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 1 U.S. ENVIRONMENTAL PROTECTION AGENCY

 2 CLEAN AIR SCIENTIFIC ADVISORY COMMITTEE (CASAC)

 3 OXIDES OF NITROGEN AND SULFUR OXIDES

 4 SECONDARY REVIEW PANEL

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 10 - - -

 11 TRANSCRIPT OF PUBLIC MEETING

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 17 October 7, 2010

 18 8:32 a.m. - 12:17 p.m.

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 20 Marriott at Research Triangle Park

 4700 Guardian Drive

 21 Durham, North Carolina 28803

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 1 CASAC SECONDARY REVIEW PANEL MEMBERS PRESENT:

 2 Dr. Armistead (Ted) Russell

 3 Dr. Anthony Maciorowski

 4 Dr. Praveen Amar

 5 Dr. Charles T. Driscoll, Jr.

 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, Designated Federal Officer

 18 ENVIRONMENTAL PROTECTION AGENCY STAFF:

 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 STAFF CONTINUED:

 2 Leah Anderson, Esq.

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 1 DR. NUGENT: Good morning, everyone. It's

 2 time to convene our advisory meeting, day two of

 3 the CASAC Panel Oxides, NOx and SOx 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 very 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 individual panelists had

 12 to the charge questions. And you should have paper

 13 copies of those sitting in front of you. And how I

 14 would like to do this is to go to the leads to

 15 essentially give us the, you know, one or two-line

 16 synopsis of what's written and then recognize that

 17 each of us can read the -- read what's there.

 18 I recognize one thing this will do is we'll

 19 have a lot of sort of dead silent time because what

 20 I want to get out of this is essentially everybody

 21 is on board with what we're sending forward to the

 22 Administrator. And this is going to be one of our

 23 more important transmittals.

 24 So with that, charge question one, which was

 25 Lauri, was it? I don't remember from yesterday.

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 1 I'll have to get my agenda.

 2 MR. McNAMARA: You want to be 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 about a minute.

 8 MS. CHESTNUT: Okay. This probably is still

 9 too wordy, but I think the main point 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 function and that the link

 13 is well established in the Policy Assessment

 14 between the effects indicator A and C and the

 15 public welfare effects.

 16 They've made the -- the second 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 of the value of

 20 habitat, biodiversity, independent of human use,

 21 what we call nonuse values in the economics

 22 literature, but to make that link to the ecosystem

 23 services concept explicit every time.

 24 And then the final point in the paragraph is

 25 the emphasis on clearly these resources are high

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 1 value. The importance for this is the degree to

 2 which they're diminished at current 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 paragraph just recognizes

 6 in this chapter the discussions about community and

 7 State actions that that's useful in broadening,

 8 deepening the evidentiary problem of adverse

 9 effects.

 10 DR. RUSSELL: Questions and comments? Ellis.

 11 DR. COWLING: My question has to do with the

 12 next to the last line of the last 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 terrestrial? What do

 17 you mean exactly by terrestrial and eutrophication?

 18 MS. CHESTNUT: I was trying to come up with a

 19 phrase that included everything in addition to the

 20 aquatic acidification. I probably haven't quite

 21 done that, but I think the sentence 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 magnitude and

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 1 significance, not just there can 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 mean terrestrial and

 5 aquatic eutrophication effects or are you thinking

 6 only of terrestrial effects?

 7 MS. CHESTNUT: I'm not just thinking of

 8 terrestrial.

 9 DR. COWLING: Okay. I suggest that if you

 10 mean terrestrial and aquatic eutrophication

 11 effects, that is what should be said.

 12 DR. RUSSELL: Actually, what Lauri said, I

 13 mean, I'm not sure that you lose anything by just

 14 ending at "deposition."

 15 MS. CHESTNUT: Yeah. If we 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 just suggesting --

 20 MS. CHESTNUT: A period after "deposition" and

 21 just take that out.

 22 DR. COWLING: Okay.

 23 DR. RUSSELL: Anything else?

 24 DR. COWLING: Yes. One other thing in the

 25 second paragraph, Lauraine, I suggest 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 numerical and chemical

 6 meeting.

 7 DR. AMAR: One other thing, the last sentence

 8 of the first paragraph what's important to convey

 9 is the degree to which there are 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 mind what's going to

 14 happen is at the end of this meeting, we're going

 15 to have a document I think that's going to be in

 16 pretty good shape that we're going to be able to

 17 give our thumb's up or thumb's down to and then it

 18 will be provided to the committee 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 have spoken.

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 1 DR. RUSSELL: Well, no, you can.

 2 Next, charge question two, Ellis, you're on

 3 and three.

 4 DR. COWLING: Okay. Should we take some time

 5 for reflective study?

 6 DR. RUSSELL: Yes, for four as well. We'll go

 7 from there.

 8 DR. COWLING: The draft from Ellis is

 9 different from the drafts from Dale, but what it

 10 contributed to from Ellis is in fact a result of

 11 conversations that Dale and I had late into the

 12 night. And I am very pleased to have had the

 13 chance to help with the process of more general

 14 acceptance of the points that Dale has been trying

 15 to make ever since he joined this panel.

 16 Can we move up the text on the 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 least closed-canopy

 3 forests, recirculate 80 to 90 percent of the

 4 nutrients and the only amount that they need and

 5 keep from the outside every year is about

 6 10 percent.

 7 So I made that modification. It's been sent

 8 to everybody to that effect. So the actual

 9 increment of the loblolly pine and other forecasts

 10 is actually a lot closer to nitrogen deposition

 11 rates than it indicated here.

 12 DR. COWLING: Both in the Pacific northwest

 13 region of our country and the southern part of our

 14 country fertilization is used extensively in both

 15 northwest and southeastern forests. And these

 16 rates --

 17 DR. JOHNSON: Are high.

 18 DR. COWLING: -- are standard 60.

 19 DR. JOHNSON: They're even more than that; and

 20 the reason they are is because the microbes are

 21 starved for nitrogen too and they get most of it.

 22 So when you fertilize and the fertilizer goes on

 23 the forest floor, about 60 percent 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 are much higher than

 2 the tree needs.

 3 DR. MITCHELL: Also I would suggest maybe it

 4 needs to be clarified even though you can have a

 5 nitrogen increase in production component, even

 6 under those conditions even though there is a

 7 stimulation of productivity with enhanced nitrogen

 8 inputs, there is still under those conditions a

 9 significant amount of nitrogen lost, which is

 10 deletory to the ecosystem.

 11 DR. JOHNSON: Typically always do.

 12 DR. MITCHELL: I don't want to have the

 13 impression that's the demand, there is still no

 14 deleterious impacts still possibly for those

 15 systems.

 16 DR. JOHNSON: No. There could be. Maybe it's

 17 necessary and you don't want it in production.

 18 DR. MITCHELL: It's not something -- even

 19 though you have enhanced production.

 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 saying for a couple,

 23 three years now is not -- the -- Ellis and I had a

 24 long talk about managed and unmanaged forests last

 25 night.

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 1 My thoughts is unmanaged forests can have the

 2 same effect as managed forests. It all relates to

 3 growth, which can lead to carbon 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," respectively colon -- or

 10 semicolon, "In the case of loblolly 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 each year and,

 15 therefore, must come from either the soil or

 16 external sources."

 17 DR. MITCHELL: So is agronomic that's changed

 18 to be fertilization inputs, not actual

 19 requirements? Those are fertilization rates.

 20 That's not much used by those crops.

 21 DR. JOHNSON: I don't know the exact numbers.

 22 Agronomic inputs are pretty high.

 23 DR. MITCHELL: They're pretty high, but

 24 nothing close to that.

 25 DR. JOHNSON: You don't think so?

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 1 DR. MITCHELL: No. You still have enhanced

 2 production as you increase the amount of

 3 fertilization, with the amount of net

 4 incorporation, incremental is less and less. It's

 5 like points of diminishing return. It's a curve

 6 that goes up. Sure, you can have enhanced nitrogen

 7 production, but a relatively small amount of the

 8 higher amounts of end input or incorporated corn,

 9 that's why you get all the nitrogen coming down

 10 with agronomic systems.

 11 DR. JOHNSON: Yeah, but the point is corn,

 12 nitrogen uptake is ten times higher than required

 13 from trees. The benefit of nitrogen to croplands

 14 is probably nil, too small.

 15 DR. MITCHELL: In terms of the deposition.

 16 DR. JOHNSON: Yeah. But for 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 input would be a lot

 22 less.

 23 DR. JOHNSON: It might be a problem with

 24 numbers in here 'cause it's going to start quarrels

 25 like this every time, but just the difference

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 1 between crop and forest or wild systems recycling.

 2 That's really the difference.

 3 DR. MITCHELL: There is a difference between

 4 fertilization versus requirements.

 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 state parks and Class

 9 I wilderness areas."

 10 DR. RUSSELL: Andre.

 11 DR. BYTNEROWICZ: We should 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 think it's better to

 16 say most forest lands. We do know areas of the

 17 southeast coastal plain that are 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 one comment? This

 21 point has been repeatedly in the ISA, REA, and we

 22 know most terrestrial ecosystems are nitrogen

 23 limited regarding productivity. I'm not sure -- I

 24 mean, we can point to it. On page 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 this further.

 3 DR. HUBBELL: Are you just stating it

 4 yourselves again? I was trying to figure out what

 5 this set of points meant as well. Is it something

 6 you think we need to address more or is this a

 7 statement that these are known things and,

 8 therefore, we're just reiterating 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 detail or fine a

 12 scale to -- for you to quantify Neco, but my

 13 suggestion is that either we acknowledge here or

 14 you acknowledge in the document that fertilization

 15 effects and input that are taken up by the

 16 vegetation or mobilized in the soil are in fact

 17 accounted for in the AAPI.

 18 DR. HUBBELL: Consideration of the aquatic

 19 acidification effects, yes. This seems to be more

 20 about the nutrient enrichment and nutrient use more

 21 than acidification.

 22 DR. WEATHERS: Right. But, correct me if I'm

 23 wrong, the Neco is a terrestrial uptake error. And

 24 so, in theory, if there is fertilization going on,

 25 it's captured in that Neco. It basically means if

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 1 85 percent of the inputs are retained within the

 2 system, that's a result of uptake immobilization.

 3 DR. HUBBELL: Yes.

 4 DR. WEATHERS: So, again, maybe the Neco term

 5 isn't finally resolved enough to actually deal with

 6 this, but I suggest that you made the link and you

 7 need to make that explicit.

 8 DR. GREAVER: Okay.

 9 DR. WEATHERS: Dale, is that --

 10 DR. JOHNSON: Well, we made the link. It's a

 11 matter of emphasis. Again, when 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 phenomenon, the growth

 15 increase when it produces a negative 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 continue to say it.

 20 DR. HUBBELL: So in terms of this carbon

 21 sequestration, would you want to see an expanded

 22 discussion in the ecosystem services chapter, is

 23 that --

 24 DR. JOHNSON: Yeah, I guess someplace.

 25 DR. WEATHERS: I'm just wondering whether

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 1 that -- how the Neco term would be expanded and

 2 what effect it would have on the AAPI or the

 3 trade-off curves is maybe one of those critical

 4 analyses that need to be done. So let's say that

 5 there is fertilization going on in these

 6 ecosystems. Again, is that something that the Neco

 7 term is sensitive enough to pick up? Are there

 8 some analyses that can be done that would satisfy

 9 this issue about whether --

 10 DR. JOHNSON: Neco term addresses the growth

 11 response, unintended consequence 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, the Neco term -- it's

 17 a bigger amount of nitrogen captured within the

 18 system. Maybe I'm not understanding 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 allows more nitrogen

 22 to be deposited into the system before 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 will be degassed

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 1 certainly. So that the fertilization effect is

 2 captured in that term. We haven't calculated how

 3 much additional carbon sequestration 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 convinced that there is

 9 something we need to do to Neco to specifically

 10 account for something else other than what it

 11 already accounts for. Again, what we're building

 12 the Neco for is just to recognize that it

 13 represents the sink of nitrogen that we can fill up

 14 before we start seeing the leaching and other

 15 effects, but it's already in there.

 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 getting a little

 19 confused on this is that I think a lot of the

 20 discussion -- the other discussion on this point

 21 has to do with specifically the nutrient-related

 22 impacts that are not associated with acidification.

 23 The Neco term is associated with trying to

 24 balance and make sure we're taking care of end

 25 leaching versus total end. That's obviously

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 1 related to the issue of fertilization, 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 adjust.

 9 DR. WEATHERS: I'm not suggesting adjustment.

 10 I'm suggesting that there may be a way to address

 11 the fact that in an indirect way you are

 12 considering fertilization effects or absorption

 13 basically of nitrogen.

 14 DR. HUBBELL: It's not fertilization. It's

 15 absorption. It's how much can be taken up.

 16 DR. WEATHERS: And it affects the trade-off

 17 curves.

 18 DR. HUBBELL: That's in there. That part is

 19 well described.

 20 DR. WEATHERS: Doesn't satisfy Dale yet.

 21 DR. HUBBELL: It's not his issue.

 22 DR. JOHNSON: The Neco term, as I understand

 23 it, the purpose of that is to calculate how much

 24 acidification in the water is going on. So it's

 25 not really designed, I don't believe, to try to

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 1 address this potential unintended benefit. I don't

 2 think it's relevant.

