OTAG Stakeholders Presentations, Atlanta, April 15-17, 1997:
Summary of Summaries Prepared for the AQA Workgroup
Rudolf Husar and Richard Poirot, April 29, 1997
Introduction
The summaries of the OTAG stakeholder presentations were prepared for several purposes:
1. To inform the Air Quality WG and (maybe others) about the stakeholder positions/messages.
2. To evaluate what kind of technical information is needed/used for informed policy making.
3. To adapt the AQA Executive Summary to respond to these information needs.
Disclaimer: We understand that a real danger with short summaries of complex issues is that they will miss key
features of the presentation and possibly further contribute to the polarization of positions. On the other hand, the
positions have to be clearly summarized to reduce the shear volume of material presented. The responsibility for
the content of these draft summaries lies with the above writers, not the entire AQA WG.
Summaries of OTAG Stakeholders Presentations of OTAG Stakeholders
Presentation
1. Southern Company (John Jansen) stated that ozone transport is not a significant contributor to non-attainment in
the southeastern cities. Rather, urban ozone is “homegrown”, the result of local emissions. Furthermore, emissions from
the southeast do not contribute significantly to non-attainment in the Midwest and Northeast. They cautioned that the
OTAG modeling appears to overestimate the benefit of NOx reductions and underestimates the response to VOC
reductions. They recommended state-by-state or multi-state approach to reduce non-attainment.
2. The Midwest Ozone Group & Cinergy (David Flannery/Dan Weiss) has noted that nationally ozone
concentrations are declining and further controls have been mandated but not yet implemented. Legally, OTAG lacks
the statutory checks and balances. The OTAG modeling indicates much smaller (local and sub-regional) spatial scale of
impact than originally anticipated. The resulting impact of emitting states to receptor states is below the “significance”
limit (20%). For these and other reasons MOG recommends (1) not to apply domain-wide controls (2) address
non-attainment through local and sub-regional initiatives (3) conduct finer scale modeling (4) conduct more studies
before SIP submittals and (5) avoid domain-wide “SIP call”.
3. Tennessee Valley Authority (TVA) (Larry Gautney) is a federal agency serving electric power to 8 million people
in 7 southern state, conducting cooperative AQ research since 1950s. The research indicates that ozone production in
large "southeastern" point sources occurs within 100-125 km and that ozone transport is more intra than inter-regional
"in the Southeast". From model-based analysis they conclude that emission reduction benefit the source areas most and
that domain-wide emission reductions provide little benefit to serious non-attainment areas.
4. Georgia Institute of Technology (Bill Chameides) summarized recent findings from the Southern Oxidant Study
(SOS). He indicated that there was clear evidence of Long-range ozone transport in Midwest and Northeast, but not in
the Southeast - where plume recirculation is more important. Despite this, regional NOx control strategies would be
warranted to address 8-hour standards - with an anticipated reduction of 2-3 parts ozone per part NOx (for both urban
and power emissions).
5. General Public Utilities et al. (Don Blumenthal, STI) has summarized the results of the NARSTO-NE studies.
Regional background concentrations entering the northeastern urban corridor were 70-90 ppb, transported from the west
and southwest. Peak urban plume concentrations were over 150 ppb. They suggested that reducing the incoming
regional background may not reduce the urban plume concentrations in proportion. They also found that the UAMV
models did not resolve the details of swift nighttime transport and underestimated the incoming ozone of the western
boundary at the urban corridor.
6. Pennsylvania Power & Light (Al Ferullo) summarized model performance evaluations in the Northeast, based on
ozone observations at surface sites to the west of the NE corridor during 88, 91 and 95 episodes , and NARSTO-NE
aircraft flights during the 95 episode. Daily max surface ozone upwind of the corridor was underpredicted by an average
12 ppb. Ozone aloft was underpredicted by 10-30 ppb compared to upwind aircraft measurements on the mornings of
episode days. Implications suggest the model may overstate local influences and underestimate transport effects.
7. The Northwestern OTAG states, Minnesota, Iowa, N & S. Dakota) (David Thornton) are in ozone attainment,
the precursor emission densities are low and the winds during high ozone conditions are from the south. Consequently,
these states have no ozone problem and are not causing problems to the rest of OTAG. For this reason, these states have
expressed the view that they do not belong to OTAG.
8. State of Arkansas (Keith Michaels) emphasized Arkansas' extensive agricultural production (especially chickens
and hogs); its relatively low NOx emissions (628 tons/day); and its favorable meteorological position (rarely upwind of
current non-attainment areas). Consequently Arkansas emissions have insignificant impacts in other states.
9. State Of Michigan (Dennis Drake) emphasized Michigan’s willingness to be a good neighbor, and showed that
the State's relatively high NOx emissions, if zeroed out completely, would result in modeled ozone reductions of 6 to 18
ppb in selected downwind non-attainment areas. However, when more realistic control strategies were modeled (i.e. the
difference between Level 3 and Level 1 controls), downwind benefits of Michigan controls became insignificant
compared to the high incremental costs. The presentation also emphasized the existence of different perspectives: states
with or without non-attainment areas, EPA, and state legislators.
