Ozone Transport Assessment Group Control Technologies and Options Ramada Plaza Hotel Washington, DC September 12 and 13, 1995 WORK GROUP INTRODUCTIONS AND BUSINESS Steve Gerritson of Lake Michigan Air Directors Consortium (LADCO) convened the meeting. He commented that the presentations planned for this meeting will focus on mobile, area and miscellaneous sources of nitrogen oxide (NOx). Presentations will also include the Acid Rain Program and Mike Koerber's Regional and Urban Scale Modeling Workgroup status report. A representative from the Implementation Strategies and Issues (ISI) Workgroup provided a summary of their working principles, workplan and the problems they foresee from lack of coordination with other Workgroups. Particularly, ISI has identified potential problems with the Regional and Urban Scale Modeling (RUSM) Workgroup schedule, the availability of modeling results, and constraints imposed by the availability of emission inventory data. In addition, the ISI representative stated that the ISI Workgroup is focusing some of it's efforts on the Ozone Transport Assessment Group (OTAG) goal, and operating principles. Operating principles include not assuming a goal of attainment in every area, and clarifying what is meant by "background". To address specific and general Workgroup concerns about coordination, the suggestion was made that Workgroup Co-chairs coordinate through periodic conference calls. Seven individuals provided technical presentations during the two day conference. Individuals presenting include: Mike Sklar, U. S. Environmental Protection Agency (EPA) Office of Mobile Sources (OMS); Rob Klausmeier, American Petroleum Institute (API)/Radian Corporation; Gordon Mishler, Cooper-Cameron; Peter Chant, Shell Oil Company; Bruce Carhart, Ozone Transport Commission (OTC); Ann McCabe, Amoco; and Jerome Davis, Cummins Engine. Following these presentations, Laurel Schultz and Steve Gerritson provided a status report on work in the Emissions Inventory (EI) and RUSM Workgroups. PRESENTATIONS Mike Sklar, U. S. EPA, Office of Mobile Sources Mr. Sklar offered background information on mobile sources. He commented that while progress has been made in emission reductions, trends show that growth in vehicle miles travelled (VMT) offsets progress in emissions. EPA has thus identified a continued need to reduce the rates of emissions. Since prior to vehicle model year 1990, we have seen 80-94% reduction in in-use rates, depending on the inspection and maintenance (I&M) program in place, maintenance history, and vehicle condition. Similar numbers can be shown for heavy-duty vehicles, in the range of 60% (THC and NMHC). With the reduction of major emission sources, minor sources of emissions are growing. To address some of the minor mobile sources, controls are being implemented for traditional and smaller sources, including: urban buses, large non-road engines, heavy-duty vehicles, and fleets. Source control programs are also in development for new sources, which include: locomotives, small non-road vehicles, and recreational marine sources. The group discussed the status of some of the programs in place. The current requirements of the 1990 Clean Air Act Amendments (CAA) are "final programs" (I&M and Reformulated Gasoline Program (RFG) which differ depending upon the states). The small non-road program is dependent on the NOx rule. The status of urban bus study, unknown at the time of the meeting, will be reported back to the Workgroup. As part of the initiative to control minor emission sources, the EPA is prioritizing an expanded public outreach program with information and education. They are also evaluating a new "durable car" which will not deteriorate in-use. Mr. Sklar presented an inventory of the impact of various control measures on reductions in NOx and volatile organic compounds (VOC) by the years 2000 and 2005. The impact of individual control measures, depending upon when implemented, is estimated to vary in 2000 from no impact to 17.1 % reduction. By the time of full phase-in, in 2005, impacts are expected to be larger; many ranging between 10-20% in reduction. Many of the control measures are required, and will be in the basecase. The impact on inventory of the heavy-duty NOx/PM initiative is difficult to determine at this time because the program is in the early stages of development. In many cases, the impact of control measures will not be measurable until 2000. The mobile source inventory shows negligible change after 2000. VOC emissions for light-duty (LD), nonroad and total mobile sources show negligible change after 2000. Assumptions for growth projections in VMT are 2- 3% for non-road, and less for highway sources. The group inquired whether EPAct requirements were incorporated in these projections? Mr. Sklar clarified that finalized programs were utilized, and EPAct requirements were not incorporated. He commented further that additional reductions were needed to offset growth in VMT. Mr. Sklar summarized the I&M Program. He commented that high enhanced I&M is the single most attractive program of its type because the benefits and cost per ton of emission reduction is greatest. EPA is committed to allowing states flexibility for the areas required to do Enhanced I&M as indicated by the I&M Flexibility Rule implemented in September, 1995. In this ruling, benefits accrue in 2 years, with no waiting for