 3 DR. RUSSELL: What page did 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 terrestrial ecosystems

 7 are nitrogen limited.

 8 DR. COWLING: Tara, let me try in a gentle

 9 way, if you look at page 4-45 the beginning of that

 10 paragraph there says: "In certain limited

 11 situations additions of nitrogen can increase

 12 rates." I think both Dale and I were offput, you

 13 might say, by "in certain limited situations." And

 14 if you compare that with what Dale just suggested

 15 about I said essentially all forests and he

 16 suggested most and I agreed with him that most is

 17 better.

 18 We ought to take away essentially now, but

 19 it's the tone in which detrimental and beneficial

 20 effects on growth were dealt with. And what you

 21 sought to do was to say that this PA deals only

 22 with unmanaged systems. And I think all of us in

 23 the forest community of this CASAC panel believe it

 24 is better, as Dale put it, to have a balanced

 25 perspective.

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 1 There are benefits that occur in all forests

 2 or in terms of growth; and of course Class I

 3 wilderness areas are supposed to be maintained in

 4 perpetuity for enjoyment as they 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 changed. And it will

 8 always be changed so long as there are as many

 9 people here that are as ambitious as most of us are

 10 to use natural resources and to enjoy them.

 11 So it's a question of tone more than a

 12 question of absence of acknowledgment 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 acidification effects of

 18 aquatic ecosystems in sensitive areas.

 19 DR. HUBBELL: I think we don't disagree that

 20 we certainly can do more work on tone. I will

 21 reflect that in D.

 22 One of the things that concerns me, going back

 23 to your precise uses of language, the word

 24 "positive" has many meanings, and 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 there are increases in

 2 growth that occur almost everywhere, 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 those are positive

 6 effects implies that they are good in some way as

 7 well as being in the numerical sense positive.

 8 DR. COWLING: I don't mention 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, how I read this is if

 17 you go to page 4-46, as Ellis just brought up, much

 18 of the tone there, it's mainly the tone.

 19 DR. JOHNSON: It's the tone and the emphasis

 20 because all of a sudden when we're talking about

 21 growth in ponderosa pine forests, we're going to

 22 spend a lot of time on that because it's a negative

 23 connotation. When we talk about the carbon

 24 sequestration and so forth, well, that doesn't

 25 count because we're not going to do more

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 1 fertilization. We're not going to count that

 2 'cause we're parsing in that way. 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 that.

 6 DR. JOHNSON: Of course you can.

 7 DR. GREAVER: There is so many effects of

 8 nitrogen and sulphur and we really have focused in

 9 on aquatic acidification. I don't know how we

 10 choose one nutrient-related effect, carbon, and

 11 emphasize it more without emphasizing lots of other

 12 effects more. I don't know.

 13 DR. JOHNSON: Well, if you don't want to do

 14 it, you don't want to do it, but I'm going to

 15 continue to raise the issue.

 16 DR. GREAVER: I don't know that that will

 17 satisfy. We can certainly change 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 worry about that,

 21 Tara. I mean, this is something that I think the

 22 panel can discuss because I think we're not

 23 necessarily saying that -- because 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 sensitive lakes.

 3 Rich, you're about to say?

 4 MR. POIROT: Well, it seems to me that there

 5 might be a little bit more detail in this response

 6 than it really warranted by the charge question.

 7 Just, for example, I don't know that we need to

 8 know all of the fertilization rates of all of the

 9 crops and so on and so forth.

 10 It just feels like we waited 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 condensed 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 adequacy of the current

 17 standard is the question. Are we saying the

 18 current standard is good because 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 minute, we got the whole

 23 thing wrong. So I'd like to see this --

 24 DR. JOHNSON: I've been saying this for the

 25 very first time --

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 1 MR. POIROT: I recognize that.

 2 DR. JOHNSON: -- I've been ignored throughout

 3 the whole thing. So I'm going to keep on saying

 4 it.

 5 If you don't want to -- my attitude toward

 6 these kinds of things is I don't expect to prevail,

 7 but I don't expect to shut up either. So I'll keep

 8 telling you what I think. So you can do what you

 9 want, but I'll continue to say what I'm going to

 10 say.

 11 MR. POIROT: All right. All I'm saying is I

 12 think this is longer and more detailed than is

 13 warranted for the question.

 14 DR. RUSSELL: And I would agree with that.

 15 Actually, I liked what Ellis first said was that

 16 some of the issue is the phrasing when you're

 17 saying "in certain limited situations," you know,

 18 that's probably not appropriate. And I think

 19 that's the sort of the thing that 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 sort of tighten up the

 24 response. And what Dale has said as to specific,

 25 you know, you can bring up a specific 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 sentences. "Thus the

 4 principal challenges in this PA document are to

 5 assess the adequacy." I was thinking of Karen

 6 Martin when I wrote this. "To assess the adequacy

 7 of current scientific knowledge about both

 8 beneficial and detrimental effects of airborne

 9 nitrogen and sulphur and to explore options for an

 10 NAAQS-based system of air quality management that

 11 will protect acid-sensitive aquatic ecosystems

 12 from" -- and I chose the phrase that you had used

 13 -- "disruptions in ecosystem structure and

 14 functions that are important to the people of this

 15 country in regions where annual rates of deposition

 16 are in the order of magnitude of what they are in

 17 the unmanaged regions of our country." So if

 18 you're thinking about shortening, I call attention

 19 to the effort to have a reminder of what this

 20 document is all about.

 21 DR. HUBBELL: The one thing 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 doesn'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 never answered in

 2 here. And given that in your last target -- in

 3 your last response to us you told 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, would 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 your advice to us and

 10 no longer think it's adverse, then that ought to be

 11 said. If not, then that ought to be said as well.

 12 DR. RUSSELL: I think we're looking at this

 13 that we really need to rethink the response to this

 14 one because specifically how does 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 demonstrated that the nitrogen

 21 and sulphur deposition is having detrimental

 22 effects to sensitive ecosystems. I don't think

 23 there is any disagreement on this 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 to retain the present

 3 standard as well and that should be discussed here,

 4 it needs to be -- it should be discussed here.

 5 DR. HUBBELL: We have a separate charge

 6 question.

 7 DR. JOHNSON: This is what I have in my

 8 individual comments, is the purpose 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 that for an answer?

 13 DR. JOHNSON: No what?

 14 DR. RUSSELL: Well, the ISA was, as you might

 15 put it, a dispassionate -- providing 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 acid deposition from

 21 NOx and SOx at this point. At this point this

 22 document is the Policy Assessment, essentially

 23 providing an assessment of various policy

 24 alternatives to go forward, but as part of that, it

 25 is restating that yes, they have shown that there

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 1 is -- that there are detrimental effects from

 2 current levels of NOx and SOx on the acidification

 3 of sensitive waters; and that there are also the

 4 other effects, both positive and negative, that

 5 they are not able to quantify or not quantifying at

 6 this time in terms of setting a standard. I think

 7 that's about it.

 8 I mean, you guys if you want to be more

 9 precise as to what -- what vehicle 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 very 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 focus in on those

 20 areas that are most sensitive and exclude trying to

 21 do too much protection in those that are not

 22 sensitive. We're not doing anything to try to

 23 explicitly deal with nutrient enrichment, either

 24 positive or negative, in this particular set of

 25 options that we've laid out.

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 1 And, you know, again, we're trying to

 2 acknowledge that there are these -- again, we can

 3 fix the language and tone and so forth, but

 4 ultimately these standards really 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 there is all this

 8 controversy as to what's the appropriate thing to

 9 do with that. But, again, we're trying to be very

 10 specific that we are focusing on adverse effects

 11 that are occurring due to aquatic acidification.

 12 The other pieces are not as recognized. And

 13 in dealing with adequacy it's still, again, I think

 14 the general conclusion was even given the fact that

 15 there are these potential productivity effects

 16 occurring in forests that there are still systems

 17 that are sensitive and are seeing 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 because they're getting

 22 these productivity effects, it's not adequate in

 23 all locations. The aquatic acidification is trying

 24 to deal with that in a site-specific way and we

 25 don't have a nutrient enrichment 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 protection.

 3 DR. JOHNSON: So you don't think that

 4 protecting aquatic -- you think a standard to just

 5 do one thing and not consider unintended

 6 consequences --

 7 DR. HUBBELL: It's not not considering

 8 unintended consequences. It's recognizing that

 9 we're trying to focus the impacts on these

 10 particular aquatic acidification problems. That's

 11 the focus. Again, we're acknowledging anything

 12 having to do with nitrogen is going to have an

 13 impact, obviously, that's why we point that out.

 14 But, again, we're focusing on the adverse effects

 15 in the aquatic acidification systems.

 16 We had this discussion last time, do you need

 17 to then say, okay, well, here is the extent of all

 18 the areas that are going to benefit from it and

 19 here are all the areas that will not benefit from

 20 it? It's not something we felt was doable, number

 21 one, but it's not necessarily clear what we would

 22 do with that information if we had it.

 23 In other words, if we found that there was a

 24 reduction in beneficial fertilization in a small

 25 number or even a large number of forests, the

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 1 questions of what you do with that information when

 2 the standard is intended to protect against adverse

 3 effects that, again, becomes a policy judgment.

 4 I'm just not sure what we would do with that

 5 information. I'm not sure it would change our

 6 overall approach.

 7 DR. JOHNSON: The global carbon 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 you think -- as Rich

 11 said, I look at this, and I think we can shorten it

 12 and I do believe that they -- that 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 your example that on,

 16 what was it, page 435 that might change the flavor

 17 and might include more discussion 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 4-44 -- 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 thought there was a

 3 possibility of keeping the existing standard and an

 4 additional standard. So somehow the word

 5 "alternative" kind of implies here it's replacing

 6 what you have with something new, 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 "alternative" would be

 12 replace "existing." We had that discussion

 13 yesterday, three hours, two, adding on top of that

 14 the long-term acid deposition standard. So I'm

 15 thinking the word itself "alternative," could we

 16 say "potential additional and/or 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 the question

 25 understanding it could be an additional or -- well,

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 1 actually, the alternative would be this and that.

 2 Lauri.

 3 MS. CHESTNUT: Looking back at the question, I

 4 was having the same feelings as Rich about that

 5 hasn't quite been responsive here, but it seems

 6 like there is three questions here and this is all

 7 about question number four, about 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 standard to protect against

 11 adverse effects.

 12 So maybe we can -- it seems like we should

 13 answer two and three succinctly that they've --

 14 that the current standards, you know, they've

 15 demonstrated that the current standards do not

 16 affect -- protect against adverse effects of

 17 aquatic acidification at current -- under current

 18 conditions.

 19 DR. COWLING: We'll work on it.

 20 DR. FREY: Can I just for answer two and

 21 three, the answer is yes and that's all that needs

 22 to be said.

 23 DR. RUSSELL: Do people go with 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 agree that it seems

 2 that those questions are asked and answered in

 3 different ways in different other questions here

 4 like 24. So we respond to this question, you know,

 5 in other answers. So those questions I think are

 6 asked again in question four, for example.

 7 DR. RUSSELL: Question 24 is if we recall this

 8 question regarding the conclusion section alone.

 9 DR. WEATHERS: Right.

 10 DR. RUSSELL: I think here we say yes. And

 11 question number four we can refer back to the

 12 answer here. So what we're going to do is go with

 13 2-A and 3, go with yes.

 14 Ellis, you know, as specific as you can in

 15 terms of the document you currently 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 five. Praveen.

 21 DR. AMAR: Yes, we need a minute to read it or

 22 should I just explain what's in it?

 23 DR. RUSSELL: Explain, give us a minute to

 24 read it.

 25 DR. AMAR: The answer with input 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 thought 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 to say about how the

 7 second draft is better than the previous one. It

 8 has comments from me that it still doesn't go far

 9 enough. And then Myron sent the third paragraph,

 10 which has more to do with the cycling of the notes

 11 and then NOy and cycling of SO2 not being treated

 12 correctly here.

 13 The fourth paragraph should 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 hindcasting of AAPI

 17 with data from the past. Which I 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 approach here. 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 doing well. In the

 2 end we say it's doing well. In between three

 3 things here is where we go. Dr. Myron has the

 4 language as submitted with minor editorial changes.

 5 And Naresh put in the end as it was said.

 6 Early in the first sentence I say very well

 7 thought out and I there were exceptions. I took

 8 the word "very" out and said "well thought out."

 9 DR. DRISCOLL: Can I make a wording

 10 suggestion?

 11 DR. RUSSELL: Yes.

 12 DR. DRISCOLL: So on the fifth paragraph, a

 13 couple cases, third line towards the end of the

 14 paragraph, the word "hindcasting" is used. I don't

 15 think we should -- we should not use that word

 16 because it usually has a modeling connotation.

 17 So I would say something is tested by the use

 18 of historical data, historical water chemistry data

 19 or historical water chemistry observations to make

 20 it more specific and not confusing. Is that okay?

 21 DR. AMAR: Okay.

 22 DR. RUSSELL: He says "historical water

 23 chemistry data."

 24 DR. AMAR: Pretty much evaluation of models

 25 from the past data.