10. State of North Carolina (Brock Nicholson) presented Southeastern States' perspectives that: ozone
non-attainment in the Southeast is predominantly a local problem (Atlanta), and that modeled transport from the
Southeast results in insignificant impacts in other regions. Model results (aggregated from all 4 episodes) indicate that
maximum southeastern impacts to the north occur offshore of the Northeast corridor.
11. State of Virginia (Kirit Chaudhari) has conducted model sensitivity runs to determine the state’s impact on the
Northeast urban corridor. The conclusion was that Virginia has very little impact on the Northeast. For this reason, the
state is requesting OTAG to re-assign the major portions of Virginia from the northeast control region (Zone III) to the
southeastern control region (Zone IV) that has less anticipated control on point sources.
12. Lake Michigan States (Rob Kaleel) have conducted additional model runs over the Lake Michigan sub-region to
evaluate the role of regional vs. local and urban VOC vs. NOX controls. They concluded that Round 2 Strategy 10 (75%
utility NOx reduction, 15% VOC reduction) may provide sufficient upwind NOx reductions to make 1Hr standard
attainable if (1) NOx waiver is based on detailed urban-scale modeling, (2), modeled ‘Attainment test’ will be weighed
as significant evidence of attainment demonstrations and (3) some additional VOC reductions are added.
13. Northeastern States for Coordinated Air Management (NESCAUM) (Paul Miller) stated that the Northeast
urban corridor is a significant source of NOx and VOC and they cause “homegrown” exceedances. He stressed,
however, that there is also compelling evidence for regional ozone (70-90 ppb) transported into the NE urban corridor
through its western boundaries. As a consequence, ozone non-attainment in the Northeast corridor is partially due to the
transported ozone from the west and possibly from the southern states
14. American Automobile Manufacturing Assn. (AAMA) (Ellen Shapiro) noted that that mobile source emissions
depend both on the vehicles and on the fuels. The emission benefits of a national Low Emission Vehicle (LEV) program
operating on reformulated gasoline will be reduced due to catalyst "poisoning" by conventional gasoline. They also
conducted special modeling runs to determine role of motor fuel. and found that using reformulated gasoline
everywhere, would have the same benefit as removing 5 million vehicles from the road. Consequently, fuel controls
should be incorporated into the OTAG strategies. In the context of overall emissions, AAMA noted that electric utility
plant emissions 'overshadow fuel reductions.....[and] any single mobile source control'.
15. American Petroleum Institute (Jerry Levine) suggested that OTAG recommendations should be relevant to
ozone transport, focused on impacted areas and should be cost effective. Based on the modeling runs and cost analysis
they concluded that fuels are not effective in reducing regional ozone transport, but in urban areas they may reduce
VOC. As an alternative to reformulated gasoline, they proposed the summertime use of Low Reid Pressure (RVP)
“OTAG Fuel”. They recommended to OTAG not to impose domain-wide fuel controls.
16. Citizens’ Commission for Clean Air in the Lake Michigan Basin (Alex Johnson) summarized results from
1991 and 1995 intensive measurement studies in the LADCO region, showing early morning levels of 70 - 110 ppb aloft
entering the southern study boundary preceding each episode. The presentation also emphasized consideration of indirect
health and environmental benefits of reductions in NOx emissions and/or ozone concentrations including reductions in:
acidification of surface waters and soils, eutrophication, ozone impacts on vegetation, climate change, fine particles and
regional haze.
Sycom Enterprises (Chris Cooley/David Oppenheimer) presented estimated ozone benefits and costs of
regional energy efficiency strategies. For an aggressive efficiency strategy which reduced needs for electric energy
(and demand) by 20%, they found net NOx reduction costs across the OTAG region of zero dollars/ton. Negative
costs (savings) of up to -$3,000/ton were estimated for more focused efficiency strategies. Ozone reduction and cost
savings could be maximized by incorporating EE into a trading program which provided incentives to the parties
initiating the associated EE programs.
Summaries of the Summaries
The table below is further distillation of the stakeholder summaries. Again the omissions and misrepresentations are those of the writers.
