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1 U.S. ENVIRONMENTAL PROTECT ION AGENCY 2 CLEAN AIR SCIENTIFIC ADVISORY COMMITTEE (CASAC) 3 OXIDES OF NITROGEN AND SUL FUR OXIDES 4 SECONDARY REVIEW PANEL 5 6 7 8 9 10 - - - 11 TRANSCRIPT OF PUBLIC MEETING 12 - - - 13 14 15 16 17 October 7, 2010 18 8:32 a.m. - 12:17 p .m. 19 20 Marriott at Research Tria ngle Park 4700 Guardian Driv e 21 Durham, North Carolina 28803 22 23 24 25

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1 CASAC SECONDARY REVIEW PANEL MEMBERS PRESENT: 2 Dr. Armistead (Ted) Russel l 3 Dr. Anthony Maciorowski 4 Dr. Praveen Amar 5 Dr. Charles T. Driscoll, J r. 6 Ms. Lauraine Chestnut 7 Dr. Dale Johnson 8 Dr. Myron Mitchell 9 Dr. Andrzej Bytnerowicz 10 Dr. H. Christopher Frey 11 Dr. Ellis B. Cowling 12 Mr. Richard L. Poirot 13 Dr. Kathleen Weathers 14 Dr. Rudolf Husar 15 Dr. Naresh Kumar 16 SCIENCE ADVISORY BOARD STAFF: 17 Dr. Angela Nugent, Designa ted Federal Officer 18 ENVIRONMENTAL PROTECTION AGENCY STAF F: 19 Lydia Wegman, Esq. 20 Dr. Bryan Hubbell 21 Dr. Richard Scheffe 22 Dr. Tara Greaver 23 Karen Martin, Esq. 24 Dr. Jason Lynch 25 Mr. Randy Wade

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1 ENVIRONMENTAL PROTECTION AGENCY STAF F CONTINUED: 2 Leah Anderson, Esq. 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

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1 DR. NUGENT: Good morning, everyone. It's 2 time to convene our advisory me eting, day two of 3 the CASAC Panel Oxides, NOx andSOx Secondary NAAQS 4 Review Panel Meeting. And I'll just turn the mike 5 over to our chair, Ted Russell. 6 DR. RUSSELL: Thank you ve ry much. And thank 7 you very much for all the work that folks did last 8 night. 9 What I would like to start off with is 10 essentially going through each of the responses 11 that you had -- that the indivi dual panelists had 12 to the charge questions. And y ou should have paper 13 copies of those sitting in fron t of you. And how I 14 would like to do this is to go to the leads to 15 essentially give us the, you kn ow, one or two-line 16 synopsis of what's written and then recognize that 17 each of us can read the -- readwhat's there. 18 I recognize one thing this will do is we'll 19 have a lot of sort of dead sile nt time because what 20 I want to get out of this is es sentially everybody 21 is on board with what we're sen ding forward to the 22 Administrator. And this is goi ng to be one of our 23 more important transmittals. 24 So with that, charge quest ion one, which was 25 Lauri, was it? I don't remembe r from yesterday.

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1 I'll have to get my agenda. 2 MR. McNAMARA: You want tobe up on the 3 screen? 4 DR. RUSSELL: Yeah, put it up. 5 MS. CHESTNUT: You want me to say something 6 now or let people read it? 7 DR. RUSSELL: Give them ab out a minute. 8 MS. CHESTNUT: Okay. This probably is still 9 too wordy, but I think the mainpoint is that the 10 ecosystem services framework we endorse as a way to 11 characterize the public welfare effects of the 12 changes in peak system functionand that the link 13 is well established in the Poli cy Assessment 14 between the effects indicator Aand C and the 15 public welfare effects. 16 They've made the -- the se cond point is it's 17 not that it's not in there, but to just keep 18 bringing to the forefront that the ecosystem 19 services includes the concept o f the value of 20 habitat, biodiversity, independ ent of human use, 21 what we call nonuse values in t he economics 22 literature, but to make that li nk to the ecosystem 23 services concept explicit everytime. 24 And then the final point i n the paragraph is 25 the emphasis on clearly these r esources are high

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1 value. The importance for this is the degree to 2 which they're diminished at cur rent deposition 3 levels. It kind of spills over into question four. 4 So maybe we need to see if that 's redundant. 5 And then the final paragra ph just recognizes 6 in this chapter the discussions about community and 7 State actions that that's usefu l in broadening, 8 deepening the evidentiary probl em of adverse 9 effects. 10 DR. RUSSELL: Questions an d comments? Ellis. 11 DR. COWLING: My question has to do with the 12 next to the last line of the la st paragraph. A 13 specific amount of deposition, especially for 14 terrestrial and eutrophication effects, do you mean 15 for terrestrial eutrophication effects or do you 16 mean acidification effects on t errestrial? What do 17 you mean exactly by terrestrial and eutrophication? 18 MS. CHESTNUT: I was tryin g to come up with a 19 phrase that included everythingin addition to the 20 aquatic acidification. I proba bly haven't quite 21 done that, but I think the sent ence doesn't 22 necessarily need that phrase at all. The emphasis 23 really is more on those things that can't be fully 24 quantified at this point. Can still be described 25 and characterized as to their m agnitude and

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1 significance, not just there ca n be these kinds of 2 effects, but it's in this much of an area and to 3 this degree of loss, something like that. 4 DR. COWLING: So do you me an terrestrial and 5 aquatic eutrophication effects or are you thinking 6 only of terrestrial effects? 7 MS. CHESTNUT: I'm not jus t thinking of 8 terrestrial. 9 DR. COWLING: Okay. I sug gest that if you 10 mean terrestrial and aquatic eu trophication 11 effects, that is what should be said. 12 DR. RUSSELL: Actually, wh at Lauri said, I 13 mean, I'm not sure that you los e anything by just 14 ending at "deposition." 15 MS. CHESTNUT: Yeah. If w e want to take some 16 words out. 17 DR. COWLING: Atmospheric deposition effects, 18 is that what you're suggesting? 19 DR. RUSSELL: No. I'm jus t suggesting -- 20 MS. CHESTNUT: A period af ter "deposition" and 21 just take that out. 22 DR. COWLING: Okay. 23 DR. RUSSELL: Anything els e? 24 DR. COWLING: Yes. One ot her thing in the 25 second paragraph, Lauraine, I s uggest that we use

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1 the word "decrease" rather than"reduce" 2 acidification. 3 MS. CHESTNUT: Thank you. 4 DR. COWLING: Decrease has only a numerical 5 meaning. Decrease has a numeri cal and chemical 6 meeting. 7 DR. AMAR: One other thing , the last sentence 8 of the first paragraph what's i mportant to convey 9 is the degree to which there ar e diminished I think 10 is missing. 11 DR. RUSSELL: Very good. And actually, again, 12 you all -- everybody will have a chance to go over 13 these again. Just keep in mindwhat's going to 14 happen is at the end of this me eting, we're going 15 to have a document I think that 's going to be in 16 pretty good shape that we're go ing to be able to 17 give our thumb's up or thumb's down to and then it 18 will be provided to the committ ee for further 19 comment. So everyone will have a chance to provide 20 specific items. 21 DR. WEATHERS: Does that mean the goal here is 22 not to wordsmith? 23 DR. RUSSELL: Yes, that's what I'm trying to 24 say in a very long way. 25 DR. AMAR: I shouldn't hav e spoken.

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1 DR. RUSSELL: Well, no, yo u can. 2 Next, charge question two, Ellis, you're on 3 and three. 4 DR. COWLING: Okay. Shoul d we take some time 5 for reflective study? 6 DR. RUSSELL: Yes, for fou r as well. We'll go 7 from there. 8 DR. COWLING: The draft fr om Ellis is 9 different from the drafts from Dale, but what it 10 contributed to from Ellis is infact a result of 11 conversations that Dale and I h ad late into the 12 night. And I am very pleased t o have had the 13 chance to help with the process of more general 14 acceptance of the points that D ale has been trying 15 to make ever since he joined th is panel. 16 Can we move up the text onthe screen so that 17 it's relevant? Thank you very much. 18 DR. MITCHELL: In point E it says: "Typical 19 nitrogen requirements for optimum production of 20 wheat, corn, and loblolly pine. " Aren't those more 21 like fertilization rates? 22 DR. COWLING: That's what I changed there. 23 DR. JOHNSON: That's what Ellis sent us this 24 morning and I sent in a couple e-mails that 25 everybody should have got, but I don't know if you

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1 read it yet. The loblolly pine one is quite 2 different because forests, at l east closed-canopy 3 forests, recirculate 80 to 90 p ercent of the 4 nutrients and the only amount t hat they need and 5 keep from the outside every yea r is about 6 10 percent. 7 So I made that modificatio n. It's been sent 8 to everybody to that effect. S o the actual 9 increment of the loblolly pine and other forecasts 10 is actually a lot closer to nit rogen deposition 11 rates than it indicated here. 12 DR. COWLING: Both in the Pacific northwest 13 region of our country and the s outhern part of our 14 country fertilization is used e xtensively in both 15 northwest and southeastern fore sts. And these 16 rates -- 17 DR. JOHNSON: Are high. 18 DR. COWLING: -- are stand ard 60. 19 DR. JOHNSON: They're evenmore than that; and 20 the reason they are is because the microbes are 21 starved for nitrogen too and th ey get most of it. 22 So when you fertilize and the f ertilizer goes on 23 the forest floor, about 60 perc ent of it ends up 24 tied up in microbial biomass. Typical tree 25 recovery is 10 percent, 15, 20 percent maybe if

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1 you're lucky. So those rates a re much higher than 2 the tree needs. 3 DR. MITCHELL: Also I woul d suggest maybe it 4 needs to be clarified even thou gh you can have a 5 nitrogen increase in productioncomponent, even 6 under those conditions even tho ugh there is a 7 stimulation of productivity wit h enhanced nitrogen 8 inputs, there is still under th ose conditions a 9 significant amount of nitrogen lost, which is 10 deletory to the ecosystem. 11 DR. JOHNSON: Typically al ways do. 12 DR. MITCHELL: I don't wan t to have the 13 impression that's the demand, t here is still no 14 deleterious impacts still possi bly for those 15 systems. 16 DR. JOHNSON: No. There c ould be. Maybe it's 17 necessary and you don't want it in production. 18 DR. MITCHELL: It's not so mething -- even 19 though you have enhanced produc tion. 20 DR. JOHNSON: Or you don't want excess fuel 21 growing fire. I'm just saying that the other side 22 of the coin, as I've been sayin g for a couple, 23 three years now is not -- the - - Ellis and I had a 24 long talk about managed and unm anaged forests last 25 night.

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1 My thoughts is unmanaged f orests can have the 2 same effect as managed forests. It all relates to 3 growth, which can lead to carbo n sequestration. 4 And I continue to say that it's a mistake to try to 5 parse that out and toss it out. I don't agree with 6 that. That's what's being done . 7 DR. RUSSELL: So what Dale is actually 8 recommending, I'll just read it to the committee is 9 on the end of "E," respectivelycolon -- or 10 semicolon, "In the case of lobl olly pine, however, 11 80 to 90 percent of this annual uptake is from 12 internally recycling within the ecosystem and only 13 about 10 to 20 percent of this amount is actually 14 incremented within the tree eac h year and, 15 therefore, must come from eithe r the soil or 16 external sources." 17 DR. MITCHELL: So is agron omic that's changed 18 to be fertilization inputs, not actual 19 requirements? Those are fertil ization rates. 20 That's not much used by those c rops. 21 DR. JOHNSON: I don't knowthe exact numbers. 22 Agronomic inputs are pretty hig h. 23 DR. MITCHELL: They're pre tty high, but 24 nothing close to that. 25 DR. JOHNSON: You don't th ink so?

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1 DR. MITCHELL: No. You st ill have enhanced 2 production as you increase the amount of 3 fertilization, with the amount of net 4 incorporation, incremental is l ess and less. It's 5 like points of diminishing retu rn. It's a curve 6 that goes up. Sure, you can ha ve enhanced nitrogen 7 production, but a relatively sm all amount of the 8 higher amounts of end input or incorporated corn, 9 that's why you get all the nitr ogen coming down 10 with agronomic systems. 11 DR. JOHNSON: Yeah, but th e point is corn, 12 nitrogen uptake is ten times hi gher than required 13 from trees. The benefit of nit rogen to croplands 14 is probably nil, too small. 15 DR. MITCHELL: In terms of the deposition. 16 DR. JOHNSON: Yeah. But f or trees it's kind 17 of in the ballpark. 18 DR. MITCHELL: I'm saying for optimum 19 production, you're assuming you 're just trying to 20 get -- that actually you don't want to optimize the 21 amount of production, the end i nput would be a lot 22 less. 23 DR. JOHNSON: It might be a problem with 24 numbers in here 'cause it's goi ng to start quarrels 25 like this every time, but just the difference

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1 between crop and forest or wildsystems recycling. 2 That's really the difference. 3 DR. MITCHELL: There is a difference between 4 fertilization versus requiremen ts. 5 DR. JOHNSON: Of course. 6 DR. COWLING: I would like to suggest after 7 the word "U.S." in Part B that we insert the words 8 "including many national and st ate parks and Class 9 I wilderness areas." 10 DR. RUSSELL: Andre. 11 DR. BYTNEROWICZ: We shoul d also add deserts 12 if we are so specific. 13 DR. GREAVER: Could I make one comment real 14 quick? 15 DR. JOHNSON: Ellis, I thi nk it's better to 16 say most forest lands. We do k now areas of the 17 southeast coastal plain that ar e limited, for 18 example. So not all. It says essentially all, but 19 it's actually most I think. 20 DR. GREAVER: Can I make o ne comment? This 21 point has been repeatedly in th e ISA, REA, and we 22 know most terrestrial ecosystem s are nitrogen 23 limited regarding productivity. I'm not sure -- I 24 mean, we can point to it. On p age 223, we cite 25 some papers that show that most terrestrial systems

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1 are nitrogen limited. I don't know if you want -- 2 I'm not sure how to address thi s further. 3 DR. HUBBELL: Are you just stating it 4 yourselves again? I was tryingto figure out what 5 this set of points meant as wel l. Is it something 6 you think we need to address mo re or is this a 7 statement that these are known things and, 8 therefore, we're just reiterati ng them? 9 DR. WEATHERS: Yesterday I was recognizing 10 that this fertilization effect is considered in 11 Neco and it may be too fine a d etail or fine a 12 scale to -- for you to quantifyNeco, but my 13 suggestion is that either we ac knowledge here or 14 you acknowledge in the document that fertilization 15 effects and input that are take n up by the 16 vegetation or mobilized in the soil are in fact 17 accounted for in the AAPI. 18 DR. HUBBELL: Consideratio n of the aquatic 19 acidification effects, yes. Th is seems to be more 20 about the nutrient enrichment a nd nutrient use more 21 than acidification. 22 DR. WEATHERS: Right. But , correct me if I'm 23 wrong, the Neco is a terrestria l uptake error. And 24 so, in theory, if there is fert ilization going on, 25 it's captured in that Neco. It basically means if

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1 85 percent of the inputs are re tained within the 2 system, that's a result of upta ke immobilization. 3 DR. HUBBELL: Yes. 4 DR. WEATHERS: So, again, maybe the Neco term 5 isn't finally resolved enough t o actually deal with 6 this, but I suggest that you ma de the link and you 7 need to make that explicit. 8 DR. GREAVER: Okay. 9 DR. WEATHERS: Dale, is th at -- 10 DR. JOHNSON: Well, we mad e the link. It's a 11 matter of emphasis. Again, whe n you're looking at 12 your nitrogen limitation, maybe you're not talking 13 about the carbon sequestration issue, I don't know 14 why, but the same exact phenome non, the growth 15 increase when it produces a neg ative effect to 16 support new regulations in the southwest, three 17 full pages to that, and so it's a focus on whatever 18 is bad about nitrogen. That's what I'm saying and 19 I've said all along. I continu e to say it. 20 DR. HUBBELL: So in terms of this carbon 21 sequestration, would you want t o see an expanded 22 discussion in the ecosystem ser vices chapter, is 23 that -- 24 DR. JOHNSON: Yeah, I gues s someplace. 25 DR. WEATHERS: I'm just wo ndering whether

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1 that -- how the Neco term wouldbe expanded and 2 what effect it would have on th e AAPI or the 3 trade-off curves is maybe one o f those critical 4 analyses that need to be done. So let's say that 5 there is fertilization going onin these 6 ecosystems. Again, is that something that the Neco 7 term is sensitive enough to pic k up? Are there 8 some analyses that can be done that would satisfy 9 this issue about whether -- 10 DR. JOHNSON: Neco term ad dresses the growth 11 response, unintended consequenc e on carbon 12 sequestration or growth with --increased growth 13 forest in general. 14 DR. WEATHERS: In my mind it does. Maybe I'm 15 understanding this differently. It says to me that 16 if there is more production, th e Neco term -- it's 17 a bigger amount of nitrogen cap tured within the 18 system. Maybe I'm not understa nding right. Maybe 19 it's not the dynamic. 20 DR. GREAVER: I think that 's exactly what we 21 intend. What Neco does is it a llows more nitrogen 22 to be deposited into the systembefore it 23 contributes to acidification. And the reason we 24 allow that is because the trees will take it up and 25 it will be mobilized and it wil l be degassed

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1 certainly. So that the fertili zation effect is 2 captured in that term. We have n't calculated how 3 much additional carbon sequestr ation that would 4 mean, but I don't know that -- I don't know that. 5 DR. WEATHERS: I agree completely with Dale 6 that that's a really important point that you can 7 get increased production. 8 DR. HUBBELL: I'm not conv inced that there is 9 something we need to do to Necoto specifically 10 account for something else othe r than what it 11 already accounts for. Again, w hat we're building 12 the Neco for is just to recogni ze that it 13 represents the sink of nitrogenthat we can fill up 14 before we start seeing the leac hing and other 15 effects, but it's already in th ere. 16 So it's not something -- I mean, we can -- 17 it's noted that that's its role is to deal with the 18 nitrogen. I think where I'm ge tting a little 19 confused on this is that I thin k a lot of the 20 discussion -- the other discuss ion on this point 21 has to do with specifically the nutrient-related 22 impacts that are not associatedwith acidification. 23 The Neco term is associate d with trying to 24 balance and make sure we're tak ing care of end 25 leaching versus total end. Tha t's obviously

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1 related to the issue of fertili zation, but it's not 2 an effect of fertilization. It 's the process 3 whether or not -- 4 DR. WEATHERS: Takes into account the effects 5 of fertilization. 6 DR. HUBBELL: It's trying to make sure the 7 balance works within the system . It's not 8 something that we need to adjus t. 9 DR. WEATHERS: I'm not sug gesting adjustment. 10 I'm suggesting that there may b e a way to address 11 the fact that in an indirect wa y you are 12 considering fertilization effec ts or absorption 13 basically of nitrogen. 14 DR. HUBBELL: It's not fer tilization. It's 15 absorption. It's how much can be taken up. 16 DR. WEATHERS: And it affe cts the trade-off 17 curves. 18 DR. HUBBELL: That's in th ere. That part is 19 well described. 20 DR. WEATHERS: Doesn't sat isfy Dale yet. 21 DR. HUBBELL: It's not his issue. 22 DR. JOHNSON: The Neco ter m, as I understand 23 it, the purpose of that is to c alculate how much 24 acidification in the water is g oing on. So it's 25 not really designed, I don't be lieve, to try to

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1 address this potential unintend ed benefit. I don't 2 think it's relevant. 3 DR. RUSSELL: What page di d you bring up? 4 DR. GREAVER: This is just one. I know it's 5 mentioned multiple times in the document, but on 6 page 2-23 we say that most terr estrial ecosystems 7 are nitrogen limited. 8 DR. COWLING: Tara, let me try in a gentle 9 way, if you look at page 4-45 t he beginning of that 10 paragraph there says: "In cert ain limited 11 situations additions of nitroge n can increase 12 rates." I think both Dale and I were offput, you 13 might say, by "in certain limit ed situations." And 14 if you compare that with what D ale just suggested 15 about I said essentially all fo rests and he 16 suggested most and I agreed wit h him that most is 17 better. 18 We ought to take away esse ntially now, but 19 it's the tone in which detrimen tal and beneficial 20 effects on growth were dealt wi th. And what you 21 sought to do was to say that th is PA deals only 22 with unmanaged systems. And I think all of us in 23 the forest community of this CA SAC panel believe it 24 is better, as Dale put it, to h ave a balanced 25 perspective.

