### 202-234-4433 Neal R. Gross & Co., Inc. Page 1 U.S. ENVIRONMENTAL PROTECTION AGENCY + + + + + CLEAN AIR SCIENTIFIC ADVISORY COMMITTEE (CASAC) NOX & SOX SECONDARY NAAQS REVIEW PANEL + + + + + MEETING

+ + + + +

FRIDAY, APRIL 2, 2010
+ + + + + The meeting convened at 8:30 a.m.

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

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

PRAVEEN AMAR

LAURAINE CHESTNUT CHARLES T. DRISCOLL, JR. PAUL J. HANSON

### 202-234-4433 Neal R. Gross & Co., Inc. Page 2 MEMBERS PRESENT (Cont.): RUDOLF HUSAR DALE JOHNSON*

NARESH KUMAR

MYRON MITCHELL

RICHARD L. POIROT

KATHLEEN WEATHERS*

SCIENCE ADVISORY BOARD STAFF:

KYNDALL BARRY, Designated Federal Officer

*Participating via teleconference

### 202-234-4433 Neal R. Gross & Co., Inc. Page 3 1 C-O-N-T-E-N-T-S
2 3 Reconvene the Panel Meeting

4 Ms. Kyndall Barry . . . . . . . . . . . .4

5 Discussion of Draft PA Responses

6 Dr. Ted Russell and Panel . . . . . . . .4

7 Wrap up

8 Dr. Ted Russell . . . . . . . . . . . .249

9 Adjournment

10 Ms. Kyndall Barry . . . . . . . . . . .250

11

12

### 202-234-4433 Neal R. Gross & Co., Inc. Page 4 1 P-R-O-C-E-E-D-I-N-G-S 2 8:32 a.m. 3 MS. BARRY: Okay, we are right at 4 the 8:30 time and aiming on an on time start 5 for this second day of the NOX and SOX 6 Secondary NAAQS Review Panel Meeting. So, I 7 would ask that everyone please join us at the 8 table so that we can go ahead and get started. 9 Thank you. 10 CHAIRMAN RUSSELL: All right. Good 11 morning. Yes, if we can get folks to the 12 table. In front of everybody you should see, 13 and also maybe -- Are we going to try 14 projecting? 15 And also in front of you should be 16 you are going to see the letter that we 17 drafted overnight and this morning that 18 summarizes our review of the first draft of 19 the policy assessment. 20 So what I would like to do is go 21 through this. And one of the things to keep 22 in mind is that the administration or the EPA,

### 202-234-4433 Neal R. Gross & Co., Inc. Page 5 1 not the administration, the EPA has requested 2 that we prioritize our recommendations just so 3 that they will know what we think are the 4 things that they really must do, should do, 5 etcetera, given the limited time. 6 So as we go through this, if 7 people can help identify what they think are 8 the primary or the priority items, action 9 items, let's try to indicate those as we go. 10 So with that, to the letter. And 11 Kyndall is trying to bring it up but we can 12 start going through it. 13 What I am going to do is ask the 14 leads again to cover their sections, which 15 means I have to remember who the leads are. 16 Well, I am the lead on the first one so while 17 we bring up the thing -- 18 So the first paragraph is just our 19 standard boilerplate. So going on the second 20 paragraph, the general idea on the second 21 paragraph, as you read through it is to say 22 that we found that the first draft of the PA

### 202-234-4433 Neal R. Gross & Co., Inc. Page 6 1 has started to lay the framework for a 2 scientifically reasoned secondary standard 3 that integrates the two criteria pollutants. 4 That we found portions to be 5 incomplete, which of course they knew coming 6 in, and some of the other parts rough. And I 7 could be more specific. I think the ones we 8 thought were the most rough at this point were 9 chapters five and six, though there were other 10 sections, too. So I wasn't going to be 11 specific on that one. 12 In general, we are supportive of 13 the APPI approach and how it integrates the 14 effects of NOX and SOX on aquatic 15 acidification. And then the comment as was 16 pointed out yesterday, since I found no better 17 place to put it, just one sentencing saying 18 that we think the g(.) term should be 19 expanded. At least my take was is that we 20 didn't think that it needed to not have the 21 two terms more explicitly. 22 Comments? Charlie.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 7 1 MEMBER DRISCOLL: So is it 2 possible to just make that a little bit more 3 explicit by just saying to show the nitrogen 4 cycling and background cation weathering 5 supply terms separately? See what I am 6 saying? It is less phrase to show the two 7 terms just to say what those two terms are. 8 Yes, to show -- I would phrase it 9 is to show the two or excuse me. To show the 10 nitrogen cycling and background cation supply 11 terms explicitly. 12 MEMBER WEATHERS: Or maybe you 13 could just say weathering. 14 MEMBER DRISCOLL: Weathering. We 15 could say weathering, if that is preferred. 16 CHAIRMAN RUSSELL: So background 17 cation weathering term? 18 MEMBER DRISCOLL: Yes; however you 19 want to phrase it. Just to make it explicit 20 what those two terms are. 21 CHAIRMAN RUSSELL: Sounds good. 22 MEMBER HUSAR: The dot, do we need

### 202-234-4433 Neal R. Gross & Co., Inc. Page 8 1 the dot there? What does that dot -- which 2 convention? 3 CHAIRMAN RUSSELL: It basically 4 means all sorts of things can go there. 5 MEMBER HUSAR: Yes, that is what I 6 mean. 7 CHAIRMAN RUSSELL: But they have 8 got it so -- In the letter we can remove it, 9 too. And hopefully the idea is that the g(.) 10 term gets lost. 11 MEMBER HUSAR: But whoever reads 12 it, you know, -- 13 MEMBER AMAR: I would think -- 14 MEMBER JOHNSON: This is Dale. 15 MEMBER AMAR: -- you know, this 16 reference to g(.) term maybe needs to come a 17 little later.18 MEMBER JOHNSON: Sorry if I am re19 treading old ground but -- 20 MEMBER AMAR: I think it is too 21 early in the morning to -- 22 MEMBER JOHNSON: -- I couldn't log

### 202-234-4433 Neal R. Gross & Co., Inc. Page 9 1 in yesterday but a couple of things, points I 2 wanted to make. 3 CHAIRMAN RUSSELL: Who is on the 4 line? Dale? 5 MEMBER JOHNSON: Hello? Yes, it 6 is Dale. 7 CHAIRMAN RUSSELL: Okay, what is 8 up? 9 MEMBER JOHNSON: Are you there? 10 CHAIRMAN RUSSELL: Yes. 11 MEMBER JOHNSON: I hope I am not 12 re-treading old ground. I probably am but I 13 couldn't log in yesterday. But a couple of 14 points that I hope came up and that was the 15 really big differences between the factors 16 affecting Nitrogen and sulfur retention in the 17 ecosystem and how that plays into the model 18 and the sensitivity. Because nitrogen is 19 controlled almost entirely by biology. And 20 the biological controlled sulfur retention is 21 minimal because there is every little 22 biological demand for sulfur comparatively.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 10 1 So the two have the same type of 2 effects, once they become acidifying but until 3 the point where they are mobile in the system, 4 they are entirely different, entirely 5 different criteria. 6 I don't know if that plays into 7 the model or that g(.) term or what. Of 8 course I missed the discussion. 9 CHAIRMAN RUSSELL: Okay, you 10 haven't missed it this morning in that we are 11 just starting. 12 MEMBER JOHNSON: I know. But 13 yesterday I don't know what came up. I 14 couldn't log in. 15 DR. HUBBELL: Would you like me to 16 answer, Dr. Russell? 17 MEMBER JOHNSON: Maybe it is too 18 late to get into this sort of stuff. If so, 19 that's all right. 20 MEMBER WEATHERS: Dale, I think 21 some of those comments show up later on in the 22 letter in answer to specific charges.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 11 1 MEMBER JOHNSON: Okay. 2 CHAIRMAN RUSSELL: So Dale, do you 3 have both? Do you have the letter and the 4 answer to the specific charges? 5 MEMBER JOHNSON: Well I have what 6 Paul sent last night and -- 7 CHAIRMAN RUSSELL: Do you have -- 8 MEMBER JOHNSON: -- I have other 9 things. 10 CHAIRMAN RUSSELL: -- what Kyndall 11 sent this morning? 12 MEMBER JOHNSON: Yes. 13 CHAIRMAN RUSSELL: Okay. 14 MEMBER JOHNSON: But I only see 15 one thing there. 16 CHAIRMAN RUSSELL: In terms of? 17 MEMBER JOHNSON: I see the letter. 18 CHAIRMAN RUSSELL: But there 19 should be some responses to the charge 20 questions attached to that. 21 MEMBER JOHNSON: Oh, yes. Down 22 the list.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 12 1 CHAIRMAN RUSSELL: Yes. 2 MEMBER JOHNSON: Yes, they are. 3 CHAIRMAN RUSSELL: Okay. 4 MEMBER JOHNSON: Sorry. It is a 5 little early here for me. 6 CHAIRMAN RUSSELL: We understand. 7 So Praveen, actually I am game to 8 move it somewhere else. It is just it would 9 be a stand-alone sentence. I didn't see where 10 else to put it. 11 MEMBER JOHNSON: Oh, that's okay. 12 I am just -- 13 MEMBER AMAR: We might come to a 14 point of place as we go over this letter 15 because we also are mentioning that they have 16 got to handle ammonia differently, too. So I 17 think maybe when we talk about this equation - 18 - 19 MEMBER WEATHERS: Praveen, could 20 you talk into the mike, please? 21 MEMBER AMAR: Yes, I would think 22 we have to say something about g(.) but where

### 202-234-4433 Neal R. Gross & Co., Inc. Page 13 1 we say it, placement, I think it will be clear 2 while we go through this. 3 CHAIRMAN RUSSELL: Okay. So that 4 is your job is to figure out a better place 5 for this sentence. 6 MEMBER AMAR: But it is important. 7 I think maybe not this early in the letter. 8 That is what I was saying. 9 CHAIRMAN RUSSELL: Don't take it 10 out. Just highlight it. 11 Third paragraph. There we go. 12 This paragraph has to do with our 13 recommendation that they need to more 14 comprehensively treat uncertainty. And then 15 also to add a sensitivity analysis. 16 My thought in writing this 17 paragraph was again that the uncertainty 18 chapter should be a stand-alone chapter but I 19 think the sensitivity analysis on their API 20 equation really should come as part of Chapter 21 5 to better explore its sensitivities right 22 when they bring it up.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 14 1 I should also say that hopefully 2 on Chapter 5 they don't end sort of on the -- 3 right when they bring up that equation and 4 explain it more thoroughly. 5 MEMBER MITCHELL: And I thought we 6 talked about the developing of this completely 7 separate chapter. 8 CHAIRMAN RUSSELL: Microphone. 9 MEMBER MITCHELL: Sorry. I 10 thought we talked about developing a separate 11 chapter just based upon sensitivity analysis. 12 Does that preclude that or would this just be 13 introducing that? 14 CHAIRMAN RUSSELL: Okay, this is 15 something -- The separate chapter was going to 16 be the uncertainty analysis. 17 MEMBER MITCHELL: Okay. 18 CHAIRMAN RUSSELL: But if you 19 want, I was just thinking and I am open to go 20 either way on this one is that I thought that 21 it might actually be good to do the 22 sensitivity -- Who is calling me at this hour?

### 202-234-4433 Neal R. Gross & Co., Inc. Page 15 1 It might be good to have the 2 sensitivity analysis at the same time that 3 they present the AAPI equation. What do 4 people think? 5 It could also just refer to the 6 sensitivity analysis as part of the 7 sensitivity -- The sensitivity analysis is the 8 first part of the uncertainty analysis. I am 9 game either way. What do you think would be 10 most effective? 11 MEMBER HUSAR: With the 12 uncertainty. 13 CHAIRMAN RUSSELL: You want it 14 with the uncertainty? 15 MEMBER HUSAR: Yes. It is part of 16 -- I mean that is one part of uncertainty. 17 CHAIRMAN RUSSELL: Okay. So, -- 18 MEMBER HANSON: I have one minor 19 word choice, at the risk of being too 20 specific. At least in the hard copy, it is on 21 line 43 up on the screen. I think we are in 22 the same place, I guess.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 16 1 We recommend that a chapter be 2 devoted to an assessment. I'm sorry. Next 3 line down. 4 We recognize that a probabilistic 5 uncertainty analysis is likely not 6 appropriate. I think it is always 7 appropriate. I wonder if not possible is what 8 you mean. 9 CHAIRMAN RUSSELL: Practical. 10 MEMBER HANSON: Practical? Okay. 11 CHAIRMAN RUSSELL: You know, it is 12 probably possible in some universe. 13 MEMBER AMAR: Can I suggest one 14 thing to be parallel to Charlie's questions? 15 Your first sentence talks about uncertainty 16 analysis. The question is, relative to the 17 conceptual design of this ecologically 18 relevant multi-pollutant standard, are their 19 potential implication for the secondary 20 standard. I think I mentioned that yesterday. 21 You have got to say what exactly you are 22 looking for, not just the uncertainty but the

### 202-234-4433 Neal R. Gross & Co., Inc. Page 17 1 implications of the uncertainties and how the 2 secondary standard will be -- 3 CHAIRMAN RUSSELL: So this would 4 go right after analysis. Right?
5 MEMBER AMAR: Yes. 6 CHAIRMAN RUSSELL: And so do you 7 want to give the words to Kyndall? 8 MEMBER AMAR: Yes. Uncertainty 9 analysis of the proposed approach, in terms of 10 its implication for the secondary standards. 11 I am paraphrasing the question as it was asked 12 of us. 13 CHAIRMAN RUSSELL: So then also 14 let's -- we are supposed to remove. This can 15 first be presented in Chapter 5. It would 16 just be sensitivity analysis of the AAPI 17 equation should be performed. The whole 18 sentence out. 19 Naresh? 20 MEMBER KUMAR: So I guess what we 21 just added what Praveen just added, are we 22 saying that implications for the secondary

### 202-234-4433 Neal R. Gross & Co., Inc. Page 18 1 standard is not practical at this time or do 2 we want them to? 3 CHAIRMAN RUSSELL: No, no, no. 4 Actually you put that in the wrong place. It 5 should go right after the first analysis. 6 MEMBER AMAR: Yes, at the end of -
7 - 8 CHAIRMAN RUSSELL: So line 43, the 9 first word. 10 MEMBER AMAR: That is where it 11 should go. 12 CHAIRMAN RUSSELL: That is where. 13 MEMBER KUMAR: And also I guess 14 continuing the sentence, line 45, when you say 15 a more qualitative approach is reasonable, 16 isn't the sensitivity analysis trying to 17 quantify the effect actually? 18 CHAIRMAN RUSSELL: Yes, actually 19 this is where putting the sensitivity analysis 20 into the uncertainty analysis sort of blends 21 the two. And the sensitivity analysis can be 22 quite quantitative.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 19 1 MEMBER AMAR: And what you are 2 saying is that we don't want common approaches 3 here. Right? But still -- 4 MEMBER KUMAR: Yes, but still -- I 5 mean the sensitivity analysis part of 6 uncertainty analysis and it is going to give 7 some quantitative information. 8 CHAIRMAN RUSSELL: So actually we 9 could just kill anything after the first 10 comma. 11 MEMBER AMAR: What about instead 12 of saying a more qualitative approach is 13 reasonable, what if you say a less rigorous 14 approach? That still allows quantitative but 15 not as rigorous as this probabilistic 16 uncertainty analysis. 17 MEMBER KUMAR: Well I think just 18 leaving it at this point, too, because we are 19 not asking them to do a probabilistic 20 analysis. We don't have to get into whether 21 it is rigorous or not. I think whatever is 22 done should be rigorous.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 20 1 CHAIRMAN RUSSELL: Paul? 2 MEMBER HANSON: Just at the end of 3 that paragraph, we are sort of endorsing the 4 use of the VNOy and the VNOx terms, the way it 5 is written. And I thought it was quite clear 6 yesterday that people didn't like that 7 terminology. 8 CHAIRMAN RUSSELL: Oh, in terms 9 that we want a different -- 10 MEMBER HANSON: Yes, use something 11 else. Don't substitute V for which people 12 associate with deposition velocity with these 13 terms, which means something else. Was that 14 not a -- 15 CHAIRMAN RUSSELL: Yes, we are 16 recommending that they change that but we 17 haven't told them what to. So how else do we 18 refer to it in the letter? What are currently 19 the VNOy and -- 20 MEMBER HANSON: Yes, I mean, I 21 think it is open to their creativity but it 22 could be something else, anything else.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 21 1 MEMBER DRISCOLL: Could we put in 2 parentheses after indicating those terms the 3 panel recommends that these terms be changed 4 for clarity?
5 CHAIRMAN RUSSELL: Yes. 6 MEMBER DRISCOLL: Also, there is a 7 typo there. Potential "rages". "Ranges," 8 right? Is that the last line? 9 CHAIRMAN RUSSELL: Whichever you 10 choose. I could be how the panel thinks. 11 MEMBER POIROT: Seems like the 12 report itself was proposing to use a different 13 terminology than they had previously. I 14 forget what it was but calling it -- 15 CHAIRMAN RUSSELL: A deposition 16 ratio? 17 MEMBER POIROT: Ratio, yes. 18 MEMBER AMAR: But that could be 19 DTR. 20 MEMBER POIROT: I don't think we 21 need to tell them what to change it to. 22 CHAIRMAN RUSSELL: And I would say

### 202-234-4433 Neal R. Gross & Co., Inc. Page 22 1 the panel recommends the V terms, in 2 parenthesis be explicit which terms we are 3 talking about. 4 MEMBER KUMAR: You mean in quotes? 5 CHAIRMAN RUSSELL: What? 6 MEMBER KUMAR: Did you mean V in 7 quotes? 8 CHAIRMAN RUSSELL: Yes, just to 9 say that it is the "V" that is ambiguous or 10 misleading. 11 Other comments on this one? Next 12 paragraph. 13 This paragraph deals with wanting 14 a more comprehensive evaluation of CMAQ being 15 shown. In particular, how well CMAQ simulates 16 deposition. 17 MEMBER POIROT: Just I was 18 thinking, Ted, the end of that preceding 19 paragraph might be the place for Praveen to 20 move the g(.) sentence to. 21 CHAIRMAN RUSSELL: Okay. 22 MEMBER WEATHERS: The last phrase

### 202-234-4433 Neal R. Gross & Co., Inc. Page 23 1 in that paragraph is a little awkward. And 2 then the uncertainty chapters should use this 3 information in assessing uncertainties as 4 well? 5 CHAIRMAN RUSSELL: Say that again, 6 Kathy? 7 MEMBER WEATHERS: The last phrase 8 in that paragraph is a little bit awkward. 9 CHAIRMAN RUSSELL: The "and can be 10 used to define the potential ranges?" Oh, the 11 next one. 12 MEMBER WEATHERS: Oh no, sorry. I 13 thought we were on the next. 14 CHAIRMAN RUSSELL: We are. 15 MEMBER WEATHERS: So it is the 16 phrase, "and then the uncertainty chapters 17 should use this information in assessing 18 uncertainties as well." I don't have a really 19 good fix at the moment but it is kind of 20 awkward. 21 CHAIRMAN RUSSELL: Okay. And 22 let's -- Before getting to that, is everyone

### 202-234-4433 Neal R. Gross & Co., Inc. Page 24 1 comfortable with what it is trying to say even 2 though I have put it rather awkwardly? 3 Naresh? 4 MEMBER KUMAR: How about the 5 uncertainty chapter should include this 6 information in overall assessment of 7 uncertainty? 8 CHAIRMAN RUSSELL: So you can get 9 rid of then the uncertainty chapter should use 10 this information. Okay. But people are 11 onboard with what it is saying? 12 MEMBER KUMAR: Yes. 13 CHAIRMAN RUSSELL: Myron. 14 MEMBER MITCHELL: I would suggest 15 that within this paragraph on line nine 16 instead of saying model quantities, I would 17 say model estimates. 18 And then the next sentence, "Such 19 estimates should include the components for 20 both wet deposition and dry deposition 21 fluxes." It is a little confusing as it is 22 right now, Ted.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 25 1 CHAIRMAN RUSSELL: Okay. Should 2 include the components -- 3 MEMBER MITCHELL: Of wet 4 deposition and dry deposition fluxes. Right? 5 You have a whole bunch of levels of 6 uncertainty depending on concentration 7 estimates versus the -- 8 CHAIRMAN RUSSELL: Okay. Wet and 9 dry deposition fluxes. 10 MEMBER MITCHELL: Right, that will 11 do it. 12 MEMBER WEATHERS: I like that. 13 MEMBER MITCHELL: And get rid of 14 then and simulated concentrations of -- 15 CHAIRMAN RUSSELL: Well I think 16 actually, I am game to get rid of it but 17 before you get rid of it, I think you want to 18 have those as well because they, in terms of 19 estimating the, relating the deposition to the 20 concentrations, at least I would want to know 21 that the concentrations are being simulated 22 relatively well as well.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 26 1 MEMBER MITCHELL: I guess I 2 thought that was implicit. Such estimates 3 include the components, which include both 4 concentration -- 5 CHAIRMAN RUSSELL: Okay, yes. 6 MEMBER MITCHELL: That was my -- 7 CHAIRMAN RUSSELL: I guy that. 8 MEMBER WEATHERS: Yes, I agree 9 with Myron. 10 CHAIRMAN RUSSELL: I buy that. 11 MEMBER MITCHELL: Yes, but get rid 12 of that. 13 MEMBER KUMAR: Should we include 14 that in parentheses after components was 15 clear? 16 MEMBER MITCHELL: We could do that 17 easily. No problem. 18 CHAIRMAN RUSSELL: Okay. Other 19 questions or comments on this paragraph? 20 MEMBER HUSAR: Is that deposition 21 fluxes or maybe rates? 22 CHAIRMAN RUSSELL: Fluxes or

### 202-234-4433 Neal R. Gross & Co., Inc. Page 27 1 rates? 2 MEMBER WEATHERS: Yes. It would 3 be a flux of a deposition. 4 MEMBER HUSAR: Well, flux is per 5 unit area. Rate is overall. 6 CHAIRMAN RUSSELL: Okay. I see 7 what you are saying but you know, usually the 8 measurement and the simulations and the 9 measurements, there is -- 10 MEMBER HUSAR: Depending on where 11 you use it makes no difference. But they are 12 two different concepts. But either one of 13 them is okay if that is how those rates are 14 exposed. So, no problem. 15 CHAIRMAN RUSSELL: I am game to go 16 either way on that one. 17 MEMBER HUSAR: If that is a term 18 that is used in the report then we should use 19 flux. 20 CHAIRMAN RUSSELL: I think they 21 do. We can check that out. They actually may 22 use rates in the report.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 28 1 Okay. Next -- 2 MEMBER POIROT: So in the g(.) 3 sentence, we can take out the -- 4 CHAIRMAN RUSSELL: Oh, yes. 5 MEMBER POIROT: We could say just 6 the panel also recommends, instead of "we do 7 recommend however." 8 CHAIRMAN RUSSELL: Yes. 9 MEMBER HUSAR: And if we use "V" 10 in quotes, then we could put "G" in quotes on 11 that. 12 CHAIRMAN RUSSELL: Yes. 13 MEMBER DRISCOLL: Should we 14 clarify that a little bit more and say the "g" 15 term of the whatever it is, AAPI equation, so 16 they shifted gears a little bit here? 17 MEMBER AMAR: We might say natural 18 background term or natural background ANC 19 term. That is what "g" is. 20 CHAIRMAN RUSSELL: So it would be 21 the natural background -- 22 MEMBER AMAR: That is right here.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 29 1 Define natural background ANC. It has got two 2 more components. 3 MEMBER HANSON: I like "G term". 4 I like leaving it as the "G term" better 5 simply because the primary point that we 6 brought up yesterday was that there is a lot 7 of complexity in the "G term" and throwing it 8 all into the phrase "natural background" 9 doesn't capture that. 10 CHAIRMAN RUSSELL: Okay. 11 MEMBER HANSON: Meaning, we want 12 them to fix that. 13 CHAIRMAN RUSSELL: All right, 14 moving on to the next paragraph, line 15. 15 Yes? 16 MEMBER HANSON: I like the first 17 sentence and I have suggestions for the second 18 sentence and then -- 19 CHAIRMAN RUSSELL: Give it to us. 20 MEMBER HANSON: -- an addition. 21 So I will just read what I think 22 would make a better second sentence. The PA

### 202-234-4433 Neal R. Gross & Co., Inc. Page 30 1 should include a succinct discussion of2 potential benefits from NOx deposition to N3 limited ecosystems, period. 4 CHAIRMAN RUSSELL: Okay, the 5 panel, the PA should -- 6 MEMBER HANSON: The PA should 7 include a succinct discussion -- 8 CHAIRMAN RUSSELL: Hold on. Slow 9 down. Of potential benefits? 10 MEMBER HANSON: Of potential 11 benefits from NOx deposition to N-limited 12 ecosystems. 13 CHAIRMAN RUSSELL: Potential 14 benefits of NOx to N-limited ecosystems. 15 MEMBER HANSON: And then you would 16 delete the rest and then I have a replacement 17 sentence, -- 18 CHAIRMAN RUSSELL: Okay. 19 MEMBER HANSON: -- which is a 20 little long. So you might listen to it before 21 typing it in. 22 CHAIRMAN RUSSELL: Oh, she will

### 202-234-4433 Neal R. Gross & Co., Inc. Page 31 1 type. We will listen. 2 MEMBER HANSON: And this reflects 3 me, obviously. And you guys will have to 4 decide whether you agree. 5 "The panel would like to see a 6 quantification of the percent of U.S. lands 7 likely to be enhanced by N-fertilization, 8 those adversely impacted by N-enrichment, and 9 those largely insensitive to either effect 10 under current levels of input." 11 CHAIRMAN RUSSELL: Quantification 12 of the percent of land -- 13 MEMBER HANSON: Percent of U.S.14 lands likely to be enhanced by N15 fertilization. 16 DR. HUBBELL: Can I ask for a 17 clarification on that? 18 CHAIRMAN RUSSELL: We'll let Tina 19 finish typing and keep going. 20 DR. HUBBELL: It's just that last 21 sentence, the thing you are asking for, it is 22 not clear to us at all how we would actually

### 202-234-4433 Neal R. Gross & Co., Inc. Page 32 1 proceed to do that. 2 MEMBER HANSON: Well I think that 3 is the crux of a lot of the discussion that we 4 were having is that the document is currently 5 written and based on emphasizing sensitive 6 systems. This is a sentence asking you to 7 characterize for the administrator, the public 8 and the panel, how much of the U.S. land are 9 we talking about? 10 DR. HUBBELL: Well we could do 11 probably the opposite a little better, which 12 is to say we certainly know which areas are 13 sensitive or more likely to be sensitive to 14 the adverse effects. But knowing of the 15 remaining lands which ones are likely to 16 benefit from additional NOx deposition, that 17 is not something where there is a lot of data 18 because people aren't generally looking at 19 that. 20 MEMBER MITCHELL: I agree. I 21 think that obviously that would be a nice 22 piece of information to have. But I think

### 202-234-4433 Neal R. Gross & Co., Inc. Page 33 1 that the task of doing that would be immense. 2 And therefore, just by defining the percentage 3 of sensitive land, at least keep things 4 bounded. 5 DR. HUBBELL: Yes, and we could 6 certainly do that in a much more robust way in 7 laying out what percent of the lands are 8 likely to benefit from decreases in NOx and 9 SOx but I don't know that we can say the 10 converse with as much confidence. 11 MEMBER DRISCOLL: I also have 12 concerns that there could be sort of 13 conflicting patterns and it really depends on 14 judgment. So in other words, there is 15 undoubtedly going to be carbons that keep 16 sequestration most places and that is going to 17 be viewed as positive. But then there could 18 be species changes which could be positive, 19 could be negative, depending on the 20 individual's perspective. 21 DR. HUBBELL: So just a little, if 22 you could clarify a little bit how you want it

### 202-234-4433 Neal R. Gross & Co., Inc. Page 34 1 -- 2 MEMBER HANSON: Well it is what 3 the panel wants to say not what I want to 4 say. 5 CHAIRMAN RUSSELL: Dale? 6 MEMBER JOHNSON: Well, I think it 7 would be nice to have that. And I just don' 8 know. I kind of agree with the EPA this time, 9 believe it or not, that it would be kind of 10 difficult to do. I mean, you know 11 historically, the literature indicates that 90 12 percent of terrestrial ecosystems in Europe 13 and the U.S. and North America are nitrogen 14 deficient. But how you put that on a map, I 15 don't know. And the other thing is a growth 16 response increases may not be desirable in a 17 wilderness area, even though they are changing 18 and growth is faster. Maybe you don't want 19 anything to happen there. I don't know. 20 Certainly in commercial forests, I 21 said something the other day, yesterday on 22 nitrogen fertilization in commercial forests

### 202-234-4433 Neal R. Gross & Co., Inc. Page 35 1 and atmospheric deposition can definitely 2 contribute to that. Now whether it really 3 does or not, who knows? But the numbers 4 indicate that it could. So I don't know if 5 you can go much beyond that and just say there 6 are possibilities for benefits which so far 7 haven't been really addressed but have been 8 kind of dismissed, summarily. And they really 9 need to be addressed and say well, it could 10 be. 11 I think the wording as it is now 12 is okay with me, really. 13 CHAIRMAN RUSSELL: Okay but it is 14 gone. 15 So, I think what I am hearing is 16 we could end the PA should include a succinct 17 discussion of the potential benefits of NOx 18 deposition to N-limited ecosystems. 19 MEMBER JOHNSON: Yes. Yes, that 20 would work for me. 21 I appreciate Paul's point, though. 22 I mean, if you actually have the information

### 202-234-4433 Neal R. Gross & Co., Inc. Page 36 1 to quantify this area, you will find that a 2 very large proportion of the country would 3 find growth increases with nitrogen 4 deposition. Some people might like it. Some 5 people might not like it. But probably even 6 in the desert, you get growth increases with 7 nitrogen deposition and we don't always like 8 it. And I am not sure how to map that. 9 MEMBER HANSON: Well I don't think 10 mapping is a particular requirement. This is 11 just my reaction to the way the document was 12 written in the first draft, where everything 13 seemed to apply to all ends. 14 MEMBER JOHNSON: Well, I agree 15 with that. You know, as you well know, I 16 totally agree. 17 MEMBER KUMAR: How about the 18 converse of what Paul was saying? I mean, 19 that is something that EPA can do. It would 20 still be useful information to know what 21 percentage of land is sensitive. So would you 22 agree to have that?

