DocScan Pro free trial
EPA-450/4-74-002
(OAQPS No. 1.2-021)
GUIDELINES FOR AIR QUALITY
MAINTENANCE PLANNING AND ANALYSIS
VOLUME 2:
PLAN PREPARATION
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, N. C. 27711
July 1974
-------
DocScan Pro free trial
This report is issued by the Environmental Protection Agency to report
technical data of interest to a limited number of readers. Copies are
available free of charge to Federal employees, current contractors and
grantees, and nonprofit organizations, as supplies permit, from the
Air Pollution Technical Information Center, Environmental Protection
Agency, Research Triangle Park, North Carolina 27711, or at a nominal
cost from the National Technical Information Service, 5285 Port Royal
Road, Springfield, Virginia 22151.
This report was furnished to the Environmental Protection Agency by
the Research Triangle Institute, Research Triangle Park, N. C., in
fulfilment of Task Order No. 1, Contract Number 68-02-1386. The
contents are reproduced herein as received from the contractor.
Prior to final preparation the report underwent extensive review and
editing by the Environmental Protection Agency and other concerned
organizations. The contents reflect current Agency thinking and will
form the basis for promulgation of official policy in Requirements
for Preparation, Adoption, and Submittal of Implementation
Plans (40 CFR Part 51).
Publication No. EPA-450/4-74-002
(OAQPS Guideline No. 1.2-021)
11
-------
DocScan Pro free trial
A
FOREWODD
This document is the second in a series comprising Guidelines
for Air Quality Maintenance Planning and Analysis. The intent of
the series is to provide State and local agencies with information
and guidance for the preparation of Air Quality Maintenance Plans
required under 40 CFR 51. The volumes in this series are:
Volume 1: Designation of Air Quality Maintenance Areas
Volume 2: Plan Preparation
Volume 3: Control Strategies
Volume 4: Land Use and Transportation Considerations
Volume 5: Case Studies in Plan Development
Volume 6: Overview of Air Quality Maintenance Area Analysis
Volume 7: Projecting County Emissions
Volume 8: Computer-Assisted Area Source Emissions Gridding
Procedure
Volume 9: Evaluating Indirect Sources
Volume 10: Reviewing New Stationary Sources
Volume 11: Air Quality Monitoring and Data Analysis
Volume 12: Applying Atmospheric Simulation Models to Air
Quality Maintenance Areas
Additional volumes may be issued.
All references to 40 CFR Part 51 in this document are to the
regulations as amended through July 1974.
m
-------
DocScan Pro free trial
TABLE OF CONTENTS
Chapter Page
Foreword iii
List of Figures vi
List of Tables vii
I INTRODUCTION 1-1
A. Background 1-1
B. Introduction 1-2
C. Plan Preparation 1-4
1. Time Schedule 1-4
2. Plan Preparation Sequence 1-4
3. Plan Revision and Review 1-7
D. Source Documents 1-8
1. Vol. 1. Designation of Air Quality
Maintenance Areas 1-8
2. Vol. 2. Plan Preparation 1-8
3. Vol. 3. Control Strategies 1-8
4. Vol. 4. Land Use and Transportation
Considerations 1-9
5. Vol. 5. Case Studies in Plan Development 1-9
6. Vol. 6. Overview of Air Quality Maintenance
Area Analysis 1-9
7. Vol. 7. Projecting County Emissions 1-9
8. Vol. 8. Computer-Assisted Area Source Emissions
Gridding Procedure (CAASE) 1-10
9. Vol. 9. Evaluating Indirect Sources 1-10
10. Vol. 10. Reviewing New Stationary Sources 1-10
11. Vol. 11. Air quality Monitoring and Data
Analysis 1-10
12. Vol. 12. Applying Atmospheric Simulation
Models to Air Quality Maintenance Areas 1-11
II INTERGOVERNMENTAL COOPERATION II-l
A. Introduction II-l
B. Basis for cooperation and coordination II-2
C. Existing coordination Frameworks II-3
1. Coordination Devices II-4
2. Coordination Agencies 11-8
3. Limitations in Existing Coordination Frameworks II-9
4. General Considerations for selecting
Coordination Frameworks 11-10
D. Example Modes of Coordination 11-13
1. Mode 1 II-13
2. Mode 2 11-14
3. Mode 3 11-14
4. Mode 4 11-15
E. Approaches to Interstate Management Situations 11-15
1. Preparation for Interstate Coordination 11-15
2. Noncompactual Mechanisms 11-16
3. Interstate Compacts 11-16
F. Plan Preparation Sequence and Check Lists 11-17
G. Public Participation 11-24
iv
-------
DocScan Pro free trial
Chapter
III
REVIEW OF EXISTING DATA AND RESOURCES
A. Introduction
B. Emission Inventory
C. Emission Projections
D. Ambient Air Quality Data
E. Meteorological Data
F. Governmental Structures
IV AQMA ANALYSIS
A. Introduction
B. Procedures
1. Develop Growth Factors and Development
Patterns
2. Refine AQMA Boundaries
3. Perform Analysis of the Air Quality
Situation
4. Quantify Air Quality Maintenance Requirements
5. Characterize Projected Emissions
V DEVELOPMENT OF MAINTENANCE STRATEGIES
A.
B.
Introduction
Development of Alternative Maintenance Strategies
1. Estimate Potential Further Reductions
from Existing Sources
2. Determine Potential Source Category Candidates
3. Determine Maintenance Measure Applicability
4. Determine Contribution to Emission Reduction
and for Air Quality Impact
5. Determine Compatibility of Measures
6. Develop Alternative Maintenance Strategies
Selection of Preferred Strategy
1. Social Effects
2. Economic Effects
3. Select Preferred Maintenance Strategy
VI AQMP ASSEMBLY
A.
B.
C,
D.
E.
Introduction
AQMP Format
1. Introduction
2. Documentation
3. AQMA's
State Review of the AQMP
Public Hearings
Revising, A (opting, and Submitting the AQMP
VII BIBLIOGRAPHY
APPENDIX A FUNCTIONAL PROGRAMS
APPENDIX B EVALUATING SOCIAL IMPACT OF MAINTENANCE STRATEGIES
APPENDIX C EXAMPLE OF PRESENT VALUE CALCULATIONS
APPENDIX D MAINTENANCE MEASURES
III-l
III-l
III-l
III-l
III-3
III-3
III-4
IV-1
IV-1
IV-1
IV-2
IV-2
IV-3
IV-6
IV-8
V-l
V-l
V-2
V-3
V-3
V-3
V-4
V-5
V-7
V-7
V-8
V-10
V-ll
VI-1
VI-1
VI-1
VI-1
VI-3
VI-5
VI-9
VI-9
VI-11
VII-1
A-1
B-l
C-l
D-l
-------
DocScan Pro free trial
LIST OF FIGURES
Figure No. Page
1-1 Potential Compliance Schedules 1-3
1-2 Schedule of the AQMP process of AOMP's 1-5
1-3 States' action sequence for air quality maintenance 1-6
planning
II-l Checklist for agencies involved in preparation and 11-19
implementation of AQMP
II-2 Agency requirement checklist 11-23
V-l Example format for indicating additional V-4
control potential
V-2 Suggested format for maintenance strategy summary V-l7
VI-1 An example format for identifying AQMA's, vi-2
jurisdictions involved, pollutants of concern,
and recommended action.
VI-2 An example format for summarizing agency involvement VI-4
in AQMP implementation.
VI-3 Suggested format for providing estimates of labor VI-6
requirements, by agency, for three key years.
VI-4 Suggested format for the presentation of funding VI-7
required for years beqinning June 1975, June 1980
and June 1985.
VI-5 Suggested format for summarizing in broad categories VI-8
the results of the AQMA analysis.
VI-6 Suggested format for summarizing strategy evaluations VI-10
B-l Worksheet for social evaluation of maintenance B-8
measure.
B-2 Worksheet for evaluating social impact of a B-15
maintenance measure.