vehicle turnover. Emission reductions are compared to the basecase where no I&M program is in place (if an I&M program is in place, 25% reduction is expected). Mr. Sklar commented that OBD systems on new cars can supplement I&M programs, but not replace them. Remote sensing may also supplement I&M, most effectively for carbon monoxide (CO) emissions. Possible opportunities for OTAG action include: retaining enhanced I&M for the near-term to achieve VOC and NOx reductions in nonattainment areas; considering regional application of I&M; and considering OBD as a maintenance strategy in the long-term. Mr. Sklar provided a status of the fuels programs. RFG Phase I is implemented, and industry is starting to plan for RFG Phase II. He summarized the benefits and costs of % reduction for VOC and NOx resulting from the control strategy used. Costs of reduction per gallon of fuel are greater ($0.039/gallon) for RFG Phase I, and less for RFG Phase II ($0.012/gallon). If the costs are allocated to VOC, NOx and toxics control, the cost per ton values would decrease. Fuel controls like RFG can provide near-term, cost-effective benefits that can be tailored to the emission control requirements of OTAG. An averaging program, similar to that in the RFG program, can reduce costs and enhance flexibility. The cost per ton may increase or decrease as a program grows, depending on implementation. EPA will work with OTAG to refine cost estimates, based upon annualized versus seasonal costs. Other considerations are that it is important to minimize balkanization of the fuel distribution system, avoid the enforcement of fuel specifications resulting from averaging programs, synchronize refinery and fuel changes with RFG Phase II changes, and reduce opposition to RFG in RFG markets with universal fuel controls. The group inquired about expected impacts resulting from the fuels program. Mr. Sklar commented that reductions in local ozone formation and non-attainment areas would be expected, depending upon the terrain and other factors. The audience inquired why RFG was more acceptable in winter than summer? One reason is that there are not as many complaints about the smell of fuel in the winter. In addition, areas that have RFG already have Stage II nozzles, which increases consumer acceptance. The group was advised that refiners have four years to produce new fuel. Opportunities for OTAG action include opting into the RFG program, and pursuing regional fuel performance standards or fuel specifications for NOx and/or VOC in areas not eligible for RFG. Mr. Sklar discussed the current status of the National low emission vehicle (LEV) program. He noted continuing discussions between vehicle manufacturers and the Ozone Transport Commission (OTC) states, and that the Notice of Proposed Rule Making (NPRM) for the EPA program is expected to be issued soon. Potential benefits include national NOx and exhaust VOC reductions prior to EPA promulgation of Tier 2 standards, and the implementation of enhanced I&M to achieve in-use benefits commensurate with certification standards. The NLEV program offers OTAG the opportunity to relay benefits of the program to states, localities and other parties. The Highway Statement of Principles for the NOx/PM Initiative was signed and an Advanced NPRM (ANPRM) published in the summer of 1995. The Highway proposal is scheduled for late 1995 or early 1996, and nonroad SOP proposal, tentatively planned for 1996, is under discussion. Potential benefits of the NOx/PM Initiative will not be recognized until after the year 2001, however once initiated, benefits will accrue based upon fleet turnover. Under the SOP, highway standards will be reduced. Although dependent on several factors, the NOx/PM Initiative is expected to be as cost effective as other Agency programs. OTAG could take the opportunity to support the Initiative and its potential impacts, provide more extensive PM, ammonia and nonroad NOx information, and establish the value of NOx reductions in attainment areas. Several points were made regarding fuels. Cost-effectiveness and modeling results should be a guide for selection of technologies. Ground-level versus aloft controls should be evaluated, as well as the cost-effectiveness of a variety of emission controls. Efforts should focus initially on NOx, both from mobile and stationary sources. The trade-off between NOx and PM10 reductions should be evaluated, in addition to the secondary particulate effects with NOx benefits. Mr. Sklar commented that VMT growth may offset the progress in controlling mobile source emissions, whereas VMT reductions translate into NOx and VOC reductions. Mr. Sklar concluded that mobile source emissions had been reduced dramatically on a per mile basis, and that existing and future national programs will further reduce mobile source emissions. VMT growth is expected to offset the national programs to some degree, and national programs are unlikely to solve the ozone transport problem alone. Several national mobile source initiatives underway (NOx/PM and NLEV) will not provide significant benefits until after 2005. On the State level, significant additional mobile source reductions may be achieved through programs such as I&M, fuels, VMT reduction and education. Rob Klausmeier, representing API Mr. Klausmeier presented an assessment of control strategies for fuel and thermal NOx. He noted key sources