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 1 DR. MITCHELL: We should say "historical

 2 data." It's more than just water data.

 3 DR. RUSSELL: So.

 4 DR. MITCHELL: I'd take out 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 measurements of ANC

 8 available for some aquatic systems."

 9 DR. RUSSELL: So what did you want?

 10 DR. MITCHELL: Take that sentence out. That's

 11 fine. Probably say there were such measurements,

 12 just say "reported data are available."

 13 DR. RUSSELL: Naresh.

 14 DR. KUMAR: I have a question for a

 15 different -- you want to continue 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 that 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 in charge 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 tight and I'll

 3 remember.

 4 DR. NUGENT: What was the charge question?

 5 DR. FREY: Twenty-one. And actually could

 6 say, "Evaluate robustness using sensitivity and

 7 uncertainty analysis and more uncertainty

 8 analysis," because I think that's -- I think the

 9 panel had some viewpoints about moving toward

 10 quantitative uncertainty analysis and not just

 11 sensitivity analysis. That's good.

 12 DR. RUSSELL: And I'd probably say -- this is

 13 wordsmithing. Never mind. Other things?

 14 DR. HUSAR: Could it be recognized in Chapter

 15 7, which is the full uncertainty analysis rather

 16 than just particular?

 17 MR. McNAMARA: Mike, please.

 18 DR. HUSAR: Instead of referencing pointing to

 19 questions 14 and 21 specifically, how about

 20 pointing to the Chapter 7, which is the full

 21 uncertainty, sensitivity chapter 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 suggestions to that

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 1 chapter. I don't think we can refer them to that

 2 chapter because that chapter doesn't have what we

 3 want.

 4 DR. FREY: If I could add, I think there is

 5 also elements of this in Chapter 9. So I think if

 6 you try to say more, then you have to say a lot

 7 more and it may be best just to leave it the way it

 8 is here.

 9 DR. AMAR: Also I agree, right after "but one

 10 way," I think the way -- the spirit of the sentence

 11 says, it should say "an additional way."

 12 DR. RUSSELL: Yeah, that was my wordsmithing.

 13 I think a period and "an additional way."

 14 And also, Praveen, if you can integrate what

 15 Naresh said in a cleaner way.

 16 DR. AMAR: I think at a minimum this

 17 paragraph -- it came out the way we put it

 18 together, but I think it just goes about and some

 19 wordsmithing after that. For example, I think it

 20 talks here in the conceptual framework looks fine.

 21 We have said that more than once.

 22 DR. RUSSELL: Chris.

 23 DR. FREY: I have a different paragraph to

 24 comment on, which was the second paragraph, that

 25 starts with, "For example the framework of the

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 1 structure" and in the -- well, it's actually the

 2 first sentence, but it's the last half of that

 3 sentence on lines two to four of that paragraph it

 4 talks about that the framework does so in a manner

 5 that would not allow EPA to address and require

 6 reductions in the U.S. ammonia emissions. And I

 7 think that ammonia is not a criteria pollutant and

 8 it's not in the scope of the NAAQS to try to

 9 address reductions in ammonia emissions under this

 10 standard. So I don't know the purpose of having

 11 that there.

 12 I would suggest just taking out that clause.

 13 And so one could say that the structure takes into

 14 account ambient ammonia and its deposition and the

 15 revised treatment is an improvement over the first

 16 draft. I think the rest of it's okay pointing out

 17 that ammonia emissions will change 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 there.

 21 DR. AMAR: I know I wrote that. I wrote that

 22 in the first draft too. I think I was trying to

 23 find there an opportunity I think 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 implications are. I thought it

 2 was a precursor to what follows next. And we had

 3 had this discussion from a State perspective,

 4 emissions estimates perspective and it's providing

 5 an opportunity.

 6 DR. FREY: Yeah. I suppose I guess maybe the

 7 analogy with ozone where VOC emissions are

 8 typically controlled, but VOC is not a criteria

 9 pollutant. Maybe there is something there, but I

 10 don't know. It seems like either that shouldn't be

 11 there or maybe it needs to be expanded if that's a

 12 major direction that the committee 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 okay.

 18 DR. RUSSELL: Yeah. And, actually, I like the

 19 way Chris put it, the approach does take into

 20 account the deposition of reduced nitrogen.

 21 DR. FREY: And the revised treatment is an

 22 improvement.

 23 DR. AMAR: That's the point 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 have to specify that

 3 either.

 4 DR. AMAR: Periodically.

 5 DR. RUSSELL: "The approach accounts for the

 6 deposition" -- further up. "The approach accounts

 7 for the deposition of reduced nitrogen."

 8 DR. NUGENT: New sentence. Approach accounts

 9 for the deposition of reduced nitrogen and

 10 periodically.

 11 Okay. Other panelists' suggestions on this?

 12 Anything that we're missing?

 13 DR. DRISCOLL: There was a last paragraph that

 14 was another "hindcast" further down, if we change

 15 that to, right there, second to last line, third

 16 word we change it to "this analysis" or "this

 17 analysis of water chemistry data," something like

 18 that.

 19 DR. RUSSELL: Historical data.

 20 DR. DRISCOLL: Yeah.

 21 DR. RUSSELL: Question six.

 22 DR. AMAR: Myron had his input. What I have

 23 done, while we were reading, there are six

 24 paragraphs and we start saying the option one is

 25 simple, good, but not very useful. And that's a

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 1 merger with what Myron and I had written. It's

 2 overprotection for the least and underprotection

 3 for the most sensitive.

 4 And we go on record, the second paragraph, the

 5 ecoregion three approach is reasonable, but we do

 6 add that we recommend that the revised PA include a

 7 clear and more detailed description of this

 8 approach.

 9 And the third and fourth paragraphs are from

 10 Myron talking about ANC being consistent 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 think of something

 15 else.

 16 And then in the end between three approaches,

 17 2-A, 2-B and 2-C it says, "Cluster analysis seems

 18 to be provide the right balance between not

 19 detailed enough and too detailed." That is what we

 20 tried to do between Myron and myself.

 21 Hopefully, Myron, I got your input correctly

 22 in the right places.

 23 DR. RUSSELL: Rich.

 24 MR. POIROT: I'm just thinking, Praveen, that

 25 that comment about the need for clearer, more

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 1 detailed description of the approach 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 use that approach,

 5 aren't explained with sufficient 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 off the top of your

 12 head, would you? Discussion on clarity.

 13 MR. POIROT: You mean right now?

 14 DR. RUSSELL: We might be able to take

 15 something from the cover letter too.

 16 DR. WEATHERS: We also have some language in

 17 number 24 about that general language.

 18 DR. RUSSELL: You want to give us the

 19 language?

 20 DR. WEATHERS: Yeah, I think we have, "The

 21 justification, logic and necessity 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 Angela is typing that, I

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 1 think we also have to comment on 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 enough. Not detailed

 10 enough or too much detail. Maybe that's not the

 11 right word. Appropriate.

 12 DR. RUSSELL: How are we doing?

 13 DR. AMAR: I think making a selection in 2-B

 14 is better than the other in 2-A and 2-C.

 15 DR. RUSSELL: I was just thinking that might

 16 come up higher. What do people think?

 17 MS. CHESTNUT: Yeah, it kind of jumps around.

 18 DR. RUSSELL: Yeah. I might go further up and

 19 keep going, don't get rid of it.

 20 MS. CHESTNUT: Cut and paste.

 21 DR. RUSSELL: No, not even cut and paste.

 22 That still might be a fine concluding paragraph.

 23 And yeah, state something like right there, part of

 24 that paragraph. Actually, the first paragraph,

 25 likewise, the option of dividing the U.S. into two

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 1 regions.

 2 MS. CHESTNUT: Is it really two regions or two

 3 categories?

 4 DR. RUSSELL: Categories, okay, categories.

 5 Yeah, I think an appropriate word 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 really 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 thoughts? Actually, I

 16 hear some nodding that yes, maybe we're not there

 17 yet. Right now what we can say is we think one is

 18 too few, and I think we can also 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 that?

 25 DR. DRISCOLL: It's the full, 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 got the Goldilocks.

 6 DR. RUSSELL: Yeah, the Goldilocks. Would

 7 appear to provide too much complexity?

 8 DR. DRISCOLL: It's just an unnecessary amount

 9 of detail I would say. I don't think it's gaining

 10 that much from going to that many, that much

 11 unnecessary details, something like that.

 12 DR. WEATHERS: I would say it seems that way,

 13 because I think at this point we don't know. We

 14 don't know whether the approach can be applied.

 15 DR. DRISCOLL: We don't have details.

 16 DR. MITCHELL: I think a lot of us are fairly

 17 cold in this room. Is that moving 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 on this particular

 24 issue it would help us to be clearer to indicate

 25 that while you might support the Ecoregion III as a

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 1 spatial unit that you don't necessarily support

 2 using 87 of them individually? It seems like

 3 you're throwing out ecoregions as a spatial unit.

 4 DR. RUSSELL: Okay. Actually, when we add the

 5 XX up there that was supposed to -- we actually can

 6 add that detail. Option 2-D using ecoregion --

 7 because specifically option 2-D I think is the one

 8 that has --

 9 DR. HUBBELL: We use ecoregion 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 individually.

 13 DR. RUSSELL: Actually, option 2-D, which

 14 includes, dot, dot, dot?

 15 DR. HUBBELL: That's better. That helps us.

 16 MS. CHESTNUT: Even if that second paragraph

 17 has using the Ecoregion III boundaries is a

 18 reasonable approach.

 19 DR. RUSSELL: So do we want -- how do we want

 20 to say that?

 21 DR. WEATHERS: Isn't it that 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, have -- are feasible.

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 1 It's really about using ecoregions versus using

 2 political boundaries or some other distinctional

 3 grouping.

 4 MS. CHESTNUT: Yeah. I think they're using

 5 the ecoregions either way. It's just can they

 6 be --

 7 DR. WEATHERS: Right.

 8 MS. CHESTNUT: -- lumped into more coarse

 9 categories?

 10 DR. HUBBELL: To try to help a little bit,

 11 again, last time we met we tried to distinguish

 12 between spatial aggregation areas. The ecoregion

 13 is a nice unit of spatial aggregation. The

 14 question then is how do you use those to come up

 15 with classifications based on sensitivity? That's

 16 questions do you just leave them by themselves and

 17 say each one represents its own sensitivity class;

 18 or do you try to aggregate them in some other way,

 19 which represents the other three methods, the

 20 clustering; the binary, yes or no, you're

 21 sensitive; or one nation?

 22 And I think what we're looking 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 for aggregating these

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 1 ecoregions into these classification groups?

 2 DR. RUSSELL: Yes.

 3 DR. SCHEFFE: Important reason for aggregating

 4 is because certain ecoregions have a very limited

 5 dataset. And so there could be a scenario where

 6 perhaps we do this clustering where 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 results in the

 11 critical loads that would be used for the different

 12 sensitivity classes.

 13 DR. HUBBELL: The critical load would be

 14 calculated over that larger grouping, that would

 15 then be used to establish that depositional load

 16 metric that says here is the critical load that

 17 protects 90 percent of the particular water bodies.

 18 But when they calculate the things like ammonia and

 19 TNOx and TSOx that would be at the ecoregion or

 20 below level.

 21 DR. WEATHERS: I don't know what the language

 22 is, it seems like we agree with the approach of

 23 using ecoregions and the way in which they're

 24 aggregated may be dependent upon 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 clustered; is that

 4 right?

 5 DR. HUBBELL: Well, there is two pieces that I

 6 mentioned yesterday. One is the data issues. Do

 7 we have enough data to be able to appropriately

 8 characterize the distribution of 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 significant difference

 12 in the critical loads between the groups that would

 13 recommend keeping them separate rather than

 14 collecting them together in one classification.

 15 DR. WEATHERS: We don't know what the

 16 showstoppers are, that's part of what we want from

 17 you is to know what the showstoppers are.

 18 DR. HUBBELL: I think it would be very helpful

 19 for you to lay that out and that 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 want to go on this?

 23 And I'd say, "But its weaknesses appear to be too

 24 many." Again, we're not sure yet.

 25 DR. WEATHERS: I guess in the second sentence,

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 1 it's the rationales and the limitation, the data

 2 limitation or analysis limitations must be better

 3 articulated or strengthened. We 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 yesterday as well on the

 7 second paragraph that the one-nation approach and

 8 maybe even the too-sensitivity approach are useful

 9 to actually see. Even if we don't advocate them,

 10 they're useful contracts. I would think that -- I

 11 agree with that.

 12 DR. RUSSELL: If we go down, I think

 13 conceptually we like the clustering approach.

 14 DR. WEATHERS: Ecoregion.

 15 DR. RUSSELL: Ecoregion clustering 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 somewhere. And then also

 20 bringing up Rich's point, we also -- having the

 21 example of a one or two-region -- one or two-region

 22 approach for contrast is also valuable.

 23 DR. WEATHERS: Then maybe just putting while

 24 the first approach while its weaknesses appear to

 25 be -- and nonetheless we find it useful reference

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 1 or useful contrast.

 2 DR. RUSSELL: So go over there nonetheless,

 3 make it a real sentence afterwards. 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 think we need the rest

 8 of this option.