-------
DocScan Pro free trial
LIST OF TABLES
Table No. Page
II-l Suggested functions requiring coordination in the 11-18
preparation of the Air Duality Maintenance Plan
IV-1 Calculation sheet, quantification of maintenance IV-7
strategy requirement
V-l Applicability of selected air quality maintenance V-5
measures
V-2 Interrelationships among maintenance measures V-7
V-3 Maintenance strategy cost elements and data sources V-l5
A-l Indirect sources requiring approval A-8
A-2 Operational approaches of Federal areawide A-23
programs: 1972
B-l Examples of social factors B-3
B-2 Derivation of the Wi B-4
B-3 Consistency check B-5
B-4 Example of derivation of W. B-6
B-5 Example of consistency check B-6
B-6 Example of subscore evaluation B-9
B-7 Computation of evaluation scores B-10
B-8 Summary, ranking of evaluation scores B-10
B-9 Example of differences through time B-ll
B-10 Example of computation of evaluation scores B-l2
C-l Examples of present value calculations C-2
vii
-------
DocScan Pro free trial
Chapter I: INTRODUCTION
A. BACKGROUND
All States, pursuant to 40 CFR 51.12 (e), were required to identify
areas that have the potential for exceeding any National Ambient Air
Quality Standard (NAAQS) because of present air quality and/or projected
growth over the 10-year period, 1975-1985. Such areas are called Air
Quality Maintenance Areas (AQMA's), and may be identical with counties,
urban areas, Standard Metropolitan Statistical Areas (SMSA's), or other
boundaries. EPA is currently reviewing the information supplied by the
States. The Administrator will issue an official list of the designated
AQMA's in August 1974. For each designated area, States are to "submit
a plan to prevent any national standards from being exceeded over the
10-year period from the date of plan submittal. Such plans shall
include, as necessary, control strategy revisions and/or other measures
to ensure that projected growth and development will be compatible
with maintenance of the national standards throughout such 10-year
period." States are further required to review the plan at 5-year
intervals.
The plan for the maintenance of air quality for each pollutant in
each AQMA will be a revision of the State Implementation Plan (SIP).
Accordingly, the maintenance plan must specify precisely, and supply
the rewording of, any parts, sections, or paragraphs of the SIP that
require modification as a result of air quality maintenance activities.
Once designated, an AQMA must be analyzed in detail and the analysis
must be presented in the 10-year Air Quality Maintenance Plan (AQMP).
If the analysis demonstrates that, in fact, the area is not a potential
problem, EPA will consider deleting the area from the AQMA listing during
the review and approval process. Separate maintenance strategies must be
developed and included in the AQMP for each designated pollutant in each
of the designated AQMA's for which analysis indicates that a problem will
exist during the 1975-1985 period.
1-1
-------
DocScan Pro free trial
B. INTRODUCTION
Inherent in the development of the AQMP is the assumption that
NAAQS will be attained by 1975 (or up to 1977 with an extension).
The control strategies for attainment were developed as part of the
SIP's in 1971 using 1969 or 1970 air quality and emissions data.
AQMP's will be developed using updated air quality and emissions data.
Projection of ambient air quality using more recent data might confirm
the expected attainment of the NAAQS as scheduled. There is always the
possibility, however, that such projections will indicate possible non-
attainment, especially for particulate matter and oxidants. Should
analysis of existing and projected air quality and emissions data
indicate this to be the case, States should submit a combined attainment/
maintenance plan. The maintenance or attainment/maintenance plan should
be submitted and incorporate control strategies designed to provide the
emission reductions required to maintain or to attain and maintain the
NAAQS. The control strategies in either case are designed to control
or accomodate existing emissions and the emissions that would result from
growth and development within the AQMA through 1985.
For the sake of simplicity, in this document the term "Air Quality
Maintenance Plan (AQMP)" will be used to describe the plan to be submitted
by the appropriate States in June 1975, whether it is an attainment/
maintenance plan or only a maintenance plan.
Analysis of the air quality situation in an AQMA can disclose
several possibilities for attainment and maintenance of the NAAQS. The
most probable ones are shown schematically in figure 1-1.
1. Case A represents the situation wherein the SIP attainment
strategy will result in emissions sufficiently below those required to
attain NAAQS and to accomodate growth through 1985. Neither a maintenance
plan nor a revised attainment plan is required.
2. Case B represents a situation wherein the SIP attainment
strategy will result in attainment of the NAAQS by the required time
but in which growth and development will cause the NAAQS to be violated
within 1975-1985. A maintenance plan only is required in this situation.
3. Case C represents a situation wherein the NAAQS will not be
attained. The situation is further compounded by the increased emissions
1-2
-------
DocScan Pro free trial
CASE A
E
M
I
S
S
I
0
N
S
E
M
I
S
S
I
0
N
S
E
M
I
S
S
I
0
N
S
Emissions at NAAQS
Attainment
Date
1985
CASE B
Emissions at NAAQS
Attainment
Date
1985
CASE C
Emissions at NAAQS
Attainment
Date
1985
Emissions subject to AQMP EZ3
Figure 1-1. Potential Compliance Schedules
1-3
-------
DocScan Pro free trial
that will result from growth and development. An attainment/maintenance
plan is required in this situation.
This document provides information and guidance to the States for
the preparation of AQMP's. The general requirements for preparation
are discussed in the sections that follow in this chapter.
C. PLAN PREPARATION
1. Time Schedule
A time schedule for the overall process of preparing AQMP's
is shown in figure 1-2.
2. Plan Preparation Sequence
The steps required in the detailed analysis of a potential
problem area and, where necessary, the preparation of a plan to provide
for the maintenance of air quality are shown in flow chart form in
figure 1-3. Upon publication of a list of AQMA's in the Federal Register
and the issue of guidelines for preparation and implementation of the
10-year plan, the States should undertake the following tasks.
a. Intergovernmental Cooperation. The following subtasks
are required. These are described in Chapter II of this document.
1) Establish a basis for intergovernmental cooperation.
2) Delineate roles and missions of State and local
agencies.
b. Review of Existing Data and Resources. The following
subtasks are required. These are discussed in chapter III.
1) Review SIP, emissions inventories, air quality data,
and other plans.
2) Determine adequacy of emissions and air quality data.
c. AQMA Analysis. This major task is essentially a refinement
of the rough cut analysis upon which initial recommendation of areas to be
designated as AQMS's was made. Using refined growth factor and development
patterns, the designated AQMA's are subjected to a more detailed analysis
to identify specific areas within the AQMA where air quality problems
will exist through 1985 and to quantify these problems. Output of this
analysis forms the basis for the development and selection of the main-
tenance strategies that will become a part of the AQMP. Following are
1-4
-------
DocScan Pro free trial
1974
1975
0
N
D
J
F
M
A
M
J
A
S
0
N
D
EPA PUBLISHES FINAL LIST OF AQMA'S
EPA ISSUES PLAN DEVELOPMENT GUIDELINES TO STATES; PROPOSES
REGULATIONS ON SAME IN FEDERAL REGISTER; BRIEFS REGIONAL
OFFICES ON GUIDELINES
EPA PUBLISHES FINAL REGULATIONS ON PLAN DEVELOPMENT IN
FEDERAL REGISTER
STATES COMPLETE DRAFT OF AQMP'S
STATES ANNOUNCE HEARINGS; MAKE DRAFT AQMP'S AVAILABLE
STATES HOLD PUBLIC HEARINGS
STATES REVISE AQMP'S, AS NECESSARY, BASED ON PUBLIC HEARINGS
STATES SUBMIT AQMP'S TO EPA
EPA STARTS PREPARING AQMP'S FOR STATES THAT DID NOT SUBMIT PLANS
OR SUBMITTED INADEQUATE AQMP'S
EPA PUBLISHES PROPOSED APPROVAL/DISAPPROVAL ACTION ON AQMP'S
EPA APPROVES/DISAPPROVES AQMP'S; PROPOSES AQMP'S FOR STATES
THAT DID NOT SUBMIT ADEQUATE AQMP'S
EPA ANNOUNCES HEARINGS ON PLANS FOR STATES THAT DID NOT
SUBMIT AQMP'S OR SUBMITTED INADEQUATE AQMP'S
EPA HOLDS PUBLIC HEARINGS ON PLANS DEVELOPED FOR STATES THAT
DID NOT SUBMIT AQMP'S OR SUBMITTED INADEQUATE AQMP'S
EPA PROMULGATES AQMP'S FOR STATES THAT DID NOT SUBMIT AQMP'S OR
SUBMITTED INADEQUATE AQMP'S
Figure 1-2. Schedule of the AQMP process of AQMP's.