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1 There are benefits that oc cur in all forests 2 or in terms of growth; and of c ourse Class I 3 wilderness areas are supposed t o be maintained in 4 perpetuity for enjoyment as the y were as natural 5 areas. And the way we now have industrialized 6 America everywhere, the United States of America, 7 the chemical climate has change d. And it will 8 always be changed so long as th ere are as many 9 people here that are as ambitio us as most of us are 10 to use natural resources and toenjoy them. 11 So it's a question of tone more than a 12 question of absence of acknowle dgment of these 13 effects. So -- and these words that are put up 14 there are an attempt to achieve a balanced 15 perspective with regard to what you are trying to 16 do so earnestly, and that's to continue to let 17 America run and to avoid acidif ication effects of 18 aquatic ecosystems in sensitive areas. 19 DR. HUBBELL: I think we d on't disagree that 20 we certainly can do more work o n tone. I will 21 reflect that in D. 22 One of the things that con cerns me, going back 23 to your precise uses of languag e, the word 24 "positive" has many meanings, a nd perhaps we could 25 use a word that's less full of those meanings. And

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1 what you're saying is that ther e are increases in 2 growth that occur almost everyw here, rather than 3 saying that there are positive effects. I would -- 4 I think that would make me feel a little bit 5 better. I think by saying thos e are positive 6 effects implies that they are g ood in some way as 7 well as being in the numerical sense positive. 8 DR. COWLING: I don't ment ion positive unless 9 I mention growth. Maybe I did, I don't recall. 10 Positive effects on growth. 11 DR. RUSSELL: You may not want more growth. 12 DR. COWLING: I guess you could take out 13 positive and just say growth. 14 DR. HUBBELL: Increase is fine. 15 DR. COWLING: Fine. 16 DR. RUSSELL: Actually, ho w I read this is if 17 you go to page 4-46, as Ellis j ust brought up, much 18 of the tone there, it's mainly the tone. 19 DR. JOHNSON: It's the ton e and the emphasis 20 because all of a sudden when we 're talking about 21 growth in ponderosa pine forest s, we're going to 22 spend a lot of time on that bec ause it's a negative 23 connotation. When we talk abou t the carbon 24 sequestration and so forth, wel l, that doesn't 25 count because we're not going t o do more

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1 fertilization. We're not goingto count that 2 'cause we're parsing in that wa y. That's the 3 point. It's more than tone, it 's emphasis. 4 DR. BYTNEROWICZ: And you can add negative 5 effect from biodiversity to tha t. 6 DR. JOHNSON: Of course yo u can. 7 DR. GREAVER: There is so many effects of 8 nitrogen and sulphur and we rea lly have focused in 9 on aquatic acidification. I do n't know how we 10 choose one nutrient-related eff ect, carbon, and 11 emphasize it more without empha sizing lots of other 12 effects more. I don't know. 13 DR. JOHNSON: Well, if youdon't want to do 14 it, you don't want to do it, bu t I'm going to 15 continue to raise the issue. 16 DR. GREAVER: I don't knowthat that will 17 satisfy. We can certainly chan ge tone. I'm sort 18 of speaking for this issue, but I don't write every 19 chapter in the document. 20 DR. RUSSELL: I wouldn't w orry about that, 21 Tara. I mean, this is somethin g that I think the 22 panel can discuss because I thi nk we're not 23 necessarily saying that -- beca use I think we have 24 to note what the reason behind this manuscript in 25 this document is. We do it -- it's trying to lay a

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1 foundation for a standard that is protective of 2 aquatic acidification in sensit ive lakes. 3 Rich, you're about to say? 4 MR. POIROT: Well, it seem s to me that there 5 might be a little bit more deta il in this response 6 than it really warranted by the charge question. 7 Just, for example, I don't knowthat we need to 8 know all of the fertilization r ates of all of the 9 crops and so on and so forth. 10 It just feels like we wait ed all this time to 11 let Dale make his point and all of a sudden bam, 12 here it is, and I think it's a little bit heavy 13 handed. Could this be condense d to about half its 14 length and some of these points be put together 15 rather than having a full-page answer to really -- 16 this is addressing the adequacyof the current 17 standard is the question. Are we saying the 18 current standard is good becaus e it allows all of 19 this beneficial fertilization I think? 20 The other part about that I think it's a 21 little bit late in the game for us to be in our 22 last letter saying wait a minut e, we got the whole 23 thing wrong. So I'd like to se e this -- 24 DR. JOHNSON: I've been sa ying this for the 25 very first time --

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1 MR. POIROT: I recognize t hat. 2 DR. JOHNSON: -- I've beenignored throughout 3 the whole thing. So I'm going to keep on saying 4 it. 5 If you don't want to -- myattitude toward 6 these kinds of things is I don' t expect to prevail, 7 but I don't expect to shut up e ither. So I'll keep 8 telling you what I think. So y ou can do what you 9 want, but I'll continue to say what I'm going to 10 say. 11 MR. POIROT: All right. A ll I'm saying is I 12 think this is longer and more d etailed than is 13 warranted for the question. 14 DR. RUSSELL: And I would agree with that. 15 Actually, I liked what Ellis fi rst said was that 16 some of the issue is the phrasi ng when you're 17 saying "in certain limited situ ations," you know, 18 that's probably not appropriate . And I think 19 that's the sort of the thing th at you pointed out 20 for more balance. 21 So I would -- if it were I , I would try to 22 phrase that -- me -- take into account, which Rich 23 said and what you said, and sor t of tighten up the 24 response. And what Dale has sa id as to specific, 25 you know, you can bring up a sp ecific case about

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1 the carbon sequestration. 2 DR. COWLING: Let me also call attention to 3 the next two very short sentenc es. "Thus the 4 principal challenges in this PAdocument are to 5 assess the adequacy." I was th inking of Karen 6 Martin when I wrote this. "To assess the adequacy 7 of current scientific knowledge about both 8 beneficial and detrimental effe cts of airborne 9 nitrogen and sulphur and to exp lore options for an 10 NAAQS-based system of air quali ty management that 11 will protect acid-sensitive aqu atic ecosystems 12 from" -- and I chose the phrase that you had used 13 -- "disruptions in ecosystem st ructure and 14 functions that are important tothe people of this 15 country in regions where annual rates of deposition 16 are in the order of magnitude o f what they are in 17 the unmanaged regions of our co untry." So if 18 you're thinking about shortenin g, I call attention 19 to the effort to have a reminde r of what this 20 document is all about. 21 DR. HUBBELL: The one thin g that in reading 22 through this again, as we were trying to interpret 23 what this would tell us to do, is this actually 24 does not -- number one, it does n't answer the 25 question, which is do you find this to be that, in

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1 fact, it is adverse? That's ne ver answered in 2 here. And given that in your l ast target -- in 3 your last response to us you to ld us that you 4 actually agreed, you thought it was adverse. We're 5 now asking that question again. In fact, this 6 answer, if I were to read it, w ould be saying no, 7 you have not demonstrated that and, in fact, you 8 have missed this whole big part . 9 So if you are changing you r advice to us and 10 no longer think it's adverse, t hen that ought to be 11 said. If not, then that ought to be said as well. 12 DR. RUSSELL: I think we'r e looking at this 13 that we really need to rethink the response to this 14 one because specifically how do es it address the 15 questions? Because I know what you wrote, Ellis, 16 and it's essentially restating the objective, but 17 not our answer to it. 18 So I think yesterday when we went around the 19 room at the end of the day the panel viewed that 20 yes, that they have demonstrate d that the nitrogen 21 and sulphur deposition is havin g detrimental 22 effects to sensitive ecosystems . I don't think 23 there is any disagreement on th is panel. 24 So I think we need to say that. I think 25 actually Dale laid out a very, very strong case.

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1 The answer to that one is yes. 2 DR. COWLING: You ought toretain the present 3 standard as well and that shoul d be discussed here, 4 it needs to be -- it should be discussed here. 5 DR. HUBBELL: We have a se parate charge 6 question. 7 DR. JOHNSON: This is what I have in my 8 individual comments, is the pur pose of this 9 document to be a dispassionate scientific objective 10 assessment of deposition or is its purpose to be an 11 admission to get the standards established? 12 DR. RUSSELL: No. How's t hat for an answer? 13 DR. JOHNSON: No what? 14 DR. RUSSELL: Well, the IS A was, as you might 15 put it, a dispassionate -- prov iding a 16 dispassionate scientific basis for going forward in 17 terms of laying the foundation for the scientific 18 basis of a proposed standard. 19 And the REA was looking at potential risks 20 associated with the -- with aci d deposition from 21 NOx and SOx at this point. At this point this 22 document is the Policy Assessme nt, essentially 23 providing an assessment of vari ous policy 24 alternatives to go forward, but as part of that, it 25 is restating that yes, they hav e shown that there

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1 is -- that there are detrimenta l effects from 2 current levels of NOx and SOx o n the acidification 3 of sensitive waters; and that t here are also the 4 other effects, both positive an d negative, that 5 they are not able to quantify o r not quantifying at 6 this time in terms of setting astandard. I think 7 that's about it. 8 I mean, you guys if you wa nt to be more 9 precise as to what -- what vehi cle this document is 10 supposed to be. 11 DR. HUBBELL: Well, again, in Chapter 1 we 12 tried to lay out very clearly - - and, again, you 13 may reject this and say we don' t like the way this 14 is working, but, again, we're v ery explicit that 15 what we're focusing on in these standards is to 16 protect against adverse effects occurring in these 17 sensitive aquatic ecosystems. 18 And, in fact, most of the design elements are 19 trying to do exactly that, to f ocus in on those 20 areas that are most sensitive a nd exclude trying to 21 do too much protection in those that are not 22 sensitive. We're not doing any thing to try to 23 explicitly deal with nutrient e nrichment, either 24 positive or negative, in this p articular set of 25 options that we've laid out.

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1 And, you know, again, we'r e trying to 2 acknowledge that there are thes e -- again, we can 3 fix the language and tone and s o forth, but 4 ultimately these standards real ly are not being 5 designed to deal with nutrient enrichment effects. 6 And perhaps one, you know, one additional 7 reason to not do that is that t here is all this 8 controversy as to what's the ap propriate thing to 9 do with that. But, again, we'r e trying to be very 10 specific that we are focusing o n adverse effects 11 that are occurring due to aquat ic acidification. 12 The other pieces are not a s recognized. And 13 in dealing with adequacy it's s till, again, I think 14 the general conclusion was evengiven the fact that 15 there are these potential produ ctivity effects 16 occurring in forests that there are still systems 17 that are sensitive and are seei ng adverse effects 18 and that that's at the current levels of 19 deposition. 20 So we're trying to lay out even if it may be 21 adequate in some locations beca use they're getting 22 these productivity effects, it' s not adequate in 23 all locations. The aquatic aci dification is trying 24 to deal with that in a site-spe cific way and we 25 don't have a nutrient enrichmen t standard because

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1 we're not able to put that all together and come up 2 with an appropriate level of pr otection. 3 DR. JOHNSON: So you don't think that 4 protecting aquatic -- you thinka standard to just 5 do one thing and not consider u nintended 6 consequences -- 7 DR. HUBBELL: It's not not considering 8 unintended consequences. It's recognizing that 9 we're trying to focus the impac ts on these 10 particular aquatic acidificatio n problems. That's 11 the focus. Again, we're acknow ledging anything 12 having to do with nitrogen is g oing to have an 13 impact, obviously, that's why w e point that out. 14 But, again, we're focusing on t he adverse effects 15 in the aquatic acidification sy stems. 16 We had this discussion las t time, do you need 17 to then say, okay, well, here i s the extent of all 18 the areas that are going to ben efit from it and 19 here are all the areas that wil l not benefit from 20 it? It's not something we felt was doable, number 21 one, but it's not necessarily c lear what we would 22 do with that information if we had it. 23 In other words, if we foun d that there was a 24 reduction in beneficial fertili zation in a small 25 number or even a large number o f forests, the

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1 questions of what you do with t hat information when 2 the standard is intended to pro tect against adverse 3 effects that, again, becomes a policy judgment. 4 I'm just not sure what we woulddo with that 5 information. I'm not sure it w ould change our 6 overall approach. 7 DR. JOHNSON: The global c arbon monitor might 8 do something with it. Anyway, I've said it too 9 long I guess. I give up. 10 DR. RUSSELL: Ellis, do yo u think -- as Rich 11 said, I look at this, and I thi nk we can shorten it 12 and I do believe that they -- t hat they made their 13 point. The one piece that you could say is on four 14 is that there are aspects, you could be very 15 specific, again, bringing up yo ur example that on, 16 what was it, page 435 that migh t change the flavor 17 and might include more discussi on about carbon 18 sequestration. 19 DR. COWLING: I'd be glad to perfect the 20 language. 21 DR. RUSSELL: Okay. 22 DR. COWLING: It's 4-45. 23 DR. RUSSELL: 4-45? 24 DR. COWLING: No, it's 4-4 4 -- no, it's 4-45. 25 DR. AMAR: I have a quick question on question

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1 two, it deals with alternative standards twice in 2 question two and three. I thou ght there was a 3 possibility of keeping the exis ting standard and an 4 additional standard. So someho w the word 5 "alternative" kind of implies h ere it's replacing 6 what you have with something ne w, but you have 7 both. You have existing and -- 8 DR. RUSSELL: This is the adequacy of the 9 current standards. 10 DR. AMAR: -- alternative standards. Somehow 11 it means to me anyway that "alt ernative" would be 12 replace "existing." We had tha t discussion 13 yesterday, three hours, two, ad ding on top of that 14 the long-term acid deposition s tandard. So I'm 15 thinking the word itself "alter native," could we 16 say "potential additional and/o r alternative 17 standards"? 18 DR. RUSSELL: No. This is their question to 19 us. 20 DR. AMAR: I know. I know . I'm thinking 21 maybe the question asked wasn't right. 22 DR. RUSSELL: We just -- 23 DR. AMAR: Respond to the question. 24 DR. RUSSELL: Respond to t he question 25 understanding it could be an ad ditional or -- well,

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1 actually, the alternative wouldbe this and that. 2 Lauri. 3 MS. CHESTNUT: Looking bac k at the question, I 4 was having the same feelings as Rich about that 5 hasn't quite been responsive he re, but it seems 6 like there is three questions h ere and this is all 7 about question number four, abo ut the potential 8 beneficial effects of nitrogen inputs. But we 9 haven't answered two and three, which is about the 10 adequacy of the current standar d to protect against 11 adverse effects. 12 So maybe we can -- it seem s like we should 13 answer two and three succinctlythat they've -- 14 that the current standards, youknow, they've 15 demonstrated that the current s tandards do not 16 affect -- protect against adver se effects of 17 aquatic acidification at curren t -- under current 18 conditions. 19 DR. COWLING: We'll work o n it. 20 DR. FREY: Can I just for answer two and 21 three, the answer is yes and th at's all that needs 22 to be said. 23 DR. RUSSELL: Do people gowith that? Chris 24 has suggested that for 2-A and 3 we put yes. 25 Kathy.

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1 DR. WEATHERS: I would agr ee that it seems 2 that those questions are asked and answered in 3 different ways in different oth er questions here 4 like 24. So we respond to this question, you know, 5 in other answers. So those que stions I think are 6 asked again in question four, f or example. 7 DR. RUSSELL: Question 24 is if we recall this 8 question regarding the conclusi on section alone. 9 DR. WEATHERS: Right. 10 DR. RUSSELL: I think here we say yes. And 11 question number four we can ref er back to the 12 answer here. So what we're goi ng to do is go with 13 2-A and 3, go with yes. 14 Ellis, you know, as specif ic as you can in 15 terms of the document you curre ntly have, you know, 16 I think to bring up the -- what may make it more -- 17 bridge up these other issues, I 'll leave it at 18 that. I'm stumbling. 19 DR. COWLING: Very good. I shall try harder. 20 DR. RUSSELL: Question fiv e. Praveen. 21 DR. AMAR: Yes, we need a minute to read it or 22 should I just explain what's init? 23 DR. RUSSELL: Explain, giv e us a minute to 24 read it. 25 DR. AMAR: The answer withinput from me, and

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1 Naresh, it starts with a point of view that the 2 approach is good, it's well tho ught out and then we 3 have in the middle, second and third paragraph 4 exceptions. 5 There is a reference to ammonia, takes into 6 account what Rich Poirot had tosay about how the 7 second draft is better than the previous one. It 8 has comments from me that it st ill doesn't go far 9 enough. And then Myron sent th e third paragraph, 10 which has more to do with the c ycling of the notes 11 and then NOy and cycling of SO2 not being treated 12 correctly here. 13 The fourth paragraph shoul d really go at the 14 end now because the fifth point is from Naresh, 15 which finds the approach is not robust enough, but 16 could be made robust by doing h indcasting of AAPI 17 with data from the past. WhichI think was 1990 to 18 2006, Charlie, the recent data from lakes if you're 19 doing hindcasting of AAPI? 20 DR. DRISCOLL: Yeah, comes up I think to 2008. 21 DR. AMAR: 2008. I think that's what Naresh 22 is implying in the paragraph is it could come forth 23 as one weakness of the approachhere. And then in 24 the end we say we have concerns . We think it's 25 done an adequate job.