### 202-234-4433 Neal R. Gross & Co., Inc. Page 37 1 CHAIRMAN RUSSELL: Sure. I am 2 still worried that that would still kind of 3 come out as a bias in that it still emphasizes 4 the sensitive ecosystems. But as long as it 5 is put in the context of trying to reduce the 6 apparent bias in the current document, I think 7 it does, that would help. 8 Rich and then Praveen. 9 MEMBER JOHNSON: Could you repeat 10 that? I couldn't quite hear you. 11 CHAIRMAN RUSSELL: What I was 12 saying that is so what Naresh said was that 13 EPA could provide the percent of land that is 14 sensitive to nitrogen deposition or adversely 15 impacted by nitrogen deposition. 16 MEMBER JOHNSON: Even that is kind 17 of tricky because you know, sensitive to acid 18 deposition in what way? I don't know. 19 CHAIRMAN RUSSELL: Right. 20 MEMBER JOHNSON: I mean, growth 21 increases, not desirable, or -- it is kind of 22 tricky.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 38 1 I think more of a generic, here 2 are the pluses and here are the minuses 3 statement. And there are review articles, 4 many of them, that talk about the generality 5 of nitrogen deficiency you could site. You 6 know, they have been around for a long time 7 and kind of leave it at that. 8 CHAIRMAN RUSSELL: Rich? 9 MEMBER POIROT: I guess I was 10 wondering about the concept of beneficial. 11 Does that apply to other than agricultural and 12 forestry activities? Like outside of those 13 applications, beneficial is a little bit of an 14 odd choice. 15 Outside of those applications, you 16 might include additional discussions of carbon 17 fixation or something like that. But is there 18 a concept of beneficial that is external to 19 agriculture and forestry places where people 20 can make money out of growing things faster? 21 CHAIRMAN RUSSELL: So I think, I 22 mean in terms of response to you, Rich, is we

### 202-234-4433 Neal R. Gross & Co., Inc. Page 39 1 are not, I think that is one reason why we 2 killed the latter part -- that latter 3 sentence. 4 MEMBER POIROT: I don't understand 5 what the benefit to an ecosystem is -- 6 CHAIRMAN RUSSELL: Oh. 7 MEMBER POIROT: -- of growing 8 faster. 9 MEMBER DRISCOLL: It can produce 10 more fish, if you want. 11 MEMBER POIROT: It could be 12 agriculturally this is -- 13 MEMBER DRISCOLL: You can grow 14 certain types of fish, if you like certain 15 types of fish. You know, so it is entirely a 16 judgment situation. Right? 17 MEMBER JOHNSON: Yes. So the same 18 with the growth. Some people don't want more 19 growth and commercial forestry's people do 20 want more growth. Something that is not in 21 here really at all, not hardly at all is the 22 effects of nitrogen deposition on insect and

### 202-234-4433 Neal R. Gross & Co., Inc. Page 40 1 disease. It can go in either direction. Some 2 bugs really love that high protein foliage. 3 The more nitrogen deposition is going to make 4 him really start gobbling it up. And on the 5 other hand, it increases the vigor of the 6 vegetation to resist pest and pathogens. So 7 that is a whole other area. 8 CHAIRMAN RUSSELL: Okay. 9 MEMBER HANSON: I mean, I don't 10 think all of that is involved. I just think 11 we should remind ourselves that this is a 12 standard to protect human welfare. And human 13 welfare isn't just viewed form the ecosystem 14 perspective. It can be -- Productivity is 15 part of that mix. 16 CHAIRMAN RUSSELL: Any -- 17 MEMBER AMAR: I am just having 18 trouble with the first part of that paragraph. 19 CHAIRMAN RUSSELL: That is the 20 part that Paul liked. 21 MEMBER AMAR: I know. 22 (Laughter.)

### 202-234-4433 Neal R. Gross & Co., Inc. Page 41 1 MEMBER AMAR: And we are panel. 2 So I think you know, when you say panel 3 continues to be concerned, I am not. And I 4 think what we need to say there instead of 5 that we are, because that implies there is 6 this bias which is apparent, but that is what 7 the charge, as I understand it, of EPA is. 8 That is, to look at the adverse impacts and 9 then what to do about those sensitive areas. 10 So, I might say you know, the 11 panel acknowledges or the critical thought 12 that was the focus of this work is indeed on 13 presentation results related to adverse 14 impact. 15 I am not concerned, I would not 16 even call it apparent bias. It is simply what 17 the EPA charge, I think, is. So that is what 18 I think they are doing. 19 Now we may want to acknowledge it. 20 That is what they are doing and they should be 21 doing some other things, too. But I think, 22 you know, what they are doing, what they are

### 202-234-4433 Neal R. Gross & Co., Inc. Page 42 1 required to do, as I see it. So I am not 2 concerned. I don't think it is an apparent 3 bias. They are doing what their mission is. 4 Now that is what I think. If you 5 want to acknowledge it but don't call it bias 6 or apparent or be concerned about it. You 7 acknowledge it, you recognize it, but then 8 move on. 9 MEMBER HUSAR: If the word 10 potential benefit could be replaced by 11 consequences of NOx enrichment, would that 12 eliminate the beneficial question. 13 MEMBER JOHNSON: Sorry, I can't 14 hear a thing. 15 MEMBER HUSAR: Well one way to 16 respond here is that instead of saying 17 potential benefits of NOx deposition, include 18 a succinct discussion on the consequences of 19 NOx enrichment, which is more neutral but it 20 still says that it is the opposite. 21 MEMBER WEATHERS: I like that 22 rephrasing.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 43 1 MEMBER HUSAR: No, no. Enrichment 2 is not enough. 3 CHAIRMAN RUSSELL: So you are 4 shaking your head about what you just said?
5 MEMBER HUSAR: Yes. 6 CHAIRMAN RUSSELL: Okay. 7 MEMBER HUSAR: I said I disagree 8 with myself. 9 CHAIRMAN RUSSELL: Okay. When you 10 are done with the discussion, you can -- 11 (Laughter.) 12 MEMBER HUSAR: I will let you know 13 the outcome. 14 CHAIRMAN RUSSELL: What was that? 15 MEMBER HUSAR: I will let you know 16 the outcome of my discussion. 17 CHAIRMAN RUSSELL: Okay. 18 MEMBER AMAR: Seriously, the first 19 sentence. I mean -- 20 CHAIRMAN RUSSELL: Yes, I see what 21 you are saying. And I am just -- if the 22 majority of the panel thinks we are concerned

### 202-234-4433 Neal R. Gross & Co., Inc. Page 44 1 about apparent bias and those are too strong 2 words, then you know, I mean, I am the 3 minority but if many of us don't think that 4 sentence kind of captures what you are trying 5 to do -- 6 MEMBER DRISCOLL: So Praveen, do 7 you have some suggested alternative wording 8 besides bias? 9 MEMBER AMAR: I mean I did suggest 10 that panel acknowledges the focus of this REA 11 on adverse impacts and then go on to say what 12 you are saying. Maybe they should do some 13 other things, too like -- 14 MEMBER JOHNSON: I can't hear. 15 I'm sorry. Not a word. 16 CHAIRMAN RUSSELL: So you want to 17 -- 18 MEMBER AMAR: Okay, I was saying 19 panel acknowledges that the focus of this PA 20 is on adverse impacts and NOx and SOx 21 deposition. I mean, we acknowledge it. That 22 is what I am saying. I don't want to say --

### 202-234-4433 Neal R. Gross & Co., Inc. Page 45 1 MEMBER JOHNSON: Well we can 2 acknowledge that but I don't agree with it. 3 I think it is, like I said the other day, I 4 think that if you focus on only the negative, 5 then somebody at a higher level is going to 6 focus on the whole picture, both sides of it. 7 Somebody has to do it. 8 I just don't -- I don't see the 9 logic of focusing only on one side of an 10 issue, if this is supposed to be a scientific 11 document. I don't understand that. 12 MEMBER AMAR: So I think that the 13 answer to that may be right after this 14 sentence where we say we acknowledge the focus 15 of this document on adverse impacts. Then 16 what I think what language was being suggested 17 but it should also look at other things. I 18 don't have the right words but I think it says 19 we recognize it but you have got to do some 20 other things, which is saying we are concerned 21 and you have apparent bias. 22 And I am thinking most probably

### 202-234-4433 Neal R. Gross & Co., Inc. Page 46 1 they are doing what they are supposed to do 2 under their charge. 3 MEMBER CHESTNUT: Does it help if 4 we add adverse impacts in deposition and 5 sensitive ecosystems? I kind of like where 6 Praveen has gone with this.
7 CHAIRMAN RUSSELL: Yes. 8 MEMBER CHESTNUT: Yes. If we can 9 -- 10 MEMBER JOHNSON: Well if that is 11 what -- That gets to the philosophical 12 question of what are you trying to protect? 13 Are you going to protect the very sensitive 14 ecosystems and regulate for that or is it 15 going to be more of the weighted average over 16 the whole country type of thing? And I don't 17 know the answer to that. 18 CHAIRMAN RUSSELL: So what if we 19 do it, pick up as you see in front of you 20 except for those, I don't think the people on 21 the phone can see this so I will say it. The 22 panel acknowledges the focus of the PA is on

### 202-234-4433 Neal R. Gross & Co., Inc. Page 47 1 the adverse impacts of NOx and SOx deposition 2 in sensitive ecosystems. 3 Now what I would propose is that 4 then we go "However, the PA should include a 5 succinct discussion of potential benefits of 6 NOx deposition to N-limited ecosystems. 7 MEMBER JOHNSON: I will buy that, 8 yes. 9 CHAIRMAN RUSSELL: Rudy? 10 MEMBER HUSAR: Oh, I just finished 11 my discussion. 12 CHAIRMAN RUSSELL: Okay. 13 MEMBER HUSAR: We came up with, 14 what about non-adverse effects? 15 CHAIRMAN RUSSELL: Oh. 16 MEMBER HUSAR: Because it becomes 17 a problem of defining what benefit is. 18 CHAIRMAN RUSSELL: Right. 19 MEMBER HUSAR: But if you do know 20 how to define adverse, then whatever else is 21 out there. It is just a suggestion. 22 CHAIRMAN RUSSELL: So using my

### 202-234-4433 Neal R. Gross & Co., Inc. Page 48 1 southern lingo now, I like what you all came 2 up with. 3 (Laughter.) 4 MEMBER JOHNSON: Well not adverse 5 would be nothing. So I don't agree with that. 6 CHAIRMAN RUSSELL: Hmm. 7 MEMBER AMAR: Why don't we just 8 drop the word non-adverse? Because we are 9 talking potential benefits right after that. 10 So that is benefits like a non-adverse. 11 MEMBER JOHNSON: I think that is - 12 - because you are going to have adverse 13 effects or nothing implied. And you know, 14 there are potential benefits. They are there. 15 Now you know, I can be out-voted. 16 So be it but that is my opinion. I think it 17 should be mentioned and discussed. Somebody 18 is going to bring it up besides me. 19 CHAIRMAN RUSSELL: What does the20 panel think? Potential or adverse -- non21 adverse? 22 MEMBER HANSON: Is it the word

### 202-234-4433 Neal R. Gross & Co., Inc. Page 49 1 benefits that is the problem for some people? 2 MEMBER JOHNSON: It seems to be. 3 MEMBER HANSON: Can you substitute 4 the potential fertilization effects just to be 5 more -- or is that not inclusive enough? 6 MEMBER MITCHELL: I would just 7 take off potential. 8 MEMBER JOHNSON: That would work. 9 MEMBER MITCHELL: We know what 10 these are really. Potential -- it says 11 discussion of benefits of NOx. I think that 12 keeps the sentence in balance. 13 We can also talk about the 14 potential adverse impacts. Why have the 15 potential on one side and not the other? 16 MEMBER JOHNSON: I couldn't hear 17 you Myron. Sorry. 18 MEMBER MITCHELL: I'm sorry. 19 Within the sentence right now, the sentence 20 reads the panel acknowledged the focus of the 21 PA is on adverse impacts of NOx and SOx 22 deposition in sensitive ecosystems. However,

### 202-234-4433 Neal R. Gross & Co., Inc. Page 50 1 the PA should include a succinct discussion of 2 the benefits of NOx deposition to N-limited 3 ecosystems. I think that covers it. 4 MEMBER JOHNSON: Yes. Well you 5 could be really explicit and say since most 6 terrestrial systems are nitrogen limited, 7 increased NOx and SOx or NOx deposition is 8 likely to increase growth. This can be viewed 9 as beneficial or harmful, depending on your 10 perspective. That is the essence of it. 11 MEMBER POIROT: Which is why I 12 thought the word potential made it work better 13 than taking the word potential out. Because 14 now we are saying we know these are benefits. 15 There is no ambiguity about the benefits. 16 MEMBER WEATHERS: Could we state 17 it with potential in there? 18 CHAIRMAN RUSSELL: What was that? 19 MEMBER WEATHERS: Can you re-read 20 it with adding potential in? 21 CHAIRMAN RUSSELL: And before we 22 do that, Dale, hopefully you can -- can you

### 202-234-4433 Neal R. Gross & Co., Inc. Page 51 1 actually email what you just said? 2 MEMBER JOHNSON: Yes, I will do 3 that right now. 4 CHAIRMAN RUSSELL: Great. 5 MEMBER JOHNSON: Okay. 6 CHAIRMAN RUSSELL: So even though 7 it could change greatly when we get Dale's -- 8 and email it to Kyndall. 9 MEMBER JOHNSON: Okay. 10 CHAIRMAN RUSSELL: Kathy, what it 11 currently says is, "However, the PA should 12 include a succinct discussion of the potential 13 benefits of NOx deposition to N-limited 14 ecosystems." We are debating the word 15 potential. 16 MEMBER WEATHERS: Yes. I like 17 leaving the word potential in and I like that 18 that sentence is short and to the point. 19 MEMBER CHESTNUT: Dale's words 20 about growth sounded more specific. I kind of 21 liked it. 22 CHAIRMAN RUSSELL: Yes, it is

### 202-234-4433 Neal R. Gross & Co., Inc. Page 52 1 getting emailed in -- 2 MEMBER CHESTNUT: Okay. 3 CHAIRMAN RUSSELL: -- rather than 4 try to have us remember it. 5 So we will move on and come back 6 to that after we get Dale's email. 7 Okay and here is -- and I am not 8 sure we need this paragraph. I can put it in 9 my individual comments but it was just one of 10 the things that bothered me throughout was 11 that we switched units. And unless we are 12 going to have standards written as kilograms 13 per hectare to the three halves, I would 14 prefer a more consistent set of units. And 15 then just switch into the units that are more 16 common to the specific sort of topic area in 17 the example. 18 So I am game to kill this and move 19 it to my individual comments but I was going 20 to put it up there to see what other people 21 thought. 22 MEMBER WEATHERS: I think it is

### 202-234-4433 Neal R. Gross & Co., Inc. Page 53 1 important, this is also my individual 2 comments, and I would say rather than suggest, 3 I would use the word asks. 4 CHAIRMAN RUSSELL: Recommends? 5 Asks. You like asks? 6 MEMBER WEATHERS: Yes, asks. 7 CHAIRMAN RUSSELL: Okay. 8 MEMBER WEATHERS: So the panel 9 asks that EPA use a consistent set of units. 10 MEMBER MITCHELL: I would agree 11 with that except I guess I am a little 12 concerned about using equivalents because we 13 have non-charged species within our analysis 14 as well. 15 CHAIRMAN RUSSELL: Okay, moles? 16 MEMBER MITCHELL: Moles. 17 CHAIRMAN RUSSELL: Mole-based? 18 MEMBER MITCHELL: Yes, that would 19 be fine. 20 CHAIRMAN RUSSELL: So get rid of 21 equivalents and put mole-based? 22 MEMBER MITCHELL: Yes.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 54 1 CHAIRMAN RUSSELL: Mole-based 2 units. 3 MEMBER JOHNSON: Okay, I have sent 4 the email so you can read it. It is a little 5 bit wordy but perhaps it could be wordsmithed 6 a little bit. 7 MEMBER AMAR: Just to be clear, 8 hectare is a unit of area and meters isn't. 9 Are you saying square meters? 10 CHAIRMAN RUSSELL: Or you could 11 use hectares to the one-half. But the idea -- 12 MEMBER AMAR: Okay. Okay, hectare 13 as a basis. 14 CHAIRMAN RUSSELL: And we can get 15 rid of paren hectares. It was just that is a 16 unit that is not commonly used except in a 17 very specific domain. 18 I know some of you love hectares. 19 MEMBER HANSON: It has a main 20 meaning everywhere else but the U.S. 21 CHAIRMAN RUSSELL: No, no. If you 22 talk to any atmospheric scientist, hectare,

### 202-234-4433 Neal R. Gross & Co., Inc. Page 55 1 you know, it is sort of -- You know, and I 2 suspect if you talk to a limnologist, they are 3 not really going to know what a hectare is. 4 It is very much when you are talking -- 5 MEMBER HANSON: Critical load. 6 CHAIRMAN RUSSELL: Yes, critical 7 load, agriculture. So okay, it is one of my 8 domain things. 9 MEMBER JOHNSON: Well, I vote for 10 hectare because we use it all the time. 11 MEMBER WEATHERS: We are talking 12 about spatial scales that are in hectares and 13 kilometers. 14 CHAIRMAN RUSSELL: EPA, you have a 15 question/comment? 16 DR. SCHEFFE: Yes, just real 17 quick. Sometimes we get standard outputs out 18 of canned routines that are very easy for us 19 to bring into a report. 20 I am assuming that when you talk 21 about having standardization of the units, in 22 terms of the writing that we do and in terms

### 202-234-4433 Neal R. Gross & Co., Inc. Page 56 1 of the additional figures that we generate 2 that are kind of post-processing of a lot of 3 the work. 4 In other words, are you asking 5 that we got to some of the very raw kind of 6 outputs? For instance, a map from the NEDP 7 site or the CASNET site, or a standard out put 8 from CMAQ, some of those already have in them 9 on the x-axis and the y-axis other units. 10 So I am just asking how far you 11 want us to go here. 12 CHAIRMAN RUSSELL: My preference 13 is even the raw figures that you are getting 14 from these canned outputs, that you would be 15 able to change the scales on those. 16 MEMBER WEATHERS: Or at a minimum, 17 add in the legend conversion. 18 MEMBER MITCHELL: I think I 19 support what Kathy just said. I think that 20 could be a lot of work to go through -- I know 21 it is not easy to retain some of these 22 figures. But just in the legend you put the

### 202-234-4433 Neal R. Gross & Co., Inc. Page 57 1 actual conversion, that would satisfy that. 2 DR. SCHEFFE: Okay if we could do 3 something like that in the caption there -- 4 MEMBER MITCHELL: It would save a 5 lot of time. 6 DR. SCHEFFE: Okay. And that 7 will. I appreciate that. 8 MEMBER MITCHELL: Okay. 9 CHAIRMAN RUSSELL: Okay so, we 10 have the language from Dale. So it says, so11 for Kathy, here you go. "Increased N12 deposition to N-limited terrestrial ecosystems 13 which are dominant in the U.S. may cause 14 growth increases. These growth increases can 15 be viewed as either beneficial or adverse, 16 depending on the ecosystem management goals." 17 MEMBER WEATHERS: That seems to me 18 a little bit too specific to be in the letter, 19 the front end of the letter, and might better 20 go back in the responses to the questions. 21 One opinion coming from a box. 22 CHAIRMAN RUSSELL: I know. And

### 202-234-4433 Neal R. Gross & Co., Inc. Page 58 1 the panel is, just since you can't see us, is 2 looking at it quizzically, trying to decide on 3 that. 4 MEMBER AMAR: So this sentence, 5 the one that just arrived, that is really 6 explaining the sentence before, I think, 7 trying to elucidate that. And maybe it 8 appears some other place not in this one-page 9 letter. I am just thinking the content, how 10 much you want here. 11 I mean if the point being made in 12 the third sentence is kind of being made in 13 the second sentence, if not completely, but 14 still leading to. 15 MEMBER HANSON: If you changed in 16 the second sentence benefits to impacts and 17 then followed it with this sentence, that 18 works for me. You have taken the qualitative 19 statement out of the prior sentence but then 20 you are explaining. The third sentence could 21 be shortened a little bit at the end but I 22 like what Dale has tried to do here in sort of

### 202-234-4433 Neal R. Gross & Co., Inc. Page 59 1 characterizing growth increases as both of an 2 upside and a downside issue. 3 MEMBER JOHNSON: Yes, I am trying 4 to say the growth increase is probable and 5 that is a neutral statement. And it could be 6 you don't like it. It could be you like it 7 but it probably will happen. 8 MEMBER HANSON: The part that you 9 might take out is the depending on the 10 ecosystem management goals. That might sound 11 a little bit too specific and I think the 12 sentence works without it. 13 CHAIRMAN RUSSELL: Yes, remove the 14 -- And actually I would go "U.S. may cause 15 growth increases which can be viewed" or "that 16 may be viewed." Myron? 17 MEMBER MITCHELL: This might be a 18 little picky but growth in biology has many 19 different meanings. 20 CHAIRMAN RUSSELL: What? 21 MEMBER MITCHELL: Growth to a 22 biologist has many different meanings. I

### 202-234-4433 Neal R. Gross & Co., Inc. Page 60 1 think it should be made more explicit. "Can 2 cause increases in primary production." 3 MEMBER JOHNSON: That's fine. 4 That is better. 5 MEMBER MITCHELL: It is very 6 ambiguous. 7 CHAIRMAN RUSSELL: Primary 8 production. 9 MEMBER WEATHERS: Or how about 10 production? Because the example that Charlie 11 gave was secondary production. 12 MEMBER MITCHELL: That's okay. I 13 can live with that. 14 CHAIRMAN RUSSELL: Yes. 15 MEMBER DRISCOLL: I mean, if you 16 wanted to make it more generic and this may 17 not be desirable but you could say "increase 18 nitrogen deposition to nitrogen-limited 19 ecosystems." 20 CHAIRMAN RUSSELL: Yes. 21 MEMBER DRISCOLL: You may want to 22 get rid of "which are dominant in the U.S."