of NOx as on-road and off-road, and summarized sources of stationary emissions. Potential mobile source control options discussed included: vehicle I&M, fuel reformulation vehicle/engine emission control improvements, alternative fuels, and transportation control measures. I&M programs concentrate on the cost-effective NOx reduction. The program consists of inspecting light and heavy-duty vehicles for high emissions, with an optimized enhanced test program (Basic NOx I&M) and listed modifications: simplify testing, making it biennial. The program would be most effective if focussed on mid-range cars of the fleet. The effectiveness of the Basic NOx I&M program is measured by 20% reduction potential for covered vehicles, and 4.4% NOx inventory reduction. Cost-effectiveness of the standard enhanced I&M 240 is ten times higher than EPA estimates because the repair costs were assumed to be much higher. The Federal Phase II RFG Program will be implemented in non-attainment areas by 2000. If introduced nationally, a four year lead time will be necessary. Based upon a 25% RFG penetration in OTAG, NOx reduction is equivalent to 0.4% assuming a 1990 vehicle baseline. When calculating the cost-effectiveness of the RFG, it is most appropriate to restrict the analysis to NOx control, using a conventional gasoline baseline. The average terminal rack price differential between reformulated and conventional gasoline ranges between $0.029 and $0.066. Participants wanted clarification about the contribution of NOx reductions of oxygenates. Mr. Klausmeier responded that oxygenates cause the engine to take in less air, resulting in no benefits. Further, a fuel penalty is included if oxygenates are excluded from the estimations. Others inquired if, prior to the introduction of RFG, there was any comparison with other markets? The diagram showing average terminal price differential of the delivered price was referenced for explanation. Additional information will be provided further explaining of changes in price that may result from changes in RFG. Mr. Klausmeier explained that costs were derived from changes in investment and infrastructure costs. Production costs fluctuate monthly based in part on supply and market forces adjusting to the program. Capital cost estimates were provided by API studies on implementing RFG. Further clarification was requested to separate out operational from capital costs. The group discussed factors that impacted total financial impacts of the RFG program in order to evaluate the cost effectiveness. In order to determine the cost-effectiveness, there is a need to analyze on regional and temporal basis, possibly using the basis of I&M analysis as an example. It was felt that we must get beyond the "take it or leave it" approach to RFG, and look at relative costs between different programs within all activities. In general, RVP is considered to be most cost effective. Differences in refineries also impact finances; or the delivery system of fuels was stated to be much more expensive than the delivery system of 3 fuels. Concern was expressed that we may be looking at the potential for a 31 State gas program. Mr. Klausmeier commented that reformulated diesel is not as well understood as RFG because there has been no auto/oil study performed. A 2-5% NOx reduction is expected from increasing cetane. Discussions between EPA and the Engine Manufacturing Association examining cetane are on-going. He characterized the 49 State LEV program as the same as the California LEV program with enhanced I&M. NOx reductions from the 49 State LEV program are expected to be 15% (Sierra Institute study). States are assuming that vehicles would achieve a 50% reduction if a maximum I&M program were in place. Mr. Klausmeier then discussed the emissions impact of NOx reductions. He stated that diesel engines are required to meet more stringent NOx standards. Diesels account for roughly 0.33 of mobile NOx sources. Off-road vehicles also comprise a significant source of NOx. Mr. Klausmeier mentioned that there are several emission reduction strategies for off-road vehicle sources, most of which result in small near-term reductions and larger long-term emission reductions. The cost-effectiveness of emission standards is generally less than $5,000. Mr. Klausmeier summarized general control strategies for stationary sources as combustion modifications, post-combustion after treatment and fuel modifications/switching. He summarized the cost per ton of stationary source NOx control as ranging from $100 for some utility boilers to $14,000 for some industrial/combustion boilers. He commented that for utilities there is a less incremental reduction when considering recently implemented technologies. NOx reasonably available control technology (RACT) and Tier I were not included in the data presented. Gordon Mishler, Cooper-Cameron Corporation Gordon Mishler described the Cooper-Cameron Corporation as specialists in reducing emissions from existing engines. Their retrofits are concentrated in California and Nebraska. He described the CleanBurn Methodology, commenting on the effects of the lean air/fuel ratio and the pre-chamber ignition system on NOx, CO and HC emissions. CleanBurn packages include: parametric adjustment, jet cell heads, minimum, moderate and full CleanBurn, and catalytic reduction. Mr. Mishler explained that the parametric adjustment "tweeks" the