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1 So it starts that we're do ing well. In the 2 end we say it's doing well. Inbetween three 3 things here is where we go. Dr . Myron has the 4 language as submitted with mino r editorial changes. 5 And Naresh put in the end as it was said. 6 Early in the first sentenc e I say very well 7 thought out and I there were ex ceptions. I took 8 the word "very" out and said "w ell thought out." 9 DR. DRISCOLL: Can I make a wording 10 suggestion? 11 DR. RUSSELL: Yes. 12 DR. DRISCOLL: So on the f ifth paragraph, a 13 couple cases, third line toward s the end of the 14 paragraph, the word "hindcastin g" is used. I don't 15 think we should -- we should no t use that word 16 because it usually has a modeli ng connotation. 17 So I would say something i s tested by the use 18 of historical data, historical water chemistry data 19 or historical water chemistry o bservations to make 20 it more specific and not confus ing. Is that okay? 21 DR. AMAR: Okay. 22 DR. RUSSELL: He says "his torical water 23 chemistry data." 24 DR. AMAR: Pretty much eva luation of models 25 from the past data.

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1 DR. MITCHELL: We should s ay "historical 2 data." It's more than just wat er data. 3 DR. RUSSELL: So. 4 DR. MITCHELL: I'd take ou t the next sentence, 5 "There are measurements of ANC available for some 6 aquatic systems." That's over -- after historical 7 data sentence, "There are measu rements of ANC 8 available for some aquatic syst ems." 9 DR. RUSSELL: So what did you want? 10 DR. MITCHELL: Take that s entence out. That's 11 fine. Probably say there were such measurements, 12 just say "reported data are ava ilable." 13 DR. RUSSELL: Naresh. 14 DR. KUMAR: I have a quest ion for a 15 different -- you want to contin ue with this, that's 16 fine. 17 DR. RUSSELL: Chris. 18 DR. FREY: I guess on this paragraph -- there 19 is a sentence or a clause fragment of the 20 uncertainty analysis in charge question 14. But I 21 think what it means to say is t hat perhaps the 22 meaning is one way to evaluate robustness is using 23 an uncertainty analysis, which is addressed in 24 charge question 14, but also incharge question 21. 25 I had another point that I can wait.

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1 DR. RUSSELL: I put at the end of that -- not 2 to confuse Angela. Just keep t ight and I'll 3 remember. 4 DR. NUGENT: What was the charge question? 5 DR. FREY: Twenty-one. An d actually could 6 say, "Evaluate robustness usingsensitivity and 7 uncertainty analysis and more u ncertainty 8 analysis," because I think that 's -- I think the 9 panel had some viewpoints about moving toward 10 quantitative uncertainty analys is and not just 11 sensitivity analysis. That's g ood. 12 DR. RUSSELL: And I'd prob ably say -- this is 13 wordsmithing. Never mind. Oth er things? 14 DR. HUSAR: Could it be re cognized in Chapter 15 7, which is the full uncertaint y analysis rather 16 than just particular? 17 MR. McNAMARA: Mike, pleas e. 18 DR. HUSAR: Instead of ref erencing pointing to 19 questions 14 and 21 specificall y, how about 20 pointing to the Chapter 7, whic h is the full 21 uncertainty, sensitivity chapte r dealing with all 22 of them. 23 DR. RUSSELL: In that case I think it would 24 have to say in response to our charge questions 14 25 and 21, which provide our sugge stions to that

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1 chapter. I don't think we can refer them to that 2 chapter because that chapter do esn't have what we 3 want. 4 DR. FREY: If I could add, I think there is 5 also elements of this in Chapte r 9. So I think if 6 you try to say more, then you h ave to say a lot 7 more and it may be best just toleave it the way it 8 is here. 9 DR. AMAR: Also I agree, r ight after "but one 10 way," I think the way -- the sp irit of the sentence 11 says, it should say "an additio nal way." 12 DR. RUSSELL: Yeah, that w as my wordsmithing. 13 I think a period and "an additi onal way." 14 And also, Praveen, if you can integrate what 15 Naresh said in a cleaner way. 16 DR. AMAR: I think at a mi nimum this 17 paragraph -- it came out the wa y we put it 18 together, but I think it just g oes about and some 19 wordsmithing after that. For e xample, I think it 20 talks here in the conceptual fr amework looks fine. 21 We have said that more than onc e. 22 DR. RUSSELL: Chris. 23 DR. FREY: I have a differ ent paragraph to 24 comment on, which was the secon d paragraph, that 25 starts with, "For example the f ramework of the

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1 structure" and in the -- well, it's actually the 2 first sentence, but it's the la st half of that 3 sentence on lines two to four o f that paragraph it 4 talks about that the framework does so in a manner 5 that would not allow EPA to add ress and require 6 reductions in the U.S. ammonia emissions. And I 7 think that ammonia is not a cri teria pollutant and 8 it's not in the scope of the NAAQS to try to 9 address reductions in ammonia e missions under this 10 standard. So I don't know the purpose of having 11 that there. 12 I would suggest just takin g out that clause. 13 And so one could say that the s tructure takes into 14 account ambient ammonia and its deposition and the 15 revised treatment is an improve ment over the first 16 draft. I think the rest of it' s okay pointing out 17 that ammonia emissions will cha nge over time. But 18 it's almost like we're sort of -- are we implying 19 EPA should regulate ammonia if we have that clause? 20 I think it doesn't need to be t here. 21 DR. AMAR: I know I wrote that. I wrote that 22 in the first draft too. I thin k I was trying to 23 find there an opportunity I thi nk for EPA in the 24 future to address ammonia more strongly than it 25 does. And this may be one way, but, again, I don't

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1 know what the legal implication s are. I thought it 2 was a precursor to what follows next. And we had 3 had this discussion from a Stat e perspective, 4 emissions estimates perspective and it's providing 5 an opportunity. 6 DR. FREY: Yeah. I suppos e I guess maybe the 7 analogy with ozone where VOC em issions are 8 typically controlled, but VOC i s not a criteria 9 pollutant. Maybe there is some thing there, but I 10 don't know. It seems like eith er that shouldn't be 11 there or maybe it needs to be e xpanded if that's a 12 major direction that the commit tee would like to 13 see. 14 DR. RUSSELL: But I don't think this is the 15 document to start doing that. 16 DR. AMAR: If we took that out, the one 17 highlighted and the rest is oka y. 18 DR. RUSSELL: Yeah. And, actually, I like the 19 way Chris put it, the approach does take into 20 account the deposition of reduc ed nitrogen. 21 DR. FREY: And the revisedtreatment is an 22 improvement. 23 DR. AMAR: That's the poin t Rich had made 24 before. I think it's -- there is a question mark, 25 I wasn't sure.

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1 DR. HUBBELL: That hasn't been determined yet. 2 DR. RUSSELL: We don't hav e to specify that 3 either. 4 DR. AMAR: Periodically. 5 DR. RUSSELL: "The approac h accounts for the 6 deposition" -- further up. "Th e approach accounts 7 for the deposition of reduced n itrogen." 8 DR. NUGENT: New sentence. Approach accounts 9 for the deposition of reduced n itrogen and 10 periodically. 11 Okay. Other panelists' su ggestions on this? 12 Anything that we're missing? 13 DR. DRISCOLL: There was alast paragraph that 14 was another "hindcast" further down, if we change 15 that to, right there, second tolast line, third 16 word we change it to "this anal ysis" or "this 17 analysis of water chemistry dat a," something like 18 that. 19 DR. RUSSELL: Historical d ata. 20 DR. DRISCOLL: Yeah. 21 DR. RUSSELL: Question six . 22 DR. AMAR: Myron had his i nput. What I have 23 done, while we were reading, th ere are six 24 paragraphs and we start saying the option one is 25 simple, good, but not very usef ul. And that's a

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1 merger with what Myron and I ha d written. It's 2 overprotection for the least an d underprotection 3 for the most sensitive. 4 And we go on record, the s econd paragraph, the 5 ecoregion three approach is rea sonable, but we do 6 add that we recommend that the revised PA include a 7 clear and more detailed descrip tion of this 8 approach. 9 And the third and fourth p aragraphs are from 10 Myron talking about ANC being c onsistent with the 11 overall emphasis. And then the fourth one about 12 the relative appropriateness of the suggested 13 methods. Interesting, I think that's the word 14 Myron used. Maybe we could thi nk of something 15 else. 16 And then in the end betwee n three approaches, 17 2-A, 2-B and 2-C it says, "Clus ter analysis seems 18 to be provide the right balance between not 19 detailed enough and too detaile d." That is what we 20 tried to do between Myron and myself. 21 Hopefully, Myron, I got yo ur input correctly 22 in the right places. 23 DR. RUSSELL: Rich. 24 MR. POIROT: I'm just thin king, Praveen, that 25 that comment about the need for clearer, more

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1 detailed description of the app roach wasn't 2 necessarily just Ecoregion III approach, but it was 3 really the options just aren't -- all of the 4 options, including those that u se that approach, 5 aren't explained with sufficien t clarity. 6 DR. AMAR: Fair. 7 DR. RUSSELL: I think that goes up top. 8 DR. AMAR: Even before we start option one 9 right up. 10 DR. RUSSELL: Yes. Rich, you wouldn't be able 11 to come up with some wording of f the top of your 12 head, would you? Discussion onclarity. 13 MR. POIROT: You mean righ t now? 14 DR. RUSSELL: We might be able to take 15 something from the cover letter too. 16 DR. WEATHERS: We also hav e some language in 17 number 24 about that general la nguage. 18 DR. RUSSELL: You want to give us the 19 language? 20 DR. WEATHERS: Yeah, I thi nk we have, "The 21 justification, logic and necess ity of the spatial 22 grouping classification is not clear to the panel." 23 DR. RUSSELL: You got that ? 24 DR. WEATHERS: It's in 24. 25 DR. RUSSELL: While Angelais typing that, I

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1 think we also have to comment o n the two region as 2 well. 3 DR. AMAR: Two region? 4 DR. RUSSELL: You have the whole U.S. and then 5 two-region U.S. 6 DR. AMAR: Okay. 7 DR. RUSSELL: I didn't see that there. 8 DR. AMAR: We talk about 2 -B is good; 2-A we 9 talk about it is not detailed e nough. Not detailed 10 enough or too much detail. May be that's not the 11 right word. Appropriate. 12 DR. RUSSELL: How are we d oing? 13 DR. AMAR: I think making a selection in 2-B 14 is better than the other in 2-Aand 2-C. 15 DR. RUSSELL: I was just t hinking that might 16 come up higher. What do people think? 17 MS. CHESTNUT: Yeah, it ki nd of jumps around. 18 DR. RUSSELL: Yeah. I mig ht go further up and 19 keep going, don't get rid of it . 20 MS. CHESTNUT: Cut and pas te. 21 DR. RUSSELL: No, not evencut and paste. 22 That still might be a fine conc luding paragraph. 23 And yeah, state something like right there, part of 24 that paragraph. Actually, the first paragraph, 25 likewise, the option of dividin g the U.S. into two

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1 regions. 2 MS. CHESTNUT: Is it reall y two regions or two 3 categories? 4 DR. RUSSELL: Categories, okay, categories. 5 Yeah, I think an appropriate wo rd is categories. 6 Does not provide -- 7 MS. CHESTNUT: Given the questions about the 8 implications of this different level of spatial 9 resolution on this, are we real ly comfortable 10 giving conclusions about two is not enough or -- 11 I'm not sure two is not enough. I mean, I can't -- 12 I'm not -- the benefit of what we gain from going 13 to the 5 or the 70 is still not quite clear enough 14 to base a conclusion about that . 15 DR. RUSSELL: People's tho ughts? Actually, I 16 hear some nodding that yes, may be we're not there 17 yet. Right now what we can sayis we think one is 18 too few, and I think we can als o say that 70-X is 19 too many. 20 MR. POIROT: And the other middle options 21 aren't explained clear enough. 22 DR. RUSSELL: Yeah. 23 DR. NUGENT: Do we need 70 -X is too many? 24 DR. RUSSELL: What was tha t? 25 DR. DRISCOLL: It's the fu ll, what's it, Level

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1 III Ecoregion. So I think it's 87 or something 2 like that, numbers. 3 DR. FREY: Basically we're looking for the 4 Goldilocks effect. 5 DR. DRISCOLL: Chris has g ot the Goldilocks. 6 DR. RUSSELL: Yeah, the Go ldilocks. Would 7 appear to provide too much comp lexity? 8 DR. DRISCOLL: It's just a n unnecessary amount 9 of detail I would say. I don't think it's gaining 10 that much from going to that ma ny, that much 11 unnecessary details, something like that. 12 DR. WEATHERS: I would sayit seems that way, 13 because I think at this point w e don't know. We 14 don't know whether the approachcan be applied. 15 DR. DRISCOLL: We don't ha ve details. 16 DR. MITCHELL: I think a l ot of us are fairly 17 cold in this room. Is that mov ing in the right 18 direction? 19 MR. McNAMARA: Yeah. 20 DR. RUSSELL: And you want to use appear or 21 seen? 22 DR. AMAR: Either word is fine. 23 DR. HUBBELL: Can we ask o n this particular 24 issue it would help us to be cl earer to indicate 25 that while you might support th e Ecoregion III as a

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1 spatial unit that you don't nec essarily support 2 using 87 of them individually? It seems like 3 you're throwing out ecoregions as a spatial unit. 4 DR. RUSSELL: Okay. Actua lly, when we add the 5 XX up there that was supposed t o -- we actually can 6 add that detail. Option 2-D us ing ecoregion -- 7 because specifically option 2-DI think is the one 8 that has -- 9 DR. HUBBELL: We use ecore gion threes in all 10 of them. It's just a matter of whether we 11 aggregate the ecoregion threes into different 12 classes or leave them individua lly. 13 DR. RUSSELL: Actually, op tion 2-D, which 14 includes, dot, dot, dot? 15 DR. HUBBELL: That's bette r. That helps us. 16 MS. CHESTNUT: Even if tha t second paragraph 17 has using the Ecoregion III bou ndaries is a 18 reasonable approach. 19 DR. RUSSELL: So do we wan t -- how do we want 20 to say that? 21 DR. WEATHERS: Isn't it th at the ecoregion 22 approach has conceptual appeal? We don't know how 23 to evaluate it, but we have some sense that 24 ecoregions, for both logistical reasons and for 25 ecological process reasons, hav e -- are feasible.

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1 It's really about using ecoregi ons versus using 2 political boundaries or some ot her distinctional 3 grouping. 4 MS. CHESTNUT: Yeah. I th ink they're using 5 the ecoregions either way. It' s just can they 6 be -- 7 DR. WEATHERS: Right. 8 MS. CHESTNUT: -- lumped i nto more coarse 9 categories? 10 DR. HUBBELL: To try to he lp a little bit, 11 again, last time we met we trie d to distinguish 12 between spatial aggregation are as. The ecoregion 13 is a nice unit of spatial aggre gation. The 14 question then is how do you use those to come up 15 with classifications based on s ensitivity? That's 16 questions do you just leave the m by themselves and 17 say each one represents its ownsensitivity class; 18 or do you try to aggregate themin some other way, 19 which represents the other thre e methods, the 20 clustering; the binary, yes or no, you're 21 sensitive; or one nation? 22 And I think what we're loo king for it would be 23 nice if you say, you would like spatially 24 aggregated based on ecoregions? And then do you 25 like any of these approaches fo r aggregating these

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1 ecoregions into these classific ation groups? 2 DR. RUSSELL: Yes. 3 DR. SCHEFFE: Important re ason for aggregating 4 is because certain ecoregions h ave a very limited 5 dataset. And so there could be a scenario where 6 perhaps we do this clustering w here we have five 7 sensitivities which look at -- which include all 8 the different ecoregions. Yet when we actually 9 apply the method, the method is applied over an 10 ecoregion and the clustering re sults in the 11 critical loads that would be us ed for the different 12 sensitivity classes. 13 DR. HUBBELL: The critical load would be 14 calculated over that larger gro uping, that would 15 then be used to establish that depositional load 16 metric that says here is the cr itical load that 17 protects 90 percent of the part icular water bodies. 18 But when they calculate the thi ngs like ammonia and 19 TNOx and TSOx that would be at the ecoregion or 20 below level. 21 DR. WEATHERS: I don't kno w what the language 22 is, it seems like we agree withthe approach of 23 using ecoregions and the way inwhich they're 24 aggregated may be dependent upo n the data 25 restrictions, requirements. I don't know what all

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1 the details are of the approach , but that's what's 2 restricting how it is or what's advising us on how 3 it is that the ecoregions are c lustered; is that 4 right? 5 DR. HUBBELL: Well, there is two pieces that I 6 mentioned yesterday. One is th e data issues. Do 7 we have enough data to be able to appropriately 8 characterize the distribution o f critical loads? 9 And the second is this balance between complexity 10 and simplicity and what are we gaining in terms of 11 flexibility? Do you see a sign ificant difference 12 in the critical loads between t he groups that would 13 recommend keeping them separate rather than 14 collecting them together in one classification. 15 DR. WEATHERS: We don't kn ow what the 16 showstoppers are, that's part o f what we want from 17 you is to know what the showsto ppers are. 18 DR. HUBBELL: I think it w ould be very helpful 19 for you to lay that out and tha t would make it 20 clear what the expectations are . 21 DR. RUSSELL: First, let's make that a new 22 paragraph. So how far do we wa nt to go on this? 23 And I'd say, "But its weaknesse s appear to be too 24 many." Again, we're not sure y et. 25 DR. WEATHERS: I guess in the second sentence,

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1 it's the rationales and the lim itation, the data 2 limitation or analysis limitati ons must be better 3 articulated or strengthened. W e need to know more 4 about that before we can write advice of what we 5 think is a better approach. 6 Rich made the point yester day as well on the 7 second paragraph that the one-n ation approach and 8 maybe even the too-sensitivity approach are useful 9 to actually see. Even if we do n't advocate them, 10 they're useful contracts. I wo uld think that -- I 11 agree with that. 12 DR. RUSSELL: If we go dow n, I think 13 conceptually we like the cluste ring approach. 14 DR. WEATHERS: Ecoregion. 15 DR. RUSSELL: Ecoregion cl ustering to get to 16 about five clusters. We can't say that that's 17 our -- the optimal choice, but we conceptually like 18 that. We think it has merit. So we should say 19 that. I think it's there somew here. And then also 20 bringing up Rich's point, we al so -- having the 21 example of a one or two-region -- one or two-region 22 approach for contrast is also v aluable. 23 DR. WEATHERS: Then maybe just putting while 24 the first approach while its we aknesses appear to 25 be -- and nonetheless we find i t useful reference