1-5
-------
DocScan Pro free trial
AUG 74
ESTABLI
ME CHAN I
SH COOPERATION
SMS
i
*
ESTABLISH
BASIS FOR
COOPERATION/
COORDINATION
\
DELINEATE ROLES
AND MISSIONS
OF STATE AND
LOCAL AGENCIES
EXISTING DATA
1
AND RESOURCES
REVIEW IP,
EXISTING AIR
QUALITY,
EMISSIONS, AND
OTHER PLANS
<
I
DETERMINE
ADEQUACY OF
AIR QUALITY
EMISSIONS AND
DATA
OCT 74
ASSEMBLE AQMP
JAN 75
FEB 75
APR 75
MAY 75
JUN 75
JUL 75
Figure 1-3. States' action sequence for air quality maintenance planning.
1-6
-------
DocScan Pro free trial
the subtasks required for this analysis. These subtasks are described
in chapter IV.
1) Develop growth and development patterns.
2) Refine AQMA boundaries.
3) Perform analysis of 1985 air quality situation.
4) Quantify air quality maintenance requirements.
5) Characterize projected emissions.
EPA will establish procedures for early revision of AQMA boundaries,
including deletion of areas from the AQMA list, if the need develops.
d. Maintenance Strategy Development. Using the quantification
and characterization of emissions as a base, alternate maintenance
strategies are developed and evaluated to derive the strategy most
suited to the AQMA. A strategy is required for each pollutant for
which the AQMA has been designated. The strategy may apply to the
entire AQMA, as in the case of hydrocarbon and nitrogen oxide controls,
or to selected portions for particulates, sulfur oxides, and carbon
monoxide. The following subtasks, described in detail in chapter V,
comprise this task.
1) Develop alternative maintenance strategies.
2) Select preferred maintenance strategy based on
economic and social acceptability evaluations.
e. AQMP Preparation and Assembly. Upon the selection of
the maintenance strategy, the AQMP is prepared and internally reviewed
within the State. The procedures, described in detail in chapter VI,
consist of the following steps.
1) Develop draft AQMP.
2) Conduct internal State review of AQMP.
3) Revise AQMP and announce public hearings.
4) Hold public hearings.
5) Revise and adopt AQMP.
6) Submit AQMP to EPA Administrator.
3. Plan Revision and Review
Two review procedures are required at 5-year intervals:
1) reassessment of area designation to determine if additional areas
should be designated as AQMA's or if areas currently designated as
1-7
-------
DocScan Pro free trial
AQMA's should be deleted, and 2) reanalysis of the impact of growth
on air quality and the control strategies and/or other measures
adopted to ensure that projected growth and development will be com-
patible with maintenance of NAAQS.
Procedures for reanalysis of the AQMP are contained in Guidelines
for Air Quality Maintenance Planning and Analysis, vol. 6, Overview of
Air Quality Maintenance Area Analysis. The reanalysis will be made on
each AQMA designated by the Administrator, EPA. The impact of projected
growth and development on air quality, and the control strategy and/or
other measures developed to ensure attainment and maintenance of the
NAAQS will be included in the 5-year review. This reassessment process
also can be used to validate the models used to estimate the air quality
during the development of the AQMP. As with the initial designation of
AQMA's, public hearings are required prior to submission of the plan
revision.
D. SOURCE DOCUMENTS
Source documents required for the analysis and development of the
AQMP are contained in the Guidelines for Air Quality Maintenance Planning
and Analysis. This series currently consists of 12 volumes with
additional volumes to be added as necessary. For example, work is
progressing in developing a volume that will describe a methodology for
projecting and allocating projected emissions on a subcounty basis.
A brief description of the volumes in this guidelines series and
anticipated publication dates follow.
1. Vol. 1. Designation of Air Quality Maintenance Areas
This document was originally published in January 1974 as
Guidelines for Designation of Air Quality Maintenance Areas, OAQPS
1.2-016. A description of the requirements and procedures for re-
commending areas to be designated as AQMA's is contained in this
volume.
2. Vol. 2. Plan Preparation (This document)
3. Vol. 3. Control Strategies
This volume, published concurrently with vol. 2, describes
the various maintenance measures that may be used as part of the
maintenance strategy. The listing of measures is not exhaustive
1-8
-------
DocScan Pro free trial
but does provide those measures that appear to have broad application
to all States. States are encouraged to develop additional measures
that may be required for the air quality maintenance problems that
may be peculiar to their areas of responsibilities.
4. Vol. 4. Land Use and Transportation Considerations
This volume describes the relationships of air quality main-
tenance and comprehensive planning. Land use and transportation con-
siderations for the air quality maintenance planner are also presented.
5. Vol. 5. Case Studies in Plan Development
This volume describes the experiences of four contractors in
the development of AQMP's in Denver, San Diego, St. Louis, and Baltimore.
Problems and solutions are included along with examples of portions of
potential plans.
6. Vol. 6. Overview of Air Quality Maintenance Area Analysis
This document presents an overview of the specific guideline
documents described in paragraphs 7 through 12 below. The document
discusses ways to enhance the analytical capabilities of local agencies,
the role of analysis in AQMP development, and the advantages of
including provisions for augmenting analytical capabilities in an AQMA.
7. Vol. 7. Projecting County Emissions
This volume describes three levels of analysis:
a. Use of Federal and State data only—the least accurate
but the most expeditious level. This approach is to be used only after
prior consultation with the appropriate Regional Office.
b. Use of locally available data to supplement or replace
Federal and State data. Special studies and locally conducted studies,
e.g., transportation and land-use plans, may be used for this purpose.
c. Use of data developed through extensive local contacts
and interviews to supplement or replace data obtained using the first
two levels of analysis.
The analysis is applied in a three-step procedure to project
emissions on a countywide basis. Step 1 is the determination of base
period emissions through a systematized routine updating procedure of
NEDS and other emission data; step 2 is a projection of economic and
1-9
-------
DocScan Pro free trial
demographic growth; and step 3 an estimation and projection of
relationships between economic/demographic parameters and emissions.
8. Vol. 8. Computer-Assisted Area Source Emissions Gridding
Procedure (CAASE)
This document is a user's manual for a computerized technique
that apportions area source emissions within a county. The apportion-
ment is based on population data from U.S. Census Bureau tapes. An
override capability exists so that it is possible for the local agency
to apportion future emissions on the basis of land use, transportation
plans, or other information. Possible relationships among land use,
population, and emissions that could be used as bases for override
factors are enumerated. The program, documented for use on the UNIVAC
computer, will be available to EPA Regional Offices on a time-sharing
basis. Versions that are appropriate for IBM computers are also
available. State and local agencies can obtain copies through the
Regional Offices.
9. Vol. 9. Evaluating Indirect Sources
This volume presents a simple methodology for estimating CO
concentrations in the vicinity of indirect sources. The following
indirect sources are included: highways, airports, regional shopping
centers, sports complexes, municipal parking lots, amusement parks,
and recreational areas. More detailed methodologies for estimating
emissions from indirect sources and the resulting impact on air quality
are presented in appendixes.
10. Vol. 10. Reviewing New Stationary Sources
This document describes methods for estimating the impact of
point sources on ground-level concentrations of stable pollutants after
certain design parameters are identified and the source's location is
known. Concentrations estimated using these guidelines would be super-
imposed over the general background concentrations (estimated with
mesoscale models) to determine whether the proposed new source is likely
to result in an unacceptable threat to air quality standards.
11. Vol. 11. Air Quality Monitoring and Data Analysis
This volume will contain information selective to air quality
maintenance in the following eight topical areas:
1-10
-------
DocScan Pro free trial
a. Air quality monitoring network design and instrument
siting: design of air quality networks, siting of instruments, and probe
location criteria.
b. Acceptable air quality methods: discussion of approved
methods for monitoring "criteria" pollutants, listing of unacceptable
methods, and those that are unapproved pending equivalency testing.
c. Monitoring site description: informational items concern-
ing monitoring sites that could be useful in interpreting air quality
data.
d. Procedures for flow and auditing of air quality data:
data flow, validation and verification, and steps to follow to evaluate
suspect air quality data.
e. Air quality trends evaluation: provides methodologies
and statistical techniques for evaluating historical air quality trends.
f. Air quality data evaluation: provides methodologies for
summarizing air quality data such as averages, means, frequency distri-
bution, etc. and how to assess the extent and magnitude of the air
quality in a particular AQCR or geographical area.
g. Interpretation of air quality data as it relates to NAAQS:
discusses issues and presents recommendations concerning violation of
NAAQS, definition of terms such as year, day, running, averages, and the
use of extrapolation techniques.
h. Establishment of baseline air quality levels: discussion
of the quantity, type, and area! and temporal distribution of air
quality data necessary for determination of baseline air quality for a
geographical area.