 9 DR. RUSSELL: We can get rid 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 making a comment on 2-D.

 14 Basically, we don't know until we have more

 15 information. I don't feel strongly about it. And

 16 somewhere I think in maybe even that 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: Sensitivity categories.

 21 DR. RUSSELL: Yeah, spatial -- you call them

 22 spatial categories.

 23 DR. HUBBELL: It's sensitivity categories.

 24 DR. RUSSELL: Sensitivity categories.

 25 DR. HUBBELL: Because they don't have to be

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 1 contiguous with each other. Clusters can have

 2 pieces everywhere.

 3 DR. RUSSELL: Okay. Praveen, I think you can

 4 work on editing that down. I think 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: Generally we like the

 13 critical loads concept. It's logical and

 14 appropriate. And we like that it links all the

 15 necessary components and includes also reduced

 16 forms of nitrogen.

 17 MR. McNAMARA: I'm sorry, could you speak

 18 closer to the mike, please. Thank 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 -- but proposals say it

 22 would be useful to look toward the models to

 23 evaluate ecosystem effects of atmospheric

 24 deposition. And we would like to rephrase maybe

 25 this question and ask is the proposed methodology

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 1 for obtaining the BCo values correctly described

 2 and what the panel option -- if we have to rephrase

 3 it because maybe it is not needed. And continuing

 4 that, we want the panel's opinion from

 5 extrapolating the knowledge gained for the

 6 Adirondacks lakes and southern Appalachian streams

 7 can be linked to the rest of the U.S. waterbodies.

 8 In regard to B we decided that filtering of

 9 lakes and streams with high concentrations of

 10 organic acids and with low historical ANC values

 11 should be avoided since these waterbodies are often

 12 highly sensitive. However, waterbodies that have

 13 clear impact of mine drainage can be eliminated.

 14 So that's question seven.

 15 DR. RUSSELL: Comments? People 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 to recommend not

 20 eliminating sensitive lakes or what?

 21 DR. RUSSELL: Say that again.

 22 DR. KUMAR: 7-B, so we are recommending that

 23 highly sensitive lakes not be eliminated?

 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 think I was the one

 4 who recommended it and I guess my thinking is just

 5 for, you know, transparency sake. I understand the

 6 issues associated with that, but there are lakes

 7 that are naturally acidic or have naturally

 8 background low-acid neutralizing capacities. So if

 9 you target 50 or 100 microequivalents per liter,

 10 they may have never been at that value

 11 historically.

 12 So my thinking was that you also have this --

 13 you have this target percentage that you're going

 14 to try to protect 95 percent, 90 percent,

 15 75 percent. And those values -- those lakes or

 16 streams that were eliminated could be incorporated

 17 on the percentage. There are ones that are not

 18 being considered. So why not include it in the

 19 analysis, flag them, say that they were either

 20 naturally acidic because of low supply of base

 21 cations or high inputs of organic acids or

 22 whatever -- or another mechanism, 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 that are not -- that

 3 are not going to be able to make this target value,

 4 whatever it is, acid neutralizing capacity of 50 or

 5 100.

 6 So I just advocated that, you know, with the

 7 idea of greater transparency, so that was my

 8 thinking. I mean, I think we had a few comments,

 9 but I didn't hear too many other comments opposing

 10 that. If it creates problems for 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 region 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 front of me, it's hard

 19 to know for sure. But let's take Florida, for

 20 example, and if we said, you know what, we're going

 21 to include all these naturally acidic lakes in

 22 Florida and say it was 20 percent, that would mean

 23 that we would be basically -- if we didn't do that,

 24 it would mean we would have a zero critical load or

 25 negative, which is very difficult to figure out how

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 1 to express that.

 2 And if we want to have a constant percentage

 3 of lakes protected across the country, then we

 4 would have to base it on trying to 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 acidic lakes.

 10 So it really puts us in a bind in terms of how

 11 to think about making this still a national

 12 standard that focuses on sensitive and responsive

 13 lakes.

 14 DR. DRISCOLL: It seems to me you're either

 15 flagging them on the front end or you're flagging

 16 them on the back end. What difference does it

 17 make?

 18 DR. HUBBELL: Because flagging 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 think you should adjust

 24 it. You just flag them and adjust it. They're

 25 naturally acidic. You don't worry about them,

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 1 okay. You've got an excuse, you know, the dog ate

 2 my homework.

 3 DR. HUBBELL: You don't get any protection in

 4 Florida because if you flag that and say there is

 5 no reasonable critical load that we can use in

 6 Florida, it's just not -- I mean, you're -- to me

 7 this is actually making it less transparent because

 8 at the end you're saying we have a critical load

 9 that we determined would protect 80 percent of the

 10 lakes in the area, but we're now going to say we

 11 have to somehow after we've done the distribution

 12 adjust that percentile.

 13 It just seems like it's better to be very

 14 clear and say we're taking these lakes off the

 15 table. We can show with what that full

 16 distribution is before we do that. We can show

 17 here is the distribution before you filter; here's

 18 the distribution afterwards and this 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 guess we agree to

 23 disagree. I imagine from, you know, states in the

 24 northeast that are naturally acidic you're going to

 25 get cost wise for those folks because, you know,

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 1 there are a large numbers of lakes that probably

 2 had ANC values historically below 50 and they

 3 clearly have been impacted by acidic deposition.

 4 DR. HUBBELL: They'll still 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 understand the

 8 administrative end of things better than I do. I

 9 just think from a simplistic -- making it

 10 simplistic as well as transparency that's why I

 11 made my suggestion. It's a bad idea. I come up

 12 with bad ideas all the time. So I understand that.

 13 DR. RUSSELL: Rich and then Kathy.

 14 MR. POIROT: I was just wondering, 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 impacted by mine

 18 drainages; however, you know, advance elimination

 19 of lakes in these other categories should be

 20 considered more carefully because 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 much 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 bad idea to filter them

 2 on the front end. I think we'll get lost in

 3 details. So it's better off just 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 elimination of other

 8 waterbodies, let's get a little bit more specific.

 9 I was just saying not only further considered, but

 10 also the rationale, better explained and with

 11 examples given preferably in a distribution point.

 12 I'm not sure -- I mean, essentially 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, bring in the filtered,

 18 unfiltered and what would happen to the ones that

 19 got filtered out if you actually attained a

 20 targeted ANC for the remaining population.

 21 DR. RUSSELL: I don't think 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 "filtering" has other

 2 meanings too. Do we want to say removal of lakes

 3 from the sample? It's not filtering.

 4 DR. WEATHERS: From the database or from

 5 analysis.

 6 DR. RUSSELL: Removal.

 7 DR. FREY: We're not going to eliminate

 8 waterbodies.

 9 DR. RUSSELL: No, it's from the analysis after

 10 removal.

 11 MS. CHESTNUT: From the target or from the --

 12 DR. WEATHERS: I think that's part of what's

 13 confusing. I wasn't clear whether Charlie and

 14 Bryan were talking about the same thing. We want

 15 to see the database of all lakes 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, Charlie, whether you

 21 were advocating doing the critical loads analysis

 22 on a whole database or just making 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 natural characteristics

 5 that don't allow them to meet the 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 with that.

 9 DR. WEATHERS: I agree it's now on there.

 10 DR. HUBBELL: We're all on the 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 as sensitive because

 16 they had all -- or as responsive because they had

 17 all these other factors that were 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 and streams with high

 22 concentrations of organic acids or low historical

 23 ANC should be retained in the database, but not

 24 included in the critical loads analysis.

 25 DR. RUSSELL: Do we want to say that

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 1 specifically?

 2 DR. WEATHERS: No, it would be better to leave

 3 it.

 4 MS. CHESTNUT: Could we just say the panel's

 5 concerned about removing lakes that are --

 6 DR. RUSSELL: Yes. That certainly is --

 7 MS. CHESTNUT: Because they are still

 8 sensitive to acidification.

 9 DR. KUMAR: What do you mean by the highly

 10 sensitive sites in the last sentence, the often

 11 highly sensitive sites?

 12 DR. BYTNEROWICZ: Waterbodies, yes. Charlie,

 13 that's what you have, sensitive sites?

 14 DR. DRISCOLL: Yeah, they have historically

 15 low rates of ANC or base cation supply. They are

 16 highly sensitive. They are below -- historically

 17 they're below the target value, whatever it is, 50

 18 or 100. So they would never get 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 definitely 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 it's worth, the

 2 exceptional event rule for ozone and PM to five

 3 does the filtering at the tail end. In other

 4 words, do the calculation on the exceedances or

 5 compliance, but then at the tail end say, oh, this

 6 is not applicable or not to be considered for this

 7 and that reason, which would go along with what

 8 Charlie was saying. That you just perform and

 9 excuse it for good reasons. That's fine. I'm not

 10 sure it is exactly the same situation, but this is

 11 just, you know, for compatibility 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 eventually get translated

 15 into atmospheric concentrations to be able to

 16 recognize these highly otherwise impacted

 17 waterbodies that we would not expect 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 lakes that are of

 22 concern, but we're not going to base our critical

 23 load calculation on that set that are not likely to

 24 be responsive. That's what we need to preserve.

 25 Otherwise, I think it's going to get to the point

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 1 where we can't -- it's going to be 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, you need to make sure

 5 that that's stated. I don't think it's stated very

 6 clearly in the document as it stands that there are

 7 a certain fraction of lakes that are highly

 8 sensitive that have been impacted and, therefore,

 9 would derive some benefit, but below this 50 or 100

 10 threshold and then make it problematic to use that

 11 for a standard with those systems. 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 makes sense, utilizes

 18 best available knowledge which comes from the CMAQ

 19 outputs. We know that there are limitations here.

 20 And we also think that potentially NADP chemistry

 21 and prism precipitation results could be utilized.

 22 And due to high ammonia deposition velocity,

 23 steep concentrations of ammonia concentrations near

 24 the source areas can be expected. Therefore,

 25 averaging reduced nitrogen concentrations over

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 1 larger areas may lead to missing some potential

 2 problems near the sources and also possibility for

 3 some significant ecological effects. So,

 4 therefore, we thought that option two is preferable

 5 since it allows for additional spatial refinement

 6 of sensitive areas. And we also think that a

 7 better understanding of spatial and temporal

 8 distribution of reduced nitrogen, especially

 9 ammonia, in the U.S. is critical and, therefore,

 10 efforts should be continued to assure the

 11 nationwide monitoring of ammonia, especially in

 12 remote areas where you have multiple sources of

 13 ammonia emissions.

 14 DR. RUSSELL: And I'd change ammonia, if I

 15 might, to reduced nitrogen.

 16 DR. BYTNEROWICZ: Yeah, that'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 panel comments?

 22 Question nine. That would be Naresh.

 23 DR. KUMAR: I had input from Praveen and Rich

 24 in addition to mine on this one. The first

 25 paragraph is what I had discussed yesterday. The

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 1 second one is from Praveen and the other is from

 2 Rich.

 3 DR. RUSSELL: Okay. One thing 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 account 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 around. I've got a

 14 couple calls in on things. I mean, again, you

 15 know, sulfate was -- our emphasis has been on

 16 particle -- on inhalable particles so much that

 17 there is some logic to why nitrate's covered and

 18 not sulfate.

 19 DR. MITCHELL: I guess I have one suggestion

 20 for revision though of how to emphasize what EPA

 21 should possibly attack on this. I guess I -- I

 22 would prefer looking at some other measurements

 23 that have the similar -- like CASTNET does not have

 24 all the chemistry associated with the CMAQ model,

 25 but at least doing some comparisons on how stable

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 1 those ratios of chemical species are over time. I

 2 think that would be a more helpful and more useful

 3 analysis than doing a number of different CMAQ,

 4 CMAQ model runs, 'cause that just 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, just to see how some of

 9 these ratios could vary over time using other data

 10 which could be available and that would just kind

 11 of be a nice link in terms of CMAQ with other types

 12 of efforts.

 13 DR. WEATHERS: I agree with Myron. That's my

 14 comment to things --

 15 DR. MITCHELL: I guess that was a section

 16 here, I'd like to see that.

 17 DR. RUSSELL: So time to punish you, give us

 18 about a paragraph on that, a short paragraph.

 19 DR. MITCHELL: Okay.

 20 DR. RUSSELL: Send it to Angela.

 21 DR. MITCHELL: I'll do that.

 22 DR. SCHEFFE: That would have to be

 23 communicated pretty clearly because 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'm thinking Richard,

 2 obviously, we don't want to make 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 chemical species and

 8 compare whether those ratios have been stable over

 9 time as kind of an inference that some of the

 10 ratios --

 11 DR. SCHEFFE: There might be some things we

 12 can do where we separate out, we can build a dry

 13 transference ratio and get it from that perspective

 14 perhaps. There might be some creative 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 certainly explore it.

 19 We'll do what we can, yes.

 20 DR. RUSSELL: Anything else on this one?

 21 Okay. Moving on, 10.

 22 DR. KUMAR: Can we go back to the third

 23 paragraph? I want Rich to explain that more

 24 because I don't think we got to hear that, I guess,

 25 whatever he said.