### 202-234-4433 Neal R. Gross & Co., Inc. Page 61 1 And then you can apply it to aquatic systems, 2 which generally it is viewed as negative for 3 aquatic systems but from a fishery production 4 standpoint, it could be viewed as positive. 5 In some countries it is. 6 CHAIRMAN RUSSELL: Okay. 7 MEMBER JOHNSON: Yes. 8 CHAIRMAN RUSSELL: Great. So now 9 what it says, this is the last sentence. So10 we have added one sentence. "Increased N11 deposition to N-limited ecosystems may cause 12 production increases that may be viewed as 13 either beneficial or adverse." One too many 14 mays but we will work on that one. That is a 15 wordsmithing one. 16 All right. Then the last 17 paragraph is the typical sign-off. So I would 18 actually read each one of these 19 recommendations in terms of prioritization as 20 something that really, really, really should 21 be done. That these are all top priority 22 items.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 62 1 MEMBER DRISCOLL: There was one 2 thing that we had talked about but hadn't 3 discussed in terms of giving some sort of 4 prioritization in terms of tasks. If we do 5 that, would we want to include a paragraph on 6 that here? 7 CHAIRMAN RUSSELL: Actually that 8 would be something that we could -- 9 MEMBER DRISCOLL: Could add in 10 after we discussed it if we want to? 11 CHAIRMAN RUSSELL: Right. And 12 though I like the idea that that should be in 13 the letter. We just have to figure out what 14 that would be. 15 MEMBER KUMAR: I mean the 16 paragraph we just edited has kind of become 17 ambiguous to me. So may I suggest a few minor 18 edits? 19 CHAIRMAN RUSSELL: You may. 20 MEMBER KUMAR: How about "The 21 panel acknowledged the current focus of the PA 22 is on adverse impacts of NOx and SOx

### 202-234-4433 Neal R. Gross & Co., Inc. Page 63 1 deposition-sensitive ecosystems. However, the 2 PA should also include a succinct discussion 3 of other potential impacts." Because we are 4 already talking about adverse before. So I 5 think that is -- 6 CHAIRMAN RUSSELL: Yes, it makes 7 it clearer. Thank you. 8 All right, moving on to the charge 9 questions. Oh, first the executive summary 10 and Rudy, thank you. I forgot to give you my 11 marked up executive summary but actually I 12 think you captured it all when I read them. 13 you captured the idea of what is in mind. So, 14 I was pleased. So thank you. 15 So Rudy, you want to start us off? 16 MEMBER HUSAR: The first two 17 sentences say positive but what it does well, 18 the routine sentence that "Future versions 19 will need to include the changes from the 20 input now in any other evolution," the 14-page 21 size seems too long. So suggestion to shorten 22 that.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 64 1 And then there is a highlight on 2 Chapter 5 on conceptual design of ecological 3 standards should be improved to effectively 4 communicate the significant new concept, such 5 as SOx NOy deposition trade-off deposition 6 load function," maybe etcetera or not or this 7 would be okay. 8 In particular, the non-trivial 9 equation for the proposed standard would need 10 to be explained more clearly, maybe or 11 possibly with the aid of a conceptual diagram 12 specifically representing the physical meaning 13 of each of the terms in the proposed AAPI 14 equation. 15 CHAIRMAN RUSSELL: Any comments? 16 MEMBER DRISCOLL: I would17 recommend changing the wording from non18 trivial to maybe complex or something like 19 that? 20 MEMBER HUSAR: Okay. I started 21 with complex but you know, everything is 22 complex. Okay but the same. Yes, that is

### 202-234-4433 Neal R. Gross & Co., Inc. Page 65 1 fine. Anyone? 2 CHAIRMAN RUSSELL: I actually 3 might just remove that qualifier totally. 4 MEMBER HUSAR: Which one? 5 CHAIRMAN RUSSELL: The complex. 6 Just the equation for the proposed standard. 7 MEMBER HUSAR: That's fine. 8 MEMBER DRISCOLL: That is fine. 9 MEMBER HUSAR: Fine, no problem. 10 By the way, probably as we go, 11 this very last sentence or part that pertains 12 to 5, I was hoping to take some of that back 13 into your upcoming piece. One part of it is 14 just to highlight the same topics so that we 15 also cover it in the question ten. 16 MEMBER AMAR: I think ten, yes, 17 the basic structure of the framework. 18 MEMBER HUSAR: Yes. 19 MEMBER AMAR: That should be fine. 20 MEMBER HUSAR: Okay. 21 CHAIRMAN RUSSELL: Other comments 22 on Rudy's piece? Great. Let's hope each one

### 202-234-4433 Neal R. Gross & Co., Inc. Page 66 1 goes quite so smoothly. 2 Chapter 2, Naresh. 3 MEMBER KUMAR: I guess there was 4 not much discussion on Chapter 2. So I have 5 kind of taken the comments that were said here 6 and also in the written summaries. 7 So for the first question, I think 8 we see the panel agrees that it provided a 9 good review. The summary has done well and 10 some details, I guess, need more information 11 on specific years and also there is some 12 discussion which is repetitive. So they need 13 some additional other things. So that is a 14 pretty generic comment. 15 The second comment, mainly came 16 from Paul's writing about sensitive 17 ecosystems. So, you want to read it or -- I 18 guess you all can read it and suggest any 19 changes. 20 MEMBER JOHNSON: I think it reads 21 well. 22 MEMBER HANSON: Just a question on

### 202-234-4433 Neal R. Gross & Co., Inc. Page 67 1 line, well I don't know what line numbers we 2 are on now, but the second line of the first 3 paragraph at the end. How the document 4 provides results with respect to specific 5 years, I didn't understand what that meant. 6 MEMBER KUMAR: I was hoping Myron 7 would be here because he is the one who 8 provided that comment. 9 CHAIRMAN RUSSELL: He will be 10 back. 11 MEMBER DRISCOLL: So there was a 12 comment I had on this section in particular 13 but throughout the document and I mentioned it 14 yesterday, about the referencing. That there 15 seems to be in some sections there is very 16 good documentation with adequate citations and 17 in others, there are sweeping statements made 18 with few, if any, citations. I don't know if 19 that is too picky but I think it should be 20 somewhere. 21 CHAIRMAN RUSSELL: And I think 22 this is a fine place to put it is right up

### 202-234-4433 Neal R. Gross & Co., Inc. Page 68 1 there. 2 DR. HUBBELL: Can I ask one 3 clarifying question on what we were just 4 discussing? In the way that the current5 document is set up, we do a lot of cross6 referencing to sections of both ISA and the 7 Risk and Exposure Assessment document by 8 section number and so forth. And those 9 documents, of course, are very well referenced 10 and identified. Is that an acceptable process 11 and just want more of the specific references 12 to those documents or do you want us to focus 13 more on primary references to the literature? 14 MEMBER DRISCOLL: Well, as I said 15 yesterday, I don't have a good feel for what 16 is the appropriate standard. But the thing 17 that I was concerned about, and I wasn't sure 18 if there is a message being sent here was the 19 consistency. So there were some sections 20 where you didn't have any additional 21 references. You just referenced the ISA. But 22 then there are other sections where you had

### 202-234-4433 Neal R. Gross & Co., Inc. Page 69 1 some referencing for other literature. And so 2 I wasn't sure whether -- I mean, it gives the 3 impression that maybe some things are better 4 known or accepted. I just wanted it to be 5 more consistent. Maybe in a policy document 6 reference to the ISA is adequately. I just 7 thought it just seemed to me that it was 8 inconsistent reading through it with the 9 approach that was used. So, I am not sure. 10 I mean, maybe I had the wrong 11 impression but that was the impression that I 12 had reading through it. 13 DR. HUBBELL: Okay. 14 MEMBER DRISCOLL: I wasn't sure 15 whether there was some sort of an appropriate 16 strategy for referencing the document. I just 17 thought it should be done in a consistent 18 manner. 19 DR. HUBBELL: Certainly we can do 20 it whichever way you guys feel is most 21 helpful. The one thing I would note on that 22 is that in some of the sections, like

### 202-234-4433 Neal R. Gross & Co., Inc. Page 70 1 especially in the section on the ecosystem 2 services and adversity and so forth, we are 3 kind of, in some cases, having to introduce 4 new literature in those cases, which is 5 probably why that section had more external 6 references than some of the other sections. 7 But I am happy to do it either 8 way. Just, you know, we had sort of a balance 9 of those chapters where we could reference the 10 ISA and REA we did and otherwise we pulled 11 from new references. 12 MEMBER DRISCOLL: Yes, so maybe it 13 was my misinterpretation of the situation. So 14 I yield to -- 15 DR. HUBBELL: Certainly we need 16 more references. There is no doubt about 17 that. 18 MEMBER DRISCOLL: Whatever the 19 panel wants to do is fine. 20 DR. HUBBELL: Okay, thank you. 21 MEMBER JOHNSON: I agree with 22 Charlie. Referencing was inconsistent. I

### 202-234-4433 Neal R. Gross & Co., Inc. Page 71 1 picked out in my review some specific places 2 where a general statement was made and it 3 needed a reference. I agree that there needed 4 to be more of. 5 MEMBER WEATHERS: If in fact a 6 protocol has been to reference the ISA and 7 anytime that you are introducing new 8 literature is to put the reference in the 9 body, then you could say that up front. 10 MEMBER DRISCOLL: That is probably 11 a good suggestion, just to clarify the intent. 12 CHAIRMAN RUSSELL: So Kathleen, 13 Kathy, do you have some wording that might fit 14 right there? 15 MEMBER WEATHERS: No. Following 16 on Charlie, maybe the thing to do is to ask 17 that referencing be consistent or the, I guess 18 whatever protocol or method is being used. 19 CHAIRMAN RUSSELL: Yes, actually I 20 can see that the panel asks that the 21 referencing to the scientific literature and 22 prior review documents be made consistent.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 72 1 MEMBER WEATHERS: And clear. 2 CHAIRMAN RUSSELL: And clear. You 3 know, keep to the scientific literature and be 4 consistent and clear throughout the PA. And 5 indeed if the way EPA wanted to do it is to 6 explain up front how that referencing was 7 going to be done, that would be good. 8 MEMBER JOHNSON: I think just in 9 general, generalized statements of fact that 10 may not be known to the public or 11 administrators need to be referenced. 12 CHAIRMAN RUSSELL: For a less 13 familiar audience? 14 MEMBER DRISCOLL: How about a 15 general audience, something like that, or a 16 non-technical audience? 17 CHAIRMAN RUSSELL: I'd go with a 18 non-technical. So even one could say, well, 19 I would hope, -- 20 MEMBER KUMAR: I think the 21 technical audience want references. Right? 22 CHAIRMAN RUSSELL: Yes.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 73 1 MEMBER KUMAR: So I mean, what is 2 wrong with the word reader? That covers 3 everyone. 4 CHAIRMAN RUSSELL: Okay, reader. 5 Okay, next paragraph. It sounds 6 good. Question two. 7 MEMBER KUMAR: So I guess the main 8 comment here was that the most assessments 9 used steady-state models. And a comment was 10 made that physical systems are never in 11 steady-state. So maybe a summary of the 12 assumption the limitation of the model used 13 needs to be included in the document. 14 MEMBER WEATHERS: That is not just 15 physical systems. 16 CHAIRMAN RUSSELL: Say that again, 17 Kathy. 18 MEMBER WEATHERS: It is not just 19 physical systems. However the systems were. 20 CHAIRMAN RUSSELL: True. So 21 remove "physical." 22 MEMBER JOHNSON: How about

### 202-234-4433 Neal R. Gross & Co., Inc. Page 74 1 ecosystems? They are never in steady-state. 2 MEMBER WEATHERS: Yes, it could be 3 ecosystems or ecological systems. That 4 includes abiotic and biotic. 5 CHAIRMAN RUSSELL: Okay, 6 ecosystems. Just yes, I was just going to 7 have eco added. 8 All right, question three. 9 MEMBER KUMAR: Here the main 10 comment is on the discussion on pages 35 to 37 11 where we have rankings of uncertainty and the 12 comment is that there is no explanation of how 13 those rankings are arrived. So maybe we need 14 some information, some justification on those 15 assigned rankings. 16 And the second part of the comment 17 is that just like the sensitivity studies that 18 we are asking to be conducted. And I don't 19 know if you want to include this, the 20 different model that I used in aquatic 21 acidification and the sensitivity study that 22 we performed for those two. I just include it

### 202-234-4433 Neal R. Gross & Co., Inc. Page 75 1 here but I would like the panel to say 2 something whether we are going to keep that or 3 not. 4 CHAIRMAN RUSSELL: I like what it 5 said. 6 MEMBER HANSON: Are we 7 recommending a whole separate chapter on 8 uncertainties and is this the place to stick 9 them? 10 CHAIRMAN RUSSELL: That is the 11 second paragraph. 12 MEMBER HANSON: Oh. 13 CHAIRMAN RUSSELL: Laurie, did 14 you? 15 MEMBER CHESTNUT: No, I was just 16 yawning. Sorry. 17 CHAIRMAN RUSSELL: Everybody likes 18 it? Thank you. 19 Oh, Myron you are back. There is 20 a reason why. There is a reason why we bring 21 it up. 22 Naresh had picked up a sentence

### 202-234-4433 Neal R. Gross & Co., Inc. Page 76 1 from you where it says "There needs to be a 2 clarification; however . . . with respect to 3 specific years." And we weren't sure what 4 specific years meant. 5 MEMBER MITCHELL: Oh, okay. I can 6 tell you. 7 Within the document there is a 8 number of references to current, recent, and 9 I think versus having that type of unspecified 10 years that is going to cause real problems. 11 They should actually indicate the actual years 12 associated with the data or the analyses. 13 CHAIRMAN RUSSELL: With respect to 14 the actual years -- 15 MEMBER MITCHELL: Yes. 16 CHAIRMAN RUSSELL: -- of the 17 analyses. 18 MEMBER MITCHELL: Okay. 19 CHAIRMAN RUSSELL: The actual 20 years of the analyses. 21 MEMBER MITCHELL: Because it says 22 my current and it actually is like three or

### 202-234-4433 Neal R. Gross & Co., Inc. Page 77 1 four years ago. And this might be five years 2 ago by the time this comes out. 3 CHAIRMAN RUSSELL: Yes. Just the 4 actual years of the analyses. 5 Chapter 3, Laurie. 6 MEMBER CHESTNUT: Okay. So the 7 first paragraph just starts that this is 8 important and that the assessment of what is 9 an adverse effect is fundamental to this 10 review and the standard setting process. 11 The ecosystems services framework 12 and the economic evaluation estimates can help 13 in this but that the chapter is not, doesn't 14 yet accomplish what it should do. 15 The last two sentences in that 16 paragraph, well I guess the first one is, I 17 would like to get some, make sure we are -- 18 the one, I don't know if we are repeating 19 ourselves. Again, the way these effects are 20 described is in general terms. And it can do 21 this, it could do this. And to specify that 22 it is in sensitive areas that these effects

### 202-234-4433 Neal R. Gross & Co., Inc. Page 78 1 are concerned. And the last sentence, I am 2 not sure it goes here. But somewhere it seems 3 like this idea that the whole concept of 4 developing this index is so that there is 5 protections in the areas that are sensitive 6 and not restrictions in areas that are not. 7 And I don't know that that is a 8 Chapter 3 issue or just an up-front kind of 9 point that needs to come through as one of the 10 motivations for why we are doing all of this. 11 CHAIRMAN RUSSELL: So the question 12 is if that should be made more clear, almost 13 in a Chapter 1 context. 14 MEMBER CHESTNUT: Yes. 15 CHAIRMAN RUSSELL: I think it 16 actually does belong in Chapter 3 as well. 17 MEMBER CHESTNUT: Okay. 18 CHAIRMAN RUSSELL: And I like how 19 you phrased it. And the question is, does 20 this also have to come in a chapter further 21 up? 22 MEMBER CHESTNUT: And also while

### 202-234-4433 Neal R. Gross & Co., Inc. Page 79 1 we are going through the cover part of the 2 letter, I didn't know if there is, I was 3 wondering if there is anything from this 4 chapter that should come up at this point 5 maybe, even more than the rest of it. I don't 6 have anything else that seems -- 7 I mean obviously the assessment of 8 what is adverse is crucial. I am not sure 9 what to say about it in the -- 10 CHAIRMAN RUSSELL: In the letter. 11 MEMBER CHESTNUT: -- front part of 12 the letter, if there was something that should 13 come forward. So I just still have that 14 question but maybe this. 15 CHAIRMAN RUSSELL: But this 16 concept, I think does belong up in the letter, 17 the idea that, really the whole idea behind 18 the AAPI is to control in the sensitive areas, 19 not over control in the less sensitive areas. 20 MEMBER CHESTNUT: Right. 21 MEMBER AMAR: I mean I am having 22 trouble with that. I am just thinking about

### 202-234-4433 Neal R. Gross & Co., Inc. Page 80 1 adding on to action. You know, power plant 2 emissions up in the Adirondacks. That is, 3 maybe there are no effects in Ohio but your 4 controlling emission is there so that you are 5 trying to protect the Adirondacks. I mean, 6 that is what the whole concept of acid rain
7 was. 8 MEMBER CHESTNUT: Maybe not 9 protect. 10 MEMBER AMAR: Okay. 11 MEMBER CHESTNUT: Controls may 12 have to be in Ohio to protect New York or the 13 Adirondacks. 14 MEMBER AMAR: I mean but that over 15 controlling implies that control is okay but 16 over control is not okay. When you say over 17 controlling, controlling more than necessary. 18 MEMBER HANSON: I mean, in Chapter 19 1, the EPA staff have gone through the legal 20 definitions of this and they have got one 21 thing in there that at some point some court 22 ruling has come down and said standards need

### 202-234-4433 Neal R. Gross & Co., Inc. Page 81 1 to be sufficient but not more than necessary. 2 So I think it is sort of covered in the legal 3 sense. 4 CHAIRMAN RUSSELL: It is covered 5 in the legal sense but -- 6 MEMBER HANSON: But it is nice to 7 see it emphasized. 8 CHAIRMAN RUSSELL: -- the whole 9 idea behind AAPI is a way of addressing that. 10 MEMBER CHESTNUT: Is to address 11 that. 12 CHAIRMAN RUSSELL: And it would be 13 good if that concept really came out more, I 14 think. 15 MEMBER KUMAR: Instead of 16 controlling, why not overprotecting? 17 CHAIRMAN RUSSELL: Well how can 18 you over -- Well, you can't overprotect. We 19 do it with kids all the time. 20 (Laughter.) 21 CHAIRMAN RUSSELL: But it still 22 doesn't get to Praveen's concern. Don't get

### 202-234-4433 Neal R. Gross & Co., Inc. Page 82 1 rid of that chapter. 2 MEMBER JOHNSON: This is Dale, I 3 got to make a couple of comments on this and 4 then I have to go to my day job. But I think 5 this is the section where they specifically 6 had a paragraph saying we are not going to 7 economically evaluate any beneficial effects. 8 Again, I think this is a huge mistake and 9 leaves it open to massive criticism. 10 And the other comment, a little 11 more specific is, in the table and in the 12 analysis we talk about forest benefit or 13 ecosystem services and they don't talk about 14 timber products, such as timber fiber, things 15 like that, the whole forest industry. 16 So I think those two things need 17 to be mentioned. 18 CHAIRMAN RUSSELL: So it is 19 something in terms of the benefits to the 20 timber industry might be too specific. 21 MEMBER CHESTNUT: I think that 22 goes under question five.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 83 1 MEMBER JOHNSON: Maybe it does. 2 MEMBER CHESTNUT: But -- 3 MEMBER JOHNSON: Maybe I have got 4 the wrong chapter in mind. I don't remember. 5 But it is somewhere in there there was a 6 paragraph -- 7 MEMBER CHESTNUT: No, I think you 8 are right. 9 MEMBER JOHNSON: -- that said we 10 are not going to consider any benefits. I 11 think it is wrong, number one. And number 12 two, it is just going to leave it wide open 13 for dismissing the whole thing. 14 CHAIRMAN RUSSELL: Yes, so if you 15 look at page five, line 13, Laurie has that. 16 MEMBER JOHNSON: Okay. Maybe I am 17 on the wrong -- 18 CHAIRMAN RUSSELL: No, you are on 19 the right chapter. It is just it would be two 20 -- 21 MEMBER JOHNSON: In a different 22 place?

### 202-234-4433 Neal R. Gross & Co., Inc. Page 84 1 CHAIRMAN RUSSELL: A little bit 2 further down in the charge question response. 3 MEMBER CHESTNUT: But -- 4 CHAIRMAN RUSSELL: Yes, Laurie? 5 MEMBER CHESTNUT: This specific 6 omission about timber products, I mean I don't 7 think -- I mean that is a productivity is 8 considered an ecosystem service. 9 CHAIRMAN RUSSELL: Yes. 10 MEMBER CHESTNUT: So where -- 11 MEMBER JOHNSON: Well there is a 12 table there where it lists all kinds of things 13 and it doesn't list forest products. 14 MEMBER CHESTNUT: Right. It is 15 just an omission from a table. 16 MEMBER JOHNSON: In an economic 17 table that lists economic issues and there is 18 no forest products. That doesn't make any 19 sense to me so I think it should be listed. 20 CHAIRMAN RUSSELL: So that would 21 be a line somewhere in the paragraph -- 22 MEMBER JOHNSON: Somewhere. I

### 202-234-4433 Neal R. Gross & Co., Inc. Page 85 1 don't know where but I put it in my individual 2 comments, too. 3 CHAIRMAN RUSSELL: Okay. 4 MEMBER JOHNSON: You list all 5 these benefits to the public welfare for 6 forest, without mentioning fiber, timber, 7 furniture, you know, we have wood all over our 8 houses and some from the forest. 9 MEMBER WEATHERS: Well, I think 10 that is Table 3-1 and the service categories 11 listed provisioning and that includes timber, 12 food, stuff we like to use. 13 MEMBER JOHNSON: I am not looking 14 at it right now but I remember food and 15 agriculture specifically but not timber and 16 forest products. 17 MEMBER HANSON: They need to add 18 fiber or forest products. 19 MEMBER CHESTNUT: We just need, 20 yes, timber in that. 21 MEMBER JOHNSON: Fiber, forest 22 products, something like that.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 86 1 MEMBER CHESTNUT: Okay. 2 CHAIRMAN RUSSELL: So -- 3 MEMBER JOHNSON: I have got to go 4 to work. So if there is anything else, I will 5 check my email during breaks in class or 6 something. And if there are any other issues 7 I need to deal with, I will try to. 8 CHAIRMAN RUSSELL: Thanks, Dale. 9 MEMBER JOHNSON: Okay, bye. 10 CHAIRMAN RUSSELL: So the comment 11 would be is, and this can go in here, is 12 specifically timber products should be added 13 to provisioning in Table 1. 14 MEMBER CHESTNUT: Yes. 15 CHAIRMAN RUSSELL: So put that 16 somewhere. 17 MEMBER CHESTNUT: All right. So 18 where are we? 19 CHAIRMAN RUSSELL: So actually I 20 might -- 21 MEMBER CHESTNUT: Did we finish 22 with question four?

### 202-234-4433 Neal R. Gross & Co., Inc. Page 87 1 CHAIRMAN RUSSELL: No. Let's see. 2 Question four, no we haven't because -- 3 MEMBER CHESTNUT: We were still 4 talking about this. 5 MEMBER AMAR: The last sentence it 6 totally disappeared. What did we lose? I 7 think we lose what Laurie is saying there that 8 it needs to emphasize the intent is to protect 9 these ecosystems. 10 If you stop there and take out 11 that word without over controlling, then do we 12 leave it hanging? 13 CHAIRMAN RUSSELL: I think 14 actually it does lose some of its meaning. 15 MEMBER AMAR: And I am just 16 concerned about over controlling and what that 17 would mean. That is, really that is the, I 18 don't know over controlling, without 19 controlling just think about the word without 20 over. That is very much against what Title IV 21 was. I mean you are controlling emissions in 22 places where the NOy and SOX deposition were

### 202-234-4433 Neal R. Gross & Co., Inc. Page 88 1 not causing any significant control but you 2 are controlling them because they are causing 3 significant harm in other places. That is the 4 way I read it. 5 MEMBER CHESTNUT: Yes, I see what 6 you are saying. I am just not sure how to 7 rephrase it without losing that. 8 MEMBER AMAR: I think what you 9 were saying, is quoting some, you know, it is 10 what administrator has got to do what is 11 necessary but not more than necessary. 12 Requisite but not more than requisite. 13 Something to that effect. I think that is 14 what you are saying. 15 MEMBER CHESTNUT: Right. 16 MEMBER AMAR: Don't overdo it. 17 MEMBER HANSON: Maybe it is clear 18 that the intent -- I am reading from my paper 19 what is up on the screen. 20 Clear that the intent of the 21 secondary standard is to how about 22 sufficiently protect to mirror the word that

### 202-234-4433 Neal R. Gross & Co., Inc. Page 89 1 is in the legal language? Yes, so 2 sufficiently protect these sensitive systems 3 and then remove "without over controlling." 4 CHAIRMAN RUSSELL: So you add 5 sufficiently but still if you don't have the 6 idea that they are not looking to have the 7 same NOy and SOX concentration standard 8 everywhere. I mean, that is the real idea 9 here. 10 MEMBER CHESTNUT: You could take 11 about maybe the deposition and say without 12 over controlling in most locations where -- It 13 is this transport problem, I think Praveen 14 has, that you are going to have to control in 15 places where it is not doing harm in order to 16 protect the sensitive places. 17 CHAIRMAN RUSSELL: Without forcing 18 reductions in NOy -- or decreases in NOy and 19 SOX deposition. 20 MEMBER CHESTNUT: That are not 21 causing harm. 22 CHAIRMAN RUSSELL: That are not

### 202-234-4433 Neal R. Gross & Co., Inc. Page 90 1 causing significant harm or without requiring 2 more than forcing? Still, I am not -- 3 MEMBER AMAR: Also is it our 4 place? It says CASNET. I think we are 5 getting into what EPA does for a living. 6 MEMBER KUMAR: Are we getting an 7 implementation here? I don't understand the 8 intent of the sentence. 9 CHAIRMAN RUSSELL: Well I mean the 10 whole intent of the AAPI is that it is leading 11 to the appropriate level of reductions in NOy 12 and SOX in areas that are sensitive without 13 requiring reductions in other areas that would 14 not lead to benefits. 15 MEMBER HANSON: We want to 16 maximize the efficiency of additional SOx and 17 NOX. 18 CHAIRMAN RUSSELL: Right. So the 19 whole idea of the AAPI is to protect the 20 sensitive areas without leading or without 21 requiring decreases in NOy and SOX levels in 22 areas where you won't get any benefits or

### 202-234-4433 Neal R. Gross & Co., Inc. Page 91 1 significant benefits. 2 MEMBER WEATHERS: Yes, I agree 3 with Laurie or the others. The problem is the 4 transport issue. 5 MEMBER DRISCOLL: Isn't it just to 6 make a statement that you want to look at the 7 balance sheets between the effects and the 8 benefits and you want to err on the side of 9 making a prudent decision? I don't remember 10 the documents, the very long document, but I 11 thought there was a section talking about the 12 administrator's role in balancing these that 13 I thought was pretty good but I couldn't -- I 14 would have to take a few minutes to go through 15 the document but I think that is the intent 16 here. 17 The other thing that we are 18 ignoring is that there is a whole health side 19 to this. Right? And there are health 20 implications with respect to these things that 21 are going to come into play in the decision 22 process as well and we are ignoring that.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 92 1 MEMBER CHESTNUT: Well I don't 2 think Chapter 3 is trying to get to -- I mean, 3 that has to be done when the regulatory impact 4 analysis is done with all the co-benefits and 5 that is not what this is trying to get to. It 6 is more just this statement. I mean, I think 7 it is implied. And certainly in what they 8 talk about sufficient requisite -- I forget 9 the words but Paul had said them. 10 I just think yes. I don't know 11 where it needs to be said. I am not attached 12 to it being here. I just occurs to me that it 13 is an important point in terms of what this 14 whole thing is trying to do. 15 Otherwise, we just -- 16 MEMBER AMAR: Why don't we start 17 right after sufficiently protect the sensitive 18 systems, period and not get into this 19 requiring decrees and areas and so on. 20 MEMBER KUMAR: That does not 21 answer I think that Laurie is trying to do. 22 We might as well remove the whole sentence.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 93 1 MEMBER HANSON: I hesitate to say 2 this but I think we are putting too much into 3 what the form of the standard is capable of 4 doing. 5 CHAIRMAN RUSSELL: Pardon me? 6 MEMBER HANSON: The AAPI does a 7 very creative job of characterizing how 8 deposition might effect local phenomenon in 9 the ecosystems and organisms. What it doesn't 10 do is incorporate the source of the 11 deposition, which is I think what we are 12 wandering off into at this point. 13 MEMBER AMAR: And is that our 14 place or this document? 15 MEMBER CHESTNUT: Well but it, 16 what the index does is set a standard that is 17 going to protect the sensitive areas because 18 those calculations will come up that way. And 19 the ones that are not won't exceed the 20 standard. 21 MEMBER POIROT: What about the 22 real intent, it seems to me, is to focus the

### 202-234-4433 Neal R. Gross & Co., Inc. Page 94 1 secondary standard on the air quality 2 concentrations and deposition that effects 3 sensitive areas. I don't think we need to say 4 a lot about protecting the emission sources in 5 other areas. That is kind of really 6 irrelevant. The real intent is to focus the 7 controls most efficiently on air quality and 8 deposition or reducing air quality and 9 deposition in sensitive areas. 10 MEMBER CHESTNUT: Yes. 11 MEMBER POIROT: I don't know that 12 we have to be so detailed about the rest of 13 it. 14 MEMBER AMAR: But extending what 15 you just said, yes. But we are not saying how 16 one would go about doing that. We need to 17 protect air quality and deposition at places 18 where the systems, sensitive systems are 19 concerned. 20 MEMBER POIROT: Geographically 21 focus the efficiency of controls or something 22 like that?