engine to reduce emissions. A potential problem with the parametric adjustment is its lack of permanence, causing the engine to return to former operation and emissions. He stated the adjustment can also effect the engine performance through wear and tear, which can result in decreases in NOx, increases in CO, and variation in fuel consumption. Most engines include some pre-ignition system to contain emissions. Some systems are more appropriate for specific weather conditions or times of day. To gain permanent reductions, care is required. For baseline testing, it is necessary to know weather conditions of operation and where the engine starts from in terms of load capacity. More complete combustion takes place with the "minimum" CleanBurn technology with the addition of the Jet Cell kit (with and without turbo chargers). Mr. Mishler estimates $1,000 to $1,500 per ton reduction cost for the "minimum" CleanBurn technology. The cost increases for the "moderate" and "full" technologies. He commented that the "full" CleanBurn is the best technology for new engines. Mr. Mishler indicated that there are competitive alternative systems, but the company attempts to incorporate much of the technology and offers most of it for sale. Some examples include High Energy Ignition systems, stratified charge and selective catalytic reduction. He commented that roughly 6,000 pipeline units exist, approximately 2,000 of which are from this company, and approximately 10,000 engines of varying horsepower in the industry. Peter Chant, Shell Low NOx Fuel Mr. Chant characterized the Shell Low NOx fuel as a liquid diesel fuel used as an alternative for #2 diesel fuel. This fuel can be suitable for all categories of stationary sources, both existing and new. Low NOx fuel was developed to meet the California requirements. Currently, it is being used in 400 sources in California. The group inquired whether this option was reasonable for markets outside California? Shell believes there are reasonable applications. Emissions from a retrofitted boiler simulate the reductions for natural gas. For the purposes of shaving peak load, a 15% reduction in NOx by fuel switching for an IC generator was used for an example. Larger decreases are possible by adding slight equipment changes. In some cases, the fuel switching option can obtain reductions in both NOx and sulphur; the technology does not always require additions in sulphur to achieve NOx reductions. Calculations to show the cost per ton of NOx reduced are not yet available. This fuel is not a modified diesel. Rather, it is a blend of two fuels to compensate for the removal of nitrogen from the fuel. The cost of Low NOx fuel is higher, but the argument was made that the evaluation of this fuel should include factors other than the cost per gallon. Fuel switching is considered to be an efficient option because engines can be operated continuously without shutting down operations. The cost per ton of NOx saved as a result of fuel switching can average $2-3,000 per year. Low NOx fuel has yet to be tried on mobile sources, though research into the applications have been initiated. East of the Rockies, the fuel is only in use in two sources. It takes 18 months from initial interest to affect the change in fuel. West of the Rockies there are 400 sources utilizing the Low NOx fuel. Bruce Carhart, 49 State LEV Program Mr. Carhart described the history of the development of the 49-State LEV Program. He stated that it originates in the adoption by the Ozone Transport Commission of the California LEV program and the offer of the domestic and international vehicle manufacturers to introduce a federal low emission vehicle program. The OTC has preferred their program, approved by the U.S. EPA, but are interested in the additional emission reductions that could result from a nation-wide program. The parties continue to negotiate the details of the program. Currently, a description of the framework of the Memorandum of Understanding (MOU) has been presented to EPA's Subcommittee on Mobile Source Emissions in Northeastern States which includes representatives from States, vehicle manufacturers, the oil industry, the utility industry and other interest groups. The purpose of the program was described as the further development of motor vehicle emission controls and advanced technology vehicles. The MOU would define the parameters of the program, and EPA would implement the program through regulation. The alternative technology vehicle (ATV) component would be separately implemented through a voluntary agreement between the Northeastern States and the Vehicle Manufacturers. States would be looking for the option of incorporating additional reductions through the introduction of ATVs in the years 2000 and beyond. Currently, discussions are continuing on the issue of electric vehicle mandates, the nature of the commitment by all parties to the negotiation and other issues. The NOx standard will be .2 g/m. Accounting for the deterioration factors, the certification standards ratio is a closer indication of the reductions that can be expected. Reductions per vehicle have been estimated at 15-50% depending on the implementation of enhanced I/M. The incremental added costs for these vehicles might be: less than $100/vehicle, LEV's ~$100/vehicle, and ZEV's vary. Honda just certified LEV's under the California program and estimated the