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Protocol for Early Action Compacts
(EAC)
Purpose of Compact
Early voluntary 8-hour air quality plans can be developed
through a Compact between Local, State and the Environmental
Protection Agency (EPA) officials for areas that are in attainment
(including no monitored violations) of the 1-hour ozone standard
but approach or monitor exceedances of the 8-hour standard.
These early action plans will include all necessary elements
of a comprehensive air quality plan, but will be tailored
to local needs and driven by local decisions. The Early Action
Compact is designed to develop and implement control strategies,
account for growth, and achieve and maintain the 8-hour ozone
standard. This approach will offer a more expeditious time
line for achieving emission reductions than the EPA's expected
8- hour implementation rulemaking, while providing "fail-safe"
provisions for the area to revert to the traditional State
Implementation Plan (SIP) process if specific milestones are
not met. Early Action Compacts should complement any existing
Ozone Flex Agreements.
The principles of the tri-party Early Action Compact to be
executed by Local, State and the EPA officials are:
- Early planning, implementation, and emission reductions
leading to expeditious attainment and maintenance of the 8-hour
ozone standard;
- Local control of the measures to be employed, with
broad based public input;
- State support to ensure technical integrity of the
early action plan;
- Formal incorporation of the early action plan into
the SIP;
- Deferral of the effective date of nonattainment designation
and related requirements so long as all Compact terms and
milestones are met; and
- Safeguards to return areas to traditional SIP requirements
should Compact terms and/or milestones be unfulfilled, with
appropriate credit given for emission reduction measures implemented.
Compact Requirements
The Compact will address the following components:
A. Milestones and Reporting
In order to facilitate self-evaluation and communication
with the EPA, TNRCC and stakeholders, the Early Action Compact
must include clearly measurable milestones for the development
and implementation of the plan. Local areas will assess and
report their progress against milestones in a regular, public
process, at least every six months. Milestones will include,
at a minimum:
- Completion of emissions inventories and modeling;
- Adoption of control strategies that demonstrate attainment;
- Completion and adoption of the early action SIP revision;
- Attainment not later than December 31, 2007;
- Post-attainment demonstration and plan updates as outlined
in Section E;
In the absence of achieving milestones, including
attaining the 8-hour ozone standard on or before December
31, 2007, the area will be deemed in violation of the Compact
and will be subject to the full planning requirements under
applicable Clean Air Act (CAA) standard SIP processes including
requirements defined as part of the EPA's 8-hour implementation
rulemaking. Such an area will be subject to the same requirements
and deadlines which would have been effective under the CAA
and the EPA's 8-hour designation rulemaking had it not participated
in this program, with no preferential delays or exemptions
from the EPA. However, the area will receive appropriate credit
in the standard SIP process for all emission reductions from
measures implemented in this program.
If the area has had a nonattainment designation deferred
and the area does not reach attainment of the standard by
December 31, 2007, then the nonattainment designation will
be effective immediately. If the EPA's implementation schedule
also requires SIP's from areas on or before December 31, 2007,
then a SIP revision demonstrating attainment by the new attainment
date will be due for the nonattainment area no later than
December 31, 2008. The EPA will offer areas no extensions
or delays of the applicable attainment date.
B. Emissions Inventory
Modeling emissions inventories using the most current
tools available will be completed for at least one recent
episode in order to support the early action plan. Emission
inventories must include:
- 1999 or later episode reflective of a typical ozone season
exceedance that meets the EPA episode selection guidance to
ensure that representative meteorological regimes are considered;
- MOBIILE6 data with link based Travel Demand Model (TDM)
mobile data in urban areas;
- NONROAD model data adjusted for local equipment populations
and usage rates;
- Area source databased when possible on local survey data.
Further episode inventories will also be developed
over time to fully represent the variety of situations that
typically contribute to ozone production in the area and to
include the most recent developments.
Emission inventories will be compared and analyzed
for trends in emission sources over time. This will improve
an area's understanding of the trends in emissions in their
community and will aid in verification of the accuracy of
the inventories.
C. Modeling
Emission inventories will be used to develop SIP
quality modeling episodes that perform within the EPA's accepted
margin of accuracy, including a base case and future case
on or before December 31, 2007. Therefore, inventories must
sufficiently account for projected future growth in ozone
precursor emissions, particularly from stationary, non-road,
and on-road mobile sources.
Local area must carefully document modeling approach,
and work will be supported and reviewed by the State and concurrently
reviewed by the EPA.
Quantifiable emission reduction measures will be
integrated into the future case to produce one or more control
cases. These control cases will be used to indicate the relative
effectiveness of different measures and aid in selecting appropriate
measures.
Prior to plan implementation the control strategies
should be determined based on model results from a control
case episode that shows achievement of the 8-hour ozone standard
on or before December 31, 2007 through implementation of the
control strategies.
Communities will continue to develop other episodes
as necessary to fully represent the variety of situations
that typically contribute to ozone production in the area
and to support the plan with the most current information
and tools. Other episodes may also indicate necessary revisions
to ensure that sufficient emission reduction measures are
selected and implemented to continue to achieve target ozone
concentration levels.
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