### 202-234-4433 Neal R. Gross & Co., Inc. Page 95 1 MEMBER KUMAR: I am okay with 2 removing the whole sentence. I mean, I think 3 we already said that in the previous sentence 4 that it is important in the chapter to say 5 that what we are concerned with is not NOx and 6 SOX deposition sensitive areas. So, -- 7 MEMBER MITCHELL: The more I look 8 at this, I think it confuses issues in terms 9 of how this is going to end up being 10 implemented. I think it is clear that the 11 purpose of this is to look at sensitive areas 12 and that is the focus. I don't think we have 13 to say what it is not supposed to do. It 14 could go on and on forever. 15 CHAIRMAN RUSSELL: And actually so 16 I like what it is saying. My one thought now 17 is that I am not sure Chapter 3 is the place 18 it goes because they haven't introduced the 19 AAPI yet. So we don't even -- 20 MEMBER CHESTNUT: Right. 21 CHAIRMAN RUSSELL: -- really know 22 what that is trying to do, since we haven't

### 202-234-4433 Neal R. Gross & Co., Inc. Page 96 1 seen it. 2 MEMBER CHESTNUT: I am fine with 3 taking that last sentence out of here. 4 CHAIRMAN RUSSELL: But remember 5 the concept because I think they have to do 6 that better in Chapter 5, actually. That is 7 where it needs to come in. 8 MEMBER CHESTNUT: Okay. 9 MEMBER KUMAR: I do have a nit 10 picking comment on the first sentence. I 11 mean, are we trying to say other chapters are 12 not important? 13 MEMBER MITCHELL: I knew you were 14 going to say that. No. I think it is good to 15 say it is an important chapter. 16 MEMBER KUMAR: Although not as 17 important? This one is more important than 18 the other? 19 CHAIRMAN RUSSELL: No, Chapter 5 20 is going to have this is a really very 21 important chapter. 22 MEMBER MITCHELL: This is the most

### 202-234-4433 Neal R. Gross & Co., Inc. Page 97 1 important. 2 MEMBER CHESTNUT: It doesn't say 3 most important. 4 CHAIRMAN RUSSELL: Whoever had the 5 really, really something that day. 6 MEMBER KUMAR: I forgot to put 7 anything in Chapter 2. 8 CHAIRMAN RUSSELL: I actually yes, 9 that is -- So, this chapter needs to describe. 10 MEMBER CHESTNUT: We could just 11 say this chapter needs to describe. 12 CHAIRMAN RUSSELL: Yes. 13 Any other nit-picky things, 14 Naresh? 15 (Laughter.) 16 CHAIRMAN RUSSELL: Okay. I can do 17 that. He was my student. 18 Question five. 19 MEMBER CHESTNUT: Did we -- You 20 didn't do the second paragraph. 21 CHAIRMAN RUSSELL: Oh, we probably 22 didn't.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 98 1 MEMBER CHESTNUT: How much time do 2 you want to spend here? 3 CHAIRMAN RUSSELL: All the amount 4 of time requisite but no more. 5 (Laughter.) 6 MEMBER CHESTNUT: So this is -- I 7 think the point here is that the numbers that 8 are presented have to be put in a context. 9 And of the -- focusing on what is the change 10 or loss as the result of the deposition 11 effects. And even though you can't -- you 12 know, neither the dollars or the science will 13 exactly pinpoint when it is adverse, it does 14 help in that assessment. 15 But the numbers need more 16 explanation. They tend to be just kind of put 17 in there without an interpretation of what it 18 means and what they tell. 19 I mean, I didn't explicitly say 20 and get rid of those total, those big numbers 21 about the total value of the hiking throughout 22 the forest. But if they are interpreted and

### 202-234-4433 Neal R. Gross & Co., Inc. Page 99 1 explained, why that matters, I think that is 2 the key point. 3 MEMBER HANSON: I think you could 4 just simplify it by taking out some of the 5 material towards the middle and end of line 40 6 and the first part of line 41. So starting on 7 line 39, the monetary values that are 8 presented in the chapter need more explanation 9 period or need more clarification, period. 10 I mean, I don't think the rest of 11 it is needed down to panel on the next line. 12 I would take out the question, 13 too. I don't see -- Unless I don't understand 14 what that is for. 15 MEMBER CHESTNUT: Praveen you 16 wanted -- 17 MEMBER AMAR: Yes, I had made that 18 point, I guess, from a reader perspective. 19 People read this. I mean I have that line 20 there, you know, the purpose of computing is 21 not numbers but insights. And quite often 22 there are a lot of numbers in the chapter

### 202-234-4433 Neal R. Gross & Co., Inc. Page 100 1 without the insights. 2 So I think it is fine like that. 3 CHAIRMAN RUSSELL: Well, I would 4 take it out of the form of a question. The 5 document should highlight or explain. 6 Hopefully you are saving this as we go. 7 Now do people want highlight or 8 explain? 9 MEMBER CHESTNUT: Can't we make it 10 part of the previous sentence? The monetary 11 values that are presented in the chapter need 12 more explanation to highlight the insights 13 implied or something for policy. 14 MEMBER AMAR: And maybe policy 15 relevant context or something which kind of 16 puts numbers into perspective. 17 CHAIRMAN RUSSELL: Well, if it 18 says policy makers, I wouldn't put it in a 19 policy-relevant format. 20 MEMBER AMAR: Yes, or something. 21 CHAIRMAN RUSSELL: It could say 22 highlight insights in a policy-relevant --

### 202-234-4433 Neal R. Gross & Co., Inc. Page 101 1 MEMBER AMAR: Manner. That is 2 better, instead of policy makers. In the 3 context of policy, a policy-relevant context. 4 That's good. 5 MEMBER KUMAR: I remember there 6 was a comment made that all the numbers should 7 be brought into a separate table. I think 8 Laurie has that by saying there are comments 9 from other members, I guess. 10 CHAIRMAN RUSSELL: I would still 11 put it here. 12 MEMBER AMAR: Okay. 13 MEMBER WEATHERS: In regard to the 14 policy, explanation as to what they mean for 15 policy? 16 CHAIRMAN RUSSELL: So you want to 17 say that specifically, Kathy? 18 MEMBER WEATHERS: Do the monetary 19 values that are presented in the chapter need 20 more explanation as to what they mean for 21 policy? 22 CHAIRMAN RUSSELL: Okay.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 102 1 MEMBER CHESTNUT: More succinct? 2 CHAIRMAN RUSSELL: Yes. 3 So the monetary valuations should 4 be summarized in a table. 5 MEMBER CHESTNUT: I don't know if 6 we need to be that prescriptive. 7 CHAIRMAN RUSSELL: Well do we want 8 it? Should we put this as a good thing but a 9 lower priority thing? 10 MEMBER CHESTNUT: I think it could 11 be helpful -- 12 MEMBER WEATHERS: A table would be 13 helpful. 14 MEMBER CHESTNUT: -- but it is a - 15 - 16 CHAIRMAN RUSSELL: Then I would 17 put it -- It would be helpful? 18 MEMBER WEATHERS: Yes, a table 19 would be helpful. 20 CHAIRMAN RUSSELL: Yes. A table 21 summarizing monetary valuations would be 22 helpful.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 103 1 MEMBER WEATHERS: Yes. 2 MEMBER CHESTNUT: Okay. 3 MEMBER POIROT: Could we change as 4 to what they mean for policy to as to their 5 policy implications? The reason being -- 6 MEMBER WEATHERS: I like that.
7 CHAIRMAN RUSSELL: Yes. 8 MEMBER CHESTNUT: Yes. 9 CHAIRMAN RUSSELL: You don't even 10 have to give us a reason. We like it. 11 MEMBER KUMAR: I removed the last 12 sentence because I think that is implicit in 13 all of her comments. 14 CHAIRMAN RUSSELL: Okay. 15 MEMBER HANSON: In terms of the 16 table, I just would encourage them not to just 17 find a lot of numbers and include them in the 18 table without thinking about whether they make 19 a good argument, thinking back to the spruce 20 example. 21 I mean, just because they have a 22 numeric value for monetary impact available

### 202-234-4433 Neal R. Gross & Co., Inc. Page 104 1 doesn't mean it should be used. It may not 2 make a good argument for an adverse impact. 3 MEMBER CHESTNUT: Well, I hope the 4 rest of the paragraph communicates that. But 5 yes, I agree with you but it is not just a 6 matter of slapping some numbers together. You 7 have to -- Okay. 8 CHAIRMAN RUSSELL: Question five. 9 MEMBER CHESTNUT: Ecosystem 10 services clearly communicated. 11 So the first paragraph says that 12 they are, the concepts are clearly 13 communicated, well presented. The 14 descriptions of how these services are 15 specifically affected by deposition need to be 16 improved. 17 I don't know if this is -- Some of 18 these sentences seem a little repetition now 19 compared to the earlier one. 20 I did want to insert at line six, 21 no, at line seven, reasonable confidence that 22 they are happening in sensitive ecosystems

### 202-234-4433 Neal R. Gross & Co., Inc. Page 105 1 under current conditions. 2 CHAIRMAN RUSSELL: Other comments? 3 Again, remember we will be able to do 4 wordsmithing later for redundancy.
5 MEMBER CHESTNUT: Yes. 6 CHAIRMAN RUSSELL: Well the next 7 paragraph at the very end is where I think we 8 should add timber products should be added to 9 Table 3-1. 10 MEMBER CHESTNUT: Okay. 11 CHAIRMAN RUSSELL: And I was 12 curious. Is buffering the right word there? 13 MEMBER CHESTNUT: This is some of 14 Paul's sentence. 15 MEMBER HANSON: Yes, written late 16 yesterday. 17 CHAIRMAN RUSSELL: I am just 18 wondering. 19 MEMBER HANSON: Myron? 20 MEMBER MITCHELL: I think 21 buffering, I wouldn't use that word. 22 CHAIRMAN RUSSELL: Yes, to me that

### 202-234-4433 Neal R. Gross & Co., Inc. Page 106 1 has a specific meaning. That is why I was 2 wondering about buffering. 3 MEMBER MITCHELL: I would say 4 inherent capacities for N and S retention. 5 CHAIRMAN RUSSELL: There you go. 6 MEMBER MITCHELL: You don't need 7 for the ability to absorb and utilize that. 8 That is part of it. 9 CHAIRMAN RUSSELL: Myron? 10 MEMBER MITCHELL: I was suggesting 11 that that is encompassed. You don't need the 12 part of the sentence that says from "or the 13 ability to absorb and utilize." That can be 14 deleted. 15 CHAIRMAN RUSSELL: Okay. Everyone 16 is fine? Six. 17 MEMBER CHESTNUT: Six. So, this 18 is uncertainties with articulating adversity 19 to public welfare. 20 So the first part is that the 21 description of the effects and the 22 quantification of acidification on aquatic

### 202-234-4433 Neal R. Gross & Co., Inc. Page 107 1 resources. It is pretty clear that from a lot 2 of view points that there is adverse effects 3 and that then it goes on that the key 4 uncertainties that remain are about how much 5 adversity would be reduced of the standard 6 based on 50 versus 100 ANC. And it looks like 7 there are benefits continuous between the two. 8 I'm not sure I have any 9 suggestions on how to address that uncertainty 10 but it is an important one that is kind of 11 left there for a judgment to be made. 12 CHAIRMAN RUSSELL: And I might 13 tend away from specifying a specific ANCs. 14 Just, they have not settled on what ANC level 15 that they are looking toward. 16 MEMBER CHESTNUT: Okay, that's 17 fine. We could make it more general. Based 18 on a given ANC level. 19 CHAIRMAN RUSSELL: Yes. 20 MEMBER AMAR: And your reference 21 to how much is enough, you mean how much 22 gravity is enough. Right?

### 202-234-4433 Neal R. Gross & Co., Inc. Page 108 1 MEMBER CHESTNUT: How much -- what 2 is it? 3 MEMBER AMAR: You have line 30 or 4 31, how much is enough. The reference is to 5 how much value is enough. 6 CHAIRMAN RUSSELL: That is a 7 reduction of what you are saying should be 8 added of ANC or ANC increase? 9 MEMBER AMAR: How much improvement 10 in ANC or how much value. 11 I thought the context was value, 12 additional value. 13 MEMBER CHESTNUT: How much -- 14 MEMBER AMAR: How much of what? 15 CHAIRMAN RUSSELL: How much value 16 is added? 17 MEMBER CHESTNUT: Yes, I 18 understand your question. I am thinking. 19 MEMBER AMAR: I think you mean 20 value. 21 MEMBER CHESTNUT: That whole 22 sentence is kind of awkward if we are going to

### 202-234-4433 Neal R. Gross & Co., Inc. Page 109 1 try to take the numbers out. 2 CHAIRMAN RUSSELL: So would it be 3 but they cannot give a specific value? 4 MEMBER CHESTNUT: They can't give 5 a specific point at which the adverse effect 6 has been -- 7 CHAIRMAN RUSSELL: Adequately 8 mitigated? 9 MEMBER CHESTNUT: Adequate -- but 10 it is like it is a slow -- You never -- This 11 is -- I am not -- blah. 12 MEMBER AMAR: It seems like 13 marginal cost and marginal benefit. I think 14 that is what you are saying. 15 MEMBER CHESTNUT: Yes, every 16 improvement gives you a little bit more. And 17 when have you gotten to the point where you 18 have alleviated adverseness? 19 So the valuation estimates show 20 additional value for incremental improvements 21 in ANC. 22 DR. HUBBELL: And if I could just

### 202-234-4433 Neal R. Gross & Co., Inc. Page 110 1 clarify one thing. I mean, obviously we 2 understand that some of this is going to be 3 defined by science and some of it is going to 4 be defined by a policy judgment by the 5 administrator as to what is adverse to public 6 welfare. What obviously we want to try to do 7 is provide as much information as we can about 8 what the science and the economics say about 9 those incremental changes, how she weighs 10 those incremental changes relative to her 11 impressions of what is appropriate to protect 12 public welfare. That is going to be a policy 13 judgment. But providing that incremental 14 information I think is what maybe you are 15 trying to get at it. 16 MEMBER CHESTNUT: Right. 17 DR. HUBBELL: Is that we need to 18 provide as much information about the 19 increments of change. Is that fair? 20 MEMBER CHESTNUT: Yes. 21 DR. HUBBELL: Okay. 22 MEMBER CHESTNUT: Yes.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 111 1 DR. HUBBELL: But there is always 2 going to be a policy judgment in there. 3 MEMBER CHESTNUT: Right. 4 MEMBER POIROT: So are there 5 actually economic valuation estimates 6 presented that do show that in the chapter or 7 is this more can show or will show? 8 MEMBER CHESTNUT: Well there is 9 some for recreational fishing with ANC at 50 10 and then ANC at 100 if you get more lakes to 11 these levels. 12 MEMBER POIROT: Okay. 13 MEMBER CHESTNUT: Yes, there are 14 some numbers like that. 15 CHAIRMAN RUSSELL: Adequate. But 16 they cannot give a specific value of ANC 17 increase that is sufficient, adequate, 18 appropriate? 19 MEMBER CHESTNUT: I have to think 20 about it. I am not sure, in light of what 21 Bryan was saying, too, reminding that, I'm not 22 sure that we need that sentence, actually.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 112 1 Just leave it at "The key uncertainties 2 include how much would be reduced with a 3 standard at a given ANC level." And maybe 4 take out the -- Yes, that sentence. 5 CHAIRMAN RUSSELL: So then that 6 next sentence no longer is related, I think, 7 or is directly related to the prior sentence. 8 MEMBER CHESTNUT: I think -- 9 MEMBER POIROT: Could we put that 10 back for a second? I was just thinking they 11 don't provide it, a full estimate of the 12 economic or environmental benefits or point to 13 a specific ANC level that would -- 14 MEMBER CHESTNUT: Yes, you are 15 having another thought in there that is an 16 important point, I think. The economic values 17 that are available are not comprehensive. 18 They don't capture all the benefits and they 19 don't point to a specific ANC levels. 20 MEMBER POIROT: That is the 21 administrator's judgment. 22 CHAIRMAN RUSSELL: So Rich, what

### 202-234-4433 Neal R. Gross & Co., Inc. Page 113 1 you are saying is that it should note that 2 essentially a clause at the end but do not 3 reflect all the -- 4 MEMBER CHESTNUT: All the benefits 5 of reducing -- 6 MEMBER POIROT: Increased 7 protection. 8 MEMBER CHESTNUT: Of reducing 9 deposition effects. 10 MEMBER POIROT: Don't use 11 reducing. 12 MEMBER CHESTNUT: Not reducing. 13 Decreasing. 14 MEMBER POIROT: Decreasing 15 deposition or point to a -- 16 CHAIRMAN RUSSELL: Specific ANC 17 level that should be required. 18 MEMBER CHESTNUT: Right. Okay. 19 CHAIRMAN RUSSELL: Chapter 4. Oh, 20 I have just been told it is time for a break. 21 So 15 minutes; so we will see you at 10:45. 22 (Whereupon, the foregoing matter

### 202-234-4433 Neal R. Gross & Co., Inc. Page 114 1 went off the record at 10:31 a.m. 2 and resumed at 10:45 a.m.) 3 CHAIRMAN RUSSELL: All right. I 4 think we are to Chapter 4, which would be 5 Rich. 6 MEMBER POIROT: Well so Chapter 4 7 was the one that really addressed the question 8 of the adequacy of the current standards. And 9 the first question seven is kind of asking if 10 we agree with the chapter's assessment of the 11 adequacy. 12 So I tried to say yes, we agree 13 that first there is sort of a simple test you 14 could make looking at the results of the 15 continuing effects of acidification from the 16 effects related network and make the 17 observation that effects are occurring and18 looking at the results from the inter19 monitoring networks for NO2 and SO2 and 20 observe that the standards are being obtained. 21 So clearly then obtaining the current 22 standards does not eliminate the effects. AND

### 202-234-4433 Neal R. Gross & Co., Inc. Page 115 1 then in addition, the chapter also points out 2 that almost every aspect or element of the 3 standard, not just the level and the form but 4 also the averaging times and the indicators 5 are wrong and or not reflective of the 6 environmental effects. 7 And in addition to that, they are 8 taking one pollutant at a time for an effect 9 that is caused by the combination of the two. 10 So that is what the answer to seven was 11 intended to reflect. 12 CHAIRMAN RUSSELL: Comments? 13 Good. Question eight. 14 MEMBER POIROT: Eight was the 15 harder question, I thought. And because it is 16 really asking about the use of, the 17 appropriateness of using kind of a long-term 18 steady state and C an indicator of effects in 19 comparison to current levels of deposition or 20 air quality; whereas, in reality the current 21 status is really a combination of current 22 deposition, as well as historical deposition.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 116 1 So I tried to add in then that 2 possibly -- Well, first to say that that was 3 a reasonable approach to take but that it 4 could be enhanced. I wish Charlie were here 5 but by applying dynamic modeling techniques to 6 either back casts, historical changes, to 7 compare those with measurements or to forecast 8 future changes if current deposition rates 9 remain unchanged. 10 Then the second paragraph was just 11 intended also to indicate that perhaps if we12 are concerned about limitations of the long13 term steady-state ANC that it might not be 14 responsive to effects associated with episodic 15 events. 16 MEMBER MITCHELL: I would just 17 change the last sentence, remove associated 18 with spring snow melt events because you can 19 also have episodic acidification after 20 droughts as well. You have summer episodes as 21 well as spring episodes. 22 CHAIRMAN RUSSELL: Any other

### 202-234-4433 Neal R. Gross & Co., Inc. Page 117 1 comments? 2 MEMBER AMAR: Just one 3 clarification. I know the question came this 4 way. The long-term steady-state ANC. By that 5 do we mean the measure, model, long-term, 6 steady-state ANC or ANC as it is measured 7 today it reflects the long-term effects of all 8 the deposition of the past? Maybe it is too 9 late to ask. 10 CHAIRMAN RUSSELL: And I don't 11 think steady-state would be the right word. 12 It is more just you are trying to get to the 13 long-term E average. 14 MEMBER POIROT: Yes, to be honest, 15 I was not all that clear on that myself. It 16 is what it says in the question. 17 MEMBER AMAR: I know. Is the 18 question clear? 19 CHAIRMAN RUSSELL: So I don't 20 think steady-state is the correct word, even 21 if it is in the question. 22 MEMBER POIROT: You know, I don't

### 202-234-4433 Neal R. Gross & Co., Inc. Page 118 1 mind taking it out. Although it is really, 2 isn't it derived from use of a steady-state 3 model? I think it should be left in. 4 CHAIRMAN RUSSELL: Okay. In that 5 case, I mean this may be picky maybe it is 6 just how I would have phrased it is use of 7 long-term and ANC derived from steady-state 8 modeling. 9 MEMBER AMAR: If that is what is 10 meant. 11 MEMBER POIROT: Yes. 12 CHAIRMAN RUSSELL: That is 13 actually what is meant. It is a long 14 sentence, isn't it? 15 MEMBER POIROT: You could put a 16 period after reasonable approach. And this 17 could be enhanced. 18 CHAIRMAN RUSSELL: Yes. Anything 19 else? Bryan. 20 MEMBER MITCHELL: You could 21 actually delete historical because that is 22 redundant with back cast. And you can also

### 202-234-4433 Neal R. Gross & Co., Inc. Page 119 1 delete the word forecast because, or delete 2 the word future. Both of those are -- It is 3 implied by both those terms. 4 MEMBER AMAR: And to be clear, I 5 know logical friends use that term all the6 time, dynamic modeling. That is non-steady7 state modeling. Right? Transient modeling. 8 Is dynamic a case coming from my physics 9 background, it is not the right term I keep on 10 thinking because dynamics implies force. 11 Force, momentum, that is what you learn what 12 dynamics means. 13 But here I think what is meant is 14 not a force, a physical force but something 15 non-steady --16 CHAIRMAN RUSSELL: Non-steady17 state?18 MEMBER AMAR: Or transition, non19 equilibrium, whatever the word is.20 CHAIRMAN RUSSELL: Non-steady21 state. 22 MEMBER AMAR: Unless you know,

### 202-234-4433 Neal R. Gross & Co., Inc. Page 120 1 Charlie loves the word dynamic and others. 2 MEMBER POIROT: Going down. 3 Question nine. 4 DR. HUBBELL: Can I ask one 5 question on number eight before you get off 6 that? In your last sentence on number eight, 7 you said you make the statement that this is 8 the case, that use of long-term steady-state 9 may also fail to adequately address these 10 effects. 11 We are struggling a little bit as 12 to what we are supposed to do with that. Our 13 understanding and Charlie is not here so, it 14 is a little difficult, but our understanding 15 was that the models -- My thought was well, 16 let's just do some modeling and say okay what 17 are the episodic -- In other words, if you 18 were to look at the monthly or the seasonal 19 ANC that comes out of these models, you could 20 see where there are longer term ANC based on 21 an annual or multiple year average, whether 22 that would be protective against these shorter

### 202-234-4433 Neal R. Gross & Co., Inc. Page 121 1 term peaks. And my understanding is the 2 models actually don't produce monthly or 3 seasonal ANC values. So I am trying to figure 4 out what we are supposed to do with that
5 statement. 6 So if there is any clarification 7 you can provide on that, that would be 8 helpful. 9 MEMBER POIROT: You know, 10 personally, I wouldn't object to taking that 11 whole last little paragraph out because I kind 12 of don't think it was the intent of your 13 question to have us go into that. Some 14 people, some of us have made some comments 15 about that. But I actually don't think it is 16 that relevant to the question of determining 17 adequacy. 18 DR. HUBBELL: Right. 19 MEMBER POIROT: You know, it would 20 be perfectly fine with me to take that whole 21 paragraph out. 22 DR. HUBBELL: Okay. Like I said,

### 202-234-4433 Neal R. Gross & Co., Inc. Page 122 1 I just wanted to know, if we leave it in 2 there, it would be nice to know what we are 3 supposed to do. 4 MEMBER MITCHELL: Can I comment on 5 that? 6 MEMBER POIROT: Yes. 7 CHAIRMAN RUSSELL: Before we 8 remove it I think that is something that we 9 should discuss. 10 MEMBER MITCHELL: I think the 11 basis for this comment was that we know that 12 these events will occur and if we develop some 13 type of level of protection based upon annual 14 average ANC, how will that accommodate these 15 events? 16 So I agree with Bryan there is a 17 mission of how to do this but maybe it has to 18 be done by not using the steady-state models 19 but using some dynamic models in which the 20 values are done over a shorter time frame, at 21 least monthly, sometimes even more fine 22 resolution.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 123 1 Probably some examples versus an 2 extensive analysis is needed here. I am a 3 little bit concerned about throwing these out 4 completely because for a lot of areas it is 5 the episodic acidification which is really 6 where we are having the biological impacts on 7 aquatic systems. 8 MEMBER POIROT: I agree with that, 9 Myron. However, my argument would be that I 10 don't really believe that it is in the answer 11 to this question where that should go. 12 MEMBER MITCHELL: Okay. 13 MEMBER POIROT: Because I don't 14 really think that is likely to affect the 15 conclusions relating to adequacy of the 16 current standards, since the conclusions are 17 already that the current standards are 18 inadequate and all this could do would be to 19 say in fact, they are event more inadequate 20 than we may have thought. 21 So I think this is a good point 22 but it doesn't really quite fit to the answer

### 202-234-4433 Neal R. Gross & Co., Inc. Page 124 1 to this question. 2 MEMBER MITCHELL: So maybe it 3 should go on another portion of the document, 4 maybe? Do you feel comfortable with Bryan? 5 DR. HUBBELL: Well I don't have a 6 problem with you moving it to another section 7 but it still doesn't answer the question what 8 do we do about it. 9 So if, you know, there are two 10 ways to go. Obviously, one is to think maybe 11 there are some models that can address shorter 12 time scales, which I got the impression from 13 the modelers that I have talked to that that 14 is not an easy thing to do because they use 15 annual inputs and other things like that. 16 But the second way is if there is 17 something we can do in terms of looking at 18 observational data that you have a suggestion 19 about that might help us identify this 20 relationship between episodic acidification 21 and longer term ANC levels, if there is 22 observational data that can help us, if you

### 202-234-4433 Neal R. Gross & Co., Inc. Page 125 1 can identify where we should look, that would 2 be very helpful. 3 MEMBER POIROT: Right. 4 MEMBER MITCHELL: I understand the 5 problem and I guess through this whole process 6 there has been some suggestion that the 7 application of some dynamic modeling and some 8 of the evaluation might be helpful and this 9 could maybe be some very specific test case 10 where we think that might be a most important 11 factors. 12 In those areas where snow melt is 13 extremely important -- Certainly you have to 14 change some other models. You have to do some 15 dynamic modeling to have this occur. And 16 whether that is feasible within the context of 17 the time frame, I guess we have to have a 18 frank discussion about that. 19 DR. HUBBELL: Yes, and I am just - 20 - and I was hoping that Charlie could answer 21 the question of whether even the dynamic 22 models function on a subannual timescale or if

### 202-234-4433 Neal R. Gross & Co., Inc. Page 126 1 they just look at over multiple years, in 2 which case, the question of do you use three 3 or five year average would make sense. It 4 still doesn't help to look at seasonal snow 5 melts. 6 MEMBER WEATHERS: The DayCent-Chem 7 model, for example, is on a daily time-step. 8 DR. HUBBELL: Okay. We haven't 9 used that model so I will have to investigate 10 that. But that is, I guess if we could just 11 get a few more of those kinds of specific 12 ideas, that would be helpful. Because 13 otherwise, I am just not sure what we do and 14 qualitatively discuss it. 15 MEMBER POIROT: An example, 16 conceptual example from observational data 17 would be to make the observation that in some 18 of the lakes that have experienced substantial 19 degrees of recovery of ANC over the last 20 to 20 30 years, we are still observing these 21 episodic pulses that could relate. 22 DR. HUBBELL: That maybe what we