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 1 MR. POIROT: Well, the basic idea was to just

 2 suggest consideration of a modification to the TNOy

 3 calculation that would be based on nitric acid and

 4 particle nitrate rather than NOy. And one of the

 5 main reasons for suggesting that is that if it

 6 worked out, then all the necessary measurements to

 7 implement the standard are being made by CASTNET,

 8 methods now. So that was my reason 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 careful about putting

 15 too much weight on that correlation because it was,

 16 again, based on 12-kilometer individual grid cell

 17 comparisons rather than any kind of aggregation.

 18 It's not clear at all to me until we do some

 19 further analysis whether that correlation would

 20 still remain poor once you aggregate the higher

 21 level of resolution.

 22 The other thing to remember is we did not look

 23 at, another thing we want to do, is the correlation

 24 in the changes in deposition and the changes in

 25 atmospheric concentrations better correlated. In

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 1 other words, once you've changed NOx, for example,

 2 are the changes that you get in concentrations and

 3 deposition more closely correlate, which is really

 4 what we're interested in from a compliance stand

 5 point.

 6 So I don't want -- I just don't want to read

 7 too much into that one figure that was kind of a

 8 last minute figure that we put in. I just don't

 9 want to draw too many conclusions 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 see. I mean, because

 13 that is actually what the --

 14 MR. POIROT: You mean add that?

 15 DR. RUSSELL: Yeah, it's something that's -- I

 16 think we want to capture also the current analysis

 17 suggestion that nitric acid correlates better with

 18 the model deposition, but we recognize that there

 19 are issues due to spatial scales and how that might

 20 relate to response of deposition to emission

 21 changes. And that should be investigated.

 22 MR. POIROT: Okay.

 23 DR. RUSSELL: Do you feel that way? I can see

 24 that that's --

 25 MR. POIROT: My initial intent 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 monitoring network in

 3 place to implement it. We want that to be the

 4 reason that this can't go forward, possibly this

 5 alternative approach would allow that possibility.

 6 I wanted to recommend without pushing 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, there is a couple

 10 things that could go on here, the indicator could

 11 change from NOy to let's say total nitrate, with

 12 confidence in total nitrate more so than the

 13 individual nitrate and particle nitrate. And I

 14 just want to throw that out there, that that's a

 15 possible consequence.

 16 I actually wanted a response from Karen about

 17 that, because -- and I'm just wondering about the

 18 linkages back to Clean Air Act definition of NOx.

 19 And I think nitrate is certainly embedded in that

 20 definition in the Clean Air Act of NOx, but it's

 21 increasingly a smaller and smaller part of what we

 22 define as NOx in the Clean Air Act. Do you see any

 23 issues with that offhand, or would you like to

 24 think about it?

 25 MS. MARTIN: I think we need 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're not raising this

 4 issue on the broader question of how to define the

 5 indicator of the standard itself, are you?

 6 MR. POIROT: It's going to come around to

 7 that. However, let me try to --

 8 MS. MARTIN: It has the potential to over time

 9 say, for example, in the next review. But were you

 10 intending it now to carry over into this current

 11 review discussion of the definition of indicator

 12 itself?

 13 MR. POIROT: I think the possible parallel

 14 situation would be with the secondary PM standard

 15 in which the recommended indicator 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 and the resources to

 19 roll out this complete new PM light extinction

 20 network of methylometers and ethylometers

 21 everywhere. And, therefore, the indicator is still

 22 sort of PM light extinction, but it's estimates --

 23 it's a reconstructed estimate. So that's the kind

 24 of -- I consider it more of a subtle 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 ratio and then apply

 4 that to the total NOy. It's not going to match.

 5 So I think it actually would be -- if you change

 6 that transference ratio, it would then mean that

 7 you would change the atmospheric indicator;

 8 otherwise, they wouldn't correlate well.

 9 MR. POIROT: Yes. And then it would mean that

 10 you could make all of the necessary measurements

 11 with the existing CASTNET methods.

 12 DR. SCHEFFE: That's what I'm saying that it

 13 comes down to then the indicator then becomes total

 14 nitrate. I want people to be aware of that. I'm

 15 not saying that's a bad thing or a good thing.

 16 DR. HUBBELL: It has broader implications.

 17 MS. MARTIN: Its important to understand the

 18 implication of your comment. At the outset the

 19 desire was to define the indicator to be as

 20 parsimoniously defined as possible 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 and stop 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 gets at the very

 3 heart of the thought process that 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, again, as Rich was

 7 saying, it's a very big twist of the way that we

 8 have been considering -- you know, we went from NOx

 9 and defined fairly narrow NO2 to thinking about

 10 NOy, which is as complete as we can get, and now

 11 we're moving to a completely different component,

 12 which, again, may be tied to the deposition metric

 13 of interest, but is it fully capturing all the

 14 processes that we think are important to be able to

 15 make sure that when we control NOx, we're actually

 16 controlling the things that would reduce

 17 deposition. And that's why I think, 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 consequences, borrow

 21 Dale's phrase, but wouldn't have 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 evaluate both our

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 1 existing definitions of the transfer ratios and

 2 this alternative using similar metrics and that

 3 would allow us to give some idea what difference it

 4 makes and whether or not it gives an appropriate

 5 response.

 6 MR. POIROT: Works for me.

 7 DR. WEATHERS: Another possibility, what Myron

 8 was saying about CASTNET, in that way if you look

 9 at total nitrate and look at the transference

 10 ratios, we can compare the CASTNET deposition,

 11 estimated deposition with CMAQ and that's one of

 12 the things that we would also like to see.

 13 DR. SCHEFFE: Right. That is certainly more

 14 doable. Yes.

 15 DR. RUSSELL: Anything else? Okay. Next one.

 16 DR. NUGENT: So we are going to ask Rich to

 17 add this additional text, is that where we came

 18 out?

 19 DR. RUSSELL: I think so. Rich? Are you

 20 ready to add a little text to sort of summarize the

 21 discussions we just had or do you think it needs to

 22 be made in terms of --

 23 MR. POIROT: Yes. And I think the main thing

 24 we would like to add would be to evaluate whether

 25 this alternative TNOy would actually project into

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 1 the future, what you were saying before.

 2 DR. HUBBELL: There are three things that have

 3 come up. One is doing the CASTNET assessment,

 4 working back with that, say does using this measure

 5 allow us to get a better handle on the comparison

 6 observed with our model transference 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 affects the stability of

 10 the ratios. And then the third was to look at the

 11 changes in NOx and whether the correlation between

 12 NOy and the total deposition and nitrate -- total

 13 nitrate and total deposition whether those

 14 correlations change when you look at the changes in

 15 NOx and the changes in concentrations and

 16 deposition. Because, again, those are -- that's

 17 sort of an important metric for thinking about how

 18 good the standard is going to be is when you change

 19 NOx does that result in corresponding changes in

 20 the indicator and the deposition 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 correlation between NOy and

 25 deposition based on that one figure we provided

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 1 seemed very poor, but it was at the 12-kilometer

 2 resolution individual grid cells. 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 aggregation.

 6 And because spatial concentrations of NOy tend

 7 to be, you know, smoother and deposition tends to

 8 be more point specific, so once you average them

 9 out they may improve the correlations.

 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 be quick. That is

 16 Naresh.

 17 DR. KUMAR: Yes. If there is a prize for the

 18 shortest answer, I guess this should be it.

 19 DR. RUSSELL: Yes, shortest 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 here. We have a number

 24 of people who are leaving at noon.

 25 (Brief recess.)

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 1 DR. DRISCOLL: This section dealt with the

 2 appropriate ANC levels. My feeling was we were

 3 considering zero, 20, 50, 100, and based on aquatic

 4 effects literature, these are consistent clauses

 5 that have been established previously. And then I

 6 went on to indicate that the values 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 probably target values of

 10 somewhere between 50 and 100 are in the range and

 11 appropriate for this, so the first paragraph.

 12 The second paragraph essentially added by

 13 Dale, who is not here, so I did not really -- I

 14 only did minor edits on that, but I was thinking

 15 that really deals with soil acidification rather

 16 than aquatic ANC. And it would be good to get

 17 Dale's input, but I wonder if it would be better

 18 moved to the co-protection question 13 because it

 19 deals with issues of soil acidification and impacts

 20 on water systems.

 21 DR. RUSSELL: I would think so because this

 22 question is pretty specific to ANC.

 23 DR. DRISCOLL: Yeah, I would think so. But

 24 anyway that was his paragraph and I would recommend

 25 that we move it and try to incorporate it in

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 1 question 13.

 2 DR. RUSSELL: Sounds good. Actually, as

 3 people are coming back in, it may have been subtle,

 4 but what Charlie just said is one of those things

 5 that's fairly important for us to understand right

 6 now. In that what he is saying is that the

 7 appropriate range would not include 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 is 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 information provided.

 15 DR. DRISCOLL: Yeah, I tried to capture that,

 16 but maybe I wasn't very explicit. So I said

 17 something -- but I think we have to add in

 18 something to that effect.

 19 So maybe -- I say something about that the

 20 target ANC is an artificial value that there are,

 21 you know, at ANC values above that. There could be

 22 effects at ANC values below that. There will be

 23 some organisms that are highly insensitive and

 24 won't be impacted. So maybe what we could say

 25 after that, so that would be the one, two, three,

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 1 four, five, six, seventh line where the sentence

 2 that ends "low end of this range," 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 can take notes on what

 6 you're saying, help me again, I'm embarrassed to

 7 say, I am in question -- full disclosure -- I am on

 8 question 12.

 9 DR. DRISCOLL: First paragraph about two

 10 thirds of the way down, there is a sentence that

 11 ends "low end of this range." Maybe I'm looking at

 12 some words -- yeah, so on the left-hand side, "low

 13 end of this range," period, right there.

 14 So maybe we could say something like effects

 15 of acidification on aquatic biota are fairly

 16 certain at the low end of this range of ANC and

 17 decrease in certainty with increases 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 below 20 uncertainty is

 23 much lower. As you go between 20 and 50,

 24 uncertainty goes up, and 50 and 100 uncertainty is

 25 much more. So I'm uncomfortable just removing the

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 1 20 to 50 range and going with 100 range because of

 2 that.

 3 DR. AMAR: One question, Naresh, uncertainty

 4 about what?

 5 DR. KUMAR: The effects. There are adverse

 6 effects, but they are a lot more uncertain.

 7 DR. AMAR: You want to say that again? We

 8 have used the term here.

 9 DR. KUMAR: What I'm saying is because there

 10 is so much uncertainty, why have 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 last 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 target values that were

 19 set. I mean, they're sort of round numbers, you

 20 know, zero, 20, 50, 100. Now, are you saying that

 21 that should be opened up and maybe you could

 22 consider alternative values like 30 or 40 or

 23 something like that that's between 20 and 50 range?

 24 DR. KUMAR: What I'm saying is that they

 25 suggest that there are adverse effects at different

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 1 levels and below 20 there is less uncertainty on

 2 adverse effects. As you go at higher ANC between

 3 20 and 50, there is more uncertainty; above 50

 4 uncertainty is a lot more.

 5 And based on that information, I don't see a

 6 reason that why should we eliminate the 20 to 50

 7 range when you say in the last sentence that it

 8 varies 50 to 100 when that's the range where we

 9 have the highest uncertainty on adverse 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 reason --

 14 DR. RUSSELL: It sounds like it's between 20

 15 and 100. Chris.

 16 DR. FREY: I'm a little confused about the use

 17 of uncertainty when you go from a low to higher

 18 number. Is it not the case that the higher number

 19 is more protective? So I think the uncertainty has

 20 to do with the incremental protection from going

 21 from one number to the next. So 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 that 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 remains for the

 4 Administrator is does she want to provide a

 5 requisite level of protection or widely

 6 overprotected. That's a very clear distinction.

 7 And I don't see why we should tell that eliminate

 8 20 to 50 when we know that that's more certain, I

 9 guess the adverse effect occurring in that range.

 10 DR. HUBBELL: Can I ask one clarification on a

 11 particular word in this paragraph? In the fourth

 12 line it says, "So any specific target ANC is an

 13 artificial value." And we're trying to figure out

 14 how do we interpret that? I think what you're

 15 saying is that you can't --

 16 DR. DRISCOLL: Arbitrary. It should be

 17 arbitrary. This was late at night 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 those 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 back to the sentence,

 24 Angela, that you inserted effects? Can we say,

 25 "Adverse effects are fairly certain 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 ANC are more

 4 uncertain -- become more uncertain at higher ANC

 5 levels.

 6 DR. FREY: Maybe another way of saying is that

 7 at 20 or 50 there is a high degree of confidence

 8 that that provides some level of protection. As

 9 you go to 100 there is maybe less confidence that

 10 that provides substantially more protection.

 11 MS. CHESTNUT: Additional protection. But

 12 that concept of that incremental -- incremental

 13 protection of going higher.

 14 DR. FREY: How did that happen?

 15 DR. RUSSELL: Magically. So we still are left

 16 with the 50 to 100 recommendation. And I would

 17 actually add, you know, one of the things that I

 18 would also think we need to consider is the

 19 uncertainties inherent in this process, not just

 20 the protection that each of these levels provides,

 21 but also the whole process. So maybe that is all

 22 captured in percent of lakes protected or some

 23 other portion of what a standard might be.

 24 DR. HUBBELL: And just to interject one

 25 moment, that was the intended difference between

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 1 justifying the target ANC and justifying what your

 2 AAPI level itself would be was to capture the

 3 process uncertainties.