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1 or useful contrast. 2 DR. RUSSELL: So go over t here nonetheless, 3 make it a real sentence afterwa rds. We find it 4 useful. You can use "it." We' ll figure out 5 something with that as we go. 6 Okay. Then somewhere -- 7 DR. WEATHERS: I don't thi nk we need the rest 8 of this option. 9 DR. RUSSELL: We can get r id of that -- sorry 10 about that. I didn't mean get rid of that. I 11 think Kathy was saying further down. Don't get rid 12 of it now. 13 DR. WEATHERS: I was makin g a comment on 2-D. 14 Basically, we don't know until we have more 15 information. I don't feel stro ngly about it. And 16 somewhere I think in maybe eventhat same paragraph 17 say, "The use of clustering is conceptually 18 appealing," though we do not --though we do not 19 know what the optimal number of spatial categories. 20 MS. CHESTNUT: Sensitivitycategories. 21 DR. RUSSELL: Yeah, spatia l -- you call them 22 spatial categories. 23 DR. HUBBELL: It's sensiti vity categories. 24 DR. RUSSELL: Sensitivity categories. 25 DR. HUBBELL: Because theydon't have to be

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1 contiguous with each other. Cl usters can have 2 pieces everywhere. 3 DR. RUSSELL: Okay. Prave en, I think you can 4 work on editing that down. I t hink you have the 5 flavor of what we're trying to say. Going forward 6 Praveen will edit down. 7 Seven, that would be Andre . 8 DR. BYTNEROWICZ: Should I start or give you 9 some time to read? 10 DR. RUSSELL: You can say yes. So you can 11 start. This is nice and short. 12 DR. BYTNEROWICZ: Generall y we like the 13 critical loads concept. It's l ogical and 14 appropriate. And we like that it links all the 15 necessary components and includ es also reduced 16 forms of nitrogen. 17 MR. McNAMARA: I'm sorry, could you speak 18 closer to the mike, please. Th ank you. 19 DR. BYTNEROWICZ: I saw it was next to me, but 20 okay. In regard to question A the F-factor 21 approach is reasonable and -- b ut proposals say it 22 would be useful to look toward the models to 23 evaluate ecosystem effects of a tmospheric 24 deposition. And we would like to rephrase maybe 25 this question and ask is the pr oposed methodology

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1 for obtaining the BCo values co rrectly described 2 and what the panel option -- if we have to rephrase 3 it because maybe it is not need ed. And continuing 4 that, we want the panel's opini on from 5 extrapolating the knowledge gai ned for the 6 Adirondacks lakes and southern Appalachian streams 7 can be linked to the rest of th e U.S. waterbodies. 8 In regard to B we decided that filtering of 9 lakes and streams with high con centrations of 10 organic acids and with low hist orical ANC values 11 should be avoided since these w aterbodies are often 12 highly sensitive. However, wat erbodies that have 13 clear impact of mine drainage c an be eliminated. 14 So that's question seven. 15 DR. RUSSELL: Comments? P eople like it. 16 Naresh. 17 DR. KUMAR: So number 7-B, I know it was 18 discussed yesterday, but I didn 't think it was 19 decided whether we are going torecommend not 20 eliminating sensitive lakes or what? 21 DR. RUSSELL: Say that aga in. 22 DR. KUMAR: 7-B, so we are recommending that 23 highly sensitive lakes not be e liminated? 24 DR. RUSSELL: That's what I think we're 25 recommending.

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1 DR. KUMAR: Again, I guess who recommended 2 that, can I get a reasoning for that? 3 DR. DRISCOLL: So I -- I t hink I was the one 4 who recommended it and I guess my thinking is just 5 for, you know, transparency sak e. I understand the 6 issues associated with that, bu t there are lakes 7 that are naturally acidic or ha ve naturally 8 background low-acid neutralizin g capacities. So if 9 you target 50 or 100 microequiv alents per liter, 10 they may have never been at tha t value 11 historically. 12 So my thinking was that yo u also have this -- 13 you have this target percentage that you're going 14 to try to protect 95 percent, 9 0 percent, 15 75 percent. And those values - - those lakes or 16 streams that were eliminated co uld be incorporated 17 on the percentage. There are o nes that are not 18 being considered. So why not i nclude it in the 19 analysis, flag them, say that t hey were either 20 naturally acidic because of lowsupply of base 21 cations or high inputs of organ ic acids or 22 whatever -- or another mechanis m, maybe it's the 23 case of Florida, and just flag them as naturally 24 acidic systems. 25 They still will obtain some benefit from

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1 reductions in acidic deposition , but then you have 2 sort of the full population tha t are not -- that 3 are not going to be able to mak e this target value, 4 whatever it is, acid neutralizi ng capacity of 50 or 5 100. 6 So I just advocated that, you know, with the 7 idea of greater transparency, s o that was my 8 thinking. I mean, I think we h ad a few comments, 9 but I didn't hear too many othe r comments opposing 10 that. If it creates problems f or you in getting it 11 done at the end -- 12 DR. KUMAR: I guess one of the comments with 13 EPA was that if you go with 90 percent of the lakes 14 will be protected and if the re gion has 20 percent 15 of the lakes naturally acidic, what do you do in 16 that case? 17 DR. HUBBELL: That is our concern. Again, 18 without having the data in fron t of me, it's hard 19 to know for sure. But let's ta ke Florida, for 20 example, and if we said, you kn ow what, we're going 21 to include all these naturally acidic lakes in 22 Florida and say it was 20 perce nt, that would mean 23 that we would be basically -- i f we didn't do that, 24 it would mean we would have a z ero critical load or 25 negative, which is very difficu lt to figure out how

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1 to express that. 2 And if we want to have a c onstant percentage 3 of lakes protected across the c ountry, then we 4 would have to base it on tryingto figure out how 5 we're going to deal with, okay, Florida we might 6 need to have 70 percent; but 70 percent wouldn't be 7 adequate in other parts of the country because you 8 have a lot of places where you don't have these 9 high numbers of naturally acidi c lakes. 10 So it really puts us in a bind in terms of how 11 to think about making this stil l a national 12 standard that focuses on sensit ive and responsive 13 lakes. 14 DR. DRISCOLL: It seems tome you're either 15 flagging them on the front end or you're flagging 16 them on the back end. What dif ference does it 17 make? 18 DR. HUBBELL: Because flag ging them on the 19 front end removes them from the calculations of the 20 critical loads. Flagging them on the back end I 21 don't know how you adjust your critical loads at 22 that point. 23 DR. DRISCOLL: I don't thi nk you should adjust 24 it. You just flag them and adj ust it. They're 25 naturally acidic. You don't wo rry about them,

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1 okay. You've got an excuse, yo u know, the dog ate 2 my homework. 3 DR. HUBBELL: You don't ge t any protection in 4 Florida because if you flag tha t and say there is 5 no reasonable critical load tha t we can use in 6 Florida, it's just not -- I mea n, you're -- to me 7 this is actually making it less transparent because 8 at the end you're saying we hav e a critical load 9 that we determined would protec t 80 percent of the 10 lakes in the area, but we're no w going to say we 11 have to somehow after we've don e the distribution 12 adjust that percentile. 13 It just seems like it's be tter to be very 14 clear and say we're taking thes e lakes off the 15 table. We can show with what t hat full 16 distribution is before we do th at. We can show 17 here is the distribution before you filter; here's 18 the distribution afterwards andthis is the basis. 19 But doing it just after I don't see how we turn 20 that into a standard. It just seems very difficult 21 to work with. 22 DR. DRISCOLL: Okay. I gu ess we agree to 23 disagree. I imagine from, you know, states in the 24 northeast that are naturally ac idic you're going to 25 get cost wise for those folks b ecause, you know,

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1 there are a large numbers of la kes that probably 2 had ANC values historically bel ow 50 and they 3 clearly have been impacted by a cidic deposition. 4 DR. HUBBELL: They'll stil l get benefit. They 5 will still get benefit from the reductions. It's 6 just they won't be targeted. 7 DR. DRISCOLL: Well, you u nderstand the 8 administrative end of things be tter than I do. I 9 just think from a simplistic --making it 10 simplistic as well as transpare ncy that's why I 11 made my suggestion. It's a badidea. I come up 12 with bad ideas all the time. S o I understand that. 13 DR. RUSSELL: Rich and the n Kathy. 14 MR. POIROT: I was just wo ndering, Charlie, 15 what if we flip that paragraph around a little bit 16 and start it with it's logical to eliminate 17 waterbodies that have been impa cted by mine 18 drainages; however, you know, a dvance elimination 19 of lakes in these other categor ies should be 20 considered more carefully becau se of the reasons 21 you state. Would that work? 22 DR. DRISCOLL: Yeah, that' s fine. I mean, you 23 folks have been living this muc h more than I have. 24 I've only been looking at this for three weeks. I 25 don't really understand all the subtleties. Just

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1 my gut tells me that it's a badidea to filter them 2 on the front end. I think we'l l get lost in 3 details. So it's better off ju st making an 4 exception on the back end. If that's not the case, 5 then fine. 6 DR. RUSSELL: And I'd say not only elimination 7 of waterbodies -- advanced elim ination of other 8 waterbodies, let's get a little bit more specific. 9 I was just saying not only furt her considered, but 10 also the rationale, better expl ained and with 11 examples given preferably in a distribution point. 12 I'm not sure -- I mean, es sentially that's 13 picking up with what Brian said . I'm not sure if I 14 was saying it exactly correctly , if you can show us 15 what that does. 16 DR. HUBBELL: That's what we were just saying. 17 We very easily can do that, bri ng in the filtered, 18 unfiltered and what would happe n to the ones that 19 got filtered out if you actuall y attained a 20 targeted ANC for the remaining population. 21 DR. RUSSELL: I don't thin k we can be really 22 comfortable without seeing that . I'm not sure if 23 we'll be comfortable afterwards , but without it, 24 it's going to be problematic. Kathy. 25 DR. WEATHERS: Taken care of.

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1 DR. AMAR: The word "filte ring" has other 2 meanings too. Do we want to sa y removal of lakes 3 from the sample? It's not filt ering. 4 DR. WEATHERS: From the da tabase or from 5 analysis. 6 DR. RUSSELL: Removal. 7 DR. FREY: We're not goingto eliminate 8 waterbodies. 9 DR. RUSSELL: No, it's fro m the analysis after 10 removal. 11 MS. CHESTNUT: From the ta rget or from the -- 12 DR. WEATHERS: I think tha t's part of what's 13 confusing. I wasn't clear whet her Charlie and 14 Bryan were talking about the same thing. We want 15 to see the database of all lake s except maybe the 16 acid mine drainage lakes. And the question is does 17 the critical loads analysis get applied to the full 18 dataset or to the dataset that has flagged the 19 organic acidified lakes? 20 It wasn't clear to me, Cha rlie, whether you 21 were advocating doing the criti cal loads analysis 22 on a whole database or just mak ing clear that these 23 organically acidified lakes are out there, they're 24 part of the database. 25 DR. DRISCOLL: I just want to recognize that

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1 they are part of the system. 2 DR. WEATHERS: Right. 3 DR. DRISCOLL: And they're not going to meet 4 the target. They may have natu ral characteristics 5 that don't allow them to meet t he target, but I 6 think it's important that, you know, that they're 7 recognized that there are some impacts and 8 potential benefits associated w ith that. 9 DR. WEATHERS: I agree it' s now on there. 10 DR. HUBBELL: We're all onthe same page. We 11 will show what happens to those naturally acidic 12 lakes that are still receiving excess deposition. 13 I think that was the concern is that there were 14 some that were being impacted. They were 15 sensitive. They just weren't a s sensitive because 16 they had all -- or as responsiv e because they had 17 all these other factors that we re contributing. So 18 I think we understand what you want. 19 DR. WEATHERS: So now that means that "should 20 be avoided" should be taken out on this language. 21 Take out "removing." Lakes andstreams with high 22 concentrations of organic acids or low historical 23 ANC should be retained in the d atabase, but not 24 included in the critical loads analysis. 25 DR. RUSSELL: Do we want t o say that

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1 specifically? 2 DR. WEATHERS: No, it woul d be better to leave 3 it. 4 MS. CHESTNUT: Could we ju st say the panel's 5 concerned about removing lakes that are -- 6 DR. RUSSELL: Yes. That c ertainly is -- 7 MS. CHESTNUT: Because the y are still 8 sensitive to acidification. 9 DR. KUMAR: What do you me an by the highly 10 sensitive sites in the last sen tence, the often 11 highly sensitive sites? 12 DR. BYTNEROWICZ: Waterbod ies, yes. Charlie, 13 that's what you have, sensitive sites? 14 DR. DRISCOLL: Yeah, they have historically 15 low rates of ANC or base cationsupply. They are 16 highly sensitive. They are bel ow -- historically 17 they're below the target value, whatever it is, 50 18 or 100. So they would never ge t back to that 19 value. So that's what I meant by highly sensitive. 20 MS. CHESTNUT: Doesn't it hurt the lake if 21 they're already there? 22 DR. DRISCOLL: Yes, it def initely hurts the 23 lake to go from 30 to 20 or something like that, 24 sure. 25 DR. RUSSELL: Rudy.

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1 DR. HUSAR: For whatever i t's worth, the 2 exceptional event rule for ozon e and PM to five 3 does the filtering at the tail end. In other 4 words, do the calculation on th e exceedances or 5 compliance, but then at the tai l end say, oh, this 6 is not applicable or not to be considered for this 7 and that reason, which would goalong with what 8 Charlie was saying. That you j ust perform and 9 excuse it for good reasons. Th at's fine. I'm not 10 sure it is exactly the same sit uation, but this is 11 just, you know, for compatibili ty to understand it. 12 DR. HUBBELL: The critical thing for us, 13 again, is to be able to when we 're constructing the 14 depositional loads that eventua lly get translated 15 into atmospheric concentrations to be able to 16 recognize these highly otherwis e impacted 17 waterbodies that we would not e xpect to be able to 18 fully benefit from the NOx and SOx reductions. 19 And the concern, again, as long as we can lay 20 all those out and say, look, we understand these 21 are part of the population of l akes that are of 22 concern, but we're not going tobase our critical 23 load calculation on that set th at are not likely to 24 be responsive. That's what we need to preserve. 25 Otherwise, I think it's going t o get to the point

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1 where we can't -- it's going tobe difficult to set 2 a national standard in that way . 3 DR. DRISCOLL: I think it' s fine, but I think 4 when you revise the document, y ou need to make sure 5 that that's stated. I don't th ink it's stated very 6 clearly in the document as it s tands that there are 7 a certain fraction of lakes tha t are highly 8 sensitive that have been impact ed and, therefore, 9 would derive some benefit, but below this 50 or 100 10 threshold and then make it prob lematic to use that 11 for a standard with those syste ms. That's not very 12 clear in the document. 13 DR. HUBBELL: No, it's not . We'll work to 14 make that clearer. 15 DR. RUSSELL: Moving on. Andre. 16 DR. BYTNEROWICZ: Should I start? So we think 17 that the proposed approach make s sense, utilizes 18 best available knowledge which comes from the CMAQ 19 outputs. We know that there ar e limitations here. 20 And we also think that potentia lly NADP chemistry 21 and prism precipitation results could be utilized. 22 And due to high ammonia de position velocity, 23 steep concentrations of ammoniaconcentrations near 24 the source areas can be expecte d. Therefore, 25 averaging reduced nitrogen conc entrations over

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1 larger areas may lead to missin g some potential 2 problems near the sources and a lso possibility for 3 some significant ecological eff ects. So, 4 therefore, we thought that opti on two is preferable 5 since it allows for additional spatial refinement 6 of sensitive areas. And we als o think that a 7 better understanding of spatial and temporal 8 distribution of reduced nitroge n, especially 9 ammonia, in the U.S. is critica l and, therefore, 10 efforts should be continued to assure the 11 nationwide monitoring of ammoni a, especially in 12 remote areas where you have mul tiple sources of 13 ammonia emissions. 14 DR. RUSSELL: And I'd chan ge ammonia, if I 15 might, to reduced nitrogen. 16 DR. BYTNEROWICZ: Yeah, th at's right. You 17 mean in the last sentence? 18 DR. RUSSELL: Yes. 19 DR. BYTNEROWICZ: No, this is not what I 20 meant. Okay, here. 21 DR. RUSSELL: And the pane l comments? 22 Question nine. That wouldbe Naresh. 23 DR. KUMAR: I had input fr om Praveen and Rich 24 in addition to mine on this one . The first 25 paragraph is what I had discuss ed yesterday. The

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1 second one is from Praveen and the other is from 2 Rich. 3 DR. RUSSELL: Okay. One t hing I might say is 4 CMAQ may not adequately account for deposition of 5 coarse particle sulfate because it actually does 6 coarse particle deposition. It 's sulfate 7 particles. 8 MR. POIROT: Does it accou nt for coarse 9 particle metric? 10 DR. RUSSELL: It does now in the new version. 11 Rich, you didn't have a chance to check on that 12 yesterday, did you? 13 DR. SCHEFFE: No one was a round. I've got a 14 couple calls in on things. I mean, again, you 15 know, sulfate was -- our emphas is has been on 16 particle -- on inhalable partic les so much that 17 there is some logic to why nitr ate's covered and 18 not sulfate. 19 DR. MITCHELL: I guess I h ave one suggestion 20 for revision though of how to e mphasize what EPA 21 should possibly attack on this. I guess I -- I 22 would prefer looking at some ot her measurements 23 that have the similar -- like C ASTNET does not have 24 all the chemistry associated wi th the CMAQ model, 25 but at least doing some compari sons on how stable

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1 those ratios of chemical specie s are over time. I 2 think that would be a more help ful and more useful 3 analysis than doing a number of different CMAQ, 4 CMAQ model runs, 'cause that ju st kind of just 5 let's us flex in the model. 6 My suggestion would be in terms of how to 7 maximize effort would be to at least do some 8 comparison, not everything, jus t to see how some of 9 these ratios could vary over ti me using other data 10 which could be available and th at would just kind 11 of be a nice link in terms of C MAQ with other types 12 of efforts. 13 DR. WEATHERS: I agree wit h Myron. That's my 14 comment to things -- 15 DR. MITCHELL: I guess tha t was a section 16 here, I'd like to see that. 17 DR. RUSSELL: So time to p unish you, give us 18 about a paragraph on that, a sh ort paragraph. 19 DR. MITCHELL: Okay. 20 DR. RUSSELL: Send it to Angela. 21 DR. MITCHELL: I'll do tha t. 22 DR. SCHEFFE: That would h ave to be 23 communicated pretty clearly bec ause I'm struggling 24 with how that could be done in terms of using 25 observations to do that.

