAX) 311 approach" was reasonable , understanding that what

we ' re calling a bridge might turn into a dead

-end, is that

-- DR . RUSSELL : Correct .

DR . SAMET : Okay . DR . RUSSELL : I mean , I would point out the sentence right before the one you said is that we only do have

-- the filter

-based approaches are there , and they just have to go through

-- well , the performance

-based standard would have to be developed and that we recognize that would take time . And it

was the committee ' s view that , in the meantime while you do that , the bridging approaches would be viable . I don ' t think it was ever the committee ' s thought to short

-circuit it and the bridging approach would become the standard . If we had recognized that , I think we would have been pushing much more saying

--

DR . SAMET : So we can certainly state that very strongly in our letter .

Yeah , Lowell . DR . ASHBAUGH : My understanding right now is that we could recommend that you go directly to a light extinction standard, but you ' re not going to be able to implement it right away . So if that ' s the

case , we ' re left with two choices . One is a PM2 . 51

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mass standard and the other is this hybrid approach of calculation . Either one of those , if we recommend

one of them, may end up being there forever if you

can ' t get to a light extinction standard or it may be there for a much longer than we anticipate . If that ' s the case , I would just as soon go with the calculation method that was proposed and trust that the EPA will progress toward a light extinction standard for the next round . But in the meantime , understanding that whatever method we choose now may end up being there for a longer time than we expect if things don ' t go the right way .

DR . SAMET : Tom? MR . MOORE : So I read, as you all can tell , I read this section pretty carefully that ' s in the current draft , and it really doesn ' t tease out any of the detail that we spent the last hour talking about . So I would hope that the final version , pending everybody ' s comments , would go through this and kind of tease out the detail because I in fact think that EPA ought to recommend to its Administrator that , you know, we ought to measure optically; but we can ' t do it right now . Because I think that ' s what CASAC is saying , here ' s the preferred approach; but we all understand we can ' t do it right now . And you know,1

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the conclusions in the AAMMS report are not really carried forward into this section , at least the part that I ' m looking at here on 4

- 32 .

DR . ASHBAUGH : Tom, you ' re talking about putting explicitly in this PA the idea that we want to move toward the light extinction?

MR . MOORE : Correct , right . DR . ASHBAUGH : Yeah , I agree with that . Yeah . MR . MOORE : And so if that were possible to do , I think it ' s a little bit different take on what EPA is recommending in its Policy Assessment for the Administrator to consider as opposed to what we ' re trying to do , which is craft an interim approach . But if we don ' t get that kind of recommendation from EPA to its management , then it ' s a self

-fulfilling prophecy . We ' re not going to get this technology far enough advanced to be looked at .

DR . SAMET : So this I think has to do with the strength with which we make our recommendations .

Ted, you ' re going to be the author of this piece of Voltairean prose . Don ' t let the perfect be whatever . So I think we ' ve circled this issue . I

mean , I think we ' ve had enough discussion of it . I think now, just maybe take a crack in the remaining minute or two before break with what you ' re going to1

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say . DR . RUSSELL : Thank you . So how I would phrase what we have said is that , first , CASAC discussed the various alternatives presented and recognized that there are strengths and weaknesses of each one and members were divided on their choice

-- on the potential bridging approaches and using a bridging approach at all .

The committee as a whole very strongly prefers direct measurement of visibility extinction , but recognizes that it would take some amount of time to develop FRM instruments that could be deployed in a network . Given that

--

DR . LIPPMAN : Were they developed or selected? DR . RUSSELL : The AAMM was very specific that

we want to have performance

-based standards , so I think it ' s develop standards , performance

-based standards for the instruments . So it wouldn ' t be select . It would be to develop

-- develop the standard for the FRM .

DR . LIPPMAN : Not develop the instrument , develop the FRM .

DR . RUSSELL : Right . Develop the standards of the FRM .DR . STALLWORTH : You ' re saying given that

--1

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DR . RUSSELL : Given that . Thank you , Holly . The committee was divided on directly recommending that we set -- that we go directly to direct measurement or to adopt the bridging technique recognizing it could become a bridging technique for this review .

So how would you augment that remark? DR . SAMET : So I think after

-- the issues that we are going to have to come back and face up to after break is in terms of what is anticipated to be , let ' s say, the interim before there ' s a direct light extinction measure , whether that is PM2 . 5 , humidity corrected, maybe regionally finagled, as Rich has proposed, or it ' s this speciated approach that is in the document . So I think we ought to come back and have that discussion . Take the 15

-minute break, check out unless we think we need another day and then get back at 10 : 15 . Okay . Thank you .

(Recess taken 9 : 59 a . m . - 10 : 16 a . m . ) DR . SAMET : So let ' s see , I think we ' re back with , in a sense , maybe Ted and Bill because I ' m not

sure we settled on the , quote , " interim" or

"bridging" indicator . So I think we should just go back and have a little bit more of that discussion and see if we have a preference , I think, among --1

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between the two options .