 4 This was really -- the target ANC was supposed

 5 to be focused on what is the scientific support and

 6 the information on adversity related specifically

 7 to if you could get with certainty those target ANC

 8 levels, which ones would you go after.

 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 literature. I also

 13 think that there are water at or near 20 is highly

 14 susceptible to episodic acidification and could

 15 have results from that as well.

 16 So, you know, I understand where you're coming

 17 from, but when I tried to write this, I was looking

 18 at these specific values that appear to be advanced

 19 in the report and I was using those as draft target

 20 levels. So that's why I focused on zero, 20, 50,

 21 100, round numbers. If we want to open that up

 22 further and consider the full range of values, you

 23 know, 37 or 62 or things like that, 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 suggest 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 to accommodate that

 5 and then argue about the advantages or

 6 disadvantages of, you know, 27 versus 42 or

 7 something like that.

 8 DR. KUMAR: I'm not suggesting that. As I

 9 said, this is not my area of expertise, but I was

 10 just going on what is in the document. It said

 11 below 20 there are impacts which are certain.

 12 Between 20 and 50 you could have 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 there are impacts

 16 which are more certain. So I don't see any reason

 17 why we're taking that 20 to 50 out just because

 18 you're saying at 20 there are impacts, 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 are pretty clear

 23 effects between 20 and 50. And I 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 the 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 there 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 uncertainty that certain fish

 10 could disappear. We saw that chart, the famous

 11 graph. So it stabilizes, so to speak, on the other

 12 side of 100?

 13 DR. DRISCOLL: Yes, it reaches an ASM tote

 14 around 100.

 15 DR. AMAR: How do we demonstrate 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 should 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 with you 100 percent,

 23 that there's are more certainty that there are

 24 effects at 20 than there are at 50. The lower you

 25 go, the more clearcut the effects are.

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 1 DR. KUMAR: That's why I'm saying why are you

 2 taking that policy decision here that let's

 3 eliminate 20 to 50 from the concentration and leave

 4 that 20 to 100 range for the Administrator to

 5 decide based on all the information 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 constrained. And so

 10 if you -- if you tighten up the target range, then

 11 you can come up with recommended percentage values

 12 in the lakes, you know, for people to understand.

 13 So all these assumptions or all these decision

 14 points are sort of interconnected at the end of the

 15 day. But if the group thinks it's better within 20

 16 to 100, I'm fine, I'll go along with whatever the

 17 consensus approved is.

 18 DR. RUSSELL: So putting it to the group --

 19 first, any other comments or discussions? So

 20 putting it to the group, how many people would put

 21 the bottom line, bottom end at 20 in terms of what

 22 should be considered? Naresh will probably go

 23 along with that one.

 24 MS. CHESTNUT: I mean, I just I don't know.

 25 It's not -- I have to listen to what the ecologists

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 1 are saying about it.

 2 DR. RUSSELL: Yeah. It may come back, you

 3 know, sort of separating this from the AAPI.

 4 Actually, I think there is pretty 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 ourselves totally from the

 8 AAPI in terms of doing this I think 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 which we are pretty

 12 sure we see negative impacts, negative

 13 consequences.

 14 DR. KUMAR: Are you disregarding the

 15 information in the document then?

 16 DR. RUSSELL: No. I mean, what?

 17 DR. KUMAR: That there is a lot of uncertainty

 18 on those effects between 20 and 50?

 19 DR. RUSSELL: They also demonstrate real -- a

 20 significant amount of certainty in a number of

 21 aquatic ecosystems, that they are 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 go back to the figure

 2 that shows the fish diversity.

 3 DR. KUMAR: And if you look at the figure that

 4 shows relations of pH and ANC and then you look at

 5 the figure that shows the effect 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 you don't see any

 8 effects. And then if you go back in relation to

 9 the pH and ANC at six -- where did it go -- some

 10 evidence 20 and 50.

 11 DR. RUSSELL: Praveen, where is the figure of

 12 pH and ANC fish diversity?

 13 DR. AMAR: I clarified that too. A big curve

 14 in fish.

 15 DR. RUSSELL: Where is it?

 16 DR. AMAR: One of those figures I don't have

 17 in memory.

 18 MS. WEGMAN: It's on 581.

 19 DR. AMAR: Thank you.

 20 MS. CHESTNUT: There is one on pH, Naresh.

 21 DR. KUMAR: Yes.

 22 MS. CHESTNUT: Did you say what page this is

 23 on, which page?

 24 DR. KUMAR: 577 is a relationship between pH

 25 and a number of species and 571 is a relationship

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 1 between pH and ANC. And then the 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 and 50 and says how

 5 uncertain those effects are.

 6 So either we disagree with that information

 7 and say maybe 50 to 100 is the more appropriate

 8 range. I don't see any disagreements being

 9 proposed here with the information on page 583.

 10 DR. AMAR: I think what Chris said earlier

 11 that's why I was asking the question uncertainty of

 12 effects, but also if you're trying to have a

 13 standard, there is also a question of certainty of

 14 protection you need. When I look at that curve on

 15 527, Figure 527, it's like on the other side of 100

 16 you're kind of on the safe side so to speak. It's

 17 almost like precautionary principle. I mean,

 18 that's what I'm thinking that you want to be on

 19 that side.

 20 DR. KUMAR: That's what I'm saying for the

 21 welfare standard the language says that it has to

 22 be -- I don't know what the exact language is, but

 23 requisite protection and you don't want to overly

 24 protect. So that I think lies with the

 25 Administrator not with us, saying that we should be

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 1 overly protective. I don't think this committee

 2 has to make that decision.

 3 DR. AMAR: Whatever the role is, whatever the

 4 Administrator's role is, but I think we're

 5 providing input.

 6 DR. KUMAR: I don't know if this committee

 7 needs to do that. If it does, then you can go

 8 ahead. Of course, I would disagree with that, with

 9 that kind of decision of the committee. I don't

 10 think EPA can tell us that's what they're looking

 11 for from this committee or not.

 12 DR. RUSSELL: Chris.

 13 DR. FREY: I think, as you point 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 requisite, 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 Administrator very well

 20 could choose the lowest value of the range or the

 21 higher end based on her judgment.

 22 I guess, you know, I think we probably do our

 23 job if we give the Administrator a range that's

 24 inclusive of something -- I guess that we're highly

 25 confident that the range encloses 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 really up to the

 4 Administrator.

 5 DR. RUSSELL: Rich.

 6 MR. POIROT: Sort of a devil's advocate for a

 7 minute. It seems like a lot of the document has

 8 focused itself on 20 to 50. That's the range. And

 9 I think for starters we should be saying 20 to 100

 10 is a more appropriate range and 50 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 context of we've got this

 14 other metric that's kind of completely arbitrary.

 15 And it may be somewhat unnecessarily 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 stringent possible

 19 standard.

 20 So I guess I would like to consider 20 to 100

 21 with the recommendation of 50 to 100 is clearly

 22 more protective, something along 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 elevated concern, but

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 1 essentially, capturing your words, that going from

 2 20 to 100, it's apparent that between 50 and 100

 3 there is more -- how did you put it?

 4 MR. POIROT: Protection.

 5 DR. FREY: Additional protection. We don't

 6 know if it's significant.

 7 DR. RUSSELL: There would be additional

 8 protection.

 9 DR. NUGENT: Chris just provided the language

 10 that's shaded above.

 11 DR. RUSSELL: So then "recognizing" comma.

 12 DR. NUGENT: Start a new paragraph.

 13 DR. RUSSELL: No. "AAPI" comma, "recognizing

 14 there is additional protection."

 15 DR. COWLING: In the context of Chris's remark

 16 it's up to the Administrator ultimately. This is

 17 partly what I was thinking about when I made the

 18 recommendation yesterday to look at this figure on

 19 page 571, this sigmoid curve, that shows that the

 20 relationship between ANC and pH; and I suggested

 21 that we add that form of a curve.

 22 At least if I were sitting down with Lisa

 23 Jackson and trying to help her think this through,

 24 I would want to have that figure maybe developed in

 25 a different way with different parameters,

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 1 different end points for certain species and that

 2 sort of thing, but I believe that is a very, very

 3 instructive graph. And it's really relating to

 4 what ultimately Lisa Jackson is going to have to

 5 make up her mind about these things.

 6 So, anyway, I make this suggestion again to

 7 look at that kind of a graph, how to make it more

 8 useful than just pH and ANC. Those are my

 9 thoughts.

 10 DR. RUSSELL: Chris.

 11 DR. FREY: Just to play devil's advocate, so

 12 most of this paragraph talks about ANC and then

 13 makes a conclusion in this last sentence now about

 14 values for AAPI. Does -- is that -- that implies

 15 that there is a one-to-one correspondence between

 16 the two and that --

 17 DR. RUSSELL: AAPI should not be there.

 18 DR. FREY: Okay. But then this issue comes up

 19 later anyway. So the question is: Is AAPI

 20 unbiased -- does it have an unbiased 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 like to do now actually

 25 looking at the time, how many people have to take

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 1 off at noon? So we're losing a significant

 2 fraction. So if you look at your 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 directly from the

 7 document says, "However, uncertainty regarding the

 8 additional protection at much larger 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 it helps me.

 13 DR. RUSSELL: I think actually that's captured

 14 up above. It says it's captured in 50

 15 microequivalents per liter, such as 50 to 100,

 16 would provide additional protection 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 stating that, however,

 21 uncertainties are much larger.

 22 DR. RUSSELL: Again, I don't want to

 23 restate -- maybe we can lose what's above.

 24 Essentially we're stating exactly 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 mentioned 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 would provide additional

 7 protection. Why are we repeating that here anyway?

 8 DR. FREY: This may be getting into

 9 wordsmithing given the time -- you could rewrite

 10 that paragraph to take that middle part out as a

 11 separate paragraph so it's more evident in the

 12 charge question.

 13 DR. RUSSELL: Given that we're going to

 14 have -- it appears we're going to have a follow-on

 15 call, we have to move on. Leave it like that.

 16 Who is in charge of that question again?

 17 DR. NUGENT: This paragraph moves down to the

 18 co-benefits.

 19 DR. RUSSELL: Then moves down to the

 20 co-benefits.

 21 DR. DRISCOLL: So now that Dale is back, do we

 22 want to address the issue of the second paragraph?

 23 DR. RUSSELL: Dale, we would think we would

 24 move that second paragraph to the co-benefits

 25 because it doesn't deal directly with ANC.

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 1 DR. DRISCOLL: For terrestrial acidification,

 2 it's more relevant to that.

 3 DR. JOHNSON: Sure.

 4 DR. DRISCOLL: You want to do 11-A. This is I

 5 think a linked question to 11. It is talking about

 6 adversity concerns. And I think the gist is that

 7 it's, you know, consistent with the literature on

 8 the associated effects. I put in a couple

 9 sentences reflecting what I said yesterday that

 10 these relationships are based on spatial

 11 relationships and it's not clear that temporal

 12 response will follow these spatial relationships.

 13 So some caveats should be given in the text that

 14 these are based on spatial relationships. And the

 15 assumption is that the temporal response will

 16 follow these spatially derived relationships.

 17 DR. RUSSELL: Comments? Thank you. Moving

 18 on.

 19 DR. DRISCOLL: I've got 12 as well. I had

 20 difficulty with 12 because 12 pertains to target

 21 percentage of water bodies. So give all these

 22 items that were in play yesterday in terms of

 23 filtering lakes and target ANCs, it's hard to --

 24 it's hard to make recommendations for target

 25 percentages based on information I have available.

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 1 I think the concept is good and appropriate, but

 2 what should be a specific target percentage of

 3 lakes it's not clear what the appropriate value

 4 would be without having additional information.

 5 Hopefully if these can be constrained a little

 6 bit, we can get some information on, you know, what

 7 are the values of ANCs within these various

 8 subregions and what might appropriate target

 9 percentages be.

 10 DR. RUSSELL: Okay. Actually, what I would

 11 say, you know, it's somewhat strange. It would be

 12 say regardless, target percentages in the range of

 13 95 to 80 percent might be appropriate for the AAPI.

 14 However, it is difficult to suggest 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 right. And also early

 19 on because of the text I had provided Andre the

 20 filtering criteria, if we're going to get rid of

 21 that, we should remove that from the paragraph as

 22 well, the second sentence, second and third

 23 sentence.

 24 DR. RUSSELL: That one right there?

 25 DR. DRISCOLL: And third sentence. Because

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 1 that's sort of gone away now.

 2 DR. RUSSELL: Yeah.

 3 DR. HUBBELL: I was wondering if I could ask

 4 one thing, because it would be helpful to us,

 5 obviously, there was some discussion yesterday that

 6 perhaps there were some at least reasonable things

 7 not to consider, like 50 percent 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, telling us that, you know,

 11 protecting 20 percent of the waterbodies is not

 12 acceptable, that would be fine. So just something

 13 to help us narrow our range based 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 and what we know about

 20 ecoregions and everything else, it's very hard to

 21 say what it should be, but I would say 50 percent.

 22 MS. CHESTNUT: Isn't it already better than

 23 that in sensitive areas? We talked about that a

 24 little bit yesterday.