cost to be ~$100 per vehicle. The fall-back of Tier II emissions standard is insecure for the States because the CAA does not require the development of more stringent regulations. If the 49 State LEV program is not adopted, States can still adopt the California program individually. Mr. Carhart stated his understanding that EPA intends to issue a NPRM. States are anxious for the initiation of this process in order to invite public comment and lead to implementation by the States' February 15, 1996 SIP revision deadline. It is in all parties' interest in moving the process ahead. Mr. Carhart suggested that it might be appropriate to consider the results of the emissions inventory. He believes that a high percentage of NOx emissions are likely to be found from mobile sources through the emissions inventory. This information is critical to assessing the value of various control measures. Steve Gerritson, LADCO, Presentation on Modeling Findings Steve Gerritson provided a review of modeling findings which included a presentation of major results. Conclusions to date include that transport affects most urban areas, and that VOC control is more effective in urban areas. In addition, NOx controls offer mixed benefits and disbenefits. On a regional scale, NOx control is more effective with some benefits demonstrable for VOC control. Long range transport does occur and has been documented by LADCO in the Midwest. Sensitivity tests completed for reduction of VOC and NOx at 60%, though it is difficult to impossible to achieve 60% reductions. The disbenefits of NOx reductions in terms of increases in VOC were documented. Reductions in upper level versus lower level NOx were examined and downwind areas were shown to benefit from NOx reductions, particularly over Lake Michigan. The impacts of upper level NOx reductions go further downwind than lower level reductions. In New York, using UAMV, the results show a significant urban disbenefit for NOx and VOC reductions combined, and rural benefit for NOx and VOC reductions which is not the result sought. Not all representatives agree. Some stated that transport is the cause of some, but not all ozone exceedences. Major local emissions reductions in urban areas would have to be so large that they may not be politically feasible without transport reductions. The group inquired about the size of the rural NOx component in the inventory. Mr. Gerritson responded that upwind NOx reductions have the greatest benefit. Stationary sources provide the opportunity for rural NOx reductions. He summarized the boundary conditions as: most efficient reductions in 30-40% for incoming ozone and VOC, and 50% reduction in local emissions to reach attainment. Constraints on modeling include specific requests for data in time, and the detail of modeling one source. Laurel Schultz, U.S. EPA, Emissions Inventory Information Laurel Schultz commented that projections are available on the impact of the emissions inventory reductions on the various categories of NOx sources. She referenced the table of 1990 Interim Inventory and 2005 CAA Inventory, indicating the table utilizes RACT and current CAA requirements, and not any strategies beyond. She said that documentation is available from EPA. She discussed the assumptions used for the inventory, and suggested that it may be useful to discuss the assumptions with the Emissions Inventory Workgroup. Several questions were posed. Should the differences between Phase I controls and CAA requirements be reconciled? What is assumed to be implemented and what is not included? What about growth projections for the utility industry? What will be the impacts of deregulation? A member of the group commented that there will be shifts in the location of emissions, but growth in capacity will not be significant. Growth in generation will be more prominent. The group agreed to try to pose the question to the Emissions Inventory Workgroup. Ann McCabe, Amoco, Yorktown Refinery Ann McCabe described the history of the joint pollution prevention project at the Yorktown Refinery. In 1989, Amoco and U.S. EPA developed a joint pollution prevention project and the Yorktown Refinery was selected. The project found that there are better ways to achieve environmental results other than standard command and control regulatory program. The purposes of the project were to: determine emissions, develop options to reduce releases, identify factors that encourage pollution prevention initiatives, and increase the participant's knowledge of refinery regulatory systems. Amoco is now supporting alternative compliance mechanisms and innovative solutions to complex environmental problems as a result of participating in the program. They have developed a cost-effective release reduction ranking. Amoco has examined various risk and emissions reduction projects on the site, and selected the most effective ones. The results suggest the use of analysis of equivalent risk reduction of various alternatives. They feel that region-specific solutions are important to consider, and that starting with more accurate emissions data would be beneficial. In addition, they feel that flexibility in industry implementation can make for more efficient reductions. The audience inquired whether there are ways of accounting for the reductions achieved through these types of measures in the development of the interim inventory and the OTAG