States
Rationale
No exceedences, no impact
Northwestern on others
states
8 Arkansas
No Exceed, Low emissions,
Not upwind
10 North
NonAtt is local, little impact
Carolina
11 Virginia
Little impact on NE
7
9
Michigan
12 Lake
Michigan
13 NESCAUM
AQ Evidence
No exceedences, High
Ozone-Transport from the
South
No Exceed, Not upwind
Major Source, Some Impact
Great Control Costs
Regional
MajorLocalSource +
Regional import
Power Producers
1 Southern
O3 homerown, No impact
Company
on MW & NE
2 The Midwest O3 homerown, No
OG &
significant impact on MW &
Cinergy
NE
3 TVA
O3 intra-regional
5 General
Urban plumes + regional O3
Public
at boundaries
Utilities
6 Penn.Power OTAG Modeling
& Light
questionable for transport at
NE boundaries
Other evidence
OTAG Relationship
Model
Recommendation
Out of OTAG
Low Emissions
Out of OTAG
Modeled impact on
Northeast
Modeled impact on
Northeast
Modeled impact on
Northeast
Model sensitivity ro
regional controls
Local-Subregional controls
70-90 ppb at boundaries,
westerly winds
Reclassify VA from Zone III
to Zone IV
Try to be good neighbor
Regional Utility+Some
Fine-Scale Modeling
Urban VOC controls
Regional + Local controls to
reduce O3 at boundaries
CART - transport analysis
Model impact on MW Local-Subregional controls Better inventory and
& NE
NOx/VOC chemistry
Local-Subregional controls More Fine scale
modeling
O3 formation~100 km
70-90 ppb at NE boundaries,
W-SW transport
Modeled benefits
Local-Subregional controls
Modeled Urban plumes
Improve Transport
module, better
regional performance
Model-surface,
OTAG Modeling
Model
aircraft comparison
questionable for transport underestimates
incomming
overestimates local
ozone
Surface and aircraft data
Automobile, Fuel Industry
14 AAMA
Control Fuels & Utilities
15 Amer. Petrol. Fuels are not cost-effective
Inst.
Other
16 Citizens’
Regional input during episodes 70-110 ppb at S boundaries
Model fuel runs
Economics
Control Fuels & Utilities
Fuels are not
cost-effective
Regional+Local Controls; Indirect
4
Comm. Clean
Air
Georgia IT
No LRTP in the Southeast,
17 Sycom
Enterprises
during episodes
benefits
SOS Plume studies, AQ data
Regional NOX controls for 8Hr
standard
Economics
Energy efficiency is
cost-effective control
Air Quality-Relevant Issues Raised the Stakeholders
The AQA WG had real difficulty in extracting information ‘needs’ statements from the Policy Group. The
stakeholder presentations might help us identify what information is judged to be of value. Several of the
stakeholder presentations were done by the states, i. e. members of the Policy Group. If these represent a reasonable
sample, the Policy group is a heterogeneous mixture of states with varied interests and positions, so inherently, the
PG can not have a unified list of information needs.
Nine out of 17 stakeholders presentations have used AQ observations as evidence in making their case. About the
same number used model results to support their position. In general, “receptor”-oriented presentations (7, 13, 16)
used AQ data to demonstrate regional ozone transport into their sub-region through their boundaries. On the other
hand, “source”-oriented presentations (10,11, 1, 2) preferred the model outputs to document that their role to
regional ozone is not significant
Notable exceptions are the (12 LADCO) presentation that used the model to demonstrate regional impact and (1
Southern Company) that used AQ observations along with CART analysis to demonstrate the dominance of local
ozone sources in southern cities.
Some specific technical questions seem to deserve AQA WG attention. A real problem in the presentations is in the
usage of the term ‘region’. For example, Lake Michigan ‘Region’ and OTAG ‘Region’ are both called region but refer
to different scales. Similarly, what is itner and intra-regional transport? The WG could help fixing the lingo, so
communication is more crisp. effective to effectively communicate.
The WG could evaluate the CART analysis for the southern cities that show 80+% of ozone is “homegrown” (1.
Southern Company) and compare those to other transport/local estimates. The ozone formation distance of 100-125
in plumes (3-TVA) seems to be on the short, so these estimates could be compared to other evidence.
General Discussion
Overall, these writers found the stakeholder presentations a fascinating experience in the stakeholder style of
policy-making, science-policy interaction and environmental management in general. It could be stated, that both
AQ assessment (the use of AQ data) and modeling have been used effectively by the shareholders in making their
case. The old cry by scientist that science is not being adequately considered in policy does not seem to apply for
OTAG.
Another positive feature of the presentations was that there appeared to be no glowing misuse of AQ analysis or
modeling results. While the models performance has been questioned, it is a meaningful tool for scenario
discussions.
It has been said that key aspects of democracy include
 the legitimacy of different points of view (attitude)
 means to express and debate different points of view (e.g. OTAG as a stakeholder forum)
 mechanisms for incorporating, weighing multiple points of view and criteria (Policy Group process)
Many of the stakeholders are not part of the Policy Group - their voice was not heard otherwise. The Stakeholder
presentations were consistent with the spirit of the environmental management ‘perestroika’ and ‘glasnost’ set out in
OTAG’s mission statement.
The Remaining Challenge for the AQA WG [Heads up - subjective!]
As one presenter stated, the difficulty now in OTAG arises from “blind men and the elephant” syndrome. Is it a
wall, a tree trunk, or a snake? Different stakeholders appear to have very different perceptions and interpretations of
the existing evidence. The “receptor” stakeholders emphasize the existence of regionally transported ozone of their
boundaries, while the “source” stakeholders stress that their individual contributions are not significant. Both
statements appear to hold but they refer to different ways of looking at and perceiving the problem.
Could the AQA WG to help reconciling these two points of view? There is multiplicity of evidence at the
Workgroup’s disposal to resolve or clarify these issues. However, the evidence need to be organized, weighed, and
evaluated.