So , Ted? DR . RUSSELL : So between the two options , again , one is just using PM2 . 5 mass directly and then there ' s the reconstructed visibility . And EPA states pretty clearly that their preference is the reconstructed visibility using speciation data . And that ' s -- I agree , is that of the two , that data exists and we might as well do that

-- do that calculation even given the uncertainties . And I think my issue would be is that there ' s just more

uncertainties involved than are actually recognized there . I think either way, actually, I will say that I don ' t think we want a standard that ' s based on micrograms per meter cubed . I think we do want it in terms of light extinction . So , and maybe that comes to the next comment or next question . So those are the two .And from what I take from the discussion by the committee , I think there ' s more support for the calculated light extinction using the speciation data

as a bridging approach, though there is some comment that just using city

- specific correction and using purely the PM2 . 5 mass measurement has some support because it ' s easier and, again , there ' s -- it ' s not a1

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-1896 (FAX) 317 huge uncertainty or a huge likely bias .

So the way I currently interpret the committee is that there ' s more support for the

-- rather that they have specified, though my comment would be that they probably should add PM coarse if they can just because the reason why we went with PM2 . 5 was because

we looked at it as bridging towards an instrument that would only do PM2 . 5 . So that ' s my take on it . So I think there ' s more support for the more involved calculation .

DR . SAMET : Okay . Rich, do you want to comment ?

MR . POIROT : Well , just to be clear , the

so-called more involved calculation , the so-called simple approach , ten- step simple approach outlined in the document , as I understand it , would use the continuous fine mass measurement data along with continuous RH measurements . And then for the month in which those data were collected, it would go consult the speciation data to come up with an average monthly speciation , which it would then disaggregate to an hourly basis and combine with the

mass and the RH .

So what I was proposing as an alternative was to use historical monthly or seasonal . I think1

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-1896 (FAX) 318 monthly may be even gilding the lilly more than is necessary . I don ' t know . It can certainly be tested such that you could have your site specific

-- or if it were possible to do on a regional basis

-- speciation information in advance rather than three

or six months , or whatever it takes to get the speciation data back after the fact . This is an instantaneous effect . And to have to wait three months to know what it was seems both silly, number

one , I think in terms of all the uncertainties ; not adding very much uncertainty to use the historical rather than the concurrent month ' s data , number two . And then three , it ' s missing an opportunity to utilize this information in near realtime as a supplement to other things that are measured and reported out to the public in that way .

So that ' s what I was talking about as a simpler approach . It ' s really the same approach . It ' s just a question of can you do just as well or very close to just as well using historical data rather than the concurrent month . So just to be clear about that , that ' s what I was proposing and I still think that that would be just as good and worth

evaluating . It ' s something that can be evaluated; and if the Agency would have the time to look at it ,1

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I think it would be useful .

DR . SAMET : Mort ? DR . LIPPMAN : I disagree with everything that Rich just said .

DR . SAMET : So there might be several views captured on this point but perhaps a sentiment that the speciated is possibly more accurate . Although , I

mean , as you point out , Rich , the R2 with the PM mass alone was high and improving on it a bit might not make that much difference in practice , I suppose .

Tom? MR . MOORE : So I agree with Rich and, of

course , in practice that ' s exactly what PM2 . 5 nephelometry does , to back

-calculate PM2 . 5 right now is it uses historic , monthly . So this is something that I think is a standard practice already .

The problem with the correlation just staying with PM2 . 5 mass is that the composition is variable between every site , so it ' s an artifact of that . So I think that ' s why we want to do the speciation , not just limit it to PM2 . 5 mass .

MR . POIROT : You know, could I just mention also there are a couple different efforts that do this in reverse . EPA used to fund Sonoma Technology to take the airport ASOS visibility data and tap into1

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it at its raw level before it gets binned and truncated and most of the useful information content gets thrown away and to report that out in near realtime for the AIRNow system . And then they also had a generic inverse F of RH drying function that they applied to that data , and it was used and it was very useful to states to compare to their fine mass data . In fact , I personally use the airport ASOS data applying an inverse F of RH to just dry it out , understanding that , you know, most of the time you ' ve got some sulfate and nitrate mixed in with your organic . Most of these are always mixed together , and a generic function actually works really well . But I use it to evaluate whether I think my fine mass monitor is working right . I trust the visibility data better than I do my FDMS TEOM that is all over the place .

So again , I think that there ' s a lot of practice with doing this kind of thing and I really, you know, I think we ' re talking

-- we keep talking about all these uncertainties , I think probably because we know so much about this subject area , not because we know so little about it .

DR . SAMET : I think, why don ' t we go on to1

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-1896 (FAX) 321 Charge Question 13 . Well , so this is on the levels and forms , so the secondary standard .

So , Lowell , do you want to weigh on this one ? I don ' t know if we ' ve lost

-- I guess we lost Bill ?