12. Vol. 12. Applying Atmospheric Simulation Models to Air Quality
Maintenance Areas
In this volume models that are accessable to EPA and that are
suitable for estimating representative concentrations over spatial scales
2
ranging from approximately 1 km to citywide averages are discussed. The
document covers the applicability of both calibrated and uncalibrated
models. The models are listed in ascending order of the complexity (as
determined by data requirements). The name, developer, availability,
data requirements, appropriate pollutants, sampling times, and spatial
1-11
-------
DocScan Pro free trial
scales are given. The purpose is to indicate examples of models that
can be used for various applications and to illustrate the greater
flexibility afforded with the acquisition of a more complete data set.
Models in this volume include modified rollback, Miller-Holzworth,
Hanna-Gifford, HIWAY, APRAC, AQDM/CDM, short-term models such as GEOMET,
and SAI photochemical.
1-12
-------
DocScan Pro free trial
Chapter II: INTERGOVERNMENTAL COOPERATION
A. INTRODUCTION
In some AQMA's, the present and future air quality and the community
growth situation are such that the maintenance element to be added to
the SIP will consist of relatively simple additional measures or modi-
fications to existing measures for minimizing emission of pollutants
from new and existing sources. In other areas, principally in major
urban centers, the additions and modifications to the SIP to provide
for long-term maintenance of air quality standards may be quite
extensive, involve relatively new and innovative approaches, and
incorporate provisions that are closely associated with land-use and
transportation planning and controls. In either situation, it is
prudent to ensure that the objectives and plans for air quality control
are substantially consistent with other community objectives and plans.
In the more difficult situations, however, because of the strong
relationships to overall community growth and development, it is essential
to the ultimate effectiveness of the AQMP that various community goals
and plans and all appropriate governmental entities are considered and
involved at all stages of development and implementation of the AQMP.
In addition, early public involvement and participation are essential
for the generation of public awareness and support. This chapter
is intended to assist State and local governments in the identification
of the relationships between the AQMP and other community goals, plans,
and activities, and to suggest ways that the AQMP and its development
and implementation can be integrated into and coordinated with overall
community plans, goals, activities, and institutional arrangements.
Two main tasks are involved: 1) establishment of the basis for coop-
eration and coordination, and 2) delineation of the missions for
State and sub-State agencies and groups.
II-l
-------
DocScan Pro free trial
B. BASIS FOR COOPERATION AND COORDINATION
Each state must choose a structural framework for execution of
the AQMP process. Operations in the air quality maintenance planning
and implementation process may involve governmental entities at the
State, regional, and local levels. At these levels, a variety of
special-purpose agencies, including those concerned with air pollution
control, building regulation, transportation, water supply and
pollution control, solid waste collection and disposal, and zoning,
as well as those that engage in broader activities, such as comprehensive
community planning agencies and Councils of Governments (COG's) may be
involved. Environmental, land-use, and transportation programs are
summarized in appendix A. The governor of each State, who is ultimately
responsible for the AQMP, should ensure that appropriate arrangements
are made to involve and utilize these various agencies and to ensure
both cooperation and coordination. The State agency with the leading
responsibility for doing so, under direction of the Governor, is usually
the State air pollution control agency. However, many other agencies
may have very significant roles, and a variety of institutional
arrangements may be utilized. Provision must be made for input and
review of maintenance plans by interested citizens and public repre-
sentatives. Particular attention must be given to providing that the
AQMP balances community goals and has mechanisms for resolving conflicting
ones.
The AQMP focuses on the long-term maintenance of air quality
rather than the attainment of NAAQS by a specific date as does the
SIP. Maintenance is a continuing evaluation, planning, and implementation
process. Even though the initial AQMP, due to the short time for
preparation, may utilize increased use of straightforward emission
reduction strategies, the State must begin to identify the agencies
and coordination frameworks for long-range air quality maintenance.
These agencies and coordination procedures must provide the basis for
any needed changes of the initial AQMP.
Due to the long-term focus of the AQMP, the timing of a particular
maintenance strategy is crucial. The point in time at which a particular
strategy must be implemented is linked to the industrial growth and
II-2
-------
DocScan Pro free trial
urban development of an AQCR. This fact alone makes for effective
and continuing cooperation between air pollution control and
land-use and development planning groups.
Success of the AQMP process is dependent upon effective coor-
dination and integration of various functional bodies at different
levels of government. This process involves the coordination of
transportation, land-use, environmental, and all other considerations
that impact on planning and growth. Air quality considerations must
be successfully integrated into both the planning and decisionmaking
procedures of the parties responsible in all of the above areas.
Likewise, authorities responsible for land-use, transportation, and
other environmental functions must be integrated into the AQMP
process in order to ensure that all plans are consistent and that the
AQMP can be implemented successfully. In addition, the maintenance
planning process must be iterative in terms of information feedback
and interaction of various interests and periodic review and updating.
Formal revaluation at least once each 5 years is a requirement.
Because allowable new emissions may be constraining, they will have a
significant impact on the options a community has for development.
C. EXISTING COORDINATION FRAMEWORKS
To effectively coordinate air quality maintenance activities with
other enviornmental protection and comprehensive planning activities,
coordination on the regional to city scale is essential. "Regional"
does not have the meaning of a specified area of land. Rather it is
used to refer to an area that includes several municipalities, several
special purpose districts, and in many cases, several counties. It
is necessary to focus on the regional scale because air quality is
inherently an areawide problem that transcends city/county political
boundaries. The regional scale also bridges the functional activities
of planning and implementation activities that traditionally have
been separated. Although efforts at regional planning have continued
to increase, city/county jurisdictions have generally retained the
land-use control authority necessary for plan implementation—building
and zoning regulations, taxation, and public services.
II-3
-------
DocScan Pro free trial
A basic problem in coordination is the traditional separation
of land-use planning and environmental protection activities at all
levels of government. Any coordination framework in which imple-
mentation of air quality plans is to be effective must give due
consideration to the prevalent attitude of local governments that
land-use controls are their prerogative. A corollary to this is the
recognition that air quality, land-use, and transportation objectives,
viewed from the local perspective, must be reconciled with many other
land-use and transporation objectives and goals.
Time constraints on the preparation and submission of AQMP's
preclude, for the most part, significant local agency reorganization.
Emphasis, therefore, will be on the provision of guidance for the use
of existing regional organizational and cooperative arrangements and
agencies to obtain effective coordination of air quality maintenance
and other environmental activities. Although existing institutions
should be used to initiate air quality maintenance planning and
implementation, others that may be more effective in the longer time-
frame should be developed as part of the continuing air quality
maintenance.
1. Coordination Devices
Several mechanisms that are aimed at promoting planning
and coordination at the regional/city level are in existence. These
are the Department of Housing and Urban Development's section 701
program, A-95 review, and Environmental Impact Statement (EIS)
preparation and review.
a. 701 Planning. Substantial Federal support for metro-
politan and areawide planning began with the passage of the 1954 Housing
Act. Under section 701 of this act, financial assistance was provided
to encourage metropolitan planning. At first section 701 was aimed at
municipal planning. The Housing Act of 1959 increased its impact on
regional planning and substituted "comprehensive" planning for "urban"
planning. This act also required that federally assisted planning cover
entire urban areas with related developmental problems. Various
arrangements, from city-county and regional agencies to informal
cooperative agreements between local jurisdictions have been made to
meet section 701 grant requirements (ref. 1). However, planning under
II-4
-------
DocScan Pro free trial
the section 701 program is generally done within a COG or Regional
Planning Commission (RPC) framework.
As a condition for urban renewal assistance, a workable program
is required for community development including long-range general plans
of land-use, transportation, and public facilities. This was a boost
to the regional perspective in some areas. Physical planning and capital
improvements are the main elements stressed in section 701 planning.
b. A-95 Review. The Office of Management and Budget
Circular No. A-95 sets up the structure for implementing sections of
three acts: Title IV of the Intergovernmental Cooperation Act of 1968,
section 204 of the Demonstration Cities and Metropolitan Development
Policy Act of 1966, and section 102(2)(c) of NEPA. The significance of
the A-95 review process is that it provides a structure for multifunctional
planning by strengthening the communication among agencies and different
governmental levels. This review process has wide applicability
because State, regional, and metropolitan clearinghouses that
administer the review and comment process have been widely established.
