1
Summary
of
the
Meeting
with
Ozone
Transport
Commission
Regarding
EPA's
Advanced
Notice
to
Solicit
Comments,
Data
and
Information
for
Determining
the
Emissions
Reductions
Achieved
in
Ozone
Nonattainment
and
Maintenance
Areas
from
the
Implementation
of
Rules
Limiting
the
VOC
Content
of
Architectural
Coatings
Date:
January
11,
2006
Time:
2:
00
PM
Venue:
EPA's
OAQPS
in
Research
Triangle
Park
Attendees
Present
at
the
meeting:

Ozone
Transport
Commission
Christopher
Recchia,
Executive
Director
Douglas
Austin,
Program
Manager
EPA
David
Sanders,
OAQPS
David
Salman,
OAQPS
William
L.
Johnson,
OAQPS
Robert
Stallings,
OAQPS
Individuals
who
participated
by
conference
telephone:

EPA
Tom
Helms,
OAPQS
Geoffrey
Wilcox,
OGC
Anne
Arnold,
Region
I
Paul
Truchan,
Region
II
Kirk
Wieber,
Region
II
Neil
Bigioni,
Region
III
Christopher
Cripps,
Region
III
Marcia
Spink,
Region
III
Ozone
Transport
Commission
Janet
Johnson,
New
Jersey
DEP
Gene
Pettingill,
Delaware
Dan
Brinsko,
NY
Doris
McCloud,
VA
Gary
Graham,
VA
Summary
of
the
Meeting's
Discussions:

In
its
"
Advance
Notice
to
Solicit
Comments,
Data
and
Information
for
Determining
the
Emissions
Reductions
Achieved
in
Ozone
Nonattainment
and
Maintenance
Areas
From
the
Implementation
of
Rules
Limiting
the
VOC
Content
of
AIM
Coatings"
the
Environmental
Protection
Agency
also
offered
the
opportunity
for
interested
parties
to
2
meet
with
the
Agency
to
offer
comments.
In
response
to
this
invitation,
representatives
of
the
Ozone
Transport
Commission
(
OTC)
met
(
in
person
and
by
teleconference)
with
EPA
on
January
11,
2006
to
discuss
their
comments
on
the
issue
of
the
appropriate
baseline
and
methodology
to
use
in
architectural
and
industrial
coatings
(
AIM)
emission
reductions
calculations.

EPA:
Opened
the
meeting
and
explained
the
background
for
the
Advanced
Notice.
Reiterated
that
it
is
not
EPA's
intent
to
re­
open
its
federal
approval
of
any
State
AIM
rules
which
have
already
been
approved
as
SIP
revisions
or
to
re­
open
its
approval
of
the
Metropolitan
Washington
DC
1­
Hour
Ozone
Area's
rate­
of­
progress
(
ROP)
plan.
Explained
that
EPA
had
been
under
a
court
ordered
deadline
for
taking
final
action
on
the
Washington
area's
rate­
of­
progress
(
ROP)
plan.
Further
explained
that
in
the
course
of
preparing
its
final
action,
EPA
had
determined
that
regardless
of
whether
one
used
the
baseline
and
methodology
employed
by
EPA
or
suggested
by
the
commenters
during
the
proposed
rulemaking
to
approve
the
Washington
area
ROP
plan,
sufficient
VOC
credits
were
calculated
to
satisfy
the
contingency
measures
requirements
necessary
to
approve
the
Washington
area
ROP
plan.
Explained
that
this
meant
that
EPA
did
not
have
to
make
a
final
determination,
as
part
of
its
approval
of
the
Washington
area
ROP
plan,
as
to
the
appropriate
baseline
and
methodology
to
use
to
calculate
credit
from
the
state
AIM
rules.
Instead
EPA
stated
in
the
preamble
of
the
final
rule
on
the
Washington
area
ROP
plan
that
it
would
commence
a
separate
process
for
determining
the
appropriate
baseline
and
methodology
to
use
to
calculate
credit
from
the
state
AIM
rules.
In
publishing
The
"
Advance
Notice
to
Solicit
Comments,
Data
and
Information
for
Determining
the
Emissions
Reductions
Achieved
in
Ozone
Nonattainment
and
Maintenance
Areas
From
the
Implementation
of
Rules
Limiting
the
VOC
Content
of
AIM
Coatings"
EPA
has
commenced
that
separate
process.
Stated
that
a
summary
of
today's
meeting
will
be
placed
into
the
docket
of
the
Advanced
Notice
where
it
will
be
available
to
be
read
by
the
public
and
all
interested
parties.
The
deadline
for
comments
has
been
extended
until
February
16,
2006.