DR . STALLWORTH : Yeah . COMMENTS ON CHARGE QUESTION NO . 13 :

DR . ASHBAUGH : I didn ' t have a lot to say about it . I thought the logic behind it was done well . The document was clearly written on it . I didn ' t really have a lot to comment on for it . I know Bill had something he wanted to say about it , though . DR . WEATHERS : I also didn ' t have much to add to this . Bill did mention that it was a little difficult to follow all the different forms and levels and permutations , and it would be helpful to make that clear , that pathway a little bit clearer . And it seems to me this is intimately connected again to the indices . So much of this reflection is connected to whatever is chosen for the indicator .

On question B , it seems to me the hour daily maximum form can better capture events , short

-term events ; but I don ' t have strong feelings about that either , and so I thought it was fairly clearly laid out .1

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DR . SAMET : In light of our discussion , which might at least lead to the preference for the speciated indicator , specifically in terms of the form and level , is what is there

-- do you consider it to be on target , sufficient ?

DR . WEATHER : Yes . DR . ASHBAUGH : Yeah . Yeah , I do . DR . SAMET : Okay . Others want to weigh in on this ? Tom?

MR . MOORE : So I didn ' t really feel like the document made a strong argument for a particular level in a range that was a factor of three . My

sense of things is that the level might should be at the upper end of that range as a good rather than best starting point . I don ' t have a particular number in mind, but you know, closer to 191 than 1 12 .

And on the form, I think because the visibility impacts are likely to be organized somewhat differently in different parts of the country, that looking at the entire distribution

across three years for all hours would be the way to do it rather than trying to bracket it into individual years or months or seasons or whatever . So I think that allows places

-- again , being a parochial westerner , that where you have wintertime1

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inversions that are quite strong , and those may cross

over the end of the year , I think that ' s a good way to do that . So I guess those are my comments on form and level .

MR . POIROT : I guess I would agree with Tom that I think for various reasons maybe starting towards the upper end of the levels being considered would be prudent given the uncertainties in the approach , especially with the interim process , and there ' ll still be plenty of action , even at the upper end of the range . And so I guess I would just recommend that absent any other clear basis for making a better decision , start somewhat cautiously and hope to refine things in the future .

Regarding the details of the form, I guess I ' d been one who had been arguing that it seemed to me that using all the hours at a higher percentile would be preferable , but it wasn ' t a big preference and the information presented this time around that compares these and some of the appendices has convinced me that it actually doesn ' t matter much . It ' s yet another one of those things that it actually doesn ' t matter that much . So I ' m perfectly happy with either of the worst hour of the day or the lower percentile

or the considering all hours . I just don ' t think it1

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matters .In fact , the speciation

-- that ' s what we were concerned about . Are we really going to be going after different sources by picking those two different metrics ? At least , the illustrations provided in the appendices convinced me that , no , we ' re not . We ' re going to be going after the same mix of species and the same mix of sources , so I have

no opinion on that .

MR . MOORE : John , can I just make a real quick follow

-up to Rich?

So the two operational visibility indexes used the worst hour of the daylight hours to characterize it right now . So by staying with that model , you guys would be linking this proposal to existing programs ?

DR . PITCHFORD : We had two alternatives . Each used only daylight hours . One was all hours and looked at the distribution of those and pick the top whatever percent , and the other was just the maximum daily . So each day only could contribute one hour . It couldn ' t contribute multiple hours .

MR . MOORE : The latter approach is what those two use , I think . The one , the highest hour of the daylight ?1

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DR . PITCHFORD : Right . What about it ? MR . MOORE : That ' s what they use now . DR . MARTIN : He ' s saying it relates to the current .DR . PITCHFORD . Oh, oh , I see what you ' re saying . I see , okay . I ' m with you . I didn ' t realize .DR . SAMET : Okay . Other

-- Joe ?

DR . HELBLE : I just wanted to comment briefly, offer my support for the comments that Tom and Rich just made about starting cautiously with the level at the 191 level for a different reason . Figure 4

-2 which reproduces data that were in the Science Assessment has a fairly large spread in values and it ' s based on only four studies , each of which

-- or three out of the four of which had fair amount of scatter in the data .

With only four studies , I think one can argue

we really don ' t know what the broad overall spread of the preference distributions is nationally . The 191 could be an outlier on the high side . It could also be preference studies that tolerate at the 50 percent level a much higher level of particulate concentrations . So as a first secondary standard, starting at 191 seems appropriate and prudent .1

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DR . SAMET : Phil ? DR . HOPKE : I would argue that that ' s not the way to go because then we ' re at 30 micrograms per cubic meter . And if they set the primary standard at 30 micrograms per cubic meter , there ' s no need for a secondary standard and we ' ve lost the opportunity to get our foot in the door .

DR . MARTIN : But of course , we ' re talking 24 hours versus one hour between primary and secondary standards .

MR . POIROT : And extinction versus mass . MR . MOORE : And just closer to 191 , not 191 , so . DR . HOPKE : I still think it ' s risky, and the point is I think it ' s important to set some stretch goals . So I would be much happier looking at something more of the 20 or 25 rather than . . . .