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1 DR. MITCHELL: I guess I'mthinking Richard, 2 obviously, we don't want to mak e this be mission 3 impossible. 4 DR. SCHEFFE: Sure. 5 DR. MITCHELL: My thoughts are that within 6 CASTNET there are some measurements, deposition 7 measurements for certain chemic al species and 8 compare whether those ratios ha ve been stable over 9 time as kind of an inference th at some of the 10 ratios -- 11 DR. SCHEFFE: There might be some things we 12 can do where we separate out, w e can build a dry 13 transference ratio and get it f rom that perspective 14 perhaps. There might be some c reative things. 15 DR. MITCHELL: That would be a nice way of 16 trying to link them together. You think that will 17 be a possible approach? 18 DR. SCHEFFE: We will cert ainly explore it. 19 We'll do what we can, yes. 20 DR. RUSSELL: Anything els e on this one? 21 Okay. Moving on, 10. 22 DR. KUMAR: Can we go backto the third 23 paragraph? I want Rich to expl ain that more 24 because I don't think we got tohear that, I guess, 25 whatever he said.

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1 MR. POIROT: Well, the bas ic idea was to just 2 suggest consideration of a modi fication to the TNOy 3 calculation that would be basedon nitric acid and 4 particle nitrate rather than NO y. And one of the 5 main reasons for suggesting tha t is that if it 6 worked out, then all the necess ary measurements to 7 implement the standard are bein g made by CASTNET, 8 methods now. So that was my re ason for suggesting 9 that they look into that. 10 DR. RUSSELL: I thought a second reason was 11 that their results showed there was a greater 12 correlation between. 13 MR. POIROT: That would be the second. 14 DR. HUBBELL: I would be c areful about putting 15 too much weight on that correla tion because it was, 16 again, based on 12-kilometer in dividual grid cell 17 comparisons rather than any kin d of aggregation. 18 It's not clear at all to me unt il we do some 19 further analysis whether that c orrelation would 20 still remain poor once you aggr egate the higher 21 level of resolution. 22 The other thing to remembe r is we did not look 23 at, another thing we want to do , is the correlation 24 in the changes in deposition an d the changes in 25 atmospheric concentrations bett er correlated. In

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1 other words, once you've change d NOx, for example, 2 are the changes that you get inconcentrations and 3 deposition more closely correla te, which is really 4 what we're interested in from acompliance stand 5 point. 6 So I don't want -- I just don't want to read 7 too much into that one figure t hat was kind of a 8 last minute figure that we put in. I just don't 9 want to draw too many conclusio ns off of that. 10 DR. RUSSELL: Rich, along those lines, can you 11 capture what Bryan just said as being something 12 that would be of interest to se e. I mean, because 13 that is actually what the -- 14 MR. POIROT: You mean add that? 15 DR. RUSSELL: Yeah, it's s omething that's -- I 16 think we want to capture also t he current analysis 17 suggestion that nitric acid cor relates better with 18 the model deposition, but we re cognize that there 19 are issues due to spatial scale s and how that might 20 relate to response of depositio n to emission 21 changes. And that should be in vestigated. 22 MR. POIROT: Okay. 23 DR. RUSSELL: Do you feel that way? I can see 24 that that's -- 25 MR. POIROT: My initial in tent was to suggest

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1 the approach for the reasons I said. At the back 2 end of this we don't have a mon itoring network in 3 place to implement it. We want that to be the 4 reason that this can't go forwa rd, possibly this 5 alternative approach would allo w that possibility. 6 I wanted to recommend without p ushing real hard. 7 DR. SCHEFFE: So, you know , the possible 8 implications of this over time if this plays out 9 would be that the indicator, th ere is a couple 10 things that could go on here, t he indicator could 11 change from NOy to let's say to tal nitrate, with 12 confidence in total nitrate mor e so than the 13 individual nitrate and particle nitrate. And I 14 just want to throw that out the re, that that's a 15 possible consequence. 16 I actually wanted a respon se from Karen about 17 that, because -- and I'm just w ondering about the 18 linkages back to Clean Air Act definition of NOx. 19 And I think nitrate is certainl y embedded in that 20 definition in the Clean Air Act of NOx, but it's 21 increasingly a smaller and smal ler part of what we 22 define as NOx in the Clean Air Act. Do you see any 23 issues with that offhand, or wo uld you like to 24 think about it? 25 MS. MARTIN: I think we ne ed to think about

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1 that. The issue though -- you' re raising an issue 2 about parameters to be used for the calculation of 3 determining an equation. You'r e not raising this 4 issue on the broader question o f how to define the 5 indicator of the standard itsel f, are you? 6 MR. POIROT: It's going tocome around to 7 that. However, let me try to -

- 8 MS. MARTIN: It has the po tential to over time 9 say, for example, in the next r eview. But were you 10 intending it now to carry over into this current 11 review discussion of the defini tion of indicator 12 itself? 13 MR. POIROT: I think the p ossible parallel 14 situation would be with the sec ondary PM standard 15 in which the recommended indica tor was PM light 16 extinction, something that can perfectly well be 17 measured with state-of-the-art devices, but which 18 we currently lack the network a nd the resources to 19 roll out this complete new PM l ight extinction 20 network of methylometers and et hylometers 21 everywhere. And, therefore, th e indicator is still 22 sort of PM light extinction, bu t it's estimates -- 23 it's a reconstructed estimate. So that's the kind 24 of -- I consider it more of a s ubtle change than a 25 name change and along the same lines as that.

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1 DR. HUBBELL: Again, to be clear on this, I 2 don't think you can just change the calculation 3 that goes into the transfer rat io and then apply 4 that to the total NOy. It's no t going to match. 5 So I think it actually would be -- if you change 6 that transference ratio, it wou ld then mean that 7 you would change the atmospheri c indicator; 8 otherwise, they wouldn't correl ate well. 9 MR. POIROT: Yes. And the n it would mean that 10 you could make all of the neces sary measurements 11 with the existing CASTNET metho ds. 12 DR. SCHEFFE: That's what I'm saying that it 13 comes down to then the indicato r then becomes total 14 nitrate. I want people to be a ware of that. I'm 15 not saying that's a bad thing o r a good thing. 16 DR. HUBBELL: It has broad er implications. 17 MS. MARTIN: Its important to understand the 18 implication of your comment. At the outset the 19 desire was to define the indica tor to be as 20 parsimoniously defined as possi ble and still 21 capture what's important. And the question then 22 becomes how far do you have to go in including 23 nitrogen components before you are complete enough 24 to capture what's important andstop before you 25 have gone beyond what's -- what 's really going to

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1 make a difference. 2 And so your comment here g ets at the very 3 heart of the thought process th at fed into defining 4 how to define NOy as -- for the purpose of being an 5 indicator for the standard. 6 DR. HUBBELL: I think, aga in, as Rich was 7 saying, it's a very big twist o f the way that we 8 have been considering -- you kn ow, we went from NOx 9 and defined fairly narrow NO2 t o thinking about 10 NOy, which is as complete as we can get, and now 11 we're moving to a completely di fferent component, 12 which, again, may be tied to th e deposition metric 13 of interest, but is it fully ca pturing all the 14 processes that we think are imp ortant to be able to 15 make sure that when we control NOx, we're actually 16 controlling the things that wou ld reduce 17 deposition. And that's why I t hink, again, some 18 additional analysis on our part , doing what you've 19 asked, some additional analysis to make sure that 20 that wouldn't have unintended c onsequences, borrow 21 Dale's phrase, but wouldn't hav e unintended 22 consequences would be a useful exercise. And those 23 things I laid out I would help to get at some of 24 that. 25 In other words, we can eva luate both our

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1 existing definitions of the tra nsfer ratios and 2 this alternative using similar metrics and that 3 would allow us to give some ide a what difference it 4 makes and whether or not it giv es an appropriate 5 response. 6 MR. POIROT: Works for me. 7 DR. WEATHERS: Another pos sibility, what Myron 8 was saying about CASTNET, in th at way if you look 9 at total nitrate and look at th e transference 10 ratios, we can compare the CAST NET deposition, 11 estimated deposition with CMAQ and that's one of 12 the things that we would also l ike to see. 13 DR. SCHEFFE: Right. That is certainly more 14 doable. Yes. 15 DR. RUSSELL: Anything els e? Okay. Next one. 16 DR. NUGENT: So we are goi ng to ask Rich to 17 add this additional text, is th at where we came 18 out? 19 DR. RUSSELL: I think so. Rich? Are you 20 ready to add a little text to s ort of summarize the 21 discussions we just had or do y ou think it needs to 22 be made in terms of -- 23 MR. POIROT: Yes. And I t hink the main thing 24 we would like to add would be t o evaluate whether 25 this alternative TNOy would act ually project into

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1 the future, what you were sayin g before. 2 DR. HUBBELL: There are th ree things that have 3 come up. One is doing the CAST NET assessment, 4 working back with that, say doe s using this measure 5 allow us to get a better handle on the comparison 6 observed with our model transfe rence ratios and see 7 how stable those are over time. That's one. 8 Second was looking at the spatial extent of 9 averaging and whether that affe cts the stability of 10 the ratios. And then the thirdwas to look at the 11 changes in NOx and whether the correlation between 12 NOy and the total deposition an d nitrate -- total 13 nitrate and total deposition wh ether those 14 correlations change when you lo ok at the changes in 15 NOx and the changes in concentr ations and 16 deposition. Because, again, th ose are -- that's 17 sort of an important metric for thinking about how 18 good the standard is going to b e is when you change 19 NOx does that result in corresp onding changes in 20 the indicator and the depositio n metric. 21 MR. POIROT: I'm clear on all of those except 22 the spatial extent text. 23 DR. HUBBELL: That one is -- one of the pieces 24 you used was to say the correla tion between NOy and 25 deposition based on that one fi gure we provided

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1 seemed very poor, but it was at the 12-kilometer 2 resolution individual grid cell s. I'm suggesting 3 we also look at broader spatial aggregations to see 4 if the correlation improves as you get to the 5 higher level of spatial aggrega tion. 6 And because spatial concen trations of NOy tend 7 to be, you know, smoother and d eposition tends to 8 be more point specific, so once you average them 9 out they may improve the correl ations. 10 MR. POIROT: So what we're really looking to 11 is to see if this holds up over different scales of 12 space and time? 13 DR. HUBBELL: That's right . 14 MR. POIROT: Okay. Got it . 15 DR. RUSSELL: Ten should b e quick. That is 16 Naresh. 17 DR. KUMAR: Yes. If there is a prize for the 18 shortest answer, I guess this s hould be it. 19 DR. RUSSELL: Yes, shortes t answer. Thank 20 you. 21 It is now 10:30. Why don' t we take a quick 22 break, no more than ten minutes if possible because 23 we really want to be out of her e. We have a number 24 of people who are leaving at no on. 25 (Brief recess.)

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1 DR. DRISCOLL: This sectio n dealt with the 2 appropriate ANC levels. My fee ling was we were 3 considering zero, 20, 50, 100, and based on aquatic 4 effects literature, these are c onsistent clauses 5 that have been established prev iously. And then I 6 went on to indicate that the va lues of -- there are 7 clear effects at zero and there are fairly clear 8 effects at 20, plus the impacts of episodic 9 acidification on 20. So probab ly target values of 10 somewhere between 50 and 100 ar e in the range and 11 appropriate for this, so the fi rst paragraph. 12 The second paragraph essen tially added by 13 Dale, who is not here, so I didnot really -- I 14 only did minor edits on that, b ut I was thinking 15 that really deals with soil aci dification rather 16 than aquatic ANC. And it wouldbe good to get 17 Dale's input, but I wonder if i t would be better 18 moved to the co-protection ques tion 13 because it 19 deals with issues of soil acidi fication and impacts 20 on water systems. 21 DR. RUSSELL: I would thin k so because this 22 question is pretty specific to ANC. 23 DR. DRISCOLL: Yeah, I wou ld think so. But 24 anyway that was his paragraph a nd I would recommend 25 that we move it and try to inco rporate it in

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1 question 13. 2 DR. RUSSELL: Sounds good. Actually, as 3 people are coming back in, it m ay have been subtle, 4 but what Charlie just said is o ne of those things 5 that's fairly important for us to understand right 6 now. In that what he is sayingis that the 7 appropriate range would not inc lude 20. Naresh. 8 DR. KUMAR: As I read that Chapter 5, I think 9 it explained as we go to higher levels uncertainty 10 increases quite a lot and this paragraph does not 11 reflect that. So at 50 there i s uncertainty. At 12 100 is a lot more uncertainty. We are trying to 13 work on a range of 70, 20 to 50 which actually has 14 less uncertainty based on the i nformation provided. 15 DR. DRISCOLL: Yeah, I tri ed to capture that, 16 but maybe I wasn't very explici t. So I said 17 something -- but I think we hav e to add in 18 something to that effect. 19 So maybe -- I say somethin g about that the 20 target ANC is an artificial val ue that there are, 21 you know, at ANC values above t hat. There could be 22 effects at ANC values below tha t. There will be 23 some organisms that are highly insensitive and 24 won't be impacted. So maybe wh at we could say 25 after that, so that would be th e one, two, three,

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1 four, five, six, seventh line w here the sentence 2 that ends "low end of this rang e," maybe we could 3 say something like the effects of acidic deposition 4 on aquatic organisms are quite certain. 5 DR. NUGENT: Just so I cantake notes on what 6 you're saying, help me again, I 'm embarrassed to 7 say, I am in question -- full d isclosure -- I am on 8 question 12. 9 DR. DRISCOLL: First parag raph about two 10 thirds of the way down, there i s a sentence that 11 ends "low end of this range." Maybe I'm looking at 12 some words -- yeah, so on the l eft-hand side, "low 13 end of this range," period, rig ht there. 14 So maybe we could say some thing like effects 15 of acidification on aquatic bio ta are fairly 16 certain at the low end of this range of ANC and 17 decrease in certainty with incr eases in ANC up to 18 100 microequivalents per liter, something like 19 that. Would that capture what you're trying to 20 say, Naresh? 21 DR. KUMAR: I think going back to the question 22 on page 583, they say that belo w 20 uncertainty is 23 much lower. As you go between 20 and 50, 24 uncertainty goes up, and 50 and100 uncertainty is 25 much more. So I'm uncomfortabl e just removing the

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1 20 to 50 range and going with 1 00 range because of 2 that. 3 DR. AMAR: One question, N aresh, uncertainty 4 about what? 5 DR. KUMAR: The effects. There are adverse 6 effects, but they are a lot mor e uncertain. 7 DR. AMAR: You want to saythat again? We 8 have used the term here. 9 DR. KUMAR: What I'm sayin g is because there 10 is so much uncertainty, why hav e we eliminated the 11 20 to 50 range? That's what we 're suggesting in 12 the last sentence. 13 DR. RUSSELL: It's the las t sentence. That's 14 the -- that's the bullet right there. Keep going, 15 Charlie. 16 DR. DRISCOLL: So I guess where I wanted to 17 better understand where you're coming from, so the 18 way I understand there were tar get values that were 19 set. I mean, they're sort of r ound numbers, you 20 know, zero, 20, 50, 100. Now, are you saying that 21 that should be opened up and ma ybe you could 22 consider alternative values lik e 30 or 40 or 23 something like that that's betw een 20 and 50 range? 24 DR. KUMAR: What I'm sayin g is that they 25 suggest that there are adverse effects at different

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1 levels and below 20 there is le ss uncertainty on 2 adverse effects. As you go at higher ANC between 3 20 and 50, there is more uncert ainty; above 50 4 uncertainty is a lot more. 5 And based on that informat ion, I don't see a 6 reason that why should we elimi nate the 20 to 50 7 range when you say in the last sentence that it 8 varies 50 to 100 when that's th e range where we 9 have the highest uncertainty onadverse effects. 10 DR. DRISCOLL: Okay. 11 DR. KUMAR: I would leave it open, whether 12 it's 20 to 50 or 50 to 100 it's not very clear, 13 first of all, but I see no reas on -- 14 DR. RUSSELL: It sounds li ke it's between 20 15 and 100. Chris. 16 DR. FREY: I'm a little co nfused about the use 17 of uncertainty when you go froma low to higher 18 number. Is it not the case tha t the higher number 19 is more protective? So I thinkthe uncertainty has 20 to do with the incremental prot ection from going 21 from one number to the next. S o in some sense 100 22 is far more certain to provide protection than 20, 23 but compared to 20 the marginal benefit of 100 may 24 be uncertain. I think -- is th at a correct 25 interpretation?