The A-95 process is a step toward regional comprehensive planning.
Because intergovernmental cooperation is very important to the
success of an air quality maintenance program, AQMP's must be processed
through the A-95 review system. Time constraints on the preparation of
the AQMP dictate that internal State review and coordination prior
to formal adoption be accomplished as expeditiously as possible. Early
involvement of the agencies participating in the clearinghouse review
process during the development of the AQMP will ensure early identification
and resolution of problems areas prior to processing the AQMP for
formal A-95 review.
Circular A-95 has four basic parts, dealing with State and
areawide review of Federal aid applications to avoid conflicting
programs (Part I), Federal agency consultation with State and local
governments prior to undertaking direct Federal development projects
(Part II), gubernatorial review of federally required State functional
plans before submission for Federal funding (Part III), and coordination
of federally supported planning programs at the sub-state regional
II-5
-------
DocScan Pro free trial
level (Part IV). Parts I and IV are especially germane to the task
of implementing cooperation between land-use planning and air quality
management.
1) Part I. Project Notification and Review System
(PNRS), established under Part I of A-95, designates State and
regional/metropolitan planning agencies as clearinghouses. Every
State has established a State clearinghouse, and a majority have
designated regional clearinghouses that in many cases are the regional
COG's. Section 204 of the Demonstration Cities and Metroplitan
Development Policy Act requires metropolitan clearinghouses. It is
the responsibility of the clearinghouses to identify appropriate
State and local environmental agencies and to make them aware of
a proposed project for which a Federal grant is being requested and
on which they should have an input. With respect to section 102
of NEPA, the clearinghouses are the channels through which agencies
sponsoring a project receive State and local comments on its environ-
mental impact.
The A-95 clearinghouses are a mixed lot reflecting the status of
regional planning. As an indication of the mixture and the range of
abilities, the initial group of clearinghouses (October 1967) consisted
of 33 COG's, 59 multicounty RPC's, 72 single county or city/county
planning agencies, three general-purpose county governments, and 20
State planning agencies (ref. 2).
Applicants for Federal grants must notify State and regional or
metropolitan clearinghouses of their intent to apply and must provide
a brief project description. The clearinghouse may or may not comment
on the proposed project. However, in the case of environmental impact
review, it is the responsibility of the clearinghouse to identify and
notify State or local environmental agencies of the proposed project.
Several specific areas are defined in which comments can be made.
These include appropriate land-use, wise development and conservation
of natural resources, balanced transportation systems, and environ-
mental impact.
PNRS focuses on coordination at the beginning of the project
application process. It thus provides the potential for revising
II-6
-------
DocScan Pro free trial
projects before viewpoints and positions have solidified. Another
value of PNRS is that after the development of an AQMP it continues
to provide information on new projects. To the extent that these
projects influence development, PNRS provides intelligence on
emergi ng growth patterns.
2) Part IV. Part IV of A-95 requires coordination of
federally supported planning programs at the regional level. Utilization
of an A-95 agency for areawide planning instead of separate regional
agencies improves coordination of different plans and more efficient
integration of them into a consistent regional comprehensive plan.
In seeking Federal grants, general-purpose planning agencies are given
preference over single-purpose agencies.
c. EIS's. Section 102(2)(c) of the National Environmental
Policy Act (NEPA) of 1969 requires EIS's to be filed with the Council
on Environmental Quality (CEQ) by Federal agencies proposing major
projects. The EIS's must consider the impact of the project on the
environment; consider and describe alternatives to the proposal and
their impacts; obtain comments from Federal, State, and local agencies;
and make public the environmental analysis and agency comments. The
relationship of the proposed action to land-use plans, policies, and
controls in the project area and how conflicts with Federal, State,
and local land-use have been resolved must be discussed.
An EIS is generally not required for private developments that do
not receive Federal funding. However, some State laws require EIS's
on private as well as on public and publicly funded development.
Twelve States and Puerto Rico have adopted broad requirements for EIS's
on State actions. Broad EIS's have been under consideration in another
21 States and the District of Columbia (ref. 3).
State EIS requirements are, for the most part, modeled on section
102(2)(c) of NEPA. However, significant differences exist from State
to State. Some apply EIS's to local, as well as to State agencies;
some require EIS's for private actions for which a government permit
is required. Most States appear to limit EIS's to "agencies of the
State," without clearly indicating which agencies or levels of government.
The applicability of EIS's to private activities is also unclear in
most States having EIS requirements. A major problem with State EIS's
II-7
-------
DocScan Pro free trial
is that little provision has been made to enforce the EIS require-
ments. Different State agencies have been given coordination
responsibility but not authority to ensure compliance by other agencies.
Federally required EIS's are coordinated through the appropriate
State, regional, or metropolitan A-95 clearinghouses.
Ideally, the preparation and review of an EIS is designed to
provide the following:
Consideration of the possible adverse effects on a project
or activity.
Consideration of alternatives to the project or activity and
their adverse environmental effects.
Review of and comment on the project or activity by all
interested agencies, governmental bodies, and the public.
EIS's have several limitations as planning and implementation
mechanisms for air quality maintenance activities:
EIS review comments are in most cases advisory in nature and
do not require alteration or abandonment of a proposed project or
activity even though it may have an adverse environmental impact.
EIS review by the air quality maintenance agency occurs late
in the planning process.
EIS requirements may not cover many projects and activities.
EIS's vary widely in quality. Related to this is the fact
that most EIS's may be too general to provide useful information to the
air quality maintenance agency. The necessary spatial and temporal
details of growth are often totally lacking.
2. Coordination Agencies
COG's and RPC's represent an approach by city governments to
regional problems. It is basically a regional confederal approach
(ref. 1) to promote common interests among a numer of governments
without subordinating their individual powers or autonomy. Although
COG's and RPC's are often used synonymously in the literature, this
is not strictly correct.
a. RPC's. RPC's are metropolitan, regional, or areawide
planning agencies composed of members appointed by the State or the
local area involved. They are primarily responsible for multifunctional
II-8
-------
DocScan Pro free trial
planning with a traditional influence on land-use planning and the
coordination of local plans. RPC's are basically of three forms--county
planning commissions, economic development district agencies, and
hybrid organizations with special characteristics not generally
associated with RPC's. The Twin Cities Metropolitan Council of
Minnesota is an example of the hybrid RFC.
b. COG's. COG's are regional associations of local
governments. They are an organizational device for continuing discussions
of common problems, information exchange, and development of consensus
policies. COG's have no authority to compel participation. Their
existence rests on the good will of the constituent local governments
(ref. 1). Some COG's are based on State legislation authorizing inter-
local planning; others on a specific enabling act; and others on no
formal or implied State permissive action.
c. Other. Other agencies have been established to promote
planning and coordination on the regional scale.
State and locally sponsored groups promoting regional approaches
to problems include:
1) Air Pollution Control Districts
2) Basin Coordinating Councils
3) State Planning Offices
4) Economic Development Districts
5) Citizens Advisory Groups
3. Limitations in Existing Coordination Frameworks
Existing regional coordination arrangements have four major
limitations for coordinating air quality planning and implementation
with other environmental protection, transportation, and land-use
activities.
a. Lack of Air Quality Element. Regional planning agencies,
whether COG's or RPC's, seldom consider the air quality implications
of land-use and transportation plans and growth policies. This is due
to 1) lack of information on the relationshp between land-use and air
quality, and 2) lack of air quality expertise on their staffs.
b. Late Air Quality Input. Although the A-95 review process
must be used to process the AQMP, several conditions must be considered.
II-9
-------
DocScan Pro free trial
The very fact that an AQMP has been prepared for the A-95 review
indicates that growth projections, control strategies, and coordinate
frameworks have been considered. The best alternatives have probably
been selected from the several available. If the A-95 review process
is the first contact that a group or agency has had with the AQMP,
it can expect to make revisions and to resolve further conflicts.
Therefore, coordination is extremely important in the early planning
stages before the AQMP is prepared for A-95 review. Implications of
land-use and transportation programs and policies on air quality
maintenance strategies must be identified early enough to permit
analysis and consideration while alternatives are being formulated
and evaluated. Such early coordination should greatly reduce confrontations
over air quality and land-use and transportation objectives in the imple-
mentation phase.