MR . POIROT : This brings up kind of a related topic , but I don ' t know how it fits the charge questions . But with an extinction indicator , no matter how you combine the other things , you ' re going to have a general pattern where there ' s a -- some level is more frequently exceeded and by larger amounts in humid eastern urban areas and, depending

on the level , less frequently or not exceeded at all1

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in drier western urban areas . That ' s inevitable . That ' s the nature of the beast and how it ' s going to go , and that ' s why I think we ' ve been arguing in past meetings of the importance of the implementation phase or the concept of a progress -based rather than threshold

-based approach . It ' s going to be critically important given that that ' s the nature of the beast . And Karen has informed us very clearly in the past that the Agency can ' t do that ; and we understand that if you can ' t do it , you can ' t do it . Nevertheless , from a science perspective that kind of

an approach would be very desirable for this kind of

a secondary standard .

DR . MARTIN : Just a point of clarification , my comment before was that you couldn ' t build a progress -- a progressive definition of a standard . You can ' t build the progress -based approach into defining the standard . But how one lays out implementation strategies to meet a secondary standard where the app doesn ' t specify specific time frames , that ' s a much more open question .

MR . MOORE : So is there room for us to recommend that you consider that in the context of the Policy Assessment as a way for the next panel to address the issue that Rich is bringing up?1

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DR . MARTIN : It ' s broader than the scope of the Policy Assessment for a standard . But if it ' s a view on implementation that the committee wishes to provide advice on , it ' s perfectly reasonable to do

so . DR . SAMET : Okay . Other comments on Charge Question 13 ?

(No response . ) DR . SAMET : So that brings us to 14 , Joe , where certainly we need to make some strong recommendations for future , I guess , applied research , in a sense . COMMENTS ON CHARGE QUESTION NO . 14 :

DR . HELBLE : Sure . The comments I ' ll make here I think came out largely and equally strongly in the context of our discussion yesterday regarding research needs for fine PM and PM10 , 2 . 5 . There ' s a fair overlap .

So just briefly, as reflected in my written comments , I thought the major areas of research and data collection needed to address the uncertainties related to a visibility

-based secondary standard were captured very nicely in section 4 . 5 of the PA . As we said in the past , it ' s a laundry list ; but the list appropriately identifies the major areas of need,1

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both in the area of visibility preference and related to methods of measurement .

In the area of visibility preference , I think all of the discussion noted by EPA, both here and in the earlier science assessment , indicate there is a strong need for additional urban visibility preference studies conducted using consistent methodology . So I ' d simply like to support that recommendation and emphasize its importance given the broad range of 50 percent acceptability values that

were discussed as possible standards based on just the four different studies that exist .

In the second category related to methods of measurement , I think there ' s been a fair amount of discussion this morning alone on the importance of moving forward with developing both methods and standards to directly measure light extinction .

I support the proposal to conduct studies in several cities where there ' s a pairing of direct monitoring of extinction with enhanced monitoring of size and composition distributions , continuous PM speciation monitoring where that can be developed, and additional work to understand the contribution of PM10

-2 . 5 in southwestern areas other than Phoenix, which came out in this suggestion

-- in this section ,1

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I would strongly recommend .

But as an overall comment , I would say that underlying this overall discussion is a clear need for better particle size composition distribution information , meaning particle composition distributions as a function of particle size . It ' s addressed in the discussions of future research needs in sections 2 . 5 and 3 . 5 . It ' s addressed here in the discussion of the importance of developing continuous monitoring methods for specific PM components , and it ' s also touched on briefly in Chapter 5 . It talks about climate and the uncertainties associated with the role of aerosols in climate forcing and the importance of understanding the distribution between scattering and absorbing aerosols , which means , again , understanding composition i s a function of size . So in terms of offering suggestions for prioritization , I would suggest that given the frequency with which that appears throughout the document , that ' s certainly something that should be

near the top of the list .

DR . SAMET : Okay . Let ' s see , we have Ted on this . DR . RUSSELL : The one thing I might add to what Joe said was , I think actually, as part of the1

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urban visibility standard, they should look at the implications of the entire urban visibility standards

on regional climate forcing . I think we do have to consider how decreased light scattering in that case might actually increase regional warming .

DR . SAMET : Okay . Phil , you ' re one of the

names here .

DR . HOPKE : Okay . Yeah . I mean , again , the key here will be to develop moving forward . It ' s time we develop then the basis for extinction FRM ' s . So you know, a key research need is obviously we ' ve just been discussing how we ' re not ready to promulgate an FRM on visibility . We haven ' t seen any activity in the last six years on that . It would be nice to see some real activity on that in the next five years ; so the next time we sit down to do this , we could roll out an extinction

-based FRM with things already on the shelf that we could pull off in terms of how we would define the performance of acceptable FRM ' s and methods for equivalency .

DR . SAMET : Tom? MR . MOORE : So I agree with everyone else ' s comments . I have an operational one . I ' d like to , again , see a kind of a linked

-up operational and research agenda for the next round of the PM NAAQS1

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review, and several colleagues have brought up specific topics that need to be addressed under that .

I think one thing we ' ve also talked about is

we really need to advance our understanding of what the objective criteria are for monitoring site selection , existing sites and networks and what they ' re trying to accomplish . I mean , this is an

ongoing activity by EPA and the states , so let ' s advance that .