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1 DR. KUMAR: Yeah. I mean, I guess of course 2 if it's 100, we are sure we're providing 3 protection, but the question re mains for the 4 Administrator is does she want to provide a 5 requisite level of protection o r widely 6 overprotected. That's a very c lear distinction. 7 And I don't see why we should t ell that eliminate 8 20 to 50 when we know that that 's more certain, I 9 guess the adverse effect occurr ing in that range. 10 DR. HUBBELL: Can I ask on e clarification on a 11 particular word in this paragra ph? In the fourth 12 line it says, "So any specific target ANC is an 13 artificial value." And we're t rying to figure out 14 how do we interpret that? I th ink what you're 15 saying is that you can't -- 16 DR. DRISCOLL: Arbitrary. It should be 17 arbitrary. This was late at ni ght I wrote this. 18 DR. HUBBELL: What you're really saying it's 19 the ranges rather than pick 33 or 45 or whatever 20 else, any particular one of tho se numbers is a bit 21 arbitrary within that; is that correct? 22 DR. DRISCOLL: Yeah. Just a round number. 23 MS. CHESTNUT: Can we go b ack to the sentence, 24 Angela, that you inserted effec ts? Can we say, 25 "Adverse effects are fairly cer tain at the low end

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1 of the range," and uncertainty -- what Chris said 2 is better wording I think. The incremental 3 benefits of moving to higher AN C are more 4 uncertain -- become more uncert ain at higher ANC 5 levels. 6 DR. FREY: Maybe another w ay of saying is that 7 at 20 or 50 there is a high deg ree of confidence 8 that that provides some level o f protection. As 9 you go to 100 there is maybe le ss confidence that 10 that provides substantially mor e protection. 11 MS. CHESTNUT: Additional protection. But 12 that concept of that incrementa l -- incremental 13 protection of going higher. 14 DR. FREY: How did that ha ppen? 15 DR. RUSSELL: Magically. So we still are left 16 with the 50 to 100 recommendati on. And I would 17 actually add, you know, one of the things that I 18 would also think we need to con sider is the 19 uncertainties inherent in this process, not just 20 the protection that each of the se levels provides, 21 but also the whole process. Somaybe that is all 22 captured in percent of lakes pr otected or some 23 other portion of what a standar d might be. 24 DR. HUBBELL: And just to interject one 25 moment, that was the intended d ifference between

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1 justifying the target ANC and j ustifying what your 2 AAPI level itself would be was to capture the 3 process uncertainties. 4 This was really -- the tar get ANC was supposed 5 to be focused on what is the sc ientific support and 6 the information on adversity re lated specifically 7 to if you could get with certai nty those target ANC 8 levels, which ones would you goafter. 9 DR. DRISCOLL: So I guess getting back to 10 Naresh's question or comment, I think there are 11 pretty clear effects at 20. I think you can 12 document it in the scientific l iterature. I also 13 think that there are water at o r near 20 is highly 14 susceptible to episodic acidifi cation and could 15 have results from that as well. 16 So, you know, I understandwhere you're coming 17 from, but when I tried to write this, I was looking 18 at these specific values that a ppear to be advanced 19 in the report and I was using t hose as draft target 20 levels. So that's why I focuse d on zero, 20, 50, 21 100, round numbers. If we want to open that up 22 further and consider the full r ange of values, you 23 know, 37 or 62 or things like t hat, we could -- we 24 could do that. 25 So that's why I focus -- I think there is a

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1 lot of scientific evidence to s uggest that 20 would 2 not be suitable, so that I went to the next one, 3 50, between 50 and 100. If we want to open it up, 4 we can modify the whole thing t o accommodate that 5 and then argue about the advant ages or 6 disadvantages of, you know, 27 versus 42 or 7 something like that. 8 DR. KUMAR: I'm not sugges ting that. As I 9 said, this is not my area of ex pertise, but I was 10 just going on what is in the do cument. It said 11 below 20 there are impacts whic h are certain. 12 Between 20 and 50 you could hav e impacts, but 13 they're uncertain. 14 So that's the reason that the lower end of the 15 range is 20 because below 20 th ere are impacts 16 which are more certain. So I d on't see any reason 17 why we're taking that 20 to 50 out just because 18 you're saying at 20 there are i mpacts, maybe we 19 should stop at 21 to 50 rather than eliminate the 20 whole range. 21 DR. DRISCOLL: Well, from my reading of the 22 literature I think that there a re pretty clear 23 effects between 20 and 50. AndI think where we 24 have seen recovery, we've seen significant 25 biological recovery in terms of improvements in

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1 species' richness in lakes in t he pH range between 2 20 and 50. 3 DR. AMAR: I was going to ask you, I thought 4 we had that graph, 20 to 50 the re is an -- the ANC 5 where it says fish species and then after 50 it 6 kind of stabilizes. 7 DR. DRISCOLL: After 100. 8 DR. AMAR: After 100, okay , but there is that 9 transition. There is uncertain ty that certain fish 10 could disappear. We saw that c hart, the famous 11 graph. So it stabilizes, so tospeak, on the other 12 side of 100? 13 DR. DRISCOLL: Yes, it rea ches an ASM tote 14 around 100. 15 DR. AMAR: How do we demon strate that here? 16 That's the most relevant data. 17 DR. DRISCOLL: That's what I was trying to do. 18 DR. KUMAR: Maybe we shoul d ask EPA for more 19 clarification on why they said that there is more 20 uncertainty. You're saying it' s less certain, page 21 584, Figure 5-27. 22 DR. DRISCOLL: I agree wit h you 100 percent, 23 that there's are more certaintythat there are 24 effects at 20 than there are at 50. The lower you 25 go, the more clearcut the effec ts are.

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1 DR. KUMAR: That's why I'msaying why are you 2 taking that policy decision her e that let's 3 eliminate 20 to 50 from the con centration and leave 4 that 20 to 100 range for the Administrator to 5 decide based on all the informa tion that is there. 6 DR. DRISCOLL: Okay. Well , where I'm coming 7 from is it seems to me that the difficulty that the 8 committee has with the document is that things at 9 this point are fairly poorly co nstrained. And so 10 if you -- if you tighten up the target range, then 11 you can come up with recommende d percentage values 12 in the lakes, you know, for peo ple to understand. 13 So all these assumptions o r all these decision 14 points are sort of interconnect ed at the end of the 15 day. But if the group thinks i t's better within 20 16 to 100, I'm fine, I'll go alongwith whatever the 17 consensus approved is. 18 DR. RUSSELL: So putting i t to the group -- 19 first, any other comments or di scussions? So 20 putting it to the group, how ma ny people would put 21 the bottom line, bottom end at 20 in terms of what 22 should be considered? Naresh w ill probably go 23 along with that one. 24 MS. CHESTNUT: I mean, I j ust I don't know. 25 It's not -- I have to listen towhat the ecologists

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1 are saying about it. 2 DR. RUSSELL: Yeah. It ma y come back, you 3 know, sort of separating this f rom the AAPI. 4 Actually, I think there is pret ty demonstrated 5 impacts or -- that there are impacts when you go 6 between 50 and 20. That's well demonstrated. As 7 long as we can divorce ourselve s totally from the 8 AAPI in terms of doing this I t hink 50 to 100 does 9 make sense. 10 So with that in mind, you know, I can go 50 as 11 being one of the ranges below w hich we are pretty 12 sure we see negative impacts, n egative 13 consequences. 14 DR. KUMAR: Are you disreg arding the 15 information in the document the n? 16 DR. RUSSELL: No. I mean, what? 17 DR. KUMAR: That there is a lot of uncertainty 18 on those effects between 20 and50? 19 DR. RUSSELL: They also de monstrate real -- a 20 significant amount of certaintyin a number of 21 aquatic ecosystems, that they a re seeing effects. 22 DR. KUMAR: If you look at the overwhelming 23 evidence presented in the document, I don't see 24 that. So I guess I need to be convinced where in 25 the document do you see that?

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1 DR. RUSSELL: I mean, I goback to the figure 2 that shows the fish diversity. 3 DR. KUMAR: And if you loo k at the figure that 4 shows relations of pH and ANC a nd then you look at 5 the figure that shows the effec t of pH, it's pretty 6 clear below five and a half or maybe six of pH you 7 do see effect. About six pH yo u don't see any 8 effects. And then if you go ba ck in relation to 9 the pH and ANC at six -- where did it go -- some 10 evidence 20 and 50. 11 DR. RUSSELL: Praveen, whe re is the figure of 12 pH and ANC fish diversity? 13 DR. AMAR: I clarified tha t too. A big curve 14 in fish. 15 DR. RUSSELL: Where is it? 16 DR. AMAR: One of those fi gures I don't have 17 in memory. 18 MS. WEGMAN: It's on 581. 19 DR. AMAR: Thank you. 20 MS. CHESTNUT: There is on e on pH, Naresh. 21 DR. KUMAR: Yes. 22 MS. CHESTNUT: Did you saywhat page this is 23 on, which page? 24 DR. KUMAR: 577 is a relat ionship between pH 25 and a number of species and 571 is a relationship

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1 between pH and ANC. And then t he figure that 2 Praveen is looking to is 581. And 583 brings all 3 that together. And the second paragraph of 583 4 talks about the range of 20 and50 and says how 5 uncertain those effects are. 6 So either we disagree withthat information 7 and say maybe 50 to 100 is the more appropriate 8 range. I don't see any disagre ements being 9 proposed here with the informat ion on page 583. 10 DR. AMAR: I think what Ch ris said earlier 11 that's why I was asking the que stion uncertainty of 12 effects, but also if you're try ing to have a 13 standard, there is also a quest ion of certainty of 14 protection you need. When I lo ok at that curve on 15 527, Figure 527, it's like on t he other side of 100 16 you're kind of on the safe side so to speak. It's 17 almost like precautionary princ iple. I mean, 18 that's what I'm thinking that y ou want to be on 19 that side. 20 DR. KUMAR: That's what I' m saying for the 21 welfare standard the language s ays that it has to 22 be -- I don't know what the exa ct language is, but 23 requisite protection and you do n't want to overly 24 protect. So that I think lies with the 25 Administrator not with us, sayi ng that we should be

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1 overly protective. I don't thi nk this committee 2 has to make that decision. 3 DR. AMAR: Whatever the ro le is, whatever the 4 Administrator's role is, but I think we're 5 providing input. 6 DR. KUMAR: I don't know i f this committee 7 needs to do that. If it does, then you can go 8 ahead. Of course, I would disa gree with that, with 9 that kind of decision of the co mmittee. I don't 10 think EPA can tell us that's wh at they're looking 11 for from this committee or not. 12 DR. RUSSELL: Chris. 13 DR. FREY: I think, as youpoint out, it's 14 ultimately the Administrator's decision and the 15 Administrator's judgment about what is -- whatever 16 the language is that it's requi site, but not 17 overprotective. And I think it 's typical for CASAC 18 to offer ranges from which the Administrator can 19 make that choice. And the Admi nistrator very well 20 could choose the lowest value o f the range or the 21 higher end based on her judgmen t. 22 I guess, you know, I thinkwe probably do our 23 job if we give the Administrato r a range that's 24 inclusive of something -- I gue ss that we're highly 25 confident that the range enclos es something that is

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1 neither under or overprotective . That doesn't 2 necessarily mean the end points of the range would 3 meet that criteria, but it's re ally up to the 4 Administrator. 5 DR. RUSSELL: Rich. 6 MR. POIROT: Sort of a dev il's advocate for a 7 minute. It seems like a lot of the document has 8 focused itself on 20 to 50. Th at's the range. And 9 I think for starters we should be saying 20 to 100 10 is a more appropriate range and50 to 100 would 11 provide substantial or greater protection. 12 I think to me 20 to 50 is getting kind of 13 narrow, especially in the conte xt of we've got this 14 other metric that's kind of completely arbitrary. 15 And it may be somewhat unnecess arily limiting, you 16 know, how the whole thing plays out. And there was 17 Lauri's point yesterday of this might not be the 18 time to go in for the most stri ngent possible 19 standard. 20 So I guess I would like toconsider 20 to 100 21 with the recommendation of 50 t o 100 is clearly 22 more protective, something alon g those lines. 23 DR. RUSSELL: I like that and it actually goes 24 well with their table on 2-A is that between 20 and 25 50 they view it as having eleva ted concern, but

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1 essentially, capturing your wor ds, that going from 2 20 to 100, it's apparent that b etween 50 and 100 3 there is more -- how did you pu t it? 4 MR. POIROT: Protection. 5 DR. FREY: Additional prot ection. We don't 6 know if it's significant. 7 DR. RUSSELL: There would be additional 8 protection. 9 DR. NUGENT: Chris just pr ovided the language 10 that's shaded above. 11 DR. RUSSELL: So then "rec ognizing" comma. 12 DR. NUGENT: Start a new p aragraph. 13 DR. RUSSELL: No. "AAPI" comma, "recognizing 14 there is additional protection. " 15 DR. COWLING: In the conte xt of Chris's remark 16 it's up to the Administrator ul timately. This is 17 partly what I was thinking abou t when I made the 18 recommendation yesterday to loo k at this figure on 19 page 571, this sigmoid curve, t hat shows that the 20 relationship between ANC and pH ; and I suggested 21 that we add that form of a curv e. 22 At least if I were sittingdown with Lisa 23 Jackson and trying to help her think this through, 24 I would want to have that figur e maybe developed in 25 a different way with different parameters,

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1 different end points for certai n species and that 2 sort of thing, but I believe th at is a very, very 3 instructive graph. And it's re ally relating to 4 what ultimately Lisa Jackson is going to have to 5 make up her mind about these th ings. 6 So, anyway, I make this su ggestion again to 7 look at that kind of a graph, h ow to make it more 8 useful than just pH and ANC. T hose are my 9 thoughts. 10 DR. RUSSELL: Chris. 11 DR. FREY: Just to play de vil's advocate, so 12 most of this paragraph talks ab out ANC and then 13 makes a conclusion in this last sentence now about 14 values for AAPI. Does -- is th at -- that implies 15 that there is a one-to-one corr espondence between 16 the two and that -- 17 DR. RUSSELL: AAPI should not be there. 18 DR. FREY: Okay. But thenthis issue comes up 19 later anyway. So the question is: Is AAPI 20 unbiased -- does it have an unb iased relationship 21 with ANC; and if there is some bias, is there a 22 need to do a bias correction? Maybe we save that 23 for another charge question. 24 DR. RUSSELL: What I'd lik e to do now actually 25 looking at the time, how many p eople have to take

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1 off at noon? So we're losing asignificant 2 fraction. So if you look at yo ur watches, we may 3 have to have a follow-up phone call on this one. 4 And so with that, it should be 20, let's say 5 protection at 50 to 100. 6 DR. KUMAR: I recall direc tly from the 7 document says, "However, uncert ainty regarding the 8 additional protection at much l arger target ANC 9 levels above 50." 10 DR. RUSSELL: I'm not sure , how do people feel 11 with that? 12 DR. BYTNEROWICZ: For me i t helps me. 13 DR. RUSSELL: I think actu ally that's captured 14 up above. It says it's capture d in 50 15 microequivalents per liter, suc h as 50 to 100, 16 would provide additional protec tion but with less 17 confidence. 18 DR. KUMAR: Yeah, I think in the end we're 19 bringing it all together, kind of making it biased 20 towards 50 to 100. I think sta ting that, however, 21 uncertainties are much larger. 22 DR. RUSSELL: Again, I don 't want to 23 restate -- maybe we can lose wh at's above. 24 Essentially we're stating exact ly what's above. I 25 don't want to do that. Either we have it there,

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1 one place or another. 2 DR. AMAR: We already ment ioned it talking 3 about less confidence. 4 MS. CHESTNUT: It says it up top. 5 DR. KUMAR: Even up above it says that was 6 higher than 50, 50 to 100 wouldprovide additional 7 protection. Why are we repeati ng that here anyway? 8 DR. FREY: This may be get ting into 9 wordsmithing given the time -- you could rewrite 10 that paragraph to take that mid dle part out as a 11 separate paragraph so it's more evident in the 12 charge question. 13 DR. RUSSELL: Given that w e're going to 14 have -- it appears we're going to have a follow-on 15 call, we have to move on. Leav e it like that. 16 Who is in charge of that question again? 17 DR. NUGENT: This paragrap h moves down to the 18 co-benefits. 19 DR. RUSSELL: Then moves d own to the 20 co-benefits. 21 DR. DRISCOLL: So now that Dale is back, do we 22 want to address the issue of th e second paragraph? 23 DR. RUSSELL: Dale, we wou ld think we would 24 move that second paragraph to t he co-benefits 25 because it doesn't deal directl y with ANC.

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1 DR. DRISCOLL: For terrest rial acidification, 2 it's more relevant to that. 3 DR. JOHNSON: Sure. 4 DR. DRISCOLL: You want todo 11-A. This is I 5 think a linked question to 11. It is talking about 6 adversity concerns. And I thin k the gist is that 7 it's, you know, consistent withthe literature on 8 the associated effects. I put in a couple 9 sentences reflecting what I sai d yesterday that 10 these relationships are based o n spatial 11 relationships and it's not clea r that temporal 12 response will follow these spat ial relationships. 13 So some caveats should be givenin the text that 14 these are based on spatial rela tionships. And the 15 assumption is that the temporal response will 16 follow these spatially derived relationships. 17 DR. RUSSELL: Comments? T hank you. Moving 18 on. 19 DR. DRISCOLL: I've got 12 as well. I had 20 difficulty with 12 because 12 p ertains to target 21 percentage of water bodies. Sogive all these 22 items that were in play yesterd ay in terms of 23 filtering lakes and target ANCs , it's hard to -- 24 it's hard to make recommendatio ns for target 25 percentages based on informatio n I have available.

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1 I think the concept is good andappropriate, but 2 what should be a specific targe t percentage of 3 lakes it's not clear what the a ppropriate value 4 would be without having additio nal information. 5 Hopefully if these can be constrained a little 6 bit, we can get some informatio n on, you know, what 7 are the values of ANCs within t hese various 8 subregions and what might appro priate target 9 percentages be. 10 DR. RUSSELL: Okay. Actua lly, what I would 11 say, you know, it's somewhat st range. It would be 12 say regardless, target percenta ges in the range of 13 95 to 80 percent might be appro priate for the AAPI. 14 However, it is difficult to sug gest target 15 percentages. I would actually say not that 16 sentence there. I don't think we're ready to say 17 that. 18 DR. DRISCOLL: You're righ t. And also early 19 on because of the text I had pr ovided Andre the 20 filtering criteria, if we're go ing to get rid of 21 that, we should remove that fro m the paragraph as 22 well, the second sentence, seco nd and third 23 sentence. 24 DR. RUSSELL: That one rig ht there? 25 DR. DRISCOLL: And third s entence. Because

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1 that's sort of gone away now. 2 DR. RUSSELL: Yeah. 3 DR. HUBBELL: I was wonder ing if I could ask 4 one thing, because it would be helpful to us, 5 obviously, there was some discu ssion yesterday that 6 perhaps there were some at leas t reasonable things 7 not to consider, like 50 percen t might be too low. 8 If you can help us bound it at all, that would be 9 very helpful. Even if you can' t give us a specific 10 range on the upper part, tellin g us that, you know, 11 protecting 20 percent of the wa terbodies is not 12 acceptable, that would be fine. So just something 13 to help us narrow our range bas ed on what you 14 consider to be reasonable, you know, definitions of 15 adverse. If you can't, that's fine. I just 16 thought I'd put a pitch in. 17 DR. RUSSELL: What say the panel? My goal was 18 50 percent as a bottom end. At the bottom end 19 given what we currently know an d what we know about 20 ecoregions and everything else, it's very hard to 21 say what it should be, but I wo uld say 50 percent. 22 MS. CHESTNUT: Isn't it al ready better than 23 that in sensitive areas? We ta lked about that a 24 little bit yesterday. 25 DR. RUSSELL: I don't thin k so. Actually, I

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1 thought one of the graphs you s howed suggests that 2 it's not. 3 DR. HUBBELL: We were sayi ng, for example, in 4 the Adirondacks right now 30 pe rcent or so of lakes 5 are adversely impacted given cu rrent -- given 6 current deposition levels. 7 DR. LYNCH: Fifty. 8 DR. HUBBELL: An ANC of 50 . So if you chose 9 50, an ANC of 50, you really wo uldn't do much in 10 the Adirondacks. 11 MS. CHESTNUT: It implies that current effects 12 are not adverse based on the am ount of -- there is 13 some internal consistency here. 14 DR. HUBBELL: And actuallyif you don't feel 15 comfortable giving a percentage , if you actually 16 said that that there ought to b e internal 17 consistency or there ought to b e -- you ought to 18 try to provide at least more pr otection than exists 19 under current conditions, that could be helpful 20 too. 21 DR. RUSSELL: Yeah, I just don't think we know 22 enough how it works to be very specific. 23 DR. NUGENT: Do you want t o add that sentence 24 about internal consistency? 25 DR. RUSSELL: Charlie, didyou or someone over

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1 there sort of rephrase it or se nd it? 2 DR. DRISCOLL: I can't sen d it because I don't 3 have access to the Internet unl ess you want me to 4 do it on a pin drive. We couldsay something like 5 the PA should try to strive for internal 6 consistency. Does that capture , you know, in terms 7 of these target percentage? 8 DR. HUBBELL: Internal con sistency with what? 9 DR. DRISCOLL: I'm just tr ying to rephrase 10 what you had said previously. 11 MS. CHESTNUT: I'll try. 12 DR. HUBBELL: Good. 13 MS. CHESTNUT: That the ta rget should be a 14 higher percentage than is curre ntly adversely 15 affected in sensitive areas. I don't know if we 16 want to get that specific. 17 DR. RUSSELL: The questionwould become why? 18 MS. CHESTNUT: If the judgment is that effects 19 at current deposition levels ar e adverse, then 20 it's -- then addressing that wo uld imply a target 21 that improves it from where we are now. 22 DR. RUSSELL: Okay. But w e're not sure what 23 that would be. 24 MS. CHESTNUT: Right. So don't put numbers on 25 it.