Probably, the greatest value of the A-95 review agency is that it
may provide invaluable information on who to contact in preparing the
AQMP.
c. Advisory Role of COG/RPC's. RPC's and COG's are both
procedural mechanisms to deal with common regional multijurisdictional
problems. They perform as advisory bodies and forums for communication.
Although some authority is provided through the A-95 review process and
through their designation as metropolitan transportation planning
agencies, these agencies do not generally have the authority to enforce
land-use or emission controls consistent with a regional plan. COG's
view their role as one of fostering communication and not as one of
controlling regional planning.
d. Voluntary Participation in CQG's. COG's are multi-
functional voluntary regional associations of governments represented
by local officials. Typically, they have no governmental powers or
operating responsibilities. They cannot compel participation, attendance,
or acceptance of policy decisons. In effect, their existence depends on
the good will of constituent local governments (ref. 1).
4. General Considerations for selecting Coordination Frameworks
State and local agencies should consider the following aspects
of various institutional arrangements in deciding how they will
organize and carry out their air quality maintenance activities.
11-10
-------
DocScan Pro free trial
a. The air quality maintenance system, encompassing both
planning and implementation, should be established on an appropriate
areawide scale. It should deal with interactions occurring between
air quality and growth and development throughout the air basin
that is the geographic base for the air quality maintenance process
and plan. Normally, this will be larger than a single city and often
larger than a single county.
b. The system should reflect integration between air
pollution control objectives and other State and local activities
affecting or affected by air quality considerations. This would appear
to require:
1) Use of a uniform set of growth and development
projections and policies in all components of the area's comprehensive
plan including the air quality maintenance component of that plan.
2) Incorporation in other components of the comprehensive
plan of the constraints necessary to attain and maintain air quality
standards.
c. Because of the complexity of relating air quality con-
siderations to land-use and other growth and development decisions,
unilateral planning and implementation either by any one level of
government or by any one agency should be avoided. This means that
the system should encompass intergovernmental and interagency coordination
and consultation with concerned groups, including the general public,
is also highly desirable.
d. Because the system is likely to rely heavily on inter-
governmental arrangements, it should include procedures for resolution
of conflicts that might otherwise impede preparation or implementation
of the AQMP. Effective capacity to establish an areawide consensus on
growth and development projections and appropriate maintenance policies
is essential because this consensus forms the base on which the AQMP
will be built.
e. Within such guidelines and constraints as the State
may deem necessary, it is desirable that responsibility for whatever
land-use-related decisons are necessary for air quality maintenance be
delegated to the governmental level most directly involved in determining
the area's growth and development. Similarly, responsibility for
11-11
-------
DocScan Pro free trial
regulating emissions should be delegaged, whenever practicable, to
an appropriate local or regional air pollution control unit. In
general, delegation of maintenance responsibility should be made,
to the extent practicable, to those levels of government that are
closest to the problem and its solution. Higher echelons of government
should assume maintenance responsibility only to the extent necessary
to ensure preparation of an adequate areawide AQMP and compliance
therewith.
f. The Federal Government does not intend to impose any
particular institutional or organizational arrangement. However, the
Clean Air Act does require that SIP's (and thus the AQMP part thereof)
contain adequate provisions for intergovernmental cooperation.
g. AQMP's prepared and implemented at the State and local
levels are likely to be more reflective of local public goals and
desires than would be a plan that the Federal Government is obliged to
prepare in case a State fails to submit an approvable plan.
h. While cooperation and participation of various agencies
in the AQMP process is desirable, if not essential, it is also advantageous
to retain a clearly defined point of responsibility and authority for
air conservation.
i. The participation of various units of local government
in the AQMP process is desirable but, on the other hand, there is great
merit in having a single agency carry ultimate responsibility throughout
an entire AQMA.
j. Air pollution control agencies are generally the best
suited for conducting air pollution planning and control activities
but, at the same time, they do not often embody the ability to consider
the multiple facets of general community planning for growth and
development. Therefore, collaborative activities of air quality agencies
with comprehensive planning agencies is usually desirable.
k. In any institutional arrangement for developing an AQMP,
provisions should be made to guard against one agency or task group
preparing an overly ambitious or unrealistic plan which other agencies
that are later responsible for implementation will find to be unworkable
or unacceptable. Such a situation can be avoided by including repre-
11-12
-------
DocScan Pro free trial
sentatives of the implementing agencies in the planning process.
1. In selecting the agencies to be responsible for
implementation of the AQMP, consideration should be given to the kinds
of functions presently being carried out by existing agencies. The
desirable assignments might be such that the most capable and experienced
agency would be given the new functions, with such modifications as may
be needed. At the same time, consideration should be given to new
innovative institutions that would improve effectiveness. Obviously,
duplication and overlapping of functions among several agencies should
be avoided.
m. As indicated previously, the State is ultimately
responsible for all AQMP matters and thus will exercise some sort of
review and approval authority over actions at lower levels of government.
In the same vein, if planning or implementation is carried out by local
governments at a subregional level, it may be appropriate to provide
for some kind of overview, and perhaps veto power, at the regional level
to ensure that local actions are consistent with overall regional plans
and policies.
D. EXAMPLE MODES OF COORDINATION
Four possible modes for the division of responsibility between
State and local governments in preparing and implementing the air quality
maintenance plan can be conceptualized. While actual conditions will
probably require a combination of approaches, the modes are described
as discrete entities for guidance to the States. The general conditions
of State-local relationships and air pollution problems that warrant the
use of each mode are described.
1. Mode 1
The State Agency conducts all AQMP preparation and implementation
activities within the State. Regional and local agencies, governing
bodies, and other groups only provide requested information to the State.
Local and regional participation is less than in any of the other modes.
This situation is appropriate in the following instances:
Where no planning or air pollution control expertise is
available at the local and regional levels.
11-13
-------
DocScan Pro free trial
Where the full technical capability to prepare and implement
the AQMP exists at the State level.
Where the State agency can exercise the necessary implementation
measures required by the AQMP.
Where local governments are willing to allow the State to retain
full AQMP preparation and implementation responsibility.
2. Mode 2
The State agency participates with regional and local agencies
in preparing and implementing the AQMP. All or part of the tasks for any
or all AQMP's will be performed by regional and local agencies by mutual
agreement between the State and the agencies. The State agency would
review and approve all plan elements prepared by the local agencies.
This approach recognizes variations between AQMA's with regard to
complexity of air quality maintenance problems, differences in AQMA
jurisdictional composition, and local plan implementation capabilities.
Joint State/local efforts are generally warranted:
Where there is sufficient legal authority at the local level to
execute proposed control strategies.
Where sub-State districting for air quality (Regional Air
Pollution Control Districts, etc.) or other planning (COG's RPC's)
purposes has occurred and air quality maintenance is a feasible and
logical extension of existing activities (addition of an air quality
element).
Where a sub-State entity wishes to maintain higher standards
of air quality than required by the State plan, including the establish-
ment of standards for pollutants not covered therein.
Where specific technical capability and/or experience not
available at the State level exists at the sub-State level.
3. Mode 3
Preparation of the AQMP is done jointly by State and sub-State
agencies; implementation is done by sub-State agencies.
This mode might be used:
Where there is a strong local implementation capability
particularly where local capability is stronger than the State's
capability for implementation.
Where implementation will be relatively easy (few pollutants,
no interjurisdictional problems).
11-14
-------
DocScan Pro free trial
Where it is not feasible to involve a multitude of sub-State
agencies in an actual working capacity.
4. Mode 4
Preparation of AQMP is done jointly by State and local agencies,
but all implementation is done by the State.
This mode may be used:
Where the State agency is capable of such decentralization as
may be required by the location of AQMA;
Where there is local planning capability strong enough to
assist the State agency in plan preparation;
Where there is insufficient legal authority to allow local
participation in plan implementation;
Where the air pollution problem is of such a nature that no
local implementation activity is required;
Where, for any reason, local agencies wish to participate in
preparing the plan but not in its implementation.
E. APPROACHES TO INTERSTATE MANAGEMENT SITUATIONS
While most AQMA's probably will be located entirely within one
State, a substantial number may include territory within two or more
States. A single plan covering the multistate area or a set of compati-
ble State plans may be prepared.
State plans shall include specific descriptions of the measures
proposed to achieve the required interstate coordination of air
quality maintenance activities. Such measures may include the use of
existing interstate agreements, compacts or noncompactual, or new
agreements.