### 202-234-4433 Neal R. Gross & Co., Inc. Page 127 1 can maybe look at that. So those are the kind 2 of recommendations I think would be helpful. 3 MEMBER MITCHELL: I guess one 4 other possibility Bryan could be that 5 obviously like Charlie and other people have 6 used PnET-BGC to make these simulations. And 7 maybe the possibility of actually looking at 8 some of those results and place in the context 9 of some of the results associated with these 10 current parameters to make those comparisons 11 versus redoing those runs, that would seem 12 like it would be waste of time. Why not take 13 advantage of those analysis that already 14 occurred and then maybe have to do the 15 analysis appropriate for this particular focus 16 but actually take advantage of those previous 17 runs. 18 DR. HUBBELL: Okay, that is a good 19 idea. Thank you. 20 MEMBER HANSON: I think there is 21 an analogy here to peak ozone concentrations, 22 peak acute ozone exposure concentrations that

### 202-234-4433 Neal R. Gross & Co., Inc. Page 128 1 you could think about as well. 2 DR. HUBBELL: Yes and I think the 3 analogies are right. It is just a question 4 of, because the difference here is that the 5 thing that we are dealing with that has 6 chronic versus episodic effects is not the 7 atmospheric concentrations. It is the actual 8 effect of the deposition. So they are 9 disconnected in time. And so that is not 10 something we can address for the form of the 11 standard, but it is something that maybe we 12 need to address in terms of the target ANC, 13 rather than the atmospheric indicator. And 14 that is what I am struggling a little bit 15 with. That is why I was asking the question 16 yesterday. 17 So you know, annual values of NOx 18 and SOx may still be appropriate even to deal 19 with episodic events that are occurring from 20 deposition. But whether we choose a chronic 21 ANC level that is targeted based on the annual 22 acidification problem versus a chronic ANC

### 202-234-4433 Neal R. Gross & Co., Inc. Page 129 1 that is targeted to protect against episodic 2 effects, that is what I am trying to get a 3 handle on. 4 Because maybe you need a more, a 5 higher ANC value to protect against episodic 6 events. And I just, I don't have a real great 7 handle on that yet and it would be helpful to 8 think through some of those. 9 MEMBER HANSON: Well yes, I think 10 it is certainly important within the document 11 to point out what the AAPI can and cannot do. 12 If you don't do it the public will and 13 somebody from the public is going to say they 14 might have the potential of pointing out that 15 this is the wrong standard. And unless you 16 model it a short time-step, you are not going 17 to get the kind of adverse effects that I 18 making or that member of the public is making. 19 DR. HUBBELL: Yes and that's what 20 we want to make sure that we fully -- 21 MEMBER HANSON: I tried to 22 introduce that in some of the chapter and I

### 202-234-4433 Neal R. Gross & Co., Inc. Page 130 1 don't think I did a great job and so I am 2 looking for advise on how we can do a better 3 job with that. And again, it is just a matter 4 of figuring out are there things we can do 5 with the data that we have. And it sounds 6 like maybe some of the modeling results that 7 Charlie has can help. 8 DR. HUBBELL: Right. 9 MEMBER HANSON: I'll just leave it 10 at that. Thank you. 11 MEMBER MITCHELL: So should that 12 be made more explicit within this text or 13 Bryan do you have sufficient information? 14 DR. HUBBELL: Well, it is going to 15 get moved somewhere else. 16 MEMBER MITCHELL: Okay. 17 DR. HUBBELL: I think I got the 18 information I need from what you just said. 19 If you can clarify whether you expect 20 something quantitative specifically, that 21 would be great. If you don't and you just 22 want us to explore that, to make that

### 202-234-4433 Neal R. Gross & Co., Inc. Page 131 1 statement that something needs to be explored. 2 CHAIRMAN RUSSELL: So that is 3 something to think about is again it comes 4 with the prioritization do we expect that in 5 the next revision and how important is that. 6 If we want something quantitative versus if 7 they would explore it and provide description 8 and sort of be able to tell us if it is going 9 to be important or not. 10 But moving on, Rich. 11 MEMBER POIROT: Are done with 12 eight? And then nine is asking about 13 basically the air quality and deposition 14 characterization presented also in Chapter 4. 15 And I guess I just wanted to make the point 16 that while most of the information that was 17 presented was useful, there were some figures 18 that the information appeared to be incorrect. 19 Likely, just caption labels or units or 20 something like that. But a number of the 21 figures were in question. 22 And also then we wanted to see

### 202-234-4433 Neal R. Gross & Co., Inc. Page 132 1 additional figures showing total reduced 2 nitrogen deposition as well as the fraction of 3 total nitrogen deposition that was contributed 4 by reduced or oxidized nitrogen. That was the 5 point of the first paragraph. 6 And the second paragraph is 7 actually referring to these ratio transfer 8 maps that are introduced in Chapter 5 but 9 suggesting that those might actually be 10 presented in some form here as part of the air 11 quality characterization because in fact it 12 really is asking questions about the adequacy 13 of existing networks not only to evaluate the 14 current standards but also to potentially 15 evaluate future standards. So I thought that 16 those maps and some additional exploration of 17 them could be brought forward and expanded on 18 in this chapter. 19 CHAIRMAN RUSSELL: You know, I 20 like that idea. Because I think if they did 21 show it versus NO2, it would look weird and it 22 would make the point very clearly.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 133 1 MEMBER HANSON: Just a minor 2 point. The very last word of the second 3 paragraph, adequacy. The question asks about 4 relevance. Should that last word be 5 relevancy? 6 CHAIRMAN RUSSELL: I actually 7 prefer adequacy. Relevancy -- what say you? 8 MEMBER POIROT: Well the basic 9 title of the chapter, I think, has to do with 10 adequacy of current standards. And they kind 11 of try to make an argument that I didn't 12 really buy that we can't really assess their 13 adequacy because we don't have NOy 14 measurements and that is -- I am not buying 15 that. 16 I am saying, if you really want to 17 support your argument that NO2 is an 18 inadequate indicator, show us by showing how 19 the ratio map of NO2 deposition is less -- is 20 more variable, noisier -- 21 CHAIRMAN RUSSELL: Less stable. 22 MEMBER POIROT: -- poorer

### 202-234-4433 Neal R. Gross & Co., Inc. Page 134 1 indicator. 2 CHAIRMAN RUSSELL: Naresh. 3 MEMBER KUMAR: So in the main body 4 of the letter we are saying our CMAQ model 5 evaluation and that those results should be 6 done in appendix or brought into Chapter 4. 7 Would this be the place to mention it again? 8 Because we don't mention that 9 anywhere in Chapter 4. And I remember 10 yesterday some comments were made in response 11 to this question but this is the first time 12 you are talking about CMAQ results. You know, 13 those just need to be evaluated against 14 measurements. 15 So I am wondering I do talk about 16 model evaluation in response to question 18. 17 So, I am not sure if you want to bring it here 18 also. 19 CHAIRMAN RUSSELL: I don't think 20 it goes here. I think it actually belongs 21 more in Chapter 5. And the reason why is what 22 Rich is getting to here is just showing that

### 202-234-4433 Neal R. Gross & Co., Inc. Page 135 1 NO2 alone is probably not a good indicator. 2 And I don't think that requires a CMAQ 3 evaluation to say that. 4 MEMBER KUMAR: Because the 5 characterization of the ambient air quality 6 and deposition is done using CMAQ results. I 7 mean, the question number 9, directly asks 8 that. The question is that adequate to use 9 CMAQ results without doing an evaluation. 10 So I realize we are mentioning 11 evaluation in response to different questions. 12 Do we want to even say it here and also in the 13 main body you do mention that the results 14 should be discussed in Chapter 4. So if they 15 are going to be discussed in Chapter 4, this 16 is the place where they should be discussed. 17 MEMBER POIROT: You know, I was 18 having similar thoughts to that when I was 19 reviewing it but then it occurred to me that 20 well there was an evaluation of CMAQ 21 performance that was included as part of the 22 REAs and appendix to it last time. But in

### 202-234-4433 Neal R. Gross & Co., Inc. Page 136 1 this case, at least one difference is for 2 something like these ratio maps, that anytime 3 you have a ratio of two modeled things, you 4 have the potential to multiply your bias or 5 offset it. 6 MEMBER KUMAR: I am okay with 7 including that. I am just wondering if we 8 should also mention about model evaluation 9 here, even though we are mentioning that 10 somewhere else. 11 MEMBER AMAR: Where are we 12 mentioning it this time somewhere else? 13 MEMBER KUMAR: In response to 14 question 18. 15 MEMBER AMAR: Eighteen? 16 MEMBER KUMAR: Which is, I think, 17 chapter six. 18 MEMBER AMAR: I mean, one 19 possibility might be reference here to that, 20 question 18. Say please receive a response to 21 question 18, if that is what you are doing. 22 MEMBER POIROT: You know, in some

### 202-234-4433 Neal R. Gross & Co., Inc. Page 137 1 ways, I guess, I am trying to think if I am 2 EPA, I am wondering what is it you want us to 3 do for model evaluation that we didn't include 4 in the analysis last time. 5 MEMBER KUMAR: And I think that is 6 what -- 7 MEMBER POIROT: And I think if we 8 are going to ask them to do more, we need to 9 be specific. 10 MEMBER KUMAR: And I am being 11 specific in response to question 18. 12 MEMBER HANSON: All I wanted to 13 ask was is this the place where we need to say 14 something about chemically-reduced forms of 15 nitrogen? As far as I am concerned, the 16 wording is fine. 17 MEMBER AMAR: Eighteen is very 18 CMAQ specific. Any reference to that here 19 might -- 20 MEMBER KUMAR: I think it would be 21 useful. 22 CHAIRMAN RUSSELL: Okay. So, what

### 202-234-4433 Neal R. Gross & Co., Inc. Page 138 1 would you -- how would you phrase this? I 2 mean, I am quite game to put it here. In 3 essence something at the end of that sentence 4 saying this chapter should also contain a 5 summary of the performance evaluation of CMAQ. 6 MEMBER KUMAR: Something like that 7 and I will discuss more in response to 8 question 18. 9 CHAIRMAN RUSSELL: Okay. A 10 summary of this assessment. No, a summary of 11 the performance assessment of CMAQ as 12 discussed. 13 MEMBER POIROT: Or as it pertains 14 to these species. 15 CHAIRMAN RUSSELL: As it pertains 16 -- 17 MEMBER POIROT: Or as discussed. 18 I don't think you need both. 19 CHAIRMAN RUSSELL: That is 20 actually as Rich said, removed as it pertains 21 to and just says as discussed in response. 22 Praveen, you are on.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 139 1 MEMBER AMAR: Question number ten, 2 Chapter 5. We are going to the next one. 3 This is a summary of what many of us said 4 talking, asking us directly what we think of 5 this whole approach, conceptual framework, 6 structure and so on. And I am saying and 7 others were saying too that it's innovative, 8 people use the word creative. So it is all 9 there and it is positiveness. And it is 10 designed for addressing those four linkages 11 between concentration, deposition, aquatic 12 chemistry and then finally ecological effects. 13 And then I added this I think I 14 can reflect what everybody was saying, 15 "However, as currently proposed, calculation 16 of AAPI assumes deposition of reduced forms of 17 reactive nitrogen to be constant in the 18 future, which most probably is not true, 19 considering upward trajectory of U.S. ammonia 20 emissions," which is what I added. "A more 21 realistic approach would be to treat ammonia 22 as a precursor --" That is the word we had

### 202-234-4433 Neal R. Gross & Co., Inc. Page 140 1 used yesterday. " -- to the AAPI standard and 2 then periodically not show," I wrote annually 3 with a question mark, "update this index as 4 the ammonia emissions change, increase or 5 decrease over time." 6 And the last sentence I am not 7 sure I got it right. All the discussion with 8 respect to dynamic modeling yesterday and I 9 thought parts of this AAIP calculation is 10 based on steady-state, too. 11 So the last sentence which is 12 valid here we should keep. If I didn't get it 13 right, we should delete. But the underlying 14 assumption of steady-state behavior should be 15 evaluated with panel effort using sensitivity 16 analysis and dynamic modeling. And this 17 language appears in other places, too. So I 18 don't know whether we need it here, the last 19 sentence. 20 Yes, go ahead. 21 MEMBER KUMAR: I have a comment on 22 the previous sentence, not on this one.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 141 1 MEMBER AMAR: Which one? 2 MEMBER KUMAR: I guess where you 3 are talking what treating ammonia as a 4 precursor and periodically updating it. That 5 is pretty much what they have now. I mean, 6 they are still planning to update 7 periodically. It may not be annually but I 8 think what we discussed yesterday was to maybe 9 make it more dynamic in that equation, rather 10 than asking them to just update it 11 periodically. 12 MEMBER AMAR: So did the balance 13 between treat ammonia like SOX and NOX or not 14 and the precursor to the idea I had suggested 15 yesterday, I got some as late as yesterday but 16 I am not sure. We can talk. But then if you 17 are going to use it as a precursor, then -- 18 MEMBER KUMAR: It is not -- It is 19 directly contributing to that but it is not a 20 precursor as such. 21 MEMBER AMAR: I thought we were 22 using precursor to --

### 202-234-4433 Neal R. Gross & Co., Inc. Page 142 1 MEMBER KUMAR: I know that was 2 said yesterday but -- 3 MEMBER AMAR: -- and everything 4 else. 5 MEMBER CHESTNUT: How about input? 6 MEMBER KUMAR: Yes, it is an 7 input, it is not a precursor. 8 MEMBER AMAR: See a precursor, I 9 thought a more solid term. Like VOC is a 10 precursor to ozone and therefore we got all 11 those VOC controls in this country because it 12 is precursor to a criteria. 13 MEMBER KUMAR: If you call ammonia 14 the precursor to deposition of even NOX and 15 SOX, would you consider those precursors then? 16 MEMBER AMAR: Well SOX and NOX are 17 big time precursors in my mind. 18 MEMBER KUMAR: They also directly 19 contribute. 20 MEMBER AMAR: Yes but they make 21 sulfates and nitrates and therefore, PM2.5 and 22 acid deposition. So SOX is a precursor to

### 202-234-4433 Neal R. Gross & Co., Inc. Page 143 1 acid deposition. NOX is too. 2 MEMBER CHESTNUT: But the sentence 3 is about precursor to the AAPI -- 4 MEMBER AMAR: I know. 5 MEMBER CHESTNUT: -- standards. 6 MEMBER AMAR: And that work, I was 7 being tactful. I mean AAPI, is this a NAAQS 8 or is it something else? I mean, what is 9 AAPI? Is it a secondary NAAQS or something 10 which looks like secondary NAAQS? 11 MEMBER WEATHERS: How about as a 12 component? Component of the -- 13 DR. HUBBELL: Well, to be clear 14 what we are seeing it as is, what we are 15 treating it as at this point is a modifying 16 factor. It is not -- 17 Precursor is an interesting word 18 because it is -- 19 MEMBER HUSAR: That is why it is 20 quote, unquote here. 21 DR. HUBBELL: When we use the term 22 precursor in the terms of VOCs and with NOX

### 202-234-4433 Neal R. Gross & Co., Inc. Page 144 1 and SOX as a contributor PM, it is a precursor 2 because it transforms in the atmosphere and 3 becomes part of the regulated substance. 4 Okay? 5 When we are dealing with ammonia 6 here, it is a contributor to the AAPI and a 7 modifier to the amount of NOX and SOX that is 8 allowable but it does not actually transform 9 into NOX or SOX. It is actually something 10 that modifies the amount of NOX and SOX that 11 we are saying is acceptable in a system. 12 So it is a little different 13 conceptually. So I would be a little cautious 14 about saying it is equivalent to a precursor 15 like VOCs or NOX and SOX relative to PM. 16 Granted, I understand the concept 17 that you are trying to clarify that it is 18 something that contributes to the overall 19 standard in a way that modifies the way that 20 we look at NOX and SOX. But it is not a 21 precursor in that like NOX and SOX that 22 transform and become part of the massive PM or

### 202-234-4433 Neal R. Gross & Co., Inc. Page 145 1 VOCs which transform through their interaction 2 with NOX to form ozone. It is not the same 3 type of a transformation product in that same 4 way. 5 So I just would exercise a little 6 caution if you choose to do so. Obviously you 7 can use that word if you think it makes the 8 most sense. But just, it is a different 9 concept, I believe. 10 MEMBER HUSAR: Well, I like the 11 use o the EPA's language. It is a modifying 12 component. We have enough new vocabulary 13 here. We don't need to be adding to it. 14 MEMBER KUMAR: And in that 15 formulation of modifying component, it is 16 kosher. In other words, if you can pass 17 through if you need additional rationalization 18 or fortification through the use of precursor, 19 well then just keep it as modifying. 20 DR. HUBBELL: Yes, the big 21 difference between what we talked about 22 yesterday --

### 202-234-4433 Neal R. Gross & Co., Inc. Page 146 1 CHAIRMAN RUSSELL: And actually 2 speak into a microphone. I will say that for 3 Kathy. 4 DR. HUBBELL: My apologies. 5 MEMBER WEATHERS: Thank you. 6 DR. HUBBELL: Sorry about that 7 Kathy. What I was trying to get at is our 8 understanding has evolved a bit from when we 9 presented this to you originally to understand 10 that the key component is moving from a static 11 or a single measurement that would be fixed in 12 time to try to incorporate a dynamic variable, 13 a dynamic modifying factor that could be 14 adjusted over time to reflect changes in the 15 ammonia that is occurring because of other 16 trends and ammonia outside of our regulatory 17 approaches. 18 In other words, because 19 everybody's understanding is that ammonia 20 trends are going upwards, keeping it fixed in 21 time was going to be a problem. And I think 22 that we hear that and we are trying to

### 202-234-4433 Neal R. Gross & Co., Inc. Page 147 1 incorporate that in the next phase of this 2 design. 3 So I think your statement is about 4 the trajectory of U.S. ammonia emissions and 5 the fact that this is an important modifying 6 factor. That communicates very well what it 7 is the panel is looking for, right without 8 introducing this concept of a precursor which 9 seems a little confusing. 10 MEMBER WEATHERS: Once again -- 11 CHAIRMAN RUSSELL: Go ahead. 12 MEMBER WEATHERS: -- using the 13 word component, does that work? So treat 14 ammonia as a component of the AAPI standard? 15 CHAIRMAN RUSSELL: We have 16 modifying component. 17 MEMBER WEATHERS: Okay. 18 MEMBER HANSON: Well I actually 19 object to it. I mean I understand why you are 20 using that term. It is a modifying component 21 to the NOX and SOX part of the deposition 22 component of the AAPI but in terms of the

### 202-234-4433 Neal R. Gross & Co., Inc. Page 148 1 mechanism involved in the AAPI, it is just 2 another component of N-deposition. 3 DR. HUBBELL: Yes, and you could 4 just use the term component of the AAPI and 5 then say that, you know, because it actually 6 doesn't -- what it modifies is the amounts of 7 NOX and SOX that would be allowable to be able 8 to satisfy a given AAPI standard. 9 MEMBER HANSON: Right. 10 DR. HUBBELL: But in terms of the 11 calculation of the AAPI, it is simply another 12 component. So, I agree with you. So however 13 you want to include that, that is the correct 14 concept that you just laid out. 15 MEMBER HUSAR: I would think that 16 Ellis would also like to just keep it as a 17 component. That is what I think. 18 MEMBER AMAR: There goes the 19 precursor. 20 (Laughter.) 21 CHAIRMAN RUSSELL: He loved the 22 word but it is gone.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 149 1 MEMBER AMAR: I mean, I was not 2 careful -- well, I was. That is why I put 3 quote unquote, knowing that there will be 4 discussion here. 5 And the last -- go ahead. 6 MEMBER KUMAR: So I guess I am 7 still uncomfortable with asking to 8 periodically update it when I was recommending 9 more treating it as a dynamic term where you 10 know if it is something that stays good, 11 decide if they want to change ammonia flux as 12 of way of implementation of the standard. 13 So I guess, I mean it was not very 14 different from what is already there. All it 15 is saying is that after one year or five 16 years, EPA will look at the new values of 17 ammonia flux and update it. That is not very 18 different from what is already there. 19 MEMBER AMAR: I thought yesterday 20 the assumption was that they will have three 21 years of baseline data to figure out that NHX, 22 you know this little thing in the equation.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 150 1 MEMBER KUMAR: I mean, that wasn't 2 there but is that what we are recommending or 3 is that what EPA is saying they can do? 4 MEMBER AMAR: I was trying to 5 suggest there to the extent ammonia emissions 6 will change, which will result in change in 7 ammonia concentrations and ammonia deposition, 8 and therefore, this equation that is 9 calculated in the future should reflect change 10 in ammonia emissions, concentrations, and 11 deposition. I mean, that is what I am trying 12 to say. 13 CHAIRMAN RUSSELL: And I think 14 actually you two are saying somewhat the same 15 thing, except it would just, the word 16 periodically, I think what Naresh is saying is 17 then updating the AAPI and remove periodically 18 and annually and just updating to suggest it 19 is done on the appropriate timescale, be it 20 part of the SIP or be it part of just changes 21 in the amount levels over time. 22 Does that capture what you are

### 202-234-4433 Neal R. Gross & Co., Inc. Page 151 1 saying Naresh? 2 MEMBER KUMAR: Not entirely. 3 CHAIRMAN RUSSELL: No. 4 MEMBER KUMAR: I guess when I made 5 the comment yesterday it was just keeping it 6 as a separate term, like a constant term sends 7 the wrong message to a state so they don't 8 have to deal with ammonia emissions. 9 And what is being suggested they 10 periodically update it only become ammonia 11 emissions are going to change, most likely 12 increase. It doesn't really say what to do 13 about that. So I would say it should be 14 treated as a separate term in the AAPI. 15 MEMBER AMAR: I mean treat it as 16 with the respect as SOX and NOX, as a third 17 pollutant in this three-dimension stuff. I 18 mean that is the way I think that ammonia 19 should be treated the same way as we do SOX 20 and NOX. But then all the limitations we 21 heard that you cannot do that or how would you 22 do that. So I am just trying to have this

### 202-234-4433 Neal R. Gross & Co., Inc. Page 152 1 diplomatic language here. 2 And I don't think states when you 3 say it, that states will do this. I don't 4 think states in this country in the absence of 5 clear EPA direction will do anything 6 differently than EPA, now I am talking like a 7 policy person, especially with respect to 8 ammonia. 9 MEMBER POIROT: So would that mean 10 it would have to be measured, along with the -
11 - 12 MEMBER AMAR: That is a good 13 question. There is some reference here and 14 there were comments some place ammonia 15 measurement, some other question, I think. 16 CHAIRMAN RUSSELL: So Naresh, you 17 don't like having it -- 18 MEMBER KUMAR: I don't have a 19 suggestion but I don't agree. So I don't know 20 of others have any suggestions or not. 21 CHAIRMAN RUSSELL: So saying and 22 then updating AAPI, that doesn't address it

### 202-234-4433 Neal R. Gross & Co., Inc. Page 153 1 because what you want it to be is a separate 2 control variable. 3 MEMBER AMAR: Just be careful. I 4 think control the way Bryan used it yesterday, 5 controlling for something is not the same as 6 controlling something. When I think of 7 controlling emissions mathematically you 8 control for some area without controlling it. 9 MEMBER POIROT: I mean aren't all 10 the other, or many of the other chemical 11 elements of the AAPI are in fact updated as 12 the new data come in. So, if it is updated as 13 ammonia emissions change, what is the 14 difference? Doesn't that take care of it? 15 MEMBER KUMAR: I mean, that is 16 what I am saying. What is new here? We 17 recommend it. There is nothing new. 18 MEMBER POIROT: Well, I think what 19 is new is that without this recommendation, 20 they were proposing to hold the ammonia 21 contribution constant. 22 MEMBER AMAR: Constant in time.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 154 1 MEMBER POIROT: We are saying vary 2 it, as you vary the other stuff. That is what 3 is new. 4 MEMBER AMAR: And executive 5 summary had a statement saying that assumption 6 may not be valid. Constant ammonia and you 7 will be over or under predicting. 8 MEMBER KUMAR: Then why only the 9 ammonia term? Shouldn't the other terms also 10 be updated? 11 MEMBER AMAR: Of course. They 12 will be but I think that the assumption is 13 that they will do that for SOX and NOX. No? 14 MEMBER KUMAR: No, not SOX and NOX. 15 I am talking about other terms in AAPI which 16 are not being controlled. So VNOy, VSOx. 17 DR. HUBBELL: Yes, our plan was 18 originally to vary those over time. Now 19 again, to the extent that you feel that is 20 appropriate for us to, and it is all one 21 suggestion and one of the further things, 22 further questions that there is a relationship

### 202-234-4433 Neal R. Gross & Co., Inc. Page 155 1 between what we are now calling V but we will 2 change that term, but the V's and the levels 3 of NOX and SOX or other parameters. 4 So if you feel that those should 5 be updated over time or that they should 6 incorporate additional data, etcetera, that is 7 something that we can certainly start to think 8 about how to do. 9 But the plan originally was to fix 10 all those parameters at the time we set the 11 standards because I thought that was what our 12 legal folks were telling us to do. 13 I am understanding now that we 14 have some more flexibility than that, 15 potentially. So if that is something that is 16 supportable or desirable in the standard, that 17 that is a good comment to provide to us. 18 MEMBER AMAR: Then look at this 19 equation, the one you showed us yesterday, I 20 thought as you go in the future, these terms 21 won't change because you will figure that out 22 through CMAQ. But the concentrations

### 202-234-4433 Neal R. Gross & Co., Inc. Page 156 1 themselves, NOY and SOX, they will change. 2 DR. HUBBELL: Yes, they do because 3 those are what you are actually measuring in 4 compliance. 5 MEMBER AMAR: And maybe the Q 6 terms won't change but those concentrations 7 will. 8 DR. HUBBELL: Yes, the 9 concentrations are the things that you are 10 measuring for compliance. The idea was that 11 the Q and the V's and the NHX would be fixed 12 as parameters that would go into when we gave 13 the tradeoff curves to the states, they would 14 be based on the values of those variables at 15 the time we set the standard. 16 If instead what you are saying is 17 well we think that perhaps this should be 18 evaluated and potentially updated over time 19 and therefore that would affect the tradeoff 20 curve is that individual states would have to 21 try to comply with, that is going to 22 complicate things but it may be something that

### 202-234-4433 Neal R. Gross & Co., Inc. Page 157 1 you think is desirable as part of the overall 2 way we implement the standards. 3 So I am not telling you whether 4 these -- 5 MEMBER KUMAR: I mean, I think we 6 at least need to evaluate whether to throw 7 stones with change or not. I don't know if 8 the deposition concentration ratios will 9 change when the emissions change, emissions of 10 NOX and SOX change over time. Those 11 relationships should not change but since we 12 are using models, should models be -- 13 CHAIRMAN RUSSELL: Right. I would 14 actually say that that can be added to our 15 request for the sensitivity analysis. 16 MEMBER KUMAR: I think I have 17 added that. 18 DR. HUBBELL: That is what we -- 19 We actually included those plots that were 20 very, I think somewhat difficult to look at 21 sometimes. But we included the plots of the - 22 - We ran four years of the ratios to look at

### 202-234-4433 Neal R. Gross & Co., Inc. Page 158 1 what is the temporal stability of the ratios 2 in different locations and we saw they were 3 relatively stable over that four-year period 4 that we looked at. And the question is, is 5 that enough to look at stability to say that 6 we ought to keep those stable or is it 7 something that we need to be checking over 8 time. 9 And that is just something that 10 certainly we can incorporate that information 11 if that is desired. 12 CHAIRMAN RUSSELL: Right. And I 13 think Naresh will get to that as one of the 14 sensitivity analyses would be to test it 15 currently for conditions of different NOy 16 levels in the future and different SOX levels 17 in the future that one would expect due to 18 current control programs just to see if you 19 cut SOX and NOX by 50 percent, if your V's 20 change significantly in over one year. 21 MEMBER POIROT: So would it help 22 to make it clear in this case to treat ammonia

### 202-234-4433 Neal R. Gross & Co., Inc. Page 159 1 as a variable component of the APPI standard 2 and to update the APPI as ammonia emissions 3 change? 4 CHAIRMAN RUSSELL: I think that is 5 and then updating. I would get rid of 6 periodically and just update. 7 MEMBER WEATHERS: Yes, I like 8 that. 9 CHAIRMAN RUSSELL: Update or 10 updating? Updating the AAPI? 11 MEMBER WEATHERS: It is a variable 12 component right? 13 CHAIRMAN RUSSELL: Yes. Variable 14 component of the AAPI standard and then 15 updating the AAPI as ammonia emissions change 16 over time. 17 MEMBER WEATHERS: Yes. 18 MEMBER HUSAR: Is that really the 19 intent, making ammonia special? In other 20 words, not treating it coming out of the CMAQ, 21 let's say, just like SOX and NOX but rather it 22 is something different that is just

### 202-234-4433 Neal R. Gross & Co., Inc. Page 160 1 periodically updated, rather than just part 2 of, just the components that you normally 3 estimate anyway through the way you estimate 4 the SOX and NOX. 5 CHAIRMAN RUSSELL: So the SOX and 6 NOX are measured. As part of the standard, 7 they are measured. 8 MEMBER HUSAR: Oh. Okay but -- 9 Measured but -- 10 CHAIRMAN RUSSELL: Keep going, 11 Rudy. 12 MEMBER HUSAR: -- it is still 13 somehow kind of a, isn't it going through some 14 kind of an aggregation or something? 15 CHAIRMAN RUSSELL: It being the 16 ammonia deposition level? 17 MEMBER AMAR: Yes. Would they be 18 driven by CMAQ? That wasn't clear. 19 CHAIRMAN RUSSELL: What? 20 MEMBER AMAR: When you try to do 21 what we are proposing here for ammonia, where 22 will that data come from?