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1 DR. HUBBELL: If I might b ring up an example 2 and Karen will probably -- okay , Karen says to 3 leave it alone. So I will leav e it alone. 4 DR. RUSSELL: But we're no t sure where that 5 would be. 6 DR. DRISCOLL: If it's hel pful, I can't do it 7 now, but when I get back, I cancalculate the 8 target populations that are bel ow 100, 50, 20 and 9 zero for the Adirondacks. That probably is the 10 most impacted area. And that w ill give people a 11 feel for what the percentages a re on these various 12 classes and we can sort of go f rom there when we 13 have the call. 14 DR. RUSSELL: What I'm thi nking, again, is 15 stating again affecting sensiti ve areas, but, 16 again, without further informat ion, we cannot 17 provide specific percentage or specificity. 18 DR. NUGENT: Doesn't the p revious sentence say 19 that? 20 DR. RUSSELL: It does, tha nk you much. 21 Thirteen, Lauri. 22 MS. CHESTNUT: This is the co-protection 23 chapter. The first paragraph i s just a positive, 24 this is a good addition to the -- this is a good 25 addition to the Policy Assessme nt.

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1 The second paragraph is sa y a little bit more 2 about to what extent the terres trial systems are 3 co-located with the sensitive a quatic systems. So 4 to get a sense of the magnitude of the 5 co-protection. 6 I think the third paragrap h we can strike as 7 too much detail here. And thenwhat's currently 8 the fourth paragraph is a sugge stion that some 9 broader context be communicatedby at least listing 10 other types of co-benefits and disbenefits -- I 11 don't know if that's the right term from the -- to 12 recognize that changing NOx andSOx concentrations 13 has a whole chain of effects. But I think a list 14 here is sufficient just to ackn owledge there is 15 this broader connection betweenthese pollutants 16 and a lot of other things both positive and 17 negative. 18 And then there was a sugge stion to move Dale's 19 paragraph about the soils to th is. It doesn't 20 exactly fit with what they did, but perhaps it can 21 go here. 22 DR. JOHNSON: Whatever youwant. 23 DR. RUSSELL: Questions, c omments? Fourteen? 24 Rudy. Oh, we do have stuff fro m you now. 25 DR. HUSAR: The overall summary of the 14 and

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1 15 I put up in three bullets th ere. There has 2 been -- the contributions have been rising from 3 Mitchell, Frey and Kumar. 4 So these big points are in troduced in the 5 uncertainties section a summaryand description of 6 the general framework by which the uncertainty 7 analysis is performed, recogniz ing there are 8 multiple kinds of frame works. And then extend the 9 uncertainty beyond the componen ts of -- to the 10 propagation of the uncertaintie s to the entire 11 AAPI. 12 And then there is this pie ce that includes 13 constraints on the observations , this is a short 14 version. And then the panel re commends 15 aggressively pursuing the reduc tion of biases in 16 the CMAQ model particularly for parameters that are 17 relevant to the AAPI. So the r est is pretty much 18 elaboration on these three poin ts. 19 Now, I can go through that , but I would like 20 to bring to your attention in t he committee letter 21 that is already drafted out her e, Chapter 5, 22 conceptual framework and the un certainty chapter 23 has been singled out as particu larly relevant 24 feedback to the agency. So I w ould hope that you 25 all can make additional fixing and contributions to

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1 what these are. 2 So now under specifics, th e first paragraph 3 indicates that the emphasis on the complete 4 sensitivity analysis, not just on the pieces. This 5 is Kumar. While there are sign ificant in 6 everywhere, constraints exist. Observations exist 7 and those need to be combined w ith the uncertainty 8 analysis in some way. 9 The next paragraph is that of the improvements 10 of the CMAQ itself particularlyon the components 11 that are viable, including expl icitly considering, 12 of course, significant systemat ic biases that occur 13 in the CMAQ. Also, in that con text also there is a 14 suggestion to include other dat aset beyond CASTNET 15 in order to perform the validat ions -- or actually 16 improvement of CMAQ. 17 Then there is a question r egarding these 18 transfer -- transference ratios . The only comment 19 there is, and this could be sho rtened, and that is 20 that this section is not clear. Obviously, it is 21 not coming through as to what i s the nature of the 22 variability of the transference ratios. So it's 23 more of a request for clarifica tion. 24 The last section on the el asticities is the 25 most welcome, but -- and then o n the sensitivity

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1 analysis, it is recommended tha t one should have 2 experiments of sensitivity anal ysis way beyond the 3 one percent level, in other wor ds, into the 4 possible known segment of the o verall relationship. 5 And then Myron suggested t hat there should 6 definitely at the tail end ther e should be a 7 summary that clearly identifies the uncertainties 8 associated with the individual components and their 9 relative importance to the AAPI . 10 DR. RUSSELL: Thank you. Kathy. 11 DR. WEATHERS: I think to the extent that we 12 examine the critical needs list that you've been 13 completing that this section an d others need to be 14 consistent with that. 15 So there are all kinds of suggestions in here 16 that I think you talked about a nd are really good. 17 But if I were EPA looking at th is, I would 18 recognize that this could be an other four years. 19 And so I'm hoping that we're go ing to talk about 20 the critical needs list and pri oritize and that, 21 again, we can make consistent o ur recommendations 22 with that list. 23 DR. RUSSELL: And so I -- did you pick up 24 what, Rudy, in terms of how thi s might be modified? 25 Really need to tone down what c an be done.

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1 DR. HUSAR: Yes. I think of examining the 2 entire document and see what ar e the different 3 recommendations everywhere suchthat those could be 4 reconciled. What are here, the recommendations 5 that are here has to be consist ent with everywhere 6 else, but maybe there may be a recommendation here 7 that might influence something outside. 8 DR. RUSSELL: And so actua lly just looking at 9 the time and recognizing we're about to lose pretty 10 much half of the panel what I'dlike to do is jump 11 to the letter. Because I thinkthat actually -- 12 actually, no, let's jump to 24- D and then from 13 there jump to the letter. Reco gnizing that we 14 pretty much are going to have t o have another phone 15 call on this. 16 DR. WEATHERS: 24-D is whe re we don't have 17 that list, where there is the p laceholder for that 18 list. You continue it. 19 So 24-A through C the resp onses are fairly 20 straightforward. Ellis has off ered some edits 21 which I can pass on, but it's 2 4-D that has the 22 guts of how to deal with the un certainties in the 23 AAPI and may be the place in wh ich our prioritizing 24 list shows up. 25 DR. RUSSELL: But also thi s is where we start

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1 talking about wrapping up some of the things that 2 we've said before. 3 DR. WEATHERS: Right. 4 DR. RUSSELL: But it's rea lly the third 5 bullet, consideration of releva nt uncertainties in 6 the AAPI components. 7 DR. WEATHERS: Can you go down a little bit? 8 DR. RUSSELL: This is I th ink a critical 9 response is that how would some one respond to the 10 current uncertainties and under standing of what 11 goes into all the elements of t he AAPI? So if 12 people want to read that. 13 DR. WEATHERS: I note espe cially the brackets 14 that begin. Does not currentlyhave the list that 15 we've been talking about, the b ig picture. 16 DR. RUSSELL: Okay. Chris . 17 DR. FREY: I just want to point out that in 18 response to charge question 21, the paragraph that 19 I drafted seems to perhaps alsofit with this topic 20 and maybe they need to be combi ned or just stated 21 in one place. 22 DR. RUSSELL: Okay. You'v e read that now. I 23 think I actually will go on to the letter just -- I 24 think it's important before we lose many people 25 that we actually really get int o that letter.

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1 So if you pull it out what I'd like to do is 2 give you about five minutes to read it and then we 3 can go through it paragraph by paragraph. 4 DR. WEATHERS: I suggest, given the time, that 5 maybe we talk about the gist of each paragraph 6 rather than going through the p aragraph in detail. 7 DR. RUSSELL: Okay. Thankyou. If people are 8 ready to start discussing it, I think we should. 9 Paragraph one, typical int ro. Paragraph two, 10 basically talking that we are a ctually pleased with 11 progress that's been made and anumber of 12 complexities have been introduc ed, but I think this 13 is an important statement, we'r e not sure how one 14 could construct a simpler appro ach to achieve the 15 same end point. 16 DR. BYTNEROWICZ: Somewher e in the letter we 17 have to say that we are address ing aquatic 18 inconsistence, but we have cons idered terrestrial. 19 It's more difficult to approach . So that should be 20 emphasized somewhere that that' s something that the 21 present approach protects aquat ic ecosystems and 22 there is a very high uncertaint y how we protect 23 terrestrial ecosystems, some ki nd of general 24 statement like that is needed. 25 DR. RUSSELL: So it probab ly goes at the end

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1 of the first paragraph. The pr esent approach 2 serves as a mechanism to protec t aquatic 3 ecosystems. 4 DR. BYTNEROWICZ: Realizin g that we are far 5 away from developing a similar approach to 6 terrestrial ecosystem. 7 DR. RUSSELL: Realizing th at a similar 8 approach for protecting terrest rial ecosystems and 9 eutrophication would still needto be developed. 10 DR. BYTNEROWICZ: Somethin g like that. 11 DR. AMAR: NOx and SOx, ca n we say nitrogen 12 and sulphur? 13 DR. DRISCOLL: I had a tho ught on that, 14 increased effects of NOx and SO x, and then have 15 maybe at the end of that sayingwhile considering 16 the current effects of ammoniumdeposition or NOx 17 deposition to address it. 18 DR. RUSSELL: "NOx and SOxwhile considering" 19 goes at the end of the sentence , "while 20 considering." 21 DR. DRISCOLL: The effects of current reduced 22 nitrogen deposition or somethin g like that. 23 DR. RUSSELL: Thank you. Okay. Second 24 paragraph, this is in some ways stating our 25 frustration both in terms of th e amount of time

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1 we've had and that the current PA still has a 2 significant amount of work to b e done. And it did 3 not include the charge question s. Yes, Naresh. 4 DR. KUMAR: So we are aski ng a lot of new 5 things to be done. Do you thin k we want to see the 6 revised document before we make some of the 7 recommendations? Because the s chedule doesn't call 8 for us to review the next versi on. That goes 9 straight to the Administrator. But because of all 10 the difficulties -- yeah, that is -- actually, I 11 think what I sent this morning. Excuse me, do you 12 have what I sent you this morni ng? 13 DR. NUGENT: The previous document. 14 DR. RUSSELL: I sent you aversion two this 15 morning. 16 DR. NUGENT: Should be something like version 17 1-A. I think I've addressed th at, given that 18 addressing the issue that CASACwon't get -- may 19 not get to see this again. 20 DR. AMAR: We want to say that we would like 21 to. 22 DR. RUSSELL: Do we want t o say that we would 23 like to? 24 DR. KUMAR: I would like t o see it. 25 DR. RUSSELL: Okay. We wi ll say that we would

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1 like to see it again. Moving o n. So you can read 2 Chapter 5 -- the next two parag raphs. 3 DR. NUGENT: Here it is. 4 DR. RUSSELL: There we go. So it's not -- go 5 further down, see if it's there . 6 DR. AMAR: Chapter 5 is wh ere we said it. I 7 added something here. So somew here what's in 8 purple is new. We'd like to sa y that CASAC wants 9 to see this document again. 10 Okay. Moving on. So thes e next two 11 paragraphs are oriented and act ually the suggestion 12 was made that we might move the se out of the letter 13 into a separate section as crit ical need. This is 14 where I tried to capture all th e critical needs in 15 these next three paragraphs. What it does is it 16 makes the letter long and I thi nk it starts 17 diluting the real punch of what we want to say. 18 Nonetheless, those are critical things we brought 19 up that are critical. 20 DR. RUSSELL: So in terms of those three 21 paragraphs, do you all agree an d in particular I 22 think the first paragraph, the first of those three 23 is the first of Chapter 5, I to ok those as being 24 our primary needs. 25 DR. KUMAR: So in view of the discussion we

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1 had, in terms of ANC and levels of protection, do 2 you think it's wise to ask EPA to provide more 3 description of what kind of unc ertainties are 4 there? It is just answering a larger -- maybe 5 having more description of unce rtainty might help 6 us, or help our Administrator d ecide in the range 7 between 20 and 100. Right now it's a qualitative 8 variant in Chapter 5. 9 DR. RUSSELL: I think that 's actually in 10 Chapter 7. 11 DR. KUMAR: Chapter 7, doe s it talk about 12 uncertainties within ANC and adverse effects? 13 DR. POIROT: It refers to the charge 14 questions. 15 DR. KUMAR: Chapter 7 is t he AAPI, at 16 different levels of ANC we have different adverse 17 effects. Writing the descripti on is very 18 qualitative again. It only say s between 20 and 50 19 uncertainties are higher. Abov e 50 uncertainties 20 are much higher. Should we askfor more 21 description of what is meant bythat? 22 DR. RUSSELL: Actually, I think it's pretty 23 much there if we look at the ta ble in Chapter 2. I 24 think they describe it. I thin k our issue earlier 25 was what to do with it. I thin k it's described and

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1 actually, as you noted earlier, you said it was 2 described. It's just what we d o with it. 3 DR. KUMAR: Again, I woulddescribe 4 qualitative. Larger, much larg er, I have no idea 5 what that means. 6 DR. RUSSELL: But I don't think they can 7 get -- I mean, that graph I thi nk says a whole lot 8 to us. I mean, that is a quant itative graph. I 9 don't think they can do any mor e than sort of show 10 us that and say this is what we 're dealing with. 11 DR. KUMAR: That's fine. 12 MS. CHESTNUT: Ted. 13 DR. RUSSELL: Yes. 14 MS. CHESTNUT: On Chapter 5 there is a lot of 15 emphasis on the spatial part of it and a little 16 less -- I mean, it mentions the AAPI, but it seems 17 like a lot of concern is about some of the specific 18 quantitative links and whether there is 19 sufficient -- I mean, that's wh at the uncertainty 20 questions I think are about, yo u know, the 21 transformations from deposition-- or ambient to 22 deposition and the other elemen ts that are -- I 23 think that's what I'm hearing w hat's a lot of 24 hesitation to say yeah, you're done, you know, go 25 forward with the standard basedon this.