And I think we need to prioritize because the PM world is pretty broad and pretty important , impacts both health and welfare and it ' s very

resource intensive . So I think a logical outcome of that , that I ' d like to identify as a research need, broadly defined, is what kind of support does it actually take to characterize PM most fully? What

are the financial or the technical constraints ? What

are the administrative support that ' s needed? You have to process and analyze those data , you have to have sufficient metadata ; and those data need to be accessible to everyone for these kind of reviews .

And then one really specific point just to amplify what Joe said is that with a tighter fine particle standard possibly and, you know, a start at

a welfare visibility standard, we have an1

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intersection for short

-lived climate forcers and what they contribute to both of those . So that ' s a real possibility to do two or three things at the same time . We strategize about that in applying the standards .

Those are my comments . DR . SAMET : Okay . Do others want to weigh in here ? Yeah, Kathleen .

DR . WEATHERS : I just want to underscore the two comments about climate and making sure that in future research needs that there is this interface with the effect of aerosols on climate . I also think that that ' s a very important topic and needs to be considered .

DR . SAMET : Okay . Rich? MR . POIROT : I agree with everyone this time and wanted to also remember a really good suggestion that Bill had earlier about an idea to try to develop

an index that would sort of cut across these different preference studies that I think is actually

a really good idea and might work well . That even as

we ' re conducting more of them and in different areas , aiming to find some commonality amongst them, I think is a really good idea , physically sound and makes

sense . So I just wanted to , since Bill ' s not here ,1

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reiterate his very good idea .

And then , as long as I ' m stealing ideas , I think Ted maybe had

-- or Phil had the idea to , even

as we ' re implementing this urban visibility pilot program, to make sure we include a component of instrument development , not just the testing of what ' s currently available .

So those were two additional things I thought could be emphasized .

DR . SAMET : Lowell ? DR . ASHBAUGH : Yeah . I just want to reiterate something that Joe Helble said also and I mentioned earlier that I think it ' s also important to do some

more development on continuous speciation measurement

so we can get that fine time increment for what ' s causing visibility reduction . That will help us so much in the future .

DR . SAMET : Ed? PROF . AVOL : So in this area , maybe more so

even than in the fine and coarse , there ' s obviously a lot of work as this develops and becomes a standard and moves forward . So again , I would just reiterate the need to prioritize , sort of , where we want to go most quickly because , obviously, there ' s a lot to do here .1

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DR . SAMET : Okay . Others ? Comments ? And so we ' ve done 14 . So I mean , maybe just to recap and then we can decide what we might or might not do

-- might or might not do next .

So I think from the outset we heard that the document , I think Rich said, took a reasonable approach . Bill thought that the array of options of indicators , levels and forms was a bit confusing . Perhaps with this discussion , you can be more focussed now in the document and indicating , perhaps , guiding the readers through what was a little bit of

a maze of choices and, perhaps , beginning with a not- so-even preference up front for the visibility

versus -- direct measurement of visibility versus options and, perhaps , put in some of the branching structure in thinking about the problem that we went through today .

The indicator question , I think, is hopefully still fresh enough in everyone ' s mind that I don ' t need to go through the details of that discussion again . But I think there , the discussion hinged on the readiness of the still

-in

-evolution light extinction methods and the lack of a federal reference method and the need then to move to what we called a bridging indicator that in reality is what1

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would come into place in the standard until it ' s replaced by something , something else , a direct light extinction measure . And we went through the two alternatives , I think in part prompted by Rich ' s comments , and ended up with the idea that the speciated approach might lead to the most accurate characterization of light extinction .

And then I think there was a sense that the document was okay in its review of the alternative levels and forms . I think there ' s a clear agenda for additional research that was stated and I think roughly agreed to by everyone and I think clarified by our discussion .

So let me ask if anybody wants to add anything , if EPA has anything else for discussion . Chris ? DR . FREY : Maybe this is a naive question or

one that has been discussed before , but in talking about the indicator , is there a -- should there be consideration given to differences in coverage of existing monitoring network, is that an issue that from a practical purpose tends to favor one over the other , or is there adequate coverage to support the speciated adjustment ?

MR . POIROT : Well , I think

-- I don ' t know .1

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We have Tim here . I think there ' s , what , 5 50 continuous fine mass sites ?

MR . HANLEY : So there ' s actually closer to 7 00 continuous fine mass , and then there ' s -- when we think of the chemical speciation network, which does not include IMPROVE , there are 20 0 stations in the United States . And then , obviously, IMPROVE has another 16 0 ; but just a handful of those are in urban

areas . I think folks are aware the IMPROVE network and the chemical speciation network, we consider them essentially equivalent in terms of the data now . So I think we ' re in pretty good shape there .

So things are in good shape , clearly . There

are going to be a few cities that if we had a strategy for targeting cities over a certain population , we might have to add speciation , maybe , like , in Austin , Texas , just as an example . I don ' t

even know that for certain . But all the big cities and most cities do have chemical speciation now as we speak . MR . POIROT : It was one reason that I suggested considering trying to do it possibly on a regional basis . It may not work out . Again , it ' s something that could be evaluated, but if you did it

on a regional basis you wouldn ' t be constrained to1

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the subset of the speciation sites that have the continuous sites .