inventory work? It was acknowledged that it might be difficult to account for this. Jerome Davis, Cummins Engine Jerome Davis discussed stationary generation, diesel engines (20 parts per million), environmentally benign technologies, and exhaust after treatment technology. He introduced the Trademark, NOXtech. The technology utilizes cyanuric acid powder, a large volume reactor, and recovers waste heat (45-50%) of system. NOXtech has similar lifecycle costs ($100,000/kw) to Selective Catalytic Reduction (SCR). An advanced system achieves 20-30% more reductions than a SCR system. The technology is expected to achieve 98% NOx reduction (1000ppm to 20ppm) at $500. per ton. Fuel represents 5-7% of the total cost. NOXtech is a liquid system, with heat recovery, and no by-product emissions. In response to a question, he stated that there are commercial opportunities for the system in natural gas. It can be used on a boiler, turbine engine, incinerator, and on a reciprocating engine. Cummins expects 80% reduction in PM10. The system is permitted by SQAMD, and it may become part of an upcoming best available control technology (BACT) workshop in California. A member if the audience inquired whether the system could be miniaturized for use in mobile sources? Mr. Davis responded that it would be hard to raise the exhaust temperature. DISCUSSION As a wrap up to the four days of presentations, the group discussed forming small groups to summarize technologies for utilities, mobile sources, other stationary and area sources. The group agreed to list potential control measures, standardize cost/benefit analyses, and measure and rank technologies. The need to be able to compare across industries, but focus within industries was recognized. Those working on utilities should examine: total and unit costs, control technologies for a range of boilers, boiler population and location, caveats for use of technologies, use methodologies, and reduction potential. A goal should be to provide an evaluation of what the best way to model boiler reductions is prior to the October 5 and 6, 1995 meetings. One member mentioned their understanding for cost-effectiveness, ISI needs: consistent data format, sectors in comparable presentation, cost per unit and $ per ton, % change in reductions per unit cost, and itemized assumptions. For comparison, it is essential to establish commonality between industries. General guiding principles should include: flexibility for least cost solutions, evaluation of options in the context of and building on other existing requirements (i.e., Phase II Acid Rain rules), and continued coordination. Evaluation of mobile Sources should involve: cost per mile, total cost, seasonal needs, timing information on feasibility, total potential tons of reduction, and some consideration of geography. All options should be evaluated, and the process should be iterative. General concern was expressed about whether these strategies would result in the reductions sought. The group was reminded to focus on listing technologies and information for emissions reductions, not recommending strategies. Information generated by the Workgroup would include a comparison of the relative effectiveness of different technologies. To address some of the other specific concerns noted by the Workgroup, the possibility of involving other industry groups, such as utility boilers, was raised. Additionally, the group felt that a meeting with the ISI Workgroup would be beneficial. NEXT STEPS þ As appropriate, Workgroups will schedule conference calls to facilitate inter-Workgroup coordination. þ The CTO Workgroup will meet with the ISI Workgroup the morning of October 5, 1995. þ The group agreed to identify small task groups to summarize the technologies for industries in three areas: utilities, mobile sources, other stationary and area sources. Each task group will: 1) List potential control measures for the industry, 2) Suggest a standardized process for completing cost/benefit analyses, 3) List example locations of the technology (seasonal needs for mobile sources), 4) Provide total cost of the control measure, 5) Identify total potential tons of reduction, 6) Compute the cost per ton of emissions (as well as cost per unit, and % change in reductions per unit cost), and 7) Describe the applicability of the control measure. The group agreed on the importance of being able to compare these characteristics across industries, but suggested that the use of the controls will focus within industries. Comparability was said to be particularly important in the area of cost effectiveness, given Implementation Strategies and Issues Workgroup's task of packaging control measures. Individuals that volunteered for each industry sector included: þ Utilities: Cunningham, Herrin, and Golden þ Mobile Sources: Gottshalk, Sklar, Marin, and Meteyer þ Other Stationary and Area: Gerritson, Pezze, Forbes, Garber þ Cunningham, Golden and Herrin will draft the best way to model boiler reductions prior to the October 5 and 6, 1995 meetings. þ The group also discussed several general principles under which CT&O will operate, including: þ Flexibility for utilizing least cost solutions; use of performance-based emissions limits þ Piggybacking on other requirements such as Phase II Acid Rain and 49-State LEV þ Creativity in addressing upcoming programs such as Phase II Reform Gas. 259\08\013.skw