 25 DR. RUSSELL: I don't think so. Actually, I

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 1 thought one of the graphs you showed suggests that

 2 it's not.

 3 DR. HUBBELL: We were saying, for example, in

 4 the Adirondacks right now 30 percent or so of lakes

 5 are adversely impacted given current -- 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 wouldn't do much in

 10 the Adirondacks.

 11 MS. CHESTNUT: It implies that current effects

 12 are not adverse based on the amount of -- there is

 13 some internal consistency here.

 14 DR. HUBBELL: And actually if you don't feel

 15 comfortable giving a percentage, if you actually

 16 said that that there ought to be internal

 17 consistency or there ought to be -- you ought to

 18 try to provide at least more protection 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 to add that sentence

 24 about internal consistency?

 25 DR. RUSSELL: Charlie, did you or someone over

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 1 there sort of rephrase it or send it?

 2 DR. DRISCOLL: I can't send it because I don't

 3 have access to the Internet unless you want me to

 4 do it on a pin drive. We could say 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 consistency with what?

 9 DR. DRISCOLL: I'm just trying to rephrase

 10 what you had said previously.

 11 MS. CHESTNUT: I'll try.

 12 DR. HUBBELL: Good.

 13 MS. CHESTNUT: That the target should be a

 14 higher percentage than is currently adversely

 15 affected in sensitive areas. I don't know if we

 16 want to get that specific.

 17 DR. RUSSELL: The question would become why?

 18 MS. CHESTNUT: If the judgment is that effects

 19 at current deposition levels are adverse, then

 20 it's -- then addressing that would imply a target

 21 that improves it from where we are now.

 22 DR. RUSSELL: Okay. But we'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 bring up an example

 2 and Karen will probably -- okay, Karen says to

 3 leave it alone. So I will leave it alone.

 4 DR. RUSSELL: But we're not sure where that

 5 would be.

 6 DR. DRISCOLL: If it's helpful, I can't do it

 7 now, but when I get back, I can calculate the

 8 target populations that are below 100, 50, 20 and

 9 zero for the Adirondacks. That probably is the

 10 most impacted area. And that will give people a

 11 feel for what the percentages are on these various

 12 classes and we can sort of go from there when we

 13 have the call.

 14 DR. RUSSELL: What I'm thinking, again, is

 15 stating again affecting sensitive areas, but,

 16 again, without further information, we cannot

 17 provide specific percentage or specificity.

 18 DR. NUGENT: Doesn't the previous sentence say

 19 that?

 20 DR. RUSSELL: It does, thank you much.

 21 Thirteen, Lauri.

 22 MS. CHESTNUT: This is the co-protection

 23 chapter. The first paragraph is just a positive,

 24 this is a good addition to the -- this is a good

 25 addition to the Policy Assessment.

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 1 The second paragraph is say a little bit more

 2 about to what extent the terrestrial systems are

 3 co-located with the sensitive aquatic systems. So

 4 to get a sense of the magnitude of the

 5 co-protection.

 6 I think the third paragraph we can strike as

 7 too much detail here. And then what's currently

 8 the fourth paragraph is a suggestion that some

 9 broader context be communicated by 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 and SOx concentrations

 13 has a whole chain of effects. But I think a list

 14 here is sufficient just to acknowledge there is

 15 this broader connection between these pollutants

 16 and a lot of other things both positive and

 17 negative.

 18 And then there was a suggestion to move Dale's

 19 paragraph about the soils to this. It doesn't

 20 exactly fit with what they did, but perhaps it can

 21 go here.

 22 DR. JOHNSON: Whatever you want.

 23 DR. RUSSELL: Questions, comments? Fourteen?

 24 Rudy. Oh, we do have stuff from you now.

 25 DR. HUSAR: The overall summary of the 14 and

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 1 15 I put up in three bullets there. There has

 2 been -- the contributions have been rising from

 3 Mitchell, Frey and Kumar.

 4 So these big points are introduced in the

 5 uncertainties section a summary and description of

 6 the general framework by which the uncertainty

 7 analysis is performed, recognizing there are

 8 multiple kinds of frame works. And then extend the

 9 uncertainty beyond the components of -- to the

 10 propagation of the uncertainties to the entire

 11 AAPI.

 12 And then there is this piece that includes

 13 constraints on the observations, this is a short

 14 version. And then the panel recommends

 15 aggressively pursuing the reduction of biases in

 16 the CMAQ model particularly for parameters that are

 17 relevant to the AAPI. So the rest is pretty much

 18 elaboration on these three points.

 19 Now, I can go through that, but I would like

 20 to bring to your attention in the committee letter

 21 that is already drafted out here, Chapter 5,

 22 conceptual framework and the uncertainty chapter

 23 has been singled out as particularly relevant

 24 feedback to the agency. So I would 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, the 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 significant in

 6 everywhere, constraints exist. Observations exist

 7 and those need to be combined with the uncertainty

 8 analysis in some way.

 9 The next paragraph is that of the improvements

 10 of the CMAQ itself particularly on the components

 11 that are viable, including explicitly considering,

 12 of course, significant systematic biases that occur

 13 in the CMAQ. Also, in that context also there is a

 14 suggestion to include other dataset beyond CASTNET

 15 in order to perform the validations -- or actually

 16 improvement of CMAQ.

 17 Then there is a question regarding these

 18 transfer -- transference ratios. The only comment

 19 there is, and this could be shortened, and that is

 20 that this section is not clear. Obviously, it is

 21 not coming through as to what is the nature of the

 22 variability of the transference ratios. So it's

 23 more of a request for clarification.

 24 The last section on the elasticities is the

 25 most welcome, but -- and then on the sensitivity

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 1 analysis, it is recommended that one should have

 2 experiments of sensitivity analysis way beyond the

 3 one percent level, in other words, into the

 4 possible known segment of the overall relationship.

 5 And then Myron suggested that there should

 6 definitely at the tail end there 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 and 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 and are really good.

 17 But if I were EPA looking at this, I would

 18 recognize that this could be another four years.

 19 And so I'm hoping that we're going to talk about

 20 the critical needs list and prioritize and that,

 21 again, we can make consistent our recommendations

 22 with that list.

 23 DR. RUSSELL: And so I -- did you pick up

 24 what, Rudy, in terms of how this might be modified?

 25 Really need to tone down what can be done.

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 1 DR. HUSAR: Yes. I think of examining the

 2 entire document and see what are the different

 3 recommendations everywhere such that those could be

 4 reconciled. What are here, the recommendations

 5 that are here has to be consistent with everywhere

 6 else, but maybe there may be a recommendation here

 7 that might influence something outside.

 8 DR. RUSSELL: And so actually just looking at

 9 the time and recognizing we're about to lose pretty

 10 much half of the panel what I'd like to do is jump

 11 to the letter. Because I think that actually --

 12 actually, no, let's jump to 24-D and then from

 13 there jump to the letter. Recognizing that we

 14 pretty much are going to have to have another phone

 15 call on this.

 16 DR. WEATHERS: 24-D is where we don't have

 17 that list, where there is the placeholder for that

 18 list. You continue it.

 19 So 24-A through C the responses are fairly

 20 straightforward. Ellis has offered some edits

 21 which I can pass on, but it's 24-D that has the

 22 guts of how to deal with the uncertainties in the

 23 AAPI and may be the place in which our prioritizing

 24 list shows up.

 25 DR. RUSSELL: But also this 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 really the third

 5 bullet, consideration of relevant uncertainties in

 6 the AAPI components.

 7 DR. WEATHERS: Can you go down a little bit?

 8 DR. RUSSELL: This is I think a critical

 9 response is that how would someone respond to the

 10 current uncertainties and understanding of what

 11 goes into all the elements of the AAPI? So if

 12 people want to read that.

 13 DR. WEATHERS: I note especially the brackets

 14 that begin. Does not currently have the list that

 15 we've been talking about, the big 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 also fit with this topic

 20 and maybe they need to be combined or just stated

 21 in one place.

 22 DR. RUSSELL: Okay. You've 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 into 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 paragraph in detail.

 7 DR. RUSSELL: Okay. Thank you. If people are

 8 ready to start discussing it, I think we should.

 9 Paragraph one, typical intro. Paragraph two,

 10 basically talking that we are actually pleased with

 11 progress that's been made and a number of

 12 complexities have been introduced, but I think this

 13 is an important statement, we're not sure how one

 14 could construct a simpler approach to achieve the

 15 same end point.

 16 DR. BYTNEROWICZ: Somewhere in the letter we

 17 have to say that we are addressing aquatic

 18 inconsistence, but we have considered 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 aquatic ecosystems and

 22 there is a very high uncertainty how we protect

 23 terrestrial ecosystems, some kind of general

 24 statement like that is needed.

 25 DR. RUSSELL: So it probably goes at the end

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 1 of the first paragraph. The present approach

 2 serves as a mechanism to protect aquatic

 3 ecosystems.

 4 DR. BYTNEROWICZ: Realizing that we are far

 5 away from developing a similar approach to

 6 terrestrial ecosystem.

 7 DR. RUSSELL: Realizing that a similar

 8 approach for protecting terrestrial ecosystems and

 9 eutrophication would still need to be developed.

 10 DR. BYTNEROWICZ: Something like that.

 11 DR. AMAR: NOx and SOx, can we say nitrogen

 12 and sulphur?

 13 DR. DRISCOLL: I had a thought on that,

 14 increased effects of NOx and SOx, and then have

 15 maybe at the end of that saying while considering

 16 the current effects of ammonium deposition or NOx

 17 deposition to address it.

 18 DR. RUSSELL: "NOx and SOx while considering"

 19 goes at the end of the sentence, "while

 20 considering."

 21 DR. DRISCOLL: The effects of current reduced

 22 nitrogen deposition or something like that.

 23 DR. RUSSELL: Thank you. Okay. Second

 24 paragraph, this is in some ways stating our

 25 frustration both in terms of the 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 be done. And it did

 3 not include the charge questions. Yes, Naresh.

 4 DR. KUMAR: So we are asking a lot of new

 5 things to be done. Do you think we want to see the

 6 revised document before we make some of the

 7 recommendations? Because the schedule doesn't call

 8 for us to review the next version. 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 morning?

 13 DR. NUGENT: The previous document.

 14 DR. RUSSELL: I sent you a version two this

 15 morning.

 16 DR. NUGENT: Should be something like version

 17 1-A. I think I've addressed that, given that

 18 addressing the issue that CASAC won'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 to say that we would

 23 like to?

 24 DR. KUMAR: I would like to see it.

 25 DR. RUSSELL: Okay. We will say that we would

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 1 like to see it again. Moving on. So you can read

 2 Chapter 5 -- the next two paragraphs.

 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 where we said it. I

 7 added something here. So somewhere what's in

 8 purple is new. We'd like to say that CASAC wants

 9 to see this document again.

 10 Okay. Moving on. So these next two

 11 paragraphs are oriented and actually the suggestion

 12 was made that we might move these out of the letter

 13 into a separate section as critical need. This is

 14 where I tried to capture all the critical needs in

 15 these next three paragraphs. What it does is it

 16 makes the letter long and I think 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 and in particular I

 22 think the first paragraph, the first of those three

 23 is the first of Chapter 5, I took 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 uncertainties are

 4 there? It is just answering a larger -- maybe

 5 having more description of uncertainty might help

 6 us, or help our Administrator decide 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, does 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 the AAPI, at

 16 different levels of ANC we have different adverse

 17 effects. Writing the description is very

 18 qualitative again. It only says between 20 and 50

 19 uncertainties are higher. Above 50 uncertainties

 20 are much higher. Should we ask for more

 21 description of what is meant by that?

 22 DR. RUSSELL: Actually, I think it's pretty

 23 much there if we look at the table in Chapter 2. I

 24 think they describe it. I think our issue earlier

 25 was what to do with it. I think 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 do with it.

 3 DR. KUMAR: Again, I would describe

 4 qualitative. Larger, much larger, 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 think says a whole lot

 8 to us. I mean, that is a quantitative graph. I

 9 don't think they can do any more 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 what the uncertainty

 20 questions I think are about, you know, the

 21 transformations from deposition -- or ambient to

 22 deposition and the other elements that are -- I

 23 think that's what I'm hearing what's a lot of

 24 hesitation to say yeah, you're done, you know, go

 25 forward with the standard based on this.

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 1 DR. RUSSELL: So how would you -- 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 here. 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 any advantage to

 14 having this level of detail versus almost a bullet

 15 list of the critical needs? That's a naive

 16 question.

 17 I don't know from your perspective. 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 guidance.

 22 DR. SCHEFFE: That would be helpful.

 23 DR. WEATHERS: But is it more helpful than --

 24 they're buried in there.

 25 DR. HUBBELL: It's more helpful to be as

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 1 specific and concrete and together as possible.

 2 DR. WEATHERS: A bulleted list of high

 3 priority analysis.

 4 DR. HUBBELL: Bulleted and prioritized 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 could also rank order

 8 those.

 9 DR. HUBBELL: If you can, that would be great.

 10 DR. SCHEFFE: That would be 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 there is a relationship

 14 between elasticity and sensitivity, but we use them

 15 separately. There was a specific elasticity

 16 analysis that that sentence was referring to. So

 17 you might want to consider that last change.