MR . MOORE : So real quickly, you know, Rich is right ; and that might be the most practical thing to do . I think that the speciation at every site is a little different and that ' s what ' s going to be reflected in the value that ' s used to judge attainment or non-attainment , so it might be important to do it on a site

-specific basis . And just to clarify, most of the speciation monitors are running for 24 hours , one in six days . So we ' d be fitting those back to every hour , every day?

MR . HANLEY : That ' s right . There ' s about 6 0 to 7 0 that run every third day and the balance run every sixth day .

MR . MOORE : So Chris , I think that ' s why Phil ' s arguing for a -- and Lowell as well

-- a continuous speciation .

DR . SAMET : Okay . I think we are roughly done here . Karen , do you have

--

DR . MARTIN : Yes . DR . SAMET : Karen , don ' t undo us , whatever you do . DR . MARTIN : I would like to pose or just1

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share with you the thinking that we have evolved among ourselves as we ' ve been listening to the discussion today and it leads us to a process schedule kind of question .

So we are appreciative of the reflection you ' ve made and the input you ' ve given . We are certainly taking away from this support for the hybrid, quote , unquote , " simplified approach" that we put forward in this ; but we ' ve also heard suggestions about ways in which it could be further simplified . And especially, if a longer range goal is to move to

a direct light extinction measurement approach, the

more simplified an interim approach is , the more sensible it is as an interim approach . And while it

-- the more simplified versions are generally consistent with the concept we developed in the second draft , they are clearly different and in our view would warrant further evaluation .

So one of the things we ' re considering is to go back and work more broadly within the Agency, talking to our counsel as well and consider whether

or not it would be appropriate in light of the advice receiving

-- we ' ve received today to take somewhat

more time to develop another draft of a visibility policy chapter that would extend the time for that1

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-1896 (FAX) 340 analysis without holding up the progression of all the other work on the primary standards and allow for the schedule we had in place to be met from a Primary Standard perspective and potentially consider splitting off the decision

-making process and standard

-setting process by some months to allow for adequate consideration of the ideas that have been put forward here . I ' m not saying that ' s what we will intend to do , but I ' m saying that we think it ' s appropriate to give very serious consideration to that and we need to give it consideration more broadly than just those of us here at the meeting . I ' m going to ask that you would be supportive of that . And I would ask then , would you be prepared if that was the course we felt appropriate to take to review another version of a policy chapter that addresses visibility?

DR . SAMET : I think that ' s a reasonable request , presumably a telephone review would suffice . And I can understand that you might be bringing forth data that in terms of these interim options might look at , perhaps , a simpler proposal made by Rich

versus something more complicated, and I can understand that you would want to do that . I don ' t think I see any issues . It sounds like you would be1

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able to meet your requirement on the Primary Standard .

DR . MARTIN : Right . There would be no change to that process at all that we ' re envisioning at this point . MS . WEGMAN : (Microphone not used) And John , we also

-- for other requirements on the secondary as far as making some kind of decision

-- but that might be a -- MS . VU : I don ' t see any issues that we could provide given the Panel ' s willingness to review the next version of the

-- on the Secondary Standards . The only question I would have is to Ted and some of you on whether you want to invite the AAMM Subcommittee members as part of this group or just , you know, the experts on this particular panel to weigh in .

DR . RUSSELL : If we ' re talking about essentially the simplified approach versus the somewhat more involved approach, one , I don ' t think that that ' s an AAMM-type issue . It ' s not really

--

DR . VU : I know, because the AAMM Subcommittee looks at more instrumentation , performance standards .

DR . RUSSELL : Right . DR . VU : This is more a conceptual ,1

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-1896 (FAX) 342 particularly based on discussion we just had today, so it makes sense that this group would do it .

MR . MOORE : So that ' s a very nice offer . I think that moves things along without delaying it as long as the SOx, NOx secondary standards . I think that ' s what you ' re saying .

So with respect to that , how would that tie in , John , to the idea of some kind of a workshop to put together priorities and that kind of thing? I ' m wondering if we want to do that as quickly as possible while all this research stuff is kind of fresh in our minds .

DR . SAMET : Yeah . I actually see the workshop

as having a , probably, much broader agenda . Are you referring to the workshop we discussed yesterday which was sort of the more step back and reflect workshop ? So I think a little bit different agendas in my mind .

Vanessa? DR . VU : And I think what I would like to do is confer with Dan Costa and everybody else in OAQPS to talk about

-- and I do know I spoke yesterday with Karen and Lydia that the Agency plans to have a workshop in March to talk about multi

-pollutant approach in terms of research . So the question is1

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how do we best

-- CASAC , what to advise the Agency on the research portfolio and set priorities , et cetera . So we could conceivably have something in the fall to have a discussion and then the Agency ' s output of that workshop proceedings and they will have to bring back some proposal , and then we ' ll have CASAC would provide some feedback .