1. Preparation for Interstate Coordination
In an interstate AQMA, or where interstate transmission of
air pollutants affects air quality maintenance, it is not possible to
determine unilaterally which type of agreement is needed.
Each State affected by interstate coordination requirements should
establish an interagency task force on interstate coordination. These
groups would meet with their counterparts in the adjoining State(s),
define precisely the coordination problems, determine the appropriate
course of action, and establish the arrangements needed.
11-15
-------
DocScan Pro free trial
Each task force should include representatives of the State and
local air pollution control agencies, the State land-use planning
agency, and the State transportation planning agency legal counsel,
and appropriate regional planning agencies. EPA representatives will
attend joint work sessions of these tasks forces upon request of the
States.
2. Noncompactual Mechanisms
Required coordination of air quality maintenance activities
between or among States may be met through noncompactual mechanisms.
This approach may be used where the States and EPA are mutually satisfied
that such arrangements are satisfactory in view of:
The particular pollution problems of the multistate area; or
The existence of, or proposals for, innovative noncompactual
devices adequate to meet Federal requirements for interstate coordination.
The States' Letter of Intent to Cooperate in the SIP may provide a
basis for developing noncompactual coordinating mechanisms.
3. Interstate Compacts
Air quality maintenance planning and implementation activities
within interstate AQMA's can be carried out by a single agency created
by interstate compact. The Congress, in The Clean Air Act, has given
consent for the States to negotiate and enter into agreements or
compacts that are not in conflict with any law or treaty of the United
States, and the establishment of such agencies as are deemed desirable
for making effective such agreements or compacts. Such agreements or
compacts are not binding or obligatory upon the States that are party
thereto until they have been approved by the Congress.
Since compacts are complex instruments, considerable time may be
required for their drafting and enactment. Time constraints in the
preparation of the AQMP and the complexity of the process may preclude
drafting and enactment of enabling legislation and agreements prior to
plan submission. In such a case, State plans must, as a minimum, include
the following:
A listing of the major tasks required for drafting and enact-
ing the compact, including a schedule of target dates for their completion
and for enactment of the compact;
11-16
-------
DocScan Pro free trial
A demonstration that the several States have each made
significant progress toward creation of the compact;
A discussion of any legal problems that must be resolved
before the compact can be enacted;
A description of the noncompactual mechanism that will provide
the necessary interstate coordination of air quality maintenance activi-
ties in the period prior to enactment of the compact.
State plans should present the above information in a uniform
manner and for each compact, if more than one is proposed.
F. PLAN PREPARATION SEQUENCE AND CHECK LISTS
Functions that must be performed during the preparation of the
AQMP are listed in table II-l and shown sequentially in figure 1-3.
Their functions will be performed by the State Air Pollution Control
Agency or the State or sub-State Agency designated by the State to
prepare the AQMP.
The first function is to establish the basis for coordination
and cooperation. This involves the identification and contacting of
all agencies and groups that will be involved in the process. Figure
II-l, "Checklist for Agencies Involved in Preparation and Implementation
of AQMP," is presented in this section as an aid in identifying these
agencies and groups. This checklist provides entries for defining the
task expected of each group and agency and the coordination relationships
that exist among them. Consideration should be given to the fact that
an agency or group may be involved in both preparation and implementation
of an AQMP but that its task and/or coordination mechanism may be
different for these phases. In such a case two entries should be made
for the agency or group; one for implementation and one for preparation.
In some cases it may even be worthwhile to further subdivide implementation
into planning and enforcement.
Once the existing agencies and groups, their coordination mechanisms,
and their tasks have been defined, the task of each agency or group
should be evaluated separately. To facilitate this evaluation, figure
II-2 "Agency Requirement Checklist," is suggested. Again, if the
function of a given agency or group is different for different phases
of AQMP preparation and implementation, several entries should be made.
11-17
-------
oo
D
o
o
CO
o
Q>
TJ
o
^
CD
CD
g-
01
Table II-l. Suggested functions requiring coordination in the preparation of the
Air Quality Maintenance Plan
Plan preparation task
Governor's
office
Coordination should be effected with State and local agencies
having responsibility for the function as indicated
Transportation
Air pollution & land-use Economic
control planning Legal analysis Development
State Local State Local State Local State Local State Local
Public information,
participation,
and involvement
Establish basis for cooper-
ation & coordination
Delineate roles & missions
of State & local agencies
Review SIP existing air quality
& emissions, and other plans
Determine adequacy of emissions
& air quality data
Refine AQMA boundaries
Develop growth factors &
development patterns
Perform analysis of 1975-1985
air quality situation
Quantify air quality mainte-
nance requirements
Characterize projected
emissions
Develop alternative mainte-
nance strategies
Evaluate alternative mainte-
nance strategies
Select preferred maintenance
strategies
Conduct internal State review
of plan
Revise plan & announce public
hearing
Hold public hearings
Revise and adopt plan
Submit plan to administrator,
EPA
XX XX
-------
D
o
o
CO
o
Q>
TJ
o
31
CD
g-
01
To be Filled Out by the State Air Pollution Control Agency
or its Oesignee for the Preparation of the AQMP
AGENCY
STATE AGENCIES
State Air Pollution
Control Agency
Department of Health
State Office of
Planning
State Clearinghouse
State Highway
Department
Other (Specify)
Other (Specify)
Other (Specify)
Contacted for
Input Into
AQMP Preparation
and/or
• Implementation
Yes/No
yes
Date
9-10-74
Agency Task in
Preparation and/or
Implementation
of AQMP
1. Write AQMP with
input from other
agencies and groups.
2. Implement AQMP with
county APCA.
Reviewed
Final
AQMP
Yes/No
Date
12-2-74
Existing Mechanism for
Coordination (Advisory Board,
Review, COG, RPC, Working
Group, etc.)
Advisory Board of
County Elected Officers.
Working group of Regional
COG, State Planning Office
and State APCA.
Figure II-l. Checklist for agencies involved in preparation
and implementation of AQMP.
-------
DocScan Pro free trial
•a
ro
CO C*
o s- i.
4- O O
•i- -O O
C «* 0-
fO * -rv
JZ
o c: *^—
OJ O CD •
s: ••- o o
4-> O 4->
Ol (0 QJ
c c -
•I- -r- 5 -
4-> -O OJ O-
m t- ••— 3
•i- O > O
x o a; i-
1 1 1 (_j or* ^3
!•=-
a> Ll~
o
QJ
ro
i
0)
T3
C C C
•r- n3 O
j^ c ^j
i/l O > S- E E
u m (U cr
QJ OJ Q-
CD S- E 4-
cC Q. M 0
C
o
•r- C
I- +J 0
"~ ° * 5
"U C Q} C
+-)>-•$-
c 0.2: -a a.
o c: cr c: E
01
re
C
"Z.
(/i
O)
z
LU
CD
l/l
UJ
UJ
\
•z.
2 8
a:
o
Q_
cr
c
(U
i.
o
OJ
Q
0 -M
•r- U
C 4->
O (A
UJ £3
c
o
•M
< — -4-J
o a
Q_ -r-
I-
1- +->
•I- (/)
(TJ i—
C O
o i-
is
(/)
c
01
Nl CL
+J 0
••- i-
CJ CD
(O t-
c o
0 10
en >
O) -a
CO
c
rO
n irt
-M -t-
il
O CJ
U
g.
0
4-
O
Ou
t.
QJ
O
4-
(J
S.
LO
t-
OJ
JC
o
(O
i-
tO
Q.
OJ
Q.
c -o
•i- OJ
13
T3 £=
OJ -r-
i— c:
o o
> o
C I
•1— I
00 j^
cu o-
O) O
en
-------
D
o
o
CO
o
Q>
TJ
o
^
CD
CD
g-
01
I
F\i
AGENCY
LOCAL AGENCIES
Municipal Governments
in AQMA
Municipal Community
Planners
Municipal Transpor-
tation Planners
Local Health
Department
Local Mater and
Sewer Departments
Local Zoning
Commission
Local Solid Waste
Disposal Departments
City or County Air
Pollution Control
Agency
Other (Specify)
Other (Specify)
Contacted for
Input Into
AQMP Preparation
and/or
Implementation
Yes/No
Date
Agency Task in
Preparation and/or
Implementation
of AQMP
Reviewed
Final
AQMP
Existing Mechanism for
Coordination (Advisory Board,
Review, COG, RPC, Working
Group, etc.)