### 202-234-4433 Neal R. Gross & Co., Inc. Page 161 1 CHAIRMAN RUSSELL: It comes from 2 CMAQ. 3 MEMBER AMAR: Okay, which will 4 have ammonia concentrations, deposition, NH 5 checks, and that is for everything. 6 CHAIRMAN RUSSELL: Rich. 7 MEMBER POIROT: Well I think the 8 difference, Rudy, in this case, would be 9 really that in the way it was proposed, the 10 ammonia contribution would be taken as a 11 constant given that would never change. 12 And if we now consider it to be a 13 varying component, then if the state or 14 whatever were able to reduce its ammonia 15 emissions and concentrations, it could -- that 16 would count as an optional way towards 17 obtaining the standard. That wasn't an option 18 before and we are suggesting there should be 19 one now. So that is the point. 20 The next question is, however, 21 whether we can get by with modeling it or we 22 are going to have to measure it like

### 202-234-4433 Neal R. Gross & Co., Inc. Page 162 1 everything else. 2 CHAIRMAN RUSSELL: Rudy. 3 MEMBER HUSAR: Yes but still, I 4 see the two extremes here. You know, Naresh 5 says that well, what if you have a continued 6 available data? Is that not the idea that the 7 standard would allow the use of actual numbers 8 in updating whatever is the frequency at which 9 you "update" or measure the SOX and NOX? 10 It has to be specified that those 11 scales in which you bring in ammonia can or 12 should be different than for SOX and NOX. 13 CHAIRMAN RUSSELL: And I think -- 14 Kathleen. 15 MEMBER WEATHERS: We are testing 16 here on the frequency with which ammonia needs 17 to be included. 18 CHAIRMAN RUSSELL: Or updated. So 19 your question was -- 20 MEMBER WEATHERS: I am just trying 21 to figure out what a compromise solution might 22 be. But I am trying to restate the issue. So

### 202-234-4433 Neal R. Gross & Co., Inc. Page 163 1 it sounds like where we are stuck is the 2 frequency with which ammonia needs to be 3 included or updated as part of the AAPI. Is 4 that right? 5 MEMBER AMAR: Yes. And Kathleen, 6 one way to address it might be simply how the 7 inventories are done. It is every three years 8 for five years of ammonia and everything else. 9 So maybe that is the frequency. 10 DR. HUBBELL: If I could just 11 interject a little bit on this. One of the 12 things that again would be hopefully feasible 13 and desirable is that when we set the standard 14 we are going to have to put some levels out 15 there and say here is the ammonia levels that 16 we are initially setting the standard on. 17 And to the extent that we can 18 allow flexibility to say the states may update 19 their ammonia estimates that go into 20 determining their designation as attainment or 21 non-attainment, that they may update them as 22 they obtain the information rather than

### 202-234-4433 Neal R. Gross & Co., Inc. Page 164 1 requiring them to do it at a set time because 2 different states, I think, are going to be 3 collecting data in different ways. And again, 4 the desirability of getting the ammonia 5 monitoring as well as doing updates with the 6 modeling based on the emission inventories, 7 that is something I think we want to explore. 8 Because we certainly, from what we hear from 9 the panel and also other from the nitrogen 10 panel as well, measuring, doing monitoring, 11 additional monitoring on ammonia is desirable. 12 So finding ways to encourage that 13 while recognizing that they need flexibility 14 would be desirable. Again, I don't know how 15 that fits with what you are trying to tell us 16 but I think that is something we would see as 17 desirable is that flexibility. 18 MEMBER WEATHERS: That sounds like 19 then the phrase at a frequency that I don't 20 know if it is scientifically defensible that 21 is, again, feasible. What is the right term 22 for that? Frequency that is -- I am looking

### 202-234-4433 Neal R. Gross & Co., Inc. Page 165 1 at my colleagues. 2 CHAIRMAN RUSSELL: I know and we 3 are all looking at each other. Yes, Rich? 4 MEMBER POIROT: Well, I guess 5 personally I prefer to be somewhat silent on 6 the issue because it isn't clear to me how 7 flexible the EPA can actually be. It could in 8 the end vary anywhere from okay, go out and 9 measure ammonia, along with the other 10 components. It may be updated with emissions 11 inventories. So I actually prefer less 12 specificity rather than more at this point in 13 the review. 14 CHAIRMAN RUSSELL: And so do I. I 15 mean, I was going to make the same comment 16 because I am not sure that we yet need yet 17 weigh in on a frequency. I don't think it is 18 something that we have deliberated on or given 19 enough thought to. 20 MEMBER AMAR: Just updating the 21 AAPI as appropriate. That gives everybody an 22 out.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 166 1 MEMBER WEATHERS: And part of it 2 is implied with a variable, the two words 3 "variable component." 4 MEMBER AMAR: Yes. 5 CHAIRMAN RUSSELL: Though -- 6 MEMBER HUSAR: Without being too 7 specific, we can still encourage EPA as if it 8 makes the policy documents more firm to 9 explain the manner in which the g(.) term is 10 set or given. Here it is, God given, so to 11 speak. Okay? 12 What is the nature of the manner 13 the ammonia term to be added? So what does it 14 mean to be modifying component? Evidently it 15 has some very specific implication here. So 16 that that way we are not saying what it should 17 be but how just that the document should be 18 explained. Because sooner or later, of 19 course, people will have to clear that up. 20 CHAIRMAN RUSSELL: Though I will 21 say that Brian brings up something that we 22 want to think about. I don't think we want to

### 202-234-4433 Neal R. Gross & Co., Inc. Page 167 1 weigh in on it right now is at what point 2 might one bring in to the process observations 3 of ammonia and ammonium, as opposed to just 4 calculated values? 5 Because if, one of the questions 6 would be if you were at a location where you 7 are measuring NOy and SOX, if you also have 8 the ammonium contributors and can calculate 9 deposition, could that preferentially be used? 10 But that is something I don't 11 think we have talked about, we thought about, 12 but maybe down the road, maybe EPA could think 13 about that as well. Because that actually 14 does bring into the whole process a real 15 impetus or not to observe ammonia and ammonium 16 and I think actually provide the more natural 17 way to bring it in to the control paradigm. 18 But that is for the future. 19 MEMBER CHESTNUT: How about we 20 just say a more realistic approach would be to 21 treat ammonia as a variable component of the 22 AAPI standard that can be updated?

### 202-234-4433 Neal R. Gross & Co., Inc. Page 168 1 CHAIRMAN RUSSELL: Oh. 2 MEMBER CHESTNUT: And just leave 3 it at that. 4 CHAIRMAN RUSSELL: How do people 5 like that? 6 MEMBER WEATHERS: Thumbs up. 7 CHAIRMAN RUSSELL: Naresh? 8 Praveen? 9 MEMBER AMAR: I missed it. I'm 10 sorry. 11 CHAIRMAN RUSSELL: Okay, so it 12 would go that can be updated, period. Because 13 it doesn't even matter if it is the emissions 14 change. It could be something else. 15 MEMBER CHESTNUT: Right. 16 CHAIRMAN RUSSELL: It could be an 17 improved modeling. You know, actually one 18 thing that is going to come down the pike and 19 we are not sure how quickly EPA would 20 integrate this is they are going to have this 21 by-directional flux calculation that people do 22 expect to change the ammonia levels in CMAQ

### 202-234-4433 Neal R. Gross & Co., Inc. Page 169 1 and the deposition rates in CMAQ. So, it 2 could be due to all sorts of things. 3 MEMBER AMAR: All right, that's 4 good. 5 MEMBER WEATHERS: Congratulations, 6 Laurie, for breaking the gridlock. 7 (Laughter.) 8 CHAIRMAN RUSSELL: She should be 9 in Congress. 10 Question 11. 11 MEMBER HUSAR: At the bottom of 12 this question ten, there is a transplant or a 13 piece that was added. Praveen, you haven't -- 14 You know, this is that sentence or actually 15 the two sentences that I was talking about. 16 MEMBER AMAR: They are not -- 17 CHAIRMAN RUSSELL: No. 18 MEMBER HUSAR: The red ones that 19 we just added now and it refers to the further 20 need for clarification of the -- 21 MEMBER AMAR: Trade-off. 22 MEMBER HUSAR: -- basically the

### 202-234-4433 Neal R. Gross & Co., Inc. Page 170 1 concept, the trade-off of other functions of 2 the parts. But also that the equation of the 3 proposed standard is not set because it turns 4 out it is actually you need two equations. 5 One for the flat part, presumably and the 6 other one is the actual variable where you 7 have this proportionality. 8 Hey, Rich, is it fair to say that 9 the actual presentation of the equation of the 10 kind that you have here would really need to 11 have two equations? One for the flat part and 12 the other one is the linear part. 13 DR. SCHEFFE: Yes. It is not even 14 an equation for the flat part. 15 MEMBER HUSAR: Well but this 16 constant is still an equation. 17 DR. SCHEFFE: Right. 18 MEMBER HUSAR: There is an AAIP 19 for any value. 20 DR. SCHEFFE: Yes, we went over 21 that. That was an oversight on our part that 22 that is a conditional equation.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 171 1 MEMBER HUSAR: I understand. 2 DR. SCHEFFE: And that is only 3 applicable after you get past the nitrogen 4 saturation part of that diagram. 5 So your question? 6 MEMBER HUSAR: Well the question 7 is that actually there is more of a suggestion 8 here that the presenting that outcome, okay, 9 that AAIP, okay would be also helpful to do it 10 in terms of a damage function. Okay? 11 What I mean is that normally in 12 order to be consistent with all of these other 13 kind of damage functions that are out there, 14 you would need to have something that says 15 AAIP as a function of sulfur and nitrogen. 16 You see what I mean? 17 DR. SCHEFFE: Yes. 18 MEMBER HUSAR: That is how 19 normally you display these. Okay? And there 20 is none like that. There are all kinds of 21 other pieces in there but not the way the 22 dependence of the outcome damage as a function

### 202-234-4433 Neal R. Gross & Co., Inc. Page 172 1 of the drivers. 2 DR. SCHEFFE: Sure. Sure. You 3 are talking about a way of communicating it 4 that brings the relevancy most directly to it. 5 MEMBER HUSAR: Well, yes. Because 6 any other way you are not telling what is the 7 relationship between you measure, your index 8 of the damage as a function of what you can 9 control. 10 DR. SCHEFFE: No, I understand. I 11 understand. And so you are suggesting? 12 MEMBER HUSAR: I am suggesting, 13 therefore, that the nature of that expression 14 really should be evaluated and even shown 15 graphically. 16 DR. SCHEFFE: Yes. Yes, okay. 17 But again, we have those trade-off curves that 18 -- 19 CHAIRMAN RUSSELL: I think Myron 20 can clarify something. 21 MEMBER MITCHELL: I have just a 22 thought that we are now on question 11 --

### 202-234-4433 Neal R. Gross & Co., Inc. Page 173 1 MEMBER WEATHERS: Myron, can you 2 speak into the microphone, please? 3 MEMBER MITCHELL: -- and we have 4 26 questions. 5 CHAIRMAN RUSSELL: Yes, okay. 6 MEMBER MITCHELL: And some of us 7 are leaving early in the afternoon. So I just 8 want to be sure that we are all clear on how 9 we are proceeding. 10 CHAIRMAN RUSSELL: Yes, because 11 someone moved their flight up. 12 (Laughter.) 13 MEMBER HUSAR: But the last 14 sentence AAPI equation proposed standards 15 should include a range of applicability. Is 16 that okay? 17 MEMBER AMAR: Yes. 18 CHAIRMAN RUSSELL: Yes. Though as 19 Myron was bringing up, and actually, I should 20 just check this out, my understanding is that 21 Charlie and Myron have to leave shortly after 22 1:00?

### 202-234-4433 Neal R. Gross & Co., Inc. Page 174 1 MEMBER MITCHELL: 1:00, yes. A 2 little before 1:00. Our flight leaves at 3 2:30. 4 CHAIRMAN RUSSELL: Oh. 5 MEMBER MITCHELL: Leave at 2:00, 6 right? 7 CHAIRMAN RUSSELL: It is close. 8 MEMBER HANSON: I'm leaving at 9 12:30. 10 CHAIRMAN RUSSELL: 12:30. Okay. 11 So given that, Rich is already done. Thank 12 you. 13 So I hate to sort of take a quick 14 detour. Charlie, let's -- 15 MEMBER DRISCOLL: Do my questions? 16 CHAIRMAN RUSSELL: Yes and then we 17 will get back to the rest of the question in 18 Chapter 5. And so we will do Chapter 6, 19 Chapter 9, 5, 7. Go. 20 MEMBER DRISCOLL: Okay, I also had 21 actually, I had 11. 22 CHAIRMAN RUSSELL: Oh, yes, you

### 202-234-4433 Neal R. Gross & Co., Inc. Page 175 1 did. 2 MEMBER DRISCOLL: Yes, 11(a), I 3 should say. 4 So this question was about the 5 approach. And there is a certain amount of 6 redundancy with other questions but basically 7 it is saying that the panel believes that 8 steady-state models are the best approach but 9 recommends some consideration of using other10 approaches, such as dynamic modeling and long11 term measurements to evaluate some of the 12 assumptions and impacts of the steady-state 13 approach. 14 CHAIRMAN RUSSELL: The reason she 15 is highlighting dynamic is if we replace that 16 with non-steady state. 17 MEMBER AMAR: Because we suggest 18 the same to be parallel. 19 MEMBER DRISCOLL: So what would be 20 the alternative besides? You mean like 21 empirical approaches? Is that the 22 alternative?

### 202-234-4433 Neal R. Gross & Co., Inc. Page 176 1 CHAIRMAN RUSSELL: What to dynamic 2 or what? 3 MEMBER DRISCOLL: Well you say you4 are differentiating between dynamic and non5 dynamic. So what would non-dynamic be besides 6 -- 7 CHAIRMAN RUSSELL: It would be 8 steady-state. The reason why, and this comes 9 from our physicist, you were out of the room 10 when our physicist brought this up, was that 11 dynamics has to do with forces, accelerations 12 and such. So he preferred non-steady state. 13 MEMBER AMAR: If you are okay with 14 that, Charlie. 15 CHAIRMAN RUSSELL: If you are okay 16 with that. 17 CHAIRMAN RUSSELL: Well my 18 interpretation of dynamic would have a time 19 dependence, you know, where steady-state is 20 time independent, constant over time. And so 21 involving change, I would have a broader 22 definition of dynamic but I will yield to my

### 202-234-4433 Neal R. Gross & Co., Inc. Page 177 1 colleague. 2 MEMBER HUSAR: I think dynamics is 3 still okay. Because it is only a mechanical 4 system where dynamics is the force -- 5 MEMBER WEATHERS: Can you use the 6 microphone please? 7 MEMBER HUSAR: Only in the dynamic 8 -- Only in the mechanical systems, dynamic 9 requires the forces. But dynamic of more 10 complex chemicals and other kind of assistance
11 -- 12 MEMBER MITCHELL: Okay, let's move 13 on. 14 CHAIRMAN RUSSELL: It is time. 15 Yes, so dynamic is fine. 16 MEMBER POIROT: And I vote we 17 change it back in section four. 18 CHAIRMAN RUSSELL: Sounds good. 19 MEMBER CHESTNUT: If the meaning 20 is clear in the field of how it is used, I 21 think -- 22 MEMBER DRISCOLL: If we make the

### 202-234-4433 Neal R. Gross & Co., Inc. Page 178 1 wording too generic, nobody will understand 2 what we are talking about. 3 CHAIRMAN RUSSELL: Okay so keep 4 going. Well, first, does anyone have any 5 comments on this? 6 MEMBER MITCHELL: Just a 7 clarification that so Charlie is aware of the 8 discussion. Bryan brought up, he asked about 9 what we are really asking EPA to do in terms 10 of this particular effort. And I guess I am 11 asking one possibility would be, there has 12 been a fair amount of dynamic modeling output 13 that has been produced for certain sites. 14 Is it necessary for EPA to 15 actually do new dynamic modeling or is it the 16 possibility that some of this output that has 17 already been produced could be utilized in 18 this comparison? 19 MEMBER DRISCOLL: So in that 20 regard, towards the end of the document, I 21 took the liberty of putting in a plot which 22 shows a comparison between steady-state and

### 202-234-4433 Neal R. Gross & Co., Inc. Page 179 1 dynamic to illustrate. And this is for a 2 glaciated system. So it is not as severe as 3 it would be for non-glaciated systems. But 4 some of the differences between dynamic and 5 steady-state. 6 So I think if you could rely on 7 existing data analysis just to inform the 8 process, that is where I become, at least in 9 terms of this very short time frame. 10 MEMBER MITCHELL: I think I agree 11 with that, Charlie. I think you have done a 12 lot of those models. Those outputs are 13 available. 14 MEMBER DRISCOLL: There is a lot 15 that has been done with MAGIC, too. But I 16 also think that down the road, if this goes 17 forward, there should be sort of a parallel 18 effort where you also have a dynamic modeling 19 component to guide this because there is no 20 time dependence and managers are going to want 21 to know how fast these systems recover. and 22 if it is going to take 200 years to get to

### 202-234-4433 Neal R. Gross & Co., Inc. Page 180 1 steady-state, that may be a non-start. It 2 also may inform how much lower you would want 3 to reduce the emissions to try to accelerate 4 that process. 5 So I think that I have some 6 statement in there about building experience 7 in the use for future assessments. Because if 8 you look at what the Europeans have done, they 9 initially went entirely to steady-state models 10 and now they have recognized the limitations 11 of that so they increasingly used dynamic 12 models. So we don't need to reinvent the 13 wheel, hopefully. 14 MEMBER CHESTNUT: So do you want 15 to modify that in the middle there? It says 16 initiate an effort of dynamic modeling. Do 17 you want to -- 18 MEMBER DRISCOLL: Yes. How about 19 take advantage of ongoing efforts in dynamic 20 modeling? 21 You could just get rid of that. 22 You don't have to say a subset of the

### 202-234-4433 Neal R. Gross & Co., Inc. Page 181 1 watersheds. I thought there would be some 2 value if you did this on the same watersheds 3 that were already being analysis with the 4 steady-state approach, but that may not be 5 possible. But you could get rid of that. 6 Other questions? 7 MEMBER MITCHELL: Just quickly, I 8 see Bryan just came into the room. We just 9 talked about the utilization of dynamic versus 10 steady-state models. The suggestion we put in 11 the document now is to include some of the 12 ongoing results and efforts on the dynamic 13 modeling and making some comparison. Is that 14 a reasonable approach from EPA? 15 DR. HUBBELL: I am just giving a 16 dynamic update. And the question is when we17 differentiate between the glaciated and non18 glaciated areas, is there enough modeling, 19 dynamic modeling in the non-glaciated 20 environments to be able to inform that 21 discussion? 22 MEMBER DRISCOLL: Well there has

### 202-234-4433 Neal R. Gross & Co., Inc. Page 182 1 been quite a bit of work done with MAGIC that 2 might be able to be used. I don't know. I am 3 just throwing this out there if it is a bad 4 idea. But I think it helps, you know, inform 5 some of the assumptions that are used. 6 DR. HUBBELL: It is certainly not 7 a bad recommendation. I just wanted to 8 clarify if there is enough of that or if we 9 are going to have to think about doing some, 10 looking to see whether are able to do any 11 additional modeling in those type of systems. 12 MEMBER DRISCOLL: I think there is 13 probably quite a bit of output from MAGIC but 14 I would have to talk to Jason Lynch of Jack 15 Cosby about that. 16 DR. HUBBELL: Yes, we will check 17 with Jason. He is our guy on this stuff. 18 MEMBER DRISCOLL: Yes. 19 DR. HUBBELL: So we will make sure 20 that we check. And this is obviously again, 21 it is unfortunate that Jason wasn't able to be 22 here today but this is one of the clear areas

### 202-234-4433 Neal R. Gross & Co., Inc. Page 183 1 where we are going to take your 2 recommendations and sit down with Jason and go 3 through those. 4 MEMBER DRISCOLL: Okay, other 5 comments? Okay, if not the next question that 6 I did was on to Chapter 6. 7 So if you remember from yesterday, 8 I did some of these and my colleagues did 9 others. So I did 15, question 15. And again, 10 this is redundant with what I just did but 11 this just basically says that we endorse the 12 APPI approach. It seems appropriate for a 13 national scale assessment. But again, the 14 concerns about the non-steady-state assumption 15 and the degree to which that could be 16 evaluated would be helpful. 17 So very similar to what I had in 18 the last paragraph. 19 CHAIRMAN RUSSELL: Comments? 20 Works for me. 21 MEMBER DRISCOLL: Going, going, 22 gone.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 184 1 Let's see. The next is the 2 elements of the standard. I think I did this. 3 MEMBER WEATHERS: What number? 4 MEMBER DRISCOLL: Sixteen. I 5 think actually I didn't do this. Didn't you 6 do this, Naresh? 7 MEMBER KUMAR: I did 18. 8 MEMBER DRISCOLL: You did 18? 9 MEMBER KUMAR: Yes. 10 MEMBER DRISCOLL: Okay. It looks 11 like it was expanded from what I did, then. 12 MEMBER POIROT: What do you mean 13 Charlie by background levels of ANC in line 14 44? 15 CHAIRMAN RUSSELL: Microphone. 16 MEMBER POIROT: Background levels 17 of ANC in line 44? 18 MEMBER DRISCOLL: I'm not sure 19 that was my wording but I would assume it is 20 just pre-anthropogenic values. I mean, it is 21 used to sort of describe what that term is, 22 that background weathering term that is used

### 202-234-4433 Neal R. Gross & Co., Inc. Page 185 1 in the equation, the AAPI equation. 2 MEMBER POIROT: Yes. 3 CHAIRMAN RUSSELL: Line 12, next 4 page. Remove validation and its validation, 5 if you don't mind. Then on improvement of the 6 model performance of evaluation. 7 MEMBER WEATHERS: Did someone just 8 suggest replacing the word validation with 9 evaluation? 10 CHAIRMAN RUSSELL: Yes. 11 MEMBER WEATHERS: Yes, I like 12 that. The paragraph that starts with line 16 13 where I am, I would just say, I would put a 14 period after AAPI. 15 CHAIRMAN RUSSELL: And I might 16 just combine those last two paragraphs. 17 MEMBER DRISCOLL: So should we 18 move on? 19 CHAIRMAN RUSSELL: Yes. 20 MEMBER DRISCOLL: Has everybody 21 had a chance to read it? 22 Okay, so moving on to 17. And

### 202-234-4433 Neal R. Gross & Co., Inc. Page 186 1 again, I think this is redundant with what was 2 said before. So I think basically we said 3 that there would be advantages to separating 4 out those terms in G, the background 5 weathering rate and the nitrogen cycling term. 6 And this helps indicate the role that these 7 processes in the equation and also the 8 uncertainty in these processes in the 9 equation. 10 And then I put in, this is largely 11 my own doing, that they might want to consider 12 adding a term which accounts for the supply of 13 natural organic acids. So that is like the 14 second or third paragraph down there. 15 And then I had another sentence 16 about that I was concerned about recognition, 17 I guess of the waters with ANC values below 50 18 and acknowledgment that those may be naturally 19 acidic but those could be very sensitive 20 systems that have been impacted but are not 21 able to recover up to whatever the ANC limit 22 is of 50.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 187 1 So, it should be recognized that 2 these are potentially resources that, you 3 know, had been impacted but couldn't be 4 recovered, given the nature of the framework. 5 MEMBER CHESTNUT: Charlie, I don't 6 really understand that sentence that starts on 7 line 40, the panels concern. 8 MEMBER DRISCOLL: Okay, so we 9 talked about this yesterday. So there is like 10 an ANC limit of 50. So let's say you had a 11 system that started out as a background ANC of 12 20 or 25. It acidifies and then starts to 13 recover but it isn't able to recover up to 50. 14 It may have been impacted but because of the 15 limit, that is the limit that is going to be 16 set. So there will be a certain level of 17 sulfate and nitrate that would allow for 18 recovery of the ANC to 50, as I understand it. 19 So what do you do with those 20 systems that may have had viable resources but 21 were right on the margin, very, very highly 22 sensitive systems? And acknowledgment that

### 202-234-4433 Neal R. Gross & Co., Inc. Page 188 1 there is a subset of systems that are highly 2 sensitive that might not be recoverable. I 3 think that is what I was trying to get at in 4 that sentence. And so I think there should be 5 acknowledgment of that. 6 Do you have a comment, Naresh? 7 MEMBER KUMAR: Yes. I guess I 8 understand that a limit of 50 were used in the 9 calculation but there was no discussion of any 10 possible levels in this meeting. So I don't 11 understand why we need to mention anything 12 related to levels here. Because we did not 13 discuss -- 14 CHAIRMAN RUSSELL: Keep going. 15 MEMBER KUMAR: Yes, so I would 16 recommend not including this, at least at this 17 stage until we have some discussion of it 18 maybe in the next round. 19 MEMBER DRISCOLL: That's fine. I 20 just wanted some discussion about it so it was 21 a little bit more explicit in the document. 22 MEMBER CHESTNUT: You could make