So but , I ' d like to talk it over to Dan and OAQPS folks and then propose a time , you know, a schedule and get feedback from the CASAC . And then also talk about how we ' re going to bring other consultants to the group because we ' re not talking about PM alone . We ' re maybe going to talk about

ozone and NOx, SOx and everything else as well because , you know, resources is not that open-ended . We have tight resources within the Agency and how do

we best serve in getting CASAC ' s advice on how the Agency should proceed . I think it ' s very important . We ' ll try to as soon as possible , but I need to confer with ORD folks and OAQPS .

DR . SAMET : Okay . I think probably Holly and I had conferred about whether we should continue on and look at the responses , but

-- yeah, that was my question .

So we have two options . One is to spend a1

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half hour looking at our responses . I don ' t think we ought to do that . I think we should talk a little bit about the schedule , though , to bring this to completion and we ' re probably, I think, close to -- coming close to the end . So I think what we should do is talk over the schedule we have .

I appreciate everybody ' s hard work . We have responses from all the different writing teams compiled . This will need, I ' m sure , some editorial work and clarifications . But that will lead to -- and preparation of the , you know, draft letter to the Administrator , the briefer letter , to accompany this that we ' ve been writing and circulation of that . And then we will need a phone call .

DR . STALLWORTH : Yes . DR . SAMET : So let ' s just think a little bit about timing . Holly?

DR . STALLWORTH : Well , we have the combined responses to charge questions . It ' s 16 pages long .

John , I think you and I would put together a letter based on these responses and I would clean this up and send it out to the Panel within a week to be discussed at a subsequent teleconference , which will be about three weeks later . Does that sound okay?1

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DR . VU : So Holly, you ' re talking about having

a public teleconference call . We ' re already the end of July, so you ' re talking about probably

-- the earliest is probably the first week of September or late August because we need to have 15 days in advance for notification and all that and giving everybody

-- you know . So I would say probably first week of September . But of course , you have Labor Day weekend, but we ' ll figure out a way to make sure that you all will have a public conference call to further discuss the draft report and concur .

DR . SAMET : So I suspect at the end of August , early July ( sic ) by the time we have to deal with the realities of scheduling a meeting . So the conference call

-- we probably won ' t need a long conference call , hopefully; but who knows . The visibility group might get going again .

DR . MARTIN : If I might just offer a comment . Obviously, given what we ' ve just talked about , our desire would be to get something as soon as possible . And if there was any way to schedule a discussion by the end of August rather than extending into September , that would be highly desirable from our perspective .

MS . WEGMAN : The schedule which I showed1

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-1896 (FAX) 346 yesterday showed the final Policy Assessment --

DR . VU : Yeah . Lydia and Karen , please don ' t worry about it . We know what you need .

The point is when we ' re going to have the public draft report from the CASAC panel , it will be two weeks in advance so you have in hand what the write

-up of this esteemed group have provided you , capture the advice . So you will have it in two weeks . MS . WEGMAN : Thank you .

DR . SAMET : Okay . So we will aim for the end of August . I think probably most people are sort of back in action the last week of August if they had disappeared on vacation .

DR . HOPKE : Except the last week of August is the International Aerosol Conference , where I assume

some of us --

DR . SPEIZER : Yeah . DR . HOPKE : -- will be going to Helsinki . DR . SPEIZER : -- is in South Korea . DR . SAMET : Yeah . The telephones have arrived in Helsinki . Think Nokia .

DR . HOPKE : Will we have a free call

- in number ? DR . STALLWORTH : Yeah, we can get you a free1

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call

-in number .

DR . VU : No problem . We have international phone calls all the time .

DR . SAMET : Okay . Any other issues to raise ? Tom? MR . MOORE : So I ' m a rookie at this stuff . So then next February, I believe , there will be a standard that ' s proposed . So what ' s our involvement at the time the standard is proposed?

DR . SAMET : So we have the option when the proposal comes out to comment and have done so in the past on such .

DR . VU : So the Agency doesn ' t request the CASAC to comment on the proposed rule . However , CASAC can provide unsolicited advice with regard to the proposed rulemaking . Yeah , so we would

-- Holly would send the proposed rule out to everyone for review and then the Chair would have input from you . If you all

-- should you wish to have a public conference call to discuss the proposed rule and provide a written comment to the Administrator , we ' ll do that . CLOSING REMARKS BY DR . SAMET :

DR . SAMET : Okay . Well , I think we ' ve reached the end of this , sort of , document journey . I think1

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I was reminded when Vanessa was talking about the start of this , it was 2007 .

DR . VU : November 2007 you all reviewed the IRP , the Integrated Review Plan .

DR . SAMET : So it has been a long time . There have been five face

-to- face meetings , innumerable drafts circulated and telephone conference calls . So I want to thank you all for your hard work and diligence . I think actually we ' ve covered some remarkably interesting and complicated issues as

we ' ve looked at what the Agency has done .