OTC:
Stated
said
that
the
OTC
is
aware
that
California
(
CARB
and
South
Coast
AQMD)
are
moving
further
in
AIM
controls.
Explained
that
the
OTC
is
interested
in
what
California
is
doing
and
that
an
OTC
workgroup
is
considering
another
round
of
AIM
reductions
for
purposes
of
the
8­
hour
ozone
SIPs.
Stated
that
the
OTC
had
calculated
that
its
model
state
AIM
rules
resulted
in
a
31%
reduction
beyond
the
federal
AIM
rule
and
that
EPA
had
calculated
a
35
%
reduction.
Asked
EPA
that
given
the
relative
closeness
in
the
percent
reduction
and
given
the
entire
VOC
inventory
of
the
nonattainment
areas
and
the
total
reductions
needed,
is
it
still
necessary
to
determine,
definitively,
the
baseline
for
determining
credit
from
the
already
adopted
and
SIPapproved
AIM
rules
based
on
the
model
rule.

Wanted
further
clarification
that
any
determination
that
EPA
made
regarding
the
baseline
and
methodology
for
determining
credit
from
the
already
approved
State
AIM
rules
would
be
used
prospectively
and
not
to
revisit
any
past
determinations.
Also
wanted
clarification
that
the
Advanced
Notice
and
today's
meeting
were
not
to
consider
a
3
reactivity­
based
approach
to
determining
credit
from
the
already
adopted
and
approved
OTC
states
AIM
rules.

EPA:
Clarified
that
EPA
was
not
re­
opening
any
past
rulemakings.
Stated
that
the
Advanced
Notice
and
today's
meeting
were
on
the
OTC
states'
mass­
based,
not
reactivity
based,
AIM
rules.
Clarified
that,
to
date,
EPA
has
not
issued
a
final
rulemaking
on
the
issue
of
the
credit
baseline
and
methodology
for
determining
reductions
from
the
approved
OTC
State
AIM
rules.
Explained
that
some
OTC
State
Commissioners
had
said
to
EPA
that
if
in
fact
their
State
AIM
rules
did
generate
more
VOC
reductions
than
they
had
previously
thought
to
be
the
case,
the
additional
reductions
should
be
determined
as
they
are
needed
for
the
8­
hour
ozone
SIPs.
This
is
a
relevant
issue
because
the
8­
hour
ozone
areas
SIPs'
baseline
(
from
which
attainment
and
ROP
are
determined)
uses
2002
as
the
baseyear.
As
the
compliance
date
for
the
SIP­
approved
State
AIM
rules
is
not
until
January
1,
2005,
the
reductions
from
the
states'
SIP­
approved
mass­
based
AIM
rules
are
creditable
in
the
8­
hour
plans.

OTC:
Replied
that
the
States
would
certainly
need
every
ton
or
lb/
day
of
reduction
they
can
get
for
the
8­
hour
ozone
plans.
However,
trying
to
reproduce
the
situation
which
existed
for
the
2002
inventory
may
be
difficult.
Stated
said
that
he
had
heard
numbers
of
4.5,
4.7,
5.4,
6.3,
6.7,
and
6.9
mentioned
as
baseline
levels.
He
said
distinguishing
between
these
would
be
worthwhile
as
there
seemed
to
be
confusion
between
these
numbers.

EPA:
Relayed
some
of
the
purported
rationales
behind
certain
baselines
and
methodologies
suggested
by
various
parties
at
various
times.
For
example,
in
some
cases,
the
calculations
involved
starting
with
a
4.5
baseline
to
determine
the
percent
reduction
achieved
by
the
OTC
states'
AIM
rules
beyond
the
EPA
national
rule.
Others
determined
this
percent
reduction
starting
from
a
6.7
baseline
from
a
1991
EPA
emission
inventory
guidance
document.

OTC:
Stated
that
the
OTC
workgroup
would
be
meeting
and
would
be
submitting
written
comments
to
the
docket
established
for
the
Advanced
Notice
by
the
February
16,
2006
deadline.
Stated
they
were
likely
to
comment
on
the
appropriate
baseline
prior
to
the
implementation
of
the
Federal
AIM
rule,
after
implementation
of
the
Federal
AIM
rule,
and
after
implementation
of
the
OTC
model
rule­
based
state
AIM
rules.
Also
stated
that
while
the
OTC
would
encourage
EPA
to
issue
its
determination
regarding
the
appropriate
baseline
and
methodology,
it
recommends
that
EPA
provide
flexibility
based
on
the
quality
of
the
data
and
should
issue
guidance
rather
than
a
rule
about
calculation
approaches.

The
meeting
adjourned
at
3:
25
PM.