 18 DR. RUSSELL: That was elasticity. 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 second 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 need some feedback.

 2 It might not necessarily be clear at the early

 3 stage, but as soon as possible to have some

 4 feedback from you all about where we get the most

 5 bang for your effort.

 6 DR. SCHEFFE: Exactly. We would welcome that.

 7 DR. RUSSELL: Okay. The line, the paragraph

 8 that starts -- it is 37 on yours. 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 reasons for giving a

 15 caveat. I think that can give us a way out of not

 16 doing that analysis. We have highlighted so much

 17 that analysis is critical. And providing a caveat,

 18 if EPA doesn't have the time to do 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 caveat.

 21 DR. RUSSELL: Actually, what 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 misinterpretation

 5 just like last time. I think they misinterpreted

 6 our intentions. And that's my concern. That is,

 7 again, open to misinterpretation 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 an analysis is not

 12 possible. What is the difference between that

 13 analysis and the set of example calculations of the

 14 magnitude of uncertainties? What's the difference

 15 between the two? It's not clear to me, so I don't

 16 know if it's clear to EPA or not.

 17 DR. FREY: There are the detailed answers to

 18 the charge questions that go into 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 those details in the

 22 charge questions either. That's why I'm asking

 23 what do you mean by the detailed examples rather

 24 than the full analysis? Full analysis, Monte Carlo

 25 is full analysis. For data and calculations is

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 1 that something different, what would that be?

 2 DR. RUSSELL: So a comprehensive uncertainty

 3 assessment would be something where they would be

 4 approaching a Monte Carlo analysis, but I'm not

 5 sure that there is time to do that. 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 databases to do the

 10 calculations.

 11 DR. RUSSELL: The reason why is because they

 12 have to make assumptions as to what the

 13 distribution of those uncertainties are. So that's

 14 what I'm hesitant to tell them to do if they are

 15 going to have to start making certain assumptions.

 16 DR. KUMAR: I think we can ask them details

 17 on -- if they don't have an idea of what

 18 distribution, they would do something very simple

 19 and just explain. I see no reason 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 possible, then say in

 24 the second, more focused analysis should be done.

 25 That might answer. Just looking at the last part,

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 1 if such an analysis is not possible, replace that

 2 if a full-scale analysis is not possible given time

 3 constraints.

 4 DR. KUMAR: I would suggest we stop where you

 5 say, "A more comprehensive uncertainty assessment

 6 is called for as described in the charge

 7 questions." And then in the charge question we

 8 provide the details and not say anything here up

 9 front because there are charge questions. People

 10 are fine with that?

 11 DR. NUGENT: Strike this last sentence.

 12 DR. RUSSELL: Fine. Okay. Paragraph starting

 13 at line 37. Quorum? I was afraid of that. We're

 14 going to have to have a second phone call.

 15 DR. NUGENT: We're a group now.

 16 DR. KUMAR: Have we lost the quorum?

 17 DR. NUGENT: We have lost the quorum. So

 18 right now we are editing as a group.

 19 DR. FREY: Can I make a comment that's maybe

 20 more general than this one paragraph?

 21 DR. RUSSELL: Sure.

 22 DR. FREY: I didn't catch some of the edits

 23 earlier, so maybe it's addressed, but it seems like

 24 the Administrator would want to hear from this

 25 panel on do we agree that the current secondary

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 1 standards should be retained and that that should

 2 be in the letter.

 3 DR. RUSSELL: Very good.

 4 DR. FREY: And then I think the Administrator

 5 would like to hear that the panel concurs that, you

 6 know, there is sufficient evidence that current

 7 standards not protective against specific aquatic

 8 acidification; and, therefore, there is support for

 9 an additional I guess secondary standard beyond the

 10 current one. Because then I think 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 construct earlier

 14 would be helpful.

 15 And then I think the third thing related to

 16 that is, you know, if there are significant

 17 uncertainties about the specific levels and so on,

 18 I mean, it seems like the weight of evidence

 19 conclusion is very strong, that there is -- the

 20 current standard is not protective against aquatic

 21 acidification. So there is a need for an

 22 additional standard. And, you know, whether the

 23 Administrator picks 100 or 20 or what percentage of

 24 lakes, you know, those things would deal with the

 25 degree of protectiveness of the standard. But I

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 1 think we ought not lose sight of the kind of

 2 impetus that there should be a revised standard.

 3 DR. RUSSELL: Actually, that should probably

 4 go as paragraph two.

 5 DR. FREY: Yeah.

 6 DR. RUSSELL: And then that can dive in saying

 7 that there is a need for this new standard that

 8 addresses both NOx and SOx deposition 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 some of the other

 12 individuals, that you have is basically saying that

 13 while we identified weaknesses with the current

 14 document, we remain very supportive of the

 15 approach.

 16 DR. AMAR: Additional analysis we mean within

 17 the context of now until December?

 18 DR. RUSSELL: Yes.

 19 DR. AMAR: Should we say that? There is also

 20 research needs for the future, which are different

 21 than what we need from now until then.

 22 DR. RUSSELL: So where would you put that?

 23 DR. AMAR: Additional analysis in the next

 24 revision.

 25 DR. NUGENT: You mean before 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 foundation, I would say

 4 purpose of establishing a foundation.

 5 DR. KUMAR: Is it before it's published or

 6 before this is finalized? You mean before the

 7 NAAQS are published or before it is finalized?

 8 Those are different events. Do we want analysis to

 9 be in the final? Otherwise, where would that be

 10 seen?

 11 DR. RUSSELL: The final PAD is published.

 12 DR. NUGENT: PA is not a foundation.

 13 DR. AMAR: Establishing a foundation for

 14 building.

 15 DR. RUSSELL: Being establishing -- no, don't

 16 give foundation.

 17 Okay. Getting the paragraph 37 starts on line

 18 37, I guess that's the one we just did. Does that

 19 go with people?

 20 DR. KUMAR: So where are we asking that we be

 21 allowed to review the next version of the PAD, the

 22 final version of the PAD?

 23 DR. RUSSELL: That would be the last --

 24 actually, go up.

 25 DR. FREY: Procedurally does it make sense to

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 1 review a final PAD? If it's final --

 2 DR. RUSSELL: Karen.

 3 DR. FREY: -- at that point that we want to

 4 provide input before the proposed rule is made, but

 5 it's not going to be a review of the Policy

 6 Assessment.

 7 MS. MARTIN: There have been times in the past

 8 where the panel has chosen to provide comments to

 9 the agency on a final document, recognizing they

 10 weren't comments directed toward changing the

 11 documents since it was final, but offering their

 12 views upon what was in the final 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 comments on what

 17 might get proposed. So there are those further

 18 opportunities that at your prerogative 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 of issues of which we

 23 are not able to make recommendations right now. So

 24 unless we get to review additional --

 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 the document before we

 6 make some of the recommendations that we're not

 7 able to do it right now.

 8 MS. MARTIN: It is also our 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 we have changed in

 12 the final document relative to the document you

 13 just reviewed that were responsive to your

 14 comments. So upon receiving that from us, if you

 15 chose to provide further comments, further

 16 recommendations based on that final 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 to 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 in a meeting?

 2 DR. RUSSELL: It could be a teleconference.

 3 MS. CHESTNUT: We could say that we expect

 4 that the panel will want to provide comment on the

 5 final document if we want to say 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 decision point I think

 16 is that if we are looking to suggest that we want

 17 to interrupt this process and that's still for them

 18 to decide if they want to do so. So interrupting

 19 the process would -- they would have to decide

 20 within their court-ordered mandates what can be

 21 done or if they would go back to the litigant or

 22 whatever.

 23 DR. KUMAR: When does this letter need to be

 24 sent?

 25 DR. RUSSELL: Well, when does it need -- we're

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 1 going to have to have another teleconference on

 2 this letter in three weeks.

 3 DR. KUMAR: That's what I'm saying because

 4 when we have a full quorum, then can we make a

 5 decision on whether to ask for the review or not,

 6 right? Do we have to make a decision now?

 7 DR. NUGENT: I mean, I'm not sure how to

 8 respond to your question. I -- the -- the schedule

 9 for the proposal is not something 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 schedule 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 statement yesterday of

 20 what I think is my confidence that we are going to

 21 be pleased with what will be done in the next few

 22 weeks. And I would hope that you would look at

 23 this letter or we all should look 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 that this committee

 4 believes this CASAC committee believes this is a

 5 very important step to be taken.

 6 So I would hope that we would examine the

 7 letter from the standpoint of its optimism and its

 8 likely effect on the morale and determination on

 9 the part of the agency, morale in the troops and

 10 determination on the part of the agency as a whole.

 11 DR. RUSSELL: I tried to be positive. So if

 12 you can do something with this letter -- because I

 13 think I agree with you, and I tried 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 information up the chain

 20 that that is just not enough time. I mean, I heard

 21 enough whining, if you will, from the committee

 22 about that.

 23 DR. DRISCOLL: I was whining too, but I think

 24 in the spirit of Ellis's comment, it would be best

 25 in another letter saying it would 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 thing is I don't think

 6 it's their fault. In fact, I'm fairly sure it's

 7 not their fault.

 8 DR. DRISCOLL: I understand it's in their best

 9 interests to give us as much time as possible.

 10 DR. RUSSELL: I want to make sure that that

 11 information that, you know, if it became standard

 12 practice to have three-week turnaround on these

 13 reviews, that would be detrimental to the process.

 14 DR. DRISCOLL: I agree.

 15 DR. RUSSELL: So I want to make sure that that

 16 information goes forward.

 17 Okay. You were about to say?

 18 DR. NUGENT: I feel a little nervous saying

 19 this, but we're in a work apprentice situation. I

 20 don't -- I had it in my head that the proposal was

 21 in December, but the proposal is 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 in July, 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 possible to set up

 3 and desirable to set up maybe some teleconferences

 4 that might be -- where the committee 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 set up

 8 teleconferences where people could look at the

 9 components of special reviews?

 10 MS. MARTIN: One of the problems is making the

 11 documents publicly available for the panel to

 12 review also necessitates making them available for

 13 the public to review. And both you 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 time for that to

 17 happen simply goes beyond what our current schedule

 18 allows for.

 19 DR. KUMAR: I guess I'm not suggesting that we

 20 want to review the document to make further

 21 changes. I'm suggesting that we should review the

 22 document to make some recommendation that we are

 23 not able to make right now. And 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 changing the schedule,

 3 the court-ordered schedule because if this comes up

 4 in December, we can review it in January and

 5 provide additional documentation 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 would suggest that if the

 10 final PA is available in December that we might

 11 consider having a teleconference of this panel

 12 maybe in early February. I guess 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 and then, you know, I

 16 guess the CASAC could at that point provide

 17 whatever input it would deem to be useful. And

 18 then, although it might be helpful to hear a little

 19 bit more about the proposed rule schedule, and are

 20 there certain time points at which if this panel

 21 were to have input, when would it be most useful to

 22 receive it?

 23 MS. MARTIN: Well, that one'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 internal decision

 2 making process. There is internal process to

 3 capture those decisions in a notice. And there is

 4 interagency review across federal agencies before

 5 major rules are proposed. So all those time steps

 6 come before the July proposal date.

 7 DR. FREY: Okay.

 8 MS. MARTIN: February isn't too late to

 9 provide additional advice, recommendations, input

 10 to the process, but the earlier the better.

 11 DR. FREY: Right. And I guess any letter that

 12 comes from this panel would have to go to the seven

 13 member CASAC before it's transmitted to EPA. So

 14 we'd have to allow for that.

 15 DR. RUSSELL: Which is three weeks, right?

 16 DR. NUGENT: Yeah.

 17 DR. RUSSELL: After we finalize the letter.

 18 Well, would it have to be a finalized 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 goes 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 buy off. We have to

 3 agree to it.

 4 DR. FREY: So maybe if we had a panel

 5 discussion like January and then the seven-member

 6 CASAC could review it the third week of February or

 7 something like that, that might be the earliest we

 8 could do it.

 9 DR. RUSSELL: Okay. Recognizing that we

 10 really don't have quorum and we've just lost one

 11 more person, losing them, I think we might as

 12 well --

 13 DR. NUGENT: Officially adjourn.

 14 DR. RUSSELL: -- officially adjourn.

 15 DR. NUGENT: Thank you all. And I'll be in

 16 touch with everybody in the room 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 12:17 p.m.)

 22

 23

 24

 25

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 1 STATE OF NORTH CAROLINA )

 2 COUNTY OF WAKE )

 3 CERTIFICATE OF REPORTER

 4 I, MAREN M. FAWCETT, Registered Professional

 Reporter and Notary Public in and for the State of North

 5 Carolina, duly commissioned and authorized to administer

 oaths and to take and certify depositions, do hereby

 6 certify that I attended the meeting on October 7, 2010

 and that the preceding transcript, was reported by me

 7 verbatim to the best of my ability, and then reduced to

 typewritten form under my direct supervision; that the

 8 foregoing is a true and correct transcript of said

 proceedings to the best of my ability 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 in 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 Expires: 7/31/2011

 18

 19

 20 Maren M. Fawcett, RPR

 Bryant Court Reporting Service

 21 P.O. Box 1401

 Cary, NC 27512

 22

 23

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