### 202-234-4433 Neal R. Gross & Co., Inc. Page 189 1 it more generic concerned about addressing 2 waters where, you know, that aren't 3 recoverable or that are -- 4 MEMBER DRISCOLL: Yes, or it may 5 be premature. Maybe it will be more evident 6 in the next round. You know, whatever the 7 panel wants to do. 8 MEMBER CHESTNUT: But you are 9 making a distinction between these and places 10 where there is natural -- it is naturally 11 acidic below that. 12 MEMBER DRISCOLL: Yes, I think 13 both occur. There are systems that are 14 naturally acidic. You know, that have always 15 had very low ANCs probably because of organic 16 acids. But there are also systems that are 17 also acidic but also have been impacted, very 18 highly sensitive systems. 19 MEMBER CHESTNUT: And they are 20 beyond repair, is what you are saying. 21 MEMBER DRISCOLL: Well they may 22 be. It depends on what you set for your ANC

### 202-234-4433 Neal R. Gross & Co., Inc. Page 190 1 limit. Right? You can set it to low enough 2 value that you might recover them up. But I 3 think it is likely, given what we are seeing 4 in the trends that there are systems that had 5 a fishery at one point in time, have acidified 6 and it seems unlikely it will be able to 7 recover that fishery. 8 MEMBER CHESTNUT: So what should 9 EPA, I mean, what needs to be done to address 10 that? 11 MEMBER DRISCOLL: Well, I just 12 think that there are -- we talked a little bit 13 yesterday that there is going to be some level 14 of sites that will be recoverable, if you 15 will. And not 100 percent of the sites are 16 going to be recoverable. And I think that, 17 you know, so I think that that is appropriate, 18 that there is going to have to be some 19 explicit acknowledgment that you make some 20 sort of a decision about what is the level, 21 you know, this level the standard, what is the 22 percentage of lakes that were impacted that

### 202-234-4433 Neal R. Gross & Co., Inc. Page 191 1 will be recoverable. 2 And we had some distribution 3 curves that I think Tara showed, somebody 4 showed, yesterday, which basically showed a 5 cumulative distribution of sort of the level 6 of recovery. So I imagine that there is going 7 to be, it would be something along those 8 lines. So Brian was talking about details of 9 the curves, if you will and where the 10 implications of the tails of the curves. And 11 I think that what I am looking for is some 12 additional discussion on that. 13 CHAIRMAN RUSSELL: So I think 14 someone suggested removing it. But I don't 15 think we want to totally remove it. 16 DR. HUBBELL: This is Bryan. I 17 would say that actually, when we looked at 18 your graph, that actually sparked actually 19 some though process for Tara and myself to 20 talk about. Because we did talk about 21 excluding certain, I mean, whether it is 50 or 22 20 or whatever, --

### 202-234-4433 Neal R. Gross & Co., Inc. Page 192 1 CHAIRMAN RUSSELL: Right. 2 DR. HUBBELL: -- we talked about 3 excluding some of those lakes a priori when we 4 calculated the critical loads. And your point 5 about that made us think well is that really 6 what we want to do. If we are looking at a 7 level of 100, you exclude an awful lot of 8 lakes. 9 MEMBER DRISCOLL: Right. 10 DR. HUBBELL: And so I think we 11 need something different there and we need to 12 think about that some more, maybe to address 13 the fraction that is addressable through our 14 recovered processes, rather than addressing 15 the component is dominated by the organic 16 acids, etcetera. 17 So I think we need to be thinking 18 about that but certainly it would be helpful 19 to have the comment that it is a good thing 20 for us to consider. So I was just going to 21 say, it was a valuable comment, even if you 22 take it out now. It will help us think. So

### 202-234-4433 Neal R. Gross & Co., Inc. Page 193 1 however you want to do that because it is a 2 valuable concept. 3 CHAIRMAN RUSSELL: And Rudy, were 4 you saying something? 5 I was just thinking that if we 6 removed "the panel is concerned . . ." just go 7 to studies have shown that" -- Well, actually 8 don't. Go to the sentence don't not you can 9 go with everybody else. 10 Studies have shown that 11 chronically acidic or highly acid sensitive 12 surface waters are among the most highly 13 impacted from acid deposition. Justification 14 for -- this is where it gets tough. 15 Justification for not considering these most 16 acid-sensitive and acid-impacted surface 17 waters. 18 MEMBER DRISCOLL: Maybe since this 19 is a work in progress, maybe we should just 20 strike the whole thing if they are going to 21 rethink how they are doing it. 22 CHAIRMAN RUSSELL: Yes.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 194 1 MEMBER DRISCOLL: And then I 2 didn't intend this to have -- I was just 3 trying to capture the comments from yesterday. 4 So maybe it would be best just to wait and see 5 what -- 6 MEMBER CHESTNUT: Can it be 7 something more generic just for them to 8 reconsider how they are going to address -- 9 MEMBER DRISCOLL: Or acknowledge 10 the systems that are not, the extent of the 11 systems that are not recoverable or something 12 like that? 13 MEMBER CHESTNUT: Or take account 14 of the systems that are, you know. 15 CHAIRMAN RUSSELL: I mean I 16 wouldn't mind what as Charlie is suggesting 17 and what Brian has said is that they know, 18 they got the gist of -- 19 MEMBER CHESTNUT: Yes, but it is 20 good to have it -- 21 CHAIRMAN RUSSELL: Okay. 22 MEMBER CHESTNUT: -- documented

### 202-234-4433 Neal R. Gross & Co., Inc. Page 195 1 just so they can -- 2 MEMBER CHESTNUT: Okay, then we 3 need some language. 4 MEMBER DRISCOLL: Okay. How about 5 some consideration of highly acid-impacted and 6 acid-sensitive systems that are not 7 recoverable under an ANC limit should be 8 discussed in the next report. 9 CHAIRMAN RUSSELL: So some 10 consideration of the chronically acidic or 11 highly acid-sensitive surface waters. 12 MEMBER DRISCOLL: Yes. 13 CHAIRMAN RUSSELL: Highly 14 sensitive. Highly acid-sensitive surface 15 waters. 16 MEMBER DRISCOLL: That would not 17 be recoverable at a given ANC limit should be 18 given in the next report. Something like 19 that. 20 CHAIRMAN RUSSELL: Should be given 21 in the next PA. 22 MEMBER DRISCOLL: PA?

### 202-234-4433 Neal R. Gross & Co., Inc. Page 196 1 CHAIRMAN RUSSELL: In the next 2 draft of the PA and then get rid of the rest. 3 MEMBER DRISCOLL: Is that better? 4 Should we move on? 5 CHAIRMAN RUSSELL: Yes. 6 MEMBER DRISCOLL: Okay, so the 7 next is -- I am going to just go right through 8 the ones I have got? 9 CHAIRMAN RUSSELL: Yes. 10 MEMBER DRISCOLL: So the next one 11 is 19 that I did. That is the trade-off 12 curves. And so I said that I thought that the 13 panel thinks that the trade-off curves are a 14 useful approach to think about this problem, 15 particularly the multi-pollutant problem. 16 And then, that is what I said, I 17 took the liberty of putting in the similar 18 curves that we have developed with dynamic 19 models. We can get rid of this -- I just did 20 that just because I talked about it yesterday 21 so that we could get rid of the figure. 22 CHAIRMAN RUSSELL: I mean, I don't

### 202-234-4433 Neal R. Gross & Co., Inc. Page 197 1 see why we need to get rid of it. 2 MEMBER DRISCOLL: So I think that 3 this shows, so I think the reason why I showed 4 this is because this sort of informs the 5 nature of steady-state versus dynamic. So in 6 the theoretical framework that was put forward 7 for when you were on the angled portion of the 8 curve, it has a slope of one. One equivalent 9 of sulfate will do the same thing as one 10 equivalent of nitrate. 11 But these dynamic model curves 12 suggest that they don't have this Stokey 13 metric and that is due to the processes that 14 are occurring within the system. 15 It also illustrates that these 16 lines are lines of equal ANC. It also shows 17 the panel on the left is for steady-state and 18 the panel on the right is for just an 19 arbitrary year 2030. And so you can see that 20 over time the ANC values increase. So that 21 illustrates the difference between the dynamic 22 and steady-state values.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 198 1 So anyway, I just put that in 2 there. So again, this was a suggestion that 3 they could use dynamic models to illustrate 4 some of the assumptions associated with a 5 steady state approach. 6 Are we good? I'm not pushing 7 things through too quickly, am I? 8 CHAIRMAN RUSSELL: No. 9 MEMBER DRISCOLL: All right, good. 10 With that, I will go on. 11 Then the next one was the 12 averaging. And again, this has been covered 13 previously, single year versus multi-year. 14 And so I said we supported a multi-year 15 approach. We thought three years would be 16 good. It is probably minimal to try to sort 17 out the year to year variations. I think 18 largely due to climate. But I think we said 19 yesterday that we would support even more, if 20 that was possible, four or five years. 21 Good? All right. 22 All right, then 21 is about

### 202-234-4433 Neal R. Gross & Co., Inc. Page 199 1 monitoring. And I had a very long section and 2 I think Rich had a section. And this was cut 3 way back and I have no problem with that. But 4 I think it would be good to add a little bit 5 to the end, in the end the last line, which is 6 talking about the time and LTM programs. 7 So I thought, I had a little bit 8 of text in there talking about advantages to 9 adding additional monitoring, such as soil 10 monitoring and biological monitoring because 11 those are going to be important endpoints and 12 we have virtually no information on those 13 resources. 14 So, I for one would like to see a 15 sentence saying that we would be interested in 16 expanding to include some soils and biological 17 monitoring programs to the existing programs. 18 MEMBER AMAR: Also 21, the 19 question itself, I think is incorrect. The 20 second part, is for they. I think you want to 21 say "Are the proposed three ambient 22 measurements sufficient?"

### 202-234-4433 Neal R. Gross & Co., Inc. Page 200 1 If you notice question 21, top 2 line, end of the first line, 18. 3 Yes, the question itself is not 4 said correctly, 21. Line 18, the end of the 5 line. Instead of saying "is for three 6 proposed" it should say "are three proposed 7 ambient measurements sufficient." 8 MEMBER CHESTNUT: Charlie? 9 MEMBER DRISCOLL: Yes, we could 10 probably get rid of monitoring. We could just 11 either say expansion of existing programs to 12 include some soil and biological monitoring. 13 And I think that is all I had. 14 CHAIRMAN RUSSELL: Then 22 is -- 15 Actually you are part of 21 and then also 22. 16 And since you are also leaving us shortly. 17 MEMBER POIROT: Right, 22 was 18 asking about using the existing NOy and PM2.5 19 sulfate measurement techniques as the basis 20 for defining federal reference methods. And 21 I tried to kind of say yes, those are 22 reasonable in both cases to put a few cautions

### 202-234-4433 Neal R. Gross & Co., Inc. Page 201 1 on the simple extension of currently NOy 2 monitoring techniques that there are going to 3 be some bugs that are currently being worked 4 out. But by and large, the methods are sound. 5 In addition, recommending that we 6 have the M's Monitoring and Methods Committee 7 provides some feedback and advice on how to 8 measure those species, in addition to other 9 key species such as gaseous ammonia and 10 organic nitrates. I don't know if that was 11 taking it too far, Ted or not. 12 CHAIRMAN RUSSELL: No. 13 MEMBER POIROT: But it seems like 14 we have talked about those two things quite a 15 bit. We might as well. 16 CHAIRMAN RUSSELL: I think they go 17 in here. 18 MEMBER POIROT: I see a typo in 19 the last line of routine. That would be 20 routing. 21 CHAIRMAN RUSSELL: Yes, that 22 should be routing.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 202 1 MEMBER POIROT: You know the one 2 thing I left out, I took out a sentence I had 3 after the first one about fine particle 4 sulfate saying something about how CASNET 5 approaches using open-faced non-size-specific 6 sampling should produce similar results. I 7 put it in there because I thought some purist 8 might say oh but fine particles are not the 9 only sulfate that deposits. And I didn't want 10 people saying that we have to put fine 11 particle heads on CASNET samples because there 12 are other problems with that. 13 But I took it out because I 14 figured if somebody is going to make an 15 argument that course particle sulfate 16 deposition is really important in these remote 17 ecosystems, they should recognize that it 18 comes typically carrying its own buffering 19 cation. It is not there but for the crystal 20 cation or the sea salt cation that helped 21 deliver it. So that is why I left it out. 22 CHAIRMAN RUSSELL: Anything else

### 202-234-4433 Neal R. Gross & Co., Inc. Page 203 1 on 22? Thank you. Myron. So now we are 2 moving to Chapter 9. 3 MEMBER AMAR: May I have one 4 question?
5 CHAIRMAN RUSSELL: Yes. 6 MEMBER AMAR: Question 12, which 7 really is Richard's point of view and I wrote 8 it and Richard is leaving. I don't know, 9 Myron are you leaving, too? I am just trying 10 to find out the timing here. But I would 11 rather have Richard here when we talk about 12 question 12. 13 MEMBER POIROT: I mea leaving in 14 ten minutes. 15 MEMBER AMAR: Okay. Question 12 I 16 think I might need input also. I think you 17 added something, Paul. There is some language 18 I did not see before. I am just trying to get 19 it. 20 Question 12 I think starts with 21 Paul and then my summary of what Rich had 22 said. That it is not well written at this

### 202-234-4433 Neal R. Gross & Co., Inc. Page 204 1 time. 2 MEMBER POIROT: Yes, somebody ask 3 me to contribute something. 4 MEMBER AMAR: Yes, so I just 5 wanted to make sure. 6 MEMBER POIROT: I'm not married to 7 it. 8 MEMBER AMAR: Okay. 9 MEMBER MITCHELL: Twelve. Right? 10 MEMBER AMAR: Yes, number 12. 11 MEMBER POIROT: I guess Praveen, 12 if you were taking the last couple of 13 sentences, 39 through 41 from my comments, -- 14 MEMBER AMAR: Yes. 15 MEMBER POIROT: -- I would like to 16 pull a Husar-like argument with myself. 17 MEMBER AMAR: We only have five 18 minutes, though. 19 MEMBER POIROT: I think I am a 20 Republican after all. It doesn't matter what 21 I said yesterday. 22 I think that is, I don't know

### 202-234-4433 Neal R. Gross & Co., Inc. Page 205 1 about ideal, but that it would be ideal 2 indicators would show. I don't know if that 3 is correct. 4 MEMBER AMAR: Yes. 5 MEMBER POIROT: You know, what if 6 we were to say something like the range 7 currently considered seems rather broad, 8 considered to the ANC range of 50 to 100 and, 9 ideally, could be narrowed in future 10 assessments or something like that. 11 MEMBER AMAR: Where is the 12 pleasure of the -- Yes, that kind of takes it 13 away from ideal in part. 14 MEMBER POIROT: What does Paul 15 think about that? 16 MEMBER HANSON: Well there is just 17 a general premise here that there is a way to 18 combine the two and I am not sure that exists. 19 I think the aquatic systems have been 20 developed based on ANC and the relationships 21 that are known for upland terrestrial systems 22 are based on base cation aluminum ratios. It

### 202-234-4433 Neal R. Gross & Co., Inc. Page 206 1 would be great if they could be combined. I 2 am not convinced that they can be combined. 3 I am not sure we should spend a lot of time 4 trying to combine them. 5 MEMBER DRISCOLL: How about might 6 be narrowed in future assessments? 7 As long as we are on that line, 8 can we put after 100 microequivalents per 9 liter and after ten BC/AL so we have the 10 specific units? It is actually under recently 11 used symbols if you want the fourth one over, 12 fifth one over. 13 MEMBER POIROT: And then you could 14 delete the last sentence. Right? 15 MEMBER DRISCOLL: Yes. 16 MEMBER AMAR: And then line 43, 17 then we are saying, which I think what you 18 were saying, Rich is not consistent but what 19 we are saying right in the beginning of this 20 part, saying maybe you should not make an 21 effort to have joint standards. And this one 22 says we should. So it is one or the other or

### 202-234-4433 Neal R. Gross & Co., Inc. Page 207 1 some in-between position. 2 So I think the question is can a 3 good argument be made or not made to have 4 joint standards? So keep aquatic as it is and 5 terrestrial as it is, not mix up BC to AL 6 ratio with ANC. 7 MEMBER HANSON: I think that, I 8 mean, for me that is where the reality lies. 9 MEMBER AMAR: I mean, I claim no 10 expertise. I am just looking at the point of 11 view. 12 MEMBER HANSON: I mean some of 13 these other questions come to this issue, too. 14 And I think what I heard discussed yesterday 15 was that people were leaning towards a focus 16 on the aquatic system because the general 17 overall database was more intact and 18 defensible. And a general sense that there 19 was a higher level of sensitivity there. So 20 if you protected it, it would protect the 21 terrestrial. 22 MEMBER DRISCOLL: I don't buy

### 202-234-4433 Neal R. Gross & Co., Inc. Page 208 1 that. I think the soils are more sensitive 2 than the aquatic. Soils are continuing to 3 acidify. The aquatics are recovering, for the 4 most part. At least in the northeast. Maybe 5 not in the southeast. 6 CHAIRMAN RUSSELL: People like 7 what -- 8 MEMBER HANSON: This is a case 9 where we need to beg for simpler questions in 10 the future. 11 (Laughter.) 12 MEMBER HANSON: This is an 13 impossible question to craft a concise answer 14 to. 15 CHAIRMAN RUSSELL: Okay. 16 MEMBER DRISCOLL: We could just 17 say something, rather than a good argument, we 18 could say something like, if appropriate both 19 ANC and BC/AL could be used or appropriate -- 20 that is not right, is it? Appropriate. So 21 just before you type anything, something like 22 if appropriate aquatic or terrestrial

### 202-234-4433 Neal R. Gross & Co., Inc. Page 209 1 indicators for the more sensitive system could 2 be used or might be used to protect the lesser 3 sensitive system. However, this would need 4 further evaluation or something like that. Do 5 you understand what I am saying or is it too 6 confusing? 7 CHAIRMAN RUSSELL: I understand 8 what you are saying. If appropriate, the 9 terrestrial -- So see if we can pick this up. 10 MEMBER DRISCOLL: The indicators 11 for the more sensitive ecosystem could be used 12 to protect the lesser sensitive ecosystem. 13 However, this would need further evaluation. 14 CHAIRMAN RUSSELL: If appropriate, 15 the indicator for the more sensitive ecosystem 16 can be used to provide protection for the less 17 sensitive ecosystem. I'm not sure I heard a 18 however. 19 MEMBER DRISCOLL: However, this 20 would require -- 21 CHAIRMAN RUSSELL: Oh, that's 22 right.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 210 1 MEMBER DRISCOLL: -- further 2 evaluation. You might say rather than can, 3 you might say could, could be used. 4 CHAIRMAN RUSSELL: So, -- 5 MEMBER CHESTNUT: Delete the rest 6 of that paragraph or no? 7 MEMBER DRISCOLL: I am a little 8 confused by it. 9 MEMBER HANSON: I think what you 10 are saying is that they should just use the 11 most restrictive AAPI that they come up with. 12 Right? 13 MEMBER DRISCOLL: Right. 14 MEMBER HANSON: And don't put it 15 in units of lakes, for my benefit. 16 MEMBER DRISCOLL: Yes, it should 17 just be surface waters. 18 CHAIRMAN RUSSELL: So modifying 19 the rest of this paragraph with ANC and BC/AL, 20 it could be used as ecological indicators, 21 period. And even that I am not taken with. 22 MEMBER DRISCOLL: You could say to

### 202-234-4433 Neal R. Gross & Co., Inc. Page 211 1 protect ecosystems against acidification, be 2 like that. 3 CHAIRMAN RUSSELL: Yes. And maybe 4 and get rid of "and potentially?" 5 MEMBER DRISCOLL: So this second 6 part of the sentence is a little bit 7 different. I mean, we are talking about use8 of aquatic to protect terrestrial or vice9 versa. But the second part deals with more 10 spatial variability and scaling across space. 11 So you might have some part of the watershed 12 where there is very sensitive conditions and 13 that is sort of overwhelmed by the larger part 14 of the watershed that has least sensitive 15 conditions. So it seems like it is like two 16 different thoughts. 17 CHAIRMAN RUSSELL: Yes. I am 18 tempted to actually lose the last sentence. 19 So let's get rid of the last sentence. 20 MEMBER AMAR: The next paragraph 21 is a different concept. 22 CHAIRMAN RUSSELL: Yes.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 212 1 MEMBER AMAR: It kind of brings a 2 new point up what Rich had been saying about 3 TMD and approach and EPA should pay attention 4 to that, I guess. 5 CHAIRMAN RUSSELL: Comments on it? 6 MEMBER AMAR: And the last one 7 starting a line eight, that simply says this 8 whole business about Chesapeake Bay and have 9 a better, I don't know, through modeling or 10 measurement, a clear understanding of the 11 fraction from atmospheric deposition. 12 My sense was we are not sure. 13 CHAIRMAN RUSSELL: Well and also 14 that they weren't sure that they could show 15 how reducing nitrogen deposition would -- 16 MEMBER AMAR: May or may not help. 17 CHAIRMAN RUSSELL: Yes, may or may 18 not help. 19 MEMBER AMAR: But even before we 20 get to that judgment, the quantification 21 itself, I think. I think REA had description 22 as much as 40 percent for Chesapeake Bay

### 202-234-4433 Neal R. Gross & Co., Inc. Page 213 1 coming from atmospheric deposition. In other 2 places, it is less than 40. 3 CHAIRMAN RUSSELL: Any 4 modifications to what Praveen has? 5 And actually, can establish 6 reliable standards. It is, even they need to 7 come up with an indicator. Because right now 8 we have ANC as the indicator but we don't have 9 any indicator for -- 10 MEMBER AMAR: I think you are 11 right. That is I think what should have been 12 meant, reliable ecological indicators. 13 CHAIRMAN RUSSELL: An appropriate 14 ecological indicator and reliable standards. 15 Ecological indicator. 16 MEMBER AMAR: One more point, all 17 the surgery we did for line 43 and 44 and if 18 you go at the beginning of this thing, 19 beginning of answer to question 12, that is 20 what Paul had said, which kind of says 21 problematic, doing this thing together. 22 So are we consistent within our

### 202-234-4433 Neal R. Gross & Co., Inc. Page 214 1 own answer? 2 MEMBER HANSON: It is difficult 3 because the question asks about five different 4 disjointed things. They illuminate the first 5 paragraph. If it will move us along, that 6 will make me happy. Fine by me. 7 CHAIRMAN RUSSELL: So how about 8 removing the first sentence? Thoughts? 9 MEMBER CHESTNUT: The first 10 sentence of which? 11 CHAIRMAN RUSSELL: The development 12 of a single standard. 13 MEMBER KUMAR: I didn't follow. 14 What is the reason for removing that? I 15 thought we agreed on -- 16 MEMBER HANSON: I think it is 17 true. I don't know if it -- It doesn't 18 necessarily need to be there. 19 MEMBER MITCHELL: It doesn't add 20 to the picture. Right? 21 MEMBER HANSON: Right. 22 MEMBER MITCHELL: Take it out.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 215 1 CHAIRMAN RUSSELL: I mean it is 2 again, -- 3 MEMBER MITCHELL: And the other 4 statement is becoming implicit that that is 5 the case. 6 CHAIRMAN RUSSELL: Yes. 7 MEMBER MITCHELL: So I guess to 8 make that clear then, so probably at line 45, 9 probably ecological indicators and the like. 10 Obviously we are not going to say 11 an indicator for aquatic and terrestrial 12 systems. Right? 13 CHAIRMAN RUSSELL: Yes. 14 MEMBER MITCHELL: And that kind of 15 echoes that situation. 16 CHAIRMAN RUSSELL: Indicate? 17 MEMBER MITCHELL: Yes, appropriate 18 ecological indicators. 19 CHAIRMAN RUSSELL: Yes. Other 20 comments on it? 21 Thirteen. What? Oh, 11(b), (c), 22 (d), and (e).

