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Protocol for Early Action Compacts
(EAC) (cont.)
D. Control Strategies
After all adopted Federal and State controls that
have been or will be implemented by the attainment date of
December 31, 2007, are accounted for in the modeling, the
local area will identify additional local controls, as necessary,
to demonstrate attainment of the 8-hour standard on or before
December 31, 2007. These local controls will be specific,
quantified, permanent and enforceable control strategies.
All controls will include specific implementation dates, as
well as detailed documentation and reporting processes.
Controls will be implemented as soon as practicable,
but not later than December 31, 2005.
Controls will be designed and implemented by the
community with full stakeholder participation.
All control measures will be incorporated by the
state into the State Implementation Plan and submitted to
the EPA for review and approval. In the event that areas wish
to add or substitute measures after SIP submittal, plan modifications
will be treated as SIP revisions and facilitated by the state.
E. Maintenance for Growth
The plan must include a component to address emissions
growth at least 5 years beyond December 31, 2007, ensuring
that the area will remain in attainment of the 8-hour standard
during that period. This future attainment maintenance analysis
may employ one or more of the following or any other appropriate
techniques necessary to make such a demonstration:
- Modeling analysis showing ozone levels below the 8-hour
standard in 2012;
- An annual review of growth (especially mobile and stationary
source) to ensure control measures and growth assumptions
are adequate;
- Identification and quantification of federal, state, and/or
local measures indicating sufficient reductions to offset
growth estimates.
The plan must also detail a continuing planning process
that includes modeling updates and modeling assumption verification
(particularly growth assumptions). Modeling updates and planning
processes must consider and evaluate:
- all relevant actual new point sources;
- impacts from potential new source growth; and
- future transportation patterns and their impact on air quality
in a manner that is consistent with the most current adopted
Long Term Transportation Plan and most current trend and projections
of local motor vehicle emissions.
If the review of growth demonstrates that adopted
control measures are inadequate to address growth in emissions,
additional measures will be added to the plan. Local planning
processes should prepare for this possibility.
F. Public Involvement
Public involvement will be conducted in all stages
of the planning and implementation process.
Public education programs will be used to raise awareness
regarding issues, opportunities for involvement in the planning
process, implementation of control strategies, and any other
issues important to the area.
Interested stakeholders will be involved in the planning
process as early as possible. Planning meetings will be open
to the public, with posted meeting times and locations. Plan
drafts will be publicly available, and the drafting process
will have sufficient opportunities for comment from all interested
stakeholders.
Public comment on the proposed final plan will follow
the normal SIP revision process as implemented by the State.
Semi-annual reports detailing, at a minimum, progress
toward milestones, will be publicly presented and publicly
available.
Local, State and the EPA Commitments
Local Areas
Local areas hold primary responsibility for the development
and implementation of the plan, as well as for maintaining
communication with all parties, including:
- Drawing up the Compact, which embodies the requirements
described in Sections A-F, including a time line for milestones.
- Completing and signing by all parties of the Early
Action Compact no later than December 31, 2002.
- Completing and adopting the early action plan as
part of the SIP no later than December 31, 2004.
- Notifying parties as soon as possible of issues and
developments, which may impact performance and progress toward
milestones.
- Notifying parties as soon as possible if Compact
milestones will be missed or have been missed.
- Notifying parties as soon as possible if Compact
modification/termination is to be requested.
State
The state will assist in the drafting of the Early Action
Compact and will provide support to areas throughout the planning
and implementation process, including:
- Technical assistance in the development of emission
inventories, modeling process, trend analysis and quantification
and comparison of control measures;
- Necessary information on all Federal and State adopted
emission reduction measures which affect the area;
- Critical third party review of emissions inventory,
modeling, and self-evaluation work;
- Technical and strategic assistance, as appropriate,
in the selection and implementation of control strategies;
- Technical and planning assistance in developing and
implementing processes to address the impact of emissions
growth beyond the attainment date;
- Maintenance of monitors and reporting and analysis
of monitoring data;
- Support for public education efforts;
- Coordinate communication between local areas and
the EPA to facilitate continuing the EPA review of local work;
- Expeditious review of the locally developed plan,
and if deemed adequate, propose modification of the SIP to
adopt the early action plan;
- Adoption of control measures into the SIP as expeditiously
as possible. The final complete SIP revision must be completed,
adopted, and submitted by the state to the EPA by 2004.
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