I think it ' s also worth a comment that this is the , sort of , first

-- as I mentioned yesterday, pass through this revised process . And again , if you had the longer range view from the old days when the criteria documents arrived, I think the last PM criteria document might have been roughly that thick ( indicating approximately a foot ) , and this was before documents arrived on CD ' s . So they were -- they were weighty, truly weighty documents . And you know, to go back to readable versus unreadable prose , they just were remarkably soporific , the criteria documents . I mean , if you can just imagine hundreds of pages with each paragraph beginning, you know, Russel , et al . showed; Suh, et al . showed; Vedal , et1

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al . even showed; and they were -- and then this would go on and on and on for , like , 30 pages . And then it would be , in summary, this evidence is , or something like that . And I think you ' ve moved to a much better and clearer process , I think . And then there ' s the , here are the data bases as an addition .

So I think some real advances have been made in the process and, hopefully, that will continue to be of benefit , I think, really, to , not only to the Agency, but really to the public to make clear how these decisions are being made and what the basis of evidence is . So I think that ' s been , I think, a good mutual working ground and I think one where we should all take some pride in what looks to me to be an improvement in a process that had been longstanding .

So I want to thank you for your hard work and thank the committee for your hard work . Some of us will continue to see each other as we move on . There ' s always another pollutant , apparently . And as

we move on to ozone , others , I think Joe and his team have finished up with carbon

-- with carbon monoxide .

Some of you may be sitting around the table five years from now when there ' s yet another review . Mort , no doubt , will be there offering reminders of what has transpired since

-- yeah, 197 1 , since the1

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start of history .

DR . LIPPMANN : Not quite that bad . I didn ' t get started on PM reviews until 19 8 0 . It wasn ' t in the seventies .

DR . SAMET : Well , roughly, it would be the

same . So again , I ' m not sure I plan to be there . Rogene might be .

DR . VU : Nor Vanessa . DR . SAMET : Nor Vanessa . So there may be a sweeping out of the old guard .

Again , so thanks . Vanessa , any last words here ? CLOSING REMARKS BY DR . VU :

DR . VU : Well , I just want to add and thank you so much, committee members , panel members for your extremely hard work; and I do know that the Agency has expressed their appreciation of giving valuable advice to strengthen the science and for policy decisions for the Administrator to make .

Also , I want to express my thanks to Dr . John Samet for chairing this panel

-- chairing the CASAC and then this panel as well .

I don ' t know whether Lydia and Karen may want to say something on behalf of the Agency as well .1

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CLOSING REMARKS BY MS . WEGMAN :

MS . WEGMAN : Yes . I would like to say thank you again to all of you . This has been an extremely helpful day

-and

-a-half discussion , very stimulating for us , gave us a lot to think about ; and that has been true throughout this review .

You ' ve all really devoted yourselves . You all have full

-time jobs and beyond, and we very much appreciate the fact that you ' ve taken the time to engage with us on this review . As you well know, it ' s an extremely important review, both for public health and the environment ; and your involvement will make a big difference .

I cannot tell you how many meetings I ' m in where the question is , what does CASAC say, what was CASAC ' s advice , what was CASAC ' s view on this question or that question . Your advice is absolutely essential to the work we do at the Agency, and I very much want to thank you for all your time .

And John , thank you very much for your chair of the CASAC and this committee . And Rogene , thank you for all your work . We ' re going to miss you on CASAC . So thank you .

DR . HENDERSON : And I ' ll miss you . MS . WEGMAN : So thank you all very, very much .1

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Safe travels home .

DR . SAMET : Does Karen want the last word? CLOSING REMARKS BY DR . MARTIN :

DR . MARTIN : I ' ll obviously echo the thanks ; but more mundanely, we will be back in touch with you with regard to a schedule on the follow

-up for this chapter then .

DR . SAMET : Great . Thanks . Let ' s go home . ( The meeting was adjourned at 11 : 09 a . m . )

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REPORTER : RWK DATE : 7 /26/ 2010 T R A N S C R I P T I O N C O R R E C T I O N S U . S . ENVIRONMENTAL PROTECTION AGENCY SCIENCE ADVISORY BOARD STAFF OFFICE CLEAN AIR SCIENTIFIC ADVISORY COMMITTEE ( CASAC ) PARTICULATE MATTER REVIEW PANEL PUBLIC MEETING PAGE LINE READS SHOULD READ

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STATE OF NORTH CAROLINA COUNTY OF WAKE

CERTIFICATE OF REPORTER

I , ROBIN W . KING, the reporter by whom the foregoing proceedings were taken , do hereby certify that the proceedings were taken by me in stenotype and thereafter reduced to typewriting under my direction ; that I am neither counsel for , related to , nor employed by any of the parties to the proceedings ; and further , that I am not a relative or employee of any participants thereto , nor financially

or otherwise interested in the outcome of the action .

This , the 11 th day of August , 2010 .

____________________________ ROBIN W . KING Notary Public in and for County of Wake State of North Carolina

Notary No . 200518700077 My Commission Expires July 4 , 2015

Robin W . King Bryant Court Reporting Services ( 919 ) 387

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