### 202-234-4433 Neal R. Gross & Co., Inc. Page 216 1 So Kathleen, you are up. Eleven 2 B. Kathleen, are you there? 3 MEMBER POIROT: It's lunchtime. 4 She went to lunch. 5 CHAIRMAN RUSSELL: Okay, (b), (c), 6 (d) is Rich, (e) we are back to Praveen. 7 MEMBER AMAR: Okay, (e) is back to 8 again nitrogen. So what we said earlier, we 9 want to make sure that this is consistent with 10 what we just agreed on. 11 It says structure is good. It 12 takes into account nitrogen deposition but it 13 does so by controlling for ammonia as a 14 constant external variable. 15 CHAIRMAN RUSSELL: I would remove 16 as a constant external variable. 17 MEMBER AMAR: Okay. It was true, 18 I guess, as of yesterday. 19 CHAIRMAN RUSSELL: But it no 20 longer is true. 21 MEMBER AMAR: Okay so this would 22 lead to over or under protection. This

### 202-234-4433 Neal R. Gross & Co., Inc. Page 217 1 language is coming from the executive summary. 2 The better ammonia approach is to -- okay. 3 Explicitly. Okay again, I am back to this 4 ammonia is a significant precursor. 5 So maybe just copy the language 6 from what you did before or at least be 7 consistent with. 8 CHAIRMAN RUSSELL: Okay so where 9 we would pick it up from? 10 MEMBER AMAR: The one we had right 11 under question ten. That is the modified 12 language, where the reds are in ten. Let's 13 see. However, as currently proposed -- That 14 is line 20. I can't say it is good but you 15 know, starting 20 we start raising questions 16 about ammonia. 17 So from 20 to 28, that language, 18 some form of that should show up under 19 question what are we doing 13? 20 CHAIRMAN RUSSELL: We might just 21 refer back to our comment. 22 MEMBER AMAR: That is one way to

### 202-234-4433 Neal R. Gross & Co., Inc. Page 218 1 do it. 2 CHAIRMAN RUSSELL: Yes, I would 3 just refer back to our comments in charge 4 question ten. 5 MEMBER AMAR: Yes, I think, yes, 6 see the answer about. Yes, that will suffice. 7 I am not saying anything different here. 8 CHAIRMAN RUSSELL: And then I 9 think we can remove the rest of that 10 paragraph. 11 Okay? Other comments on this one? 12 Thirteen. Naresh. 13 MEMBER KUMAR: Yes. So this is 14 where we introduce the sensitivity study that 15 we were talking about yesterday. So I guess 16 we have to read the language whether it is 17 okay with the panel. But the main thing is in 18 the end I did quote an example on how that 19 calculation could be done in the sensitivity 20 calculation. 21 So in the current AAPI equation 22 for example, you could calculate the VECO using

### 202-234-4433 Neal R. Gross & Co., Inc. Page 219 1 the two different approaches. 2 CHAIRMAN RUSSELL: You mean NECO. 3 Right? 4 MEMBER AMAR: NECO. Sorry. 5 CHAIRMAN RUSSELL: We have too 6 many V's in there as it is. 7 MEMBER AMAR: And for BC term, see 8 I was not very clear on how that would be 9 estimated. So I just put that and we use a 10 prior range. So if anyone else has a better 11 idea on how that could be done, we could do 12 that. 13 But and then for the estimate of 14 Q, that could be based on different years. I 15 mean, dry versus wet area you are going to 16 have a very different estimate for Q term. 17 And then the other three terms, I 18 think using different air quality model 19 simulations, that may already be available. 20 So EPA doesn't have to do new modeling when 21 they could have used the CMAQ and CAMx 22 simulation for different years. If possible,

### 202-234-4433 Neal R. Gross & Co., Inc. Page 220 1 the different ecological conditions and 2 different air emissions and also if they have 3 simulations available or if they can conduct 4 new simulation with different chemical 5 mechanisms, that will also help. 6 CHAIRMAN RUSSELL: And what I 7 would say, use CMAQ, CAMx, or other model. 8 Just RMs might be able to provide some 9 information. 10 MEMBER MITCHELL: I guess I would 11 strike out the last one, using different 12 chemical mechanisms. That is going to get 13 into a very different type of, almost a 14 research type of issue versus a -- 15 MEMBER KUMAR: But different 16 chemical mechanisms could get very different 17 results. If they have similar -- because EPA 18 might already have CMAQ with CV5 and separate 19 mechanisms available. So if they have, why 20 not use both? I mean, we are not asking them 21 to do new research here. 22 MEMBER MITCHELL: I think you just

### 202-234-4433 Neal R. Gross & Co., Inc. Page 221 1 compare the different model outputs in terms 2 of what we want to do is probably -- 3 MEMBER KUMAR: This is just being 4 more specific.
5 MEMBER MITCHELL: Yes. 6 CHAIRMAN RUSSELL: Anything else 7 on 13? 8 MEMBER AMAR: Line 11 I am just a 9 little picky with. Uncertainties alone? I 10 would say rather than the uncertainties by 11 themselves, not alone. Same meaning. 12 CHAIRMAN RUSSELL: So by 13 themselves? 14 MEMBER AMAR: Yes, not stand 15 alone. 16 MEMBER DRISCOLL: How about in 17 line 14, rather than it would be good, it 18 would be helpful if all the uncertainties? 19 CHAIRMAN RUSSELL: Yes. 20 MEMBER MITCHELL: Just as a point 21 of clarification, I thought during yesterday 22 we discussed the two approaches for NECO; one

### 202-234-4433 Neal R. Gross & Co., Inc. Page 222 1 which gives you just the nitration 2 concentration, the other actually looks at the 3 mechanisms of uptake and denitrification. I 4 thought that we concluded that that former 5 method is almost impossible to do. So I am 6 not sure it is a worthwhile exercise to do an 7 uncertainty analysis of something which really 8 is not going to -- there is so much 9 uncertainty in each of those individual 10 measures, I am not sure it is going to be the 11 best time and use associated with this 12 uncertainty analysis. I don't know if others 13 on the panel agree or disagree with that. 14 CHAIRMAN RUSSELL: No, I mean, I 15 just looked at it, or I can see since it is 16 one way of coming up with that, even though it 17 may not be useful or what they should use in 18 their application, just do we have another 19 approach that makes sense on this one? 20 MEMBER MITCHELL: Just that I 21 think the staff suggested these two different 22 approaches and I guess I am just suggesting

### 202-234-4433 Neal R. Gross & Co., Inc. Page 223 1 the one approach with the more detailed 2 mechanisms, those mechanisms really are very 3 well quantified. And I just think it might 4 not be a good use of time in terms of this 5 effort. 6 There is other places where all 7 kinds of uncertainty analysis can be done. So 8 focus on those. 9 MEMBER KUMAR: And we did not 10 discuss 11(b) that talked about this term. So 11 what was the reason for not discussing that? 12 CHAIRMAN RUSSELL: Kathleen wasn't 13 on the phone. 14 MEMBER KUMAR: Oh, okay. 15 So maybe we can come back to this 16 after discussing 11(b)? 17 CHAIRMAN RUSSELL: Yes but one 18 thing I want to do is two gentlemen are 19 unplugging their laptops, is we are about to 20 lose quorum, I believe. So I think everyone 21 has had a chance to read the letter and we are 22 almost all the way through the questions. And

### 202-234-4433 Neal R. Gross & Co., Inc. Page 224 1 assuming that we do not change the flavor of 2 the letter, what I would like to do is get 3 everyone's approval for us to continue 4 wordsmithing after going through our exercise 5 here and then getting the letter back to the 6 committee for further editing. 7 So basically asking for a vote 8 that we approve the letter with the allowance 9 of us to do further editing on -- how do you 10 put that? Essentially not on content but on -
11 - 12 MEMBER CHESTNUT: Non-substantive 13 clarification.14 CHAIRMAN RUSSELL: -- on non15 substantive issues. 16 MEMBER DRISCOLL: So moved. 17 CHAIRMAN RUSSELL: Seconded? 18 MEMBER KUMAR: I second it. 19 CHAIRMAN RUSSELL: Okay, all in 20 favor? 21 (Chorus of ayes.) 22 CHAIRMAN RUSSELL: All opposed?

### 202-234-4433 Neal R. Gross & Co., Inc. Page 225 1 (No response.) 2 CHAIRMAN RUSSELL: Good but don't 3 leave until you really have to. 4 Kathleen, you are still not there. 5 Right? 6 DR. HUBBELL: I had one 7 clarification to ask on this. In the previous 8 statements about uncertainty, you acknowledged 9 that it would be impractical at this point to 10 try to do a probabilistic assessment. The 11 wording of this particular response where you 12 say propagate the uncertainty is to arrive at 13 an ensemble of this NECO and Noy response 14 service to provide a confidence interval. 15 Confidence interval implies that we are doing 16 a probabilistic estimate and that is going to 17 be really difficult to do here. 18 I think what you are recommending 19 is that you want us to take the multiple 20 sensitivities and propagate them through so we 21 can actually see how they affect the final 22 results, as well as the individual components

### 202-234-4433 Neal R. Gross & Co., Inc. Page 226 1 of the standard, which I think is a great 2 idea. 3 But in terms of providing a 4 confidence interval, it means we would have to 5 specify distributions for each of the elements 6 and then propagate them through, which I think 7 we really, really -- 8 MEMBER KUMAR: I am okay changing 9 that to range. 10 DR. HUBBELL: Yes, range would, I 11 think, be better. 12 CHAIRMAN RUSSELL: That would be 13 good. A different range. 14 MEMBER KUMAR: Next line. 15 CHAIRMAN RUSSELL: Keep going. 16 Line 19. So remove confidence interval and 17 put range. 18 MEMBER AMAR: Propagate, ensemble, 19 and confidence level, that is all coming from 20 kind of Monte Carlo stuff. 21 MEMBER KUMAR: Not necessarily. 22 MEMBER AMAR: No?

### 202-234-4433 Neal R. Gross & Co., Inc. Page 227 1 CHAIRMAN RUSSELL: No. I mean, 2 ensemble could actually there infer set. 3 Okay, that was 13. Any other 4 comments on that? 5 Actually before you two go, do you 6 have any other ways that they might estimate 7 or come up with a confidence -- not a 8 confidence but different values for NECO that 9 could be used? 10 MEMBER MITCHELL: No. I mean, 11 there are two ways. Right? How you come up 12 with those values? I think the second method 13 is almost an empirical value while the first 14 is that series of calculations? 15 CHAIRMAN RUSSELL: Yes. 16 MEMBER MITCHELL: So I guess you 17 could try to look at some places where they 18 have different empirical measurements and how 19 much that varies. 20 CHAIRMAN RUSSELL: Okay. So that 21 would be -- 22 MEMBER MITCHELL: Yes and I don't

### 202-234-4433 Neal R. Gross & Co., Inc. Page 228 1 think there is much else you can do. Do you 2 agree Charlie? 3 MEMBER DRISCOLL: Yes, I mentioned 4 yesterday there are also some nitrogen models 5 that could be applied. But given the time, I 6 think that the empirical method is really the 7 path of least resistance. 8 CHAIRMAN RUSSELL: Okay. So, -- 9 DR. HUBBELL: I think we got that 10 yesterday. We said we can try it in a couple 11 of locations and the existing work has already 12 been done with the nitrogen model and we will 13 try to think about that. 14 MEMBER DRISCOLL: The nitrogen 15 modeling isn't very good. 16 DR. HUBBELL: Okay. 17 (Laughter.) 18 CHAIRMAN RUSSELL: So calculate NECO 19 using different empirical, different observed 20 levels? 21 MEMBER HANSON: I think that 22 works. The problem, it is not a problem

### 202-234-4433 Neal R. Gross & Co., Inc. Page 229 1 because it is just that you don't know what 2 NECO is if there is zero leaching. You just 3 know that it is not less than N-leaching. 4 CHAIRMAN RUSSELL: Right. 5 MEMBER HANSON: It could be ten 6 times more than that but you won't know that. 7 CHAIRMAN RUSSELL: Levels not -- 8 Fourteen. We are back to you, Praveen. 9 MEMBER AMAR: Fourteen was the 10 easiest one. We said we liked the figures and 11 the tables and more would be good. 12 Rich had a lot of detailed 13 questions which I simply referenced here 14 saying comments are included, you know, in 15 usual comments. I think that is what I 16 said. Unless somebody objects, 17 I thought they had done a good job with 18 figures and tables and maps where they had 19 them. 20 MEMBER HUSAR: The red sentence, 21 is there just a spliced into basically affirm 22 that if anything referred to had more tables

### 202-234-4433 Neal R. Gross & Co., Inc. Page 230 1 and figures, in particular a separate 2 conceptual diagram, that would be added to 3 show the physical meaning of each of the term 4 in the APPI. 5 MEMBER AMAR: Now that point, it 6 is not in my portion. 7 MEMBER HUSAR: No, I just -- that 8 is why it is up here. 9 MEMBER AMAR: Okay. No, I like 10 it. It looks great. 11 MEMBER KUMAR: Again, sorry for 12 nitpicking but I think we should remove the 13 last sentence because it just means that we 14 are not emphasizing it for other questions. 15 MEMBER AMAR: Yes, I tried to 16 avoid writing all of what Rich had said but 17 that is what I was trying to say. 18 CHAIRMAN RUSSELL: Paul, you are 19 up. 20 MEMBER KUMAR: Number 18 has not 21 been done. 22 CHAIRMAN RUSSELL: Oh, number 18

### 202-234-4433 Neal R. Gross & Co., Inc. Page 231 1 hasn't been done. Sorry about that. 2 Eighteen, Naresh. 3 MEMBER KUMAR: I guess this is 4 where it specifically asks for these terms 5 using CMAQ modeling and what the panel thinks 6 about that. 7 So I guess we all have been 8 mentioning that we need to see more model 9 evaluation of CMAQ brought in into this 10 document. And I just laid down some of the 11 sources of uncertainty that I believe are 12 relevant for NECO and NoY terms. 13 Since we go further down, and then 14 we are going to come back to look at the 15 language. So this is where I wrote what 16 different evaluations are needed. And these 17 are not available. I think they were done 18 earlier but not at the daily or weekly average 19 quantities. So I think that is important, 20 what I have in the parentheses. 21 So basically, recommending NO2, 22 SO2, nitrate, ammonium, and sulfate, where for

### 202-234-4433 Neal R. Gross & Co., Inc. Page 232 1 networks where we had routine data available 2 and model performance for deposition and a DP 3 network. 4 And also a more detailed 5 evaluation could be done using the SEARCH 6 network in the southeastern U.S., even though 7 that is a regional evaluation. But I think it 8 is better to do that than not doing anything. 9 So those are the recommendations, 10 specific recommendations for model performance 11 evaluation. 12 Now we can go back up, look at the 13 language. 14 CHAIRMAN RUSSELL: And this 15 language, that is something we can pick up. 16 I mean, it will get modified when we edit it. 17 So, it is more conceptual. 18 MEMBER AMAR: And a picking point, 19 I mean, the question itself, line three, we 20 keep on saying concentration to deposition 21 ratio. It is really deposition to 22 concentration ratio just mathematically. The

### 202-234-4433 Neal R. Gross & Co., Inc. Page 233 1 last of the units is deposition to 2 concentration, not the other way around. 3 Because velocity is deposition, 4 which is a flux proportion of the 5 concentration, the ration of the -- 6 CHAIRMAN RUSSELL: Yes, so that 7 goes to balance. 8 MEMBER AMAR: Okay. 9 CHAIRMAN RUSSELL: So did you guys 10 get that? 11 DR. HUBBELL: What was that again? 12 MEMBER AMAR: I mean, every time 13 you say concentration to deposition ratio, it 14 is really deposition to concentration ratio. 15 DR. HUBBELL: Yes. We are still 16 trying to make sure we are doing that 17 correctly. That is why sometimes we have one 18 over V and Rich's job is next -- 19 MEMBER AMAR: To be consistent. 20 DR. HUBBELL: -- to draft our 21 limitation and units policeman. 22 MEMBER AMAR: Actually you have

### 202-234-4433 Neal R. Gross & Co., Inc. Page 234 1 got V there, which is velocity. So you know, 2 just to be correct. 3 DR. HUBBELL: Yes, we are going to 4 make sure we get that exactly right next time. 5 CHAIRMAN RUSSELL: And do you know 6 what letters you are going to use? 7 DR. HUBBELL: We were thinking 8 about T. 9 MEMBER POIROT: Transmission or 10 transformation. It is all exactly right. It 11 is just incredibly unclear. 12 (Laughter.) 13 CHAIRMAN RUSSELL: Okay, you can 14 tell we are losing it a 1:00. 15 MEMBER AMAR: I'm hungry. 16 CHAIRMAN RUSSELL: With that, 17 Paul. 18 MEMBER HANSON: Chapter 7, as 19 written in the first draft, is relatively 20 brief. A chapter dealing with the idea or the 21 concept that there was some way to relate 22 acid-based versus nutrient enrichment-based

### 202-234-4433 Neal R. Gross & Co., Inc. Page 235 1 interpretation of the API. 2 And so what I did to generate 3 these texts was to go to the written comments 4 that various people had. I combined them and 5 then I circulated them last night and got 6 feedback from Kathleen, who is no longer on 7 the phone and Dale who is no longer on the 8 phone. But so in some combination of what I 9 did and what they contributed is what is in 10 front of you. And so if you would just take 11 a look at it. 12 CHAIRMAN RUSSELL: And what you 13 like is yours. 14 MEMBER HANSON: Well, I would be 15 happy to accept changes as well. But we 16 didn't argue much on the email iteration. 17 CHAIRMAN RUSSELL: Again, might 18 remove panel members have provided. 19 MEMBER HANSON: Yes. 20 CHAIRMAN RUSSELL: And I actually 21 look a this as EPA recognizes that Chapter 7 22 is still a work in progress.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 236 1 MEMBER HANSON: Yes, this is 2 basically a call just to flesh it out some 3 more.4 CHAIRMAN RUSSELL: Yes. Twenty5 four. 6 MEMBER HANSON: I guess there is 7 one question embedded in the last line is if 8 you don't disagree with the last sentence, 9 whether you would want to use those two words, 10 developing or universal or whether universal 11 even makes sense. 12 CHAIRMAN RUSSELL: Kathleen, are 13 you back? 14 MEMBER WEATHERS: I'm back. 15 CHAIRMAN RUSSELL: Oh. We are 16 almost done but we will get to your two pieces 17 in just a second. We are currently on 18 question 24. 19 MEMBER WEATHERS: Sorry. Say it 20 again, Ted? 21 CHAIRMAN RUSSELL: We are 22 currently on question 24.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 237 1 MEMBER WEATHERS: Okay. 2 CHAIRMAN RUSSELL: And in 3 particular, the last sentence in response to 4 question 24. 5 So the panel does not recommend 6 developing a single -- 7 MEMBER HANSON: The sense of the 8 comments that I read and heard and what I 9 tried to capture here was we don't think it is 10 possible. It doesn't mean it could be -- 11 CHAIRMAN RUSSELL: Mike. 12 MEMBER HANSON: You know, a single 13 universal standard that actually does apply to 14 acidification and nutrient enrichment just may 15 be out of reach is what the -- 16 CHAIRMAN RUSSELL: The panel 17 thinks -- 18 MEMBER HANSON: I doesn't mean -- 19 CHAIRMAN RUSSELL: -- or is 20 concerned that a single standard or a single - 21 - How did you say that Paul? You used out of 22 reach and I was trying to be a little --

### 202-234-4433 Neal R. Gross & Co., Inc. Page 238 1 MEMBER HANSON: Yes. 2 CHAIRMAN RUSSELL: Covering or 3 addressing both acidification -- Well 4 actually, -- 5 MEMBER HANSON: Is not practical 6 at this point. You know, -- 7 CHAIRMAN RUSSELL: Acidification 8 and nutrient enrichment is not practical at 9 this point. That is what -- Does that capture 10 it? 11 MEMBER HANSON: Right. And then 12 just delete everything else. 13 MEMBER CHESTNUT: Do you want 14 probably not practical or in case they come up 15 with something genius? 16 CHAIRMAN RUSSELL: Yes, probably. 17 MEMBER WEATHERS: I like the 18 qualifier. 19 CHAIRMAN RUSSELL: What was that, 20 Kathleen? 21 MEMBER WEATHERS: I agree with the 22 qualifier probably.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 239 1 CHAIRMAN RUSSELL: Yes. 2 MEMBER HANSON: The only problem 3 with that is we lambasted the panel -- 4 We got on the EPA staff's case for 5 using probably and maybes and all that stuff. 6 MEMBER WEATHERS: Well in this 7 case it stops short of saying this is a show 8 stopper. This doesn't work. I'm not sure we 9 know that. 10 CHAIRMAN RUSSELL: Okay, other 11 comments on 24 or should we go to 11(b)? And 12 I think we are going to have a specific 13 question for you, Kathleen, in terms of NECO. 14 MEMBER WEATHERS: Okay. Does it 15 make sense to go back to question 11? 16 CHAIRMAN RUSSELL: Yes, so we are 17 on question 11 and -- 18 MEMBER WEATHERS: Eleven (b) and 19 (c) is that it? 20 CHAIRMAN RUSSELL: That is what we 21 are doing, yes, 11(b) and (c). 22 MEMBER WEATHERS: Okay, yes. And

### 202-234-4433 Neal R. Gross & Co., Inc. Page 240 1 are Charlie and Myron still there? 2 CHAIRMAN RUSSELL: No, they are 3 not. 4 MEMBER WEATHERS: Okay. 5 CHAIRMAN RUSSELL: So their view 6 just is that the mass balance approach is 7 better. 8 MEMBER WEATHERS: Yes, I think 9 that was expressed yesterday as well. 10 CHAIRMAN RUSSELL: And so I don't 11 see that that is expressed here yet. 12 MEMBER WEATHERS: Yes. 13 CHAIRMAN RUSSELL: So do we want 14 to say that explicitly in the last sentence? 15 MEMBER WEATHERS: Right. So the 16 panel thinks -- 17 CHAIRMAN RUSSELL: Yes. 18 MEMBER WEATHERS: -- that the mass 19 balance approach is more feasible or people 20 thinking as declarative as should be used. 21 CHAIRMAN RUSSELL: Yes, I would 22 say should be used. Should be used -- is

### 202-234-4433 Neal R. Gross & Co., Inc. Page 241 1 preferred and should be used? You know, that 2 is sort of double stating something. 3 MEMBER WEATHERS: Yes. Preferred 4 is not very clear. 5 CHAIRMAN RUSSELL: And so should 6 be used. 7 MEMBER WEATHERS: The last 8 sentence is referring, it may be not be 9 necessary, the one that is there. The 10 sentence we were just talking about could 11 possibly replace that. So that neither 12 approach may easily get is just responding to 13 the letter of the question that was proposed 14 by EPA. So someone from EPA might want to 15 comment on whether we have answered the 16 question. 17 CHAIRMAN RUSSELL: Yes, they nod 18 their heads. 19 MEMBER WEATHERS: Okay, we can 20 strike the neither approach or it is not a 21 problem if it left? 22 CHAIRMAN RUSSELL: It is struck.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 242 1 And just of note, I will probably put all 2 three of those paragraphs together and -- 3 MEMBER WEATHERS: Yes. 4 CHAIRMAN RUSSELL: -- trim it down 5 just a bit. 6 MEMBER WEATHERS: Yes. 7 CHAIRMAN RUSSELL: C. 8 MEMBER WEATHERS: Okay. So this 9 couple of sentences reflects, I think, our 10 discussion yesterday. 11 MEMBER HANSON: I think that might 12 reflect the discussion but I am not sure Dale 13 was on the phone at the time. And I would ask 14 someone to look back at Dale's written 15 comments and maybe even Myron's written 16 comments because I believe they disagreed with 17 the presumption that bedrock geology was 18 sufficient. But we did not get verbally 19 discussed. 20 MEMBER WEATHERS: Well so what 21 this says is that just as a bedrock geology is 22 likely to be more indicative and points to a

### 202-234-4433 Neal R. Gross & Co., Inc. Page 243 1 combination of features that might be used for 2 criteria. 3 CHAIRMAN RUSSELL: I think that 4 actually covers what they said. 5 MEMBER HANSON: Yes, I think the 6 gist of this is sort of like along with the 7 g(.) comment, is that use everything on the 8 left-hand side of the AAPI equation. 9 CHAIRMAN RUSSELL: Yes. So how I 10 might, one of the things I might modify this 11 is ideally a combination of topographic and 12 landscape criteria I would say could be used 13 that includes such factors. 14 MEMBER WEATHERS: Yes. Yes, 15 strike might and could and put could instead 16 of would. 17 CHAIRMAN RUSSELL: So includes. 18 MEMBER WEATHERS: The combination 19 includes. 20 CHAIRMAN RUSSELL: Includes such 21 factors as elevations. So Paul, how else 22 might you modify that?

### 202-234-4433 Neal R. Gross & Co., Inc. Page 244 1 MEMBER HANSON: Well it is sort of 2 there under land cover but I mean I think that 3 the case that Dale might have made if he were 4 still on the phone is that it is the 5 productivity potential of the vegetation that 6 is really driving that feature. 7 CHAIRMAN RUSSELL: So put a 8 comment there just let's ask Dale directly. 9 We can send this to him and get his direct 10 comments on it. 11 MEMBER WEATHERS: Or put and land 12 use and land cover make land use not have to 13 be combined with land cover. 14 MEMBER HANSON: I mean, an example 15 is if you have got a real wet rainy season, 16 you don't have as much radiation coming in. 17 You are not being as productive as you would 18 have been in a sunny season. And so on that 19 particular year, you will end up taking up 20 less nitrogen, perhaps. 21 It is much more complicated than 22 that. But the bottom line is you have to

### 202-234-4433 Neal R. Gross & Co., Inc. Page 245 1 factor in and capture the essence of 2 vegetation productivity and how much nitrogen 3 that is extracting. Or in the case of aquatic 4 systems, whatever the corollary is. 5 MEMBER AMAR: Line 27, do we 6 delete more indicative or do we mean better 7 indicative? 8 CHAIRMAN RUSSELL: Better. 9 MEMBER AMAR: I think that is what 10 we are saying. 11 CHAIRMAN RUSSELL: So what that 12 now says, Kathy is maps of bedrock geology are 13 likely to be better indicative of acid 14 deposition or acid-sensitive eco systems in 15 un-glaciated parts of the country. Where till 16 is predominant, the influence of the 17 underlying geology may be massed. Ideally, a 18 combination of topographic and landscape 19 criteria could be used that include such 20 factors as elevation, land use/land cover, as 21 well, we need an and somewhere, as well as 22 bedrock geology.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 246 1 And then with a note that Dale can 2 put in that we will get some comments from 3 Dale. 4 MEMBER WEATHERS: So and you might 5 take out land use. 6 CHAIRMAN RUSSELL: Okay. 7 MEMBER WEATHERS: In this case 8 land cover may be what Dale is looking at. 9 MEMBER HANSON: How about just 10 vegetation contributions instead of land use 11 and land cover? 12 MEMBER WEATHERS: Well I am just 13 thinking about the mapping approach here. 14 Those standards refer to as land cover. 15 MEMBER HANSON: Well I think that 16 may be part of the problem is that that in and 17 of itself may not capture. 18 MEMBER WEATHERS: Yes. I am okay 19 with leaving it as land use/land cover and 20 putting a note into Dale. 21 MEMBER KUMAR: How important is 22 the soil composition in this?

### 202-234-4433 Neal R. Gross & Co., Inc. Page 247 1 MEMBER WEATHERS: I'm sorry the 2 what composition? 3 CHAIRMAN RUSSELL: Soil 4 composition? 5 MEMBER HANSON: That will play a 6 role as well. 7 MEMBER WEATHERS: Yes. That could 8 broadly be considered land cover, that skin 9 around the bedrock. 10 MEMBER HANSON: I mean, in a 11 terrestrial system to estimate NECO 12 appropriately you need a whole other big 13 complex model. I don't believe that is what 14 is in CMAQ but there needs to be something 15 that takes the place of that. 16 CHAIRMAN RUSSELL: None of that is 17 in CMAQ. 18 MEMBER HANSON: Yes, but that is 19 what NECO is. 20 MEMBER WEATHERS: Actually land 21 cover is part of CMAQ, as I understand it, in 22 terms of quantifying deposition.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 248 1 CHAIRMAN RUSSELL: That is but in 2 terms of any description of what is happening 3 below that. 4 MEMBER WEATHERS: Yes. From the 5 top of vegetation to bedrock. 6 CHAIRMAN RUSSELL: CMAQ cares not 7 about NECO. 8 All right. Anything else that 9 people want to discuss right now? Somehow I 10 think the answer is going to be no. 11 MEMBER CHESTNUT: I sent a 12 sentence by email to -- 13 CHAIRMAN RUSSELL: You sent a 14 sentence by email? You got it? In terms of? 15 MEMBER CHESTNUT: That front 16 thing, that idea about we like the index 17 because it is -- 18 CHAIRMAN RUSSELL: Okay. And that 19 goes in -- you told us where it goes. 20 MEMBER CHESTNUT: Yes. 21 CHAIRMAN RUSSELL: Great. 22 MEMBER CHESTNUT: You can see if

### 202-234-4433 Neal R. Gross & Co., Inc. Page 249 1 it -- 2 CHAIRMAN RUSSELL: We will get it 3 included. 4 MEMBER CHESTNUT: We have already 5 discussed the concept. 6 CHAIRMAN RUSSELL: Well, with 7 that, I think we are adjourned. I want to 8 thank everyone, particularly those of you who 9 stuck it out to this last moment. 10 There is lunch. Hopefully it is 11 still warm. 12 MEMBER WEATHERS: I hope it is 13 good. 14 CHAIRMAN RUSSELL: We hope it is 15 good, too. 16 MEMBER CHESTNUT: Bye Kathleen. 17 MEMBER WEATHERS: I don't have 18 lunch. 19 CHAIRMAN RUSSELL: Kathy, special 20 thanks to you knowing how tough it is to 21 listen in so closely on teleconferences. 22 MEMBER WEATHERS: Yes and I am

### 202-234-4433 Neal R. Gross & Co., Inc. Page 250 1 probably happy that I couldn't see your eyes 2 sometimes. 3 CHAIRMAN RUSSELL: So with that, 4 Kyndall can adjourn us. 5 MS. BARRY: Yes. Again, thank you 6 panel for all of your hard work. We are 7 really, I think everyone is very excited about 8 where the Agency is going to be able to go 9 with the additional time. 10 Thank you EPA for being very 11 responsive to the advice from the panel. So 12 pleased with our great collaborative work. 13 And this adjourns the meeting of the NOX and 14 SOX Secondary Panel. Thank you. 15 (Whereupon, at 1:16 p.m., the 16 proceedings in the foregoing 17 matter were adjourned.) 18 19 20 21 22

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70:13 misleading 22:10 missed 10:8,10 168:9 mission42:3 122:17 mistake 82:8 MITCHELL 2:5 14:5,9,17 24:14 25:3,10,13 26:1,6 26:11,16 32:20 49:6,9,18 53:10 53:16,18,22 56:18 57:4,8 59:17,21 60:5,12 76:5,15 76:18,21 95:7 96:13,22 105:20 106:3,6,10 116:16 118:20 122:4,10 123:12 124:2 125:4 127:3 130:11,16 172:21 173:3,6 174:1,5 177:12 178:6 179:10 181:7 204:9 214:19,22 215:3,7,14,17 220:10,22 221:5 221:20 222:20 227:10,16,22 mitigated 109:8 mix40:15 207:5

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