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1 DR. RUSSELL: So how wouldyou -- I thought I 2 got that, but maybe I didn't. I mean, I sometimes 3 really miss. 4 DR. AMAR: Something else, can we simply use 5 the word "sensitivity" instead of "elasticity"? I 6 think it means the same thing h ere. What you wrote 7 for Chapter 7 -- 8 DR. RUSSELL: Sure. 9 DR. AMAR: -- I know there was a question the 10 word "elasticity" has been used , but why confuse 11 the issue? 12 DR. RUSSELL: Okay. 13 DR. WEATHERS: Is there an y advantage to 14 having this level of detail ver sus almost a bullet 15 list of the critical needs? Th at's a naive 16 question. 17 I don't know from your per spective. If we 18 were to, rather than have these details for Chapter 19 5 and Chapter 7, say our recommendations could be 20 synthesized by identifying this list of critical 21 needs in order to provide guida nce. 22 DR. SCHEFFE: That would b e helpful. 23 DR. WEATHERS: But is it m ore helpful than -- 24 they're buried in there. 25 DR. HUBBELL: It's more he lpful to be as

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1 specific and concrete and toget her as possible. 2 DR. WEATHERS: A bulleted list of high 3 priority analysis. 4 DR. HUBBELL: Bulleted andprioritized kind of 5 sets of analyses would be very, very helpful all 6 collected in one spot so we don 't miss something. 7 DR. RUSSELL: And we couldalso rank order 8 those. 9 DR. HUBBELL: If you can, that would be great. 10 DR. SCHEFFE: That would b e great. And on 11 that last point, I mean, there was an elasticity 12 analysis and there was a little bit attached to the 13 nomenclature there. I know the re is a relationship 14 between elasticity and sensitiv ity, but we use them 15 separately. There was a specif ic elasticity 16 analysis that that sentence was referring to. So 17 you might want to consider that last change. 18 DR. RUSSELL: That was ela sticity. Use 19 sensitivity later. 20 DR. MITCHELL: Some of us had some discussion 21 in terms of the prioritization. There is two 22 components there. One is what are the really 23 important issues, and the secon d is what's doable. 24 And I think it's important for us to have or make 25 recommendations that keep both of those in mind,

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1 which, therefore, is going to n eed some feedback. 2 It might not necessarily be cle ar at the early 3 stage, but as soon as possible to have some 4 feedback from you all about whe re we get the most 5 bang for your effort. 6 DR. SCHEFFE: Exactly. We would welcome that. 7 DR. RUSSELL: Okay. The l ine, the paragraph 8 that starts -- it is 37 on your s. Why we have 9 identified various needs, this is an important 10 paragraph I think. 11 DR. KUMAR: Ted, I have a comment on Chapter 12 7. 13 DR. RUSSELL: Very short. 14 DR. KUMAR: I don't see re asons for giving a 15 caveat. I think that can give us a way out of not 16 doing that analysis. We have h ighlighted so much 17 that analysis is critical. Andproviding a caveat, 18 if EPA doesn't have the time todo it, they can 19 come back to us that they don't have time. I don't 20 see a reason for us to give a c aveat. 21 DR. RUSSELL: Actually, wh at I would mean 22 would mean a well-explained set of example 23 calculations. I mean, that was all caveated. I 24 want them to state this is what we need done. This 25 is why we've done it. So that it doesn't -- people

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1 don't think it's something that it's not. 'Cause I 2 think one of the things to keep-- well, does that 3 do it for you? 4 DR. KUMAR: It's open to m isinterpretation 5 just like last time. I think t hey misinterpreted 6 our intentions. And that's my concern. That is, 7 again, open to misinterpretatio n what we're asking 8 them for. 9 DR. RUSSELL: I'm not sure how we can get more 10 specific on this. 11 DR. KUMAR: It says such a n analysis is not 12 possible. What is the differen ce between that 13 analysis and the set of example calculations of the 14 magnitude of uncertainties? Wh at's the difference 15 between the two? It's not clea r to me, so I don't 16 know if it's clear to EPA or no t. 17 DR. FREY: There are the d etailed answers to 18 the charge questions that go in to more detail of 19 what this means. I think it's there. It's just 20 not all in the two-page letter. 21 DR. KUMAR: I didn't see t hose details in the 22 charge questions either. That' s why I'm asking 23 what do you mean by the detaile d examples rather 24 than the full analysis? Full a nalysis, Monte Carlo 25 is full analysis. For data andcalculations is

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1 that something different, what would that be? 2 DR. RUSSELL: So a compreh ensive uncertainty 3 assessment would be something w here they would be 4 approaching a Monte Carlo analy sis, but I'm not 5 sure that there is time to do t hat. I mean, you've 6 referred to the other analyses that have been done. 7 DR. KUMAR: But why do we think it's not 8 doable? All the parameters are already there. 9 They already have all the datab ases to do the 10 calculations. 11 DR. RUSSELL: The reason w hy is because they 12 have to make assumptions as to what the 13 distribution of those uncertain ties are. So that's 14 what I'm hesitant to tell them to do if they are 15 going to have to start making c ertain assumptions. 16 DR. KUMAR: I think we canask them details 17 on -- if they don't have an ide a of what 18 distribution, they would do something very simple 19 and just explain. I see no rea son of not doing it. 20 And I think with this caveat we 're basically 21 telling them, well, they don't have to do it. 22 DR. AMAR: What about this language, if the 23 full-scale analysis is not poss ible, then say in 24 the second, more focused analys is should be done. 25 That might answer. Just lookin g at the last part,

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1 if such an analysis is not poss ible, replace that 2 if a full-scale analysis is not possible given time 3 constraints. 4 DR. KUMAR: I would sugges t we stop where you 5 say, "A more comprehensive unce rtainty assessment 6 is called for as described in t he charge 7 questions." And then in the ch arge question we 8 provide the details and not sayanything here up 9 front because there are charge questions. People 10 are fine with that? 11 DR. NUGENT: Strike this l ast sentence. 12 DR. RUSSELL: Fine. Okay. Paragraph starting 13 at line 37. Quorum? I was afr aid of that. We're 14 going to have to have a second phone call. 15 DR. NUGENT: We're a groupnow. 16 DR. KUMAR: Have we lost t he quorum? 17 DR. NUGENT: We have lost the quorum. So 18 right now we are editing as a g roup. 19 DR. FREY: Can I make a co mment that's maybe 20 more general than this one para graph? 21 DR. RUSSELL: Sure. 22 DR. FREY: I didn't catch some of the edits 23 earlier, so maybe it's addresse d, but it seems like 24 the Administrator would want tohear from this 25 panel on do we agree that the c urrent secondary

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1 standards should be retained an d that that should 2 be in the letter. 3 DR. RUSSELL: Very good. 4 DR. FREY: And then I thin k the Administrator 5 would like to hear that the pan el concurs that, you 6 know, there is sufficient evide nce that current 7 standards not protective agains t specific aquatic 8 acidification; and, therefore, there is support for 9 an additional I guess secondarystandard beyond the 10 current one. Because then I th ink the letter tends 11 to dive into the details of the proposed standard 12 and maybe in a way loses sight of the need for a 13 standard. And so having that c onstruct earlier 14 would be helpful. 15 And then I think the thirdthing related to 16 that is, you know, if there are significant 17 uncertainties about the specifi c levels and so on, 18 I mean, it seems like the weigh t of evidence 19 conclusion is very strong, that there is -- the 20 current standard is not protect ive against aquatic 21 acidification. So there is a n eed for an 22 additional standard. And, you know, whether the 23 Administrator picks 100 or 20 o r what percentage of 24 lakes, you know, those things w ould deal with the 25 degree of protectiveness of the standard. But I

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1 think we ought not lose sight o f the kind of 2 impetus that there should be a revised standard. 3 DR. RUSSELL: Actually, th at should probably 4 go as paragraph two. 5 DR. FREY: Yeah. 6 DR. RUSSELL: And then tha t can dive in saying 7 that there is a need for this n ew standard that 8 addresses both NOx and SOx depo sition and then we 9 get into that. Thank you. 10 Okay. This last paragraph , and it's really 11 too bad we've lost quorum and s ome of the other 12 individuals, that you have is b asically saying that 13 while we identified weaknesses with the current 14 document, we remain very suppor tive of the 15 approach. 16 DR. AMAR: Additional anal ysis we mean within 17 the context of now until Decemb er? 18 DR. RUSSELL: Yes. 19 DR. AMAR: Should we say t hat? There is also 20 research needs for the future, which are different 21 than what we need from now unti l then. 22 DR. RUSSELL: So where wou ld you put that? 23 DR. AMAR: Additional anal ysis in the next 24 revision. 25 DR. NUGENT: You mean befo re the proposal goes

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1 forward? 2 DR. AMAR: Yeah, the time frame is near term. 3 Also purpose of being a foundat ion, I would say 4 purpose of establishing a found ation. 5 DR. KUMAR: Is it before i t's published or 6 before this is finalized? You mean before the 7 NAAQS are published or before i t is finalized? 8 Those are different events. Dowe want analysis to 9 be in the final? Otherwise, wh ere would that be 10 seen? 11 DR. RUSSELL: The final PA D is published. 12 DR. NUGENT: PA is not a f oundation. 13 DR. AMAR: Establishing a foundation for 14 building. 15 DR. RUSSELL: Being establ ishing -- no, don't 16 give foundation. 17 Okay. Getting the paragra ph 37 starts on line 18 37, I guess that's the one we j ust did. Does that 19 go with people? 20 DR. KUMAR: So where are w e asking that we be 21 allowed to review the next vers ion of the PAD, the 22 final version of the PAD? 23 DR. RUSSELL: That would b e the last -- 24 actually, go up. 25 DR. FREY: Procedurally do es it make sense to

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1 review a final PAD? If it's fi nal -- 2 DR. RUSSELL: Karen. 3 DR. FREY: -- at that poin t that we want to 4 provide input before the propos ed rule is made, but 5 it's not going to be a review o f the Policy 6 Assessment. 7 MS. MARTIN: There have be en times in the past 8 where the panel has chosen to p rovide comments to 9 the agency on a final document, recognizing they 10 weren't comments directed towar d changing the 11 documents since it was final, b ut offering their 12 views upon what was in the fina l document. That 13 has happened in the past and it is the prerogative 14 of the panel. 15 It is also the prerogative of the panel to 16 decide to give the agency the c omments on what 17 might get proposed. So there a re those further 18 opportunities that at your prer ogative you may 19 choose to offer further advice. 20 DR. RUSSELL: We don't get another review. 21 DR. KUMAR: We can provide comments. I guess 22 we are saying there are a lot o f issues of which we 23 are not able to make recommenda tions right now. So 24 unless we get to review additio nal -- 25 DR. RUSSELL: It wouldn't be a review. It

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1 would be comment on. 2 DR. KUMAR: We can choose the right language 3 that you want to choose. 4 DR. RUSSELL: How would we ? 5 DR. KUMAR: Like to see th e document before we 6 make some of the recommendation s that we're not 7 able to do it right now. 8 MS. MARTIN: It is also ou r practice that when 9 we finalize a document we send that document to the 10 panel for your information and it includes a cover 11 letter telling you the things w e have changed in 12 the final document relative to the document you 13 just reviewed that were respons ive to your 14 comments. So upon receiving th at from us, if you 15 chose to provide further commen ts, further 16 recommendations based on that f inal document, there 17 is a ready opportunity for you to do that. 18 DR. RUSSELL: In some ways we get to do it no 19 matter what. We can't -- we're not going to get a 20 review unless we somehow want t o interrupt the 21 process. 22 DR. KUMAR: I guess we don 't have a quorum to 23 decide that. I see many hands being raised when 24 you asked if you would like to review the next 25 draft or not or the final draft .

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1 DR. AMAR: Would that be i n a meeting? 2 DR. RUSSELL: It could be a teleconference. 3 MS. CHESTNUT: We could sa y that we expect 4 that the panel will want to pro vide comment on the 5 final document if we want to sa y something in the 6 letter. 7 DR. RUSSELL: Yeah. 8 MS. CHESTNUT: Given that -- so if you go 9 up -- 10 DR. RUSSELL: Well, we'll put it at the end 11 and then we can wordsmith this around. 12 DR. FREY: We always -- I mean, we have the 13 prerogative to do that whether we put it in the 14 letter or not. 15 DR. RUSSELL: The only dec ision point I think 16 is that if we are looking to su ggest that we want 17 to interrupt this process and t hat's still for them 18 to decide if they want to do so . So interrupting 19 the process would -- they wouldhave to decide 20 within their court-ordered mand ates what can be 21 done or if they would go back t o the litigant or 22 whatever. 23 DR. KUMAR: When does this letter need to be 24 sent? 25 DR. RUSSELL: Well, when d oes it need -- we're

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1 going to have to have another t eleconference on 2 this letter in three weeks. 3 DR. KUMAR: That's what I' m saying because 4 when we have a full quorum, the n can we make a 5 decision on whether to ask for the review or not, 6 right? Do we have to make a de cision now? 7 DR. NUGENT: I mean, I'm n ot sure how to 8 respond to your question. I --the -- the schedule 9 for the proposal is not somethi ng CASAC can 10 directly affect. The schedule Lydia laid out is 11 what you're proceeding on, isn' t that true? 12 MS. MARTIN: Yes. The sch edule we have right 13 now is a court-ordered schedule calling for a 14 proposal next July. 15 DR. NUGENT: Next July. 16 DR. COWLING: The document -- the paragraph 17 that begins on line 37 is very important. And I 18 must say I reacted to the whole letter being a bit 19 discouraged. And I made the st atement yesterday of 20 what I think is my confidence t hat we are going to 21 be pleased with what will be do ne in the next few 22 weeks. And I would hope that y ou would look at 23 this letter or we all should lo ok at this letter as 24 it's finalized and be sure that we are as 25 encouraging as we can be of the success of these

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1 people achieving what they have earnestly tried to 2 do here, which is, as Chris was saying, we need to 3 be sure that it's very clear th at this committee 4 believes this CASAC committee b elieves this is a 5 very important step to be taken . 6 So I would hope that we wo uld examine the 7 letter from the standpoint of i ts optimism and its 8 likely effect on the morale anddetermination on 9 the part of the agency, morale in the troops and 10 determination on the part of th e agency as a whole. 11 DR. RUSSELL: I tried to b e positive. So if 12 you can do something with this letter -- because I 13 think I agree with you, and I t ried to be positive. 14 DR. DRISCOLL: I think we could get rid of the 15 three-week whining. I think we could just strike 16 that one sentence that we didn' t have enough time. 17 That's after the fact. That's water over the dam. 18 DR. RUSSELL: Actually, I personally think we 19 have to send that type of infor mation up the chain 20 that that is just not enough ti me. I mean, I heard 21 enough whining, if you will, fr om the committee 22 about that. 23 DR. DRISCOLL: I was whini ng too, but I think 24 in the spirit of Ellis's commen t, it would be best 25 in another letter saying it wou ld be helpful in the

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1 future -- 2 DR. RUSSELL: No, this is the letter. This is 3 the letter. 4 DR. DRISCOLL: Okay, fine. 5 DR. RUSSELL: And the thin g is I don't think 6 it's their fault. In fact, I'mfairly sure it's 7 not their fault. 8 DR. DRISCOLL: I understan d it's in their best 9 interests to give us as much ti me as possible. 10 DR. RUSSELL: I want to ma ke sure that that 11 information that, you know, if it became standard 12 practice to have three-week tur naround on these 13 reviews, that would be detrimen tal to the process. 14 DR. DRISCOLL: I agree. 15 DR. RUSSELL: So I want tomake sure that that 16 information goes forward. 17 Okay. You were about to s ay? 18 DR. NUGENT: I feel a litt le nervous saying 19 this, but we're in a work appre ntice situation. I 20 don't -- I had it in my head th at the proposal was 21 in December, but the proposal i s in July, right? 22 And the deadline for the PA is in December. 23 MS. MARTIN: That's right. If we're going to 24 meet the target of proposing inJuly, we believe we 25 need to finalize this document around the end of

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1 the year. 2 DR. NUGENT: Would it be p ossible to set up 3 and desirable to set up maybe s ome teleconferences 4 that might be -- where the comm ittee could review 5 an interim product? It may not be the final PA, 6 but it could be components that people are 7 interested in, we could maybe s et up 8 teleconferences where people co uld look at the 9 components of special reviews? 10 MS. MARTIN: One of the pr oblems is making the 11 documents publicly available fo r the panel to 12 review also necessitates makingthem available for 13 the public to review. And bothyou and the public 14 need a reasonable amount of time to review and 15 provide comments or it's not a meaningful review. 16 And to allow for an amount of t ime for that to 17 happen simply goes beyond what our current schedule 18 allows for. 19 DR. KUMAR: I guess I'm no t suggesting that we 20 want to review the document to make further 21 changes. I'm suggesting that w e should review the 22 document to make some recommend ation that we are 23 not able to make right now. An d that can occur in 24 the letter even though we know that we have that 25 prerogative to review the final document and

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1 provide additional comments. 2 We can do that without cha nging the schedule, 3 the court-ordered schedule beca use if this comes up 4 in December, we can review it i n January and 5 provide additional documentatio n in February, which 6 the Administrator may choose or not choose to look 7 at. 8 DR. RUSSELL: So -- Chris. 9 DR. FREY: I guess I wouldsuggest that if the 10 final PA is available in Decemb er that we might 11 consider having a teleconferenc e of this panel 12 maybe in early February. I gue ss it depends when 13 in December the final document would be available. 14 But then with the holidays and so on maybe giving 15 January for people to read it a nd then, you know, I 16 guess the CASAC could at that p oint provide 17 whatever input it would deem tobe useful. And 18 then, although it might be help ful to hear a little 19 bit more about the proposed rul e schedule, and are 20 there certain time points at wh ich if this panel 21 were to have input, when would it be most useful to 22 receive it? 23 MS. MARTIN: Well, that on e's easy to answer, 24 as soon as possible. 25 DR. FREY: Right. But if it was in --

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1 MS. MARTIN: There is an i nternal decision 2 making process. There is inter nal process to 3 capture those decisions in a no tice. And there is 4 interagency review across feder al agencies before 5 major rules are proposed. So a ll those time steps 6 come before the July proposal d ate. 7 DR. FREY: Okay. 8 MS. MARTIN: February isn' t too late to 9 provide additional advice, reco mmendations, input 10 to the process, but the earlier the better. 11 DR. FREY: Right. And I g uess any letter that 12 comes from this panel would hav e to go to the seven 13 member CASAC before it's transm itted to EPA. So 14 we'd have to allow for that. 15 DR. RUSSELL: Which is thr ee weeks, right? 16 DR. NUGENT: Yeah. 17 DR. RUSSELL: After we fin alize the letter. 18 Well, would it have to be a fin alized letter from 19 us? Actually, it doesn't have to be finalized from 20 us, right? 21 DR. NUGENT: Yes. I mean, yeah. 22 DR. RUSSELL: Before it go es to the 23 seven-member CASAC, because the seven-member 24 CASAC -- 25 DR. NUGENT: The panel has to buy off on the

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1 letter. 2 DR. RUSSELL: We have to b uy off. We have to 3 agree to it. 4 DR. FREY: So maybe if we had a panel 5 discussion like January and the n the seven-member 6 CASAC could review it the thirdweek of February or 7 something like that, that might be the earliest we 8 could do it. 9 DR. RUSSELL: Okay. Recog nizing that we 10 really don't have quorum and we 've just lost one 11 more person, losing them, I thi nk we might as 12 well -- 13 DR. NUGENT: Officially ad journ. 14 DR. RUSSELL: -- officiall y adjourn. 15 DR. NUGENT: Thank you all . And I'll be in 16 touch with everybody in the roo m about follow-ups. 17 Thank you EPA and panel members who are still here 18 especially. 19 MS. MARTIN: As always, we thank you all very 20 much for your time and input. 21 (Meeting adjourned at 12:1 7 p.m.) 22 23 24 25

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1 STATE OF NORTH CAROLINA ) 2 COUNTY OF WAKE ) 3 CERTIFICATE OF REPOR TER 4 I, MAREN M. FAWCETT, Regis tered Professional Reporter and Notary Public in and fo r the State of North 5 Carolina, duly commissioned and auth orized to administer oaths and to take and certify deposi tions, do hereby 6 certify that I attended the meeting on October 7, 2010 and that the preceding transcript, w as reported by me 7 verbatim to the best of my ability, and then reduced to typewritten form under my direct sup ervision; that the 8 foregoing is a true and correct tran script of said proceedings to the best of my abilit y and understanding; 9 that I am not related to any of the parties to this action; that I am not interested in the outcome of this 10 case; that I am not of counsel nor i n the employ of any of the parties to this action. 11 12 IN WITNESS WHEREOF, I have hereto set my hand, this the _____ day of October, 2010. 13 14 15 ________________

___________ 16 Maren M. Fawcett , RPR Notary Public - North Carolina 17 Certificate No.: 200621500068 My Commission Ex pires: 7/31/2011 18 19 20 Maren M. Fawcett, RPR Bryant Court Reporting Service 21 P.O. Box 1401 Cary, NC 27512 22 23 24 25

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