Figure II-1. Checklist for agencies involved in preparation
and implementation of AQMP--Continued.
-------
DocScan Pro free trial
•o
to
o en
CO C
t- >i-*i
O i- i-
^ o o
w) 3:
i/» > *
•(— -^ O
C 1. -r- 3
•r- 0 > 0
X O or o
"O
C
ro 0> O_
>> »- E s:
u 10 o> o-
C CLi— i-t t. O>
O Q_ t. E
to -M O Ol
•*-* Z» Q. "»-^ i —
c cxs: -o o,
O c cr c E
O »— i cC fO »— •
z L. a.
Ul t- 3
r^j > o
h- UJ tD
o
in
a>
c
•— 3
J3 0
a. o
O -M
l/t
t/t u
ai -a
> c:
•*->
to «o
•M
C
wi t-
O) C
> «
•*- o.
+J E
ro O
E
a> >»
V) •!-»
O) i-
Of 13
u
0)
CL
to
£
o
o
(U
a.
t_
0
**-
aJ
D.
CO
i_
O)
JT
O
Q.
CU
Q.
C
Q)
-a
a>
o o
> CJ
C I
•r- I
D-
00 ^
(U CD-
•^-
-------
CHECKLIST 2
AGENCY REQUIREMENT CHECKLIST
To Be Filled Out for Each Agency, Governmental Body, or Other Group Involved
in AQHP Preparation and Implementation
I
ro
GO
D
o
o
CO
o
01
CD
CD
g-
01
Figure II-2. Agency requirement checklist.
-------
DocScan Pro free trial
Figures II-l and II-2 are recommended for use by the States
in providing information on coordination to EPA in the AQMP. If
these figures are not submitted with the AQMP, they should be retained
by the State for future reference. These figures should serve as a
main guide in evaluating the ability of existing agencies and coordination
frameworks to prepare and implement an AQMP. They should also provide
the basis for selecting the best coordination mode available to each
State. Finally, any need for establishing different coordination
frameworks, the addition of air quality elements to existing planning
groups, the creation of new agencies, the improvement of technical
capability, or additonal funding should be highlighted with these
checklists.
G. PUBLIC PARTICIPATION
A regulatory program that impacts on as many interest areas as
does air pollution control requires public awareness and support in
order to achieve reasonable success. This is particularly true for the
implementation of several of the unique control strategies that are,
or will be associated with, maintenance control plans. It is important,
therefore, that the public be reasonably informed of the concepts,
objectives, and implementation procedures of maintenance plans. This
can be accomplished through news releases, hearings, task force meetings,
speaking engagements, etc. Because of the importance of public support,
it is urgent that activities involving and informing the public be
initiated in the early stages of plan development and continued with
timely news releases, meetings, etc. Citizens should be provided, to
the extent possible, with opportunities to assist in defining planning
goals, defining the impact of feasible alternatives, and identifying
public preferences for these alternatives. This should result in a more
informed and supportive public at the time of hearings on the adoption
of the plan. This support should also be evident during the implementation
of some of the more controversial control strategies.
11-24
-------
DocScan Pro free trial
REFERENCES
1. Advisory Commission on Intergovernmental Relations. Regional
Decision Making: New Strategies for Substate Districts,
Washington, D.C., October 1973, p. 50.
2. Advisory Commission. Regional Decision Making, p. 141.
3. T. C. Tryzna. Environmental Impact Requirements in the States,
EPA-RS-73-024, Environmental Protection Agency, Washington,
D.C., July 1973.
11-25
-------
DocScan Pro free trial
11-26
-------
DocScan Pro free trial
Chapter III: REVIEW OF EXISTING DATA AND RESOURCES
A. INTRODUCTION
The State shall identify in its AQMP's the data used as a frame-
work for the development of maintenance strategies. Furthermore, sources
of such data shall be cited, and the basis for accepting such data as
being valid shall be stated.
B. EMISSION INVENTORY
While air quality is the final measure of success of a pollution
control program, whether it be directed toward either attainment or main-
tenance of NAAQS, the emission inventory, and changes therein, is the base
on which control measures and strategies can be developed. An accurate,
up-to-date inventory is essential. Furthermore, this inventory must be
entered in the NEDS in order that EPA personnel, acting for the Adminis-
trator, may have available the most recent and reliable data on which to
base the evaluation of a State's AQMP.
Procedures for compiling and updating an emission inventory are not
given here. These procedures are well documented in APTD 1135, Guide
for Compiling a Comprehensive Emission Inventory (ref. 1), and in
Guidelines for Air Quality Maintenance Planning and Analysis, vol. 7,
Projecting County Emissions. The latter document is issued as one of
the series especially prepared to assist States in the preparation of
AQMP's. Emission factors, per se, are found in AP-42, Compilation of
Air Pollutant Emission Factors (Revised 1973) (ref. 2); a procedure for
estimating emissions from motor vehicles is given in EPA-450/2-73-003,
An Interim Report on Motor Vehicle Emission Estimation (ref. 3).
C. EMISSION PROJECTIONS
Emission projections form the link that permits the estimation of
future air quality from relationships between current emissions and
existing air quality. For the AQMP the emission projections of concern
are those that account for the increases in emissions attributable to
all aspects of community growth and development.
III-l
-------
DocScan Pro free trial
Techniques for preparing emission projections are presented in
reference 2. These are also briefly discussed in chapter IV, below.
The States must use the best available data for the projections
and either that data must be included as part of the plan or the
data sources available to EPA must be cited.
A key element for the development of emissions projections will
be the Projections of Regional Economic Activity (OBERS Projections)
prepared by the U.S. Department of Commerce, Bureau of Economic
Analysis (BEA). These projections have been obtained by EPA for each
AQMA listed by the Administrator and are available from the appropriate
Regional Office. These projections are prepared by disaggregation of
national projections on a shift-share basis and are modified by local
economists for each region. Further modifications to the BEA projections
may be justified for AQMP purposes as a result of studies and planning
documents prepared by metropolitan, county, regional, or State planning
agencies. Studies of four general types may be available. These are:
Transportation studies. These may contain projections for routes,
traffic, demand, highway construction, and may even predict vehicle
emissions. Submission of such studies to DOT is in many cases required
by law.
Land-use studies. These would contain zoning and growth information
that would prove valuable in determining the potential for industrial
growth, commercial development, and new housing starts.
Air quality or water quality studies. These might contain similar
calculations or specify data sources that would be helpful.
Energy or fuel-use studies. The energy crisis occasioned a number
of studies concerning present and projected fuel use that should be
consulted. The accuracy of some may not be acceptable because of the
very short time in which they were performed.
Utility and service studies. Near-term growth within an AQMA
may be indicated by plans for expansion of natural gas and electric
power service distribution, sewer line extensions, and sewage disposal
facility construction.
There is a wide variation in the quality and detail of such studies
and in the likelihood of their being realized as the patterns to which
growth will adhere. Judicious appraisal of the confidence to be placed
III-2
-------
DocScan Pro free trial
in such plans must be made and, if such plans are used, the appraisal
should be included in the AQMP documentation.
D. AMBIENT AIR QUALITY DATA
Adequate ambient air quality data are essential to the process of
developing control strategies for either attainment or maintenance. If
atmospheric dispersion models are to be used for evaluating strategies,
air quality data are required for model calibration; if proportional
adjustment techniques (rollback; rollforward) are to be used, current
air quality data provide a necessary base.
Just as with the emission data, evaluation procedures for AQMP's
will require that the ambient air quality data used in the preparation
of the plan be entered in the appropriate EPA data bank--in this case,
the Storage and Retrieval of Aerometric Data (SAROAD) bank.
The period of record for the ambient air quality data must coincide
with the period of the base year emissions inventory. As a general rule,
data for an annual period are considered valid if valid data for three
calendar quarters are available. Correspondingly, data for a calendar
quarter are considered valid if 75 percent of the scheduled measurements
are available.
Whether data from several air quality monitoring sites are used
individually or are averaged to provide a single value "representative"
of the AQMA depends on the techniques being used to develop and evaluate
control strategies. Proportional adjustment procedures (rollback, or
rollforward) can use only a single value; atmospheric dispersion models,
on the other hand, can best be calibrated by the use of several air
quality values because these models can account for differences in air
quality between locations. In the event that monitoring data from a
single site are used, that site must be the representative site giving
the highest ambient concentration values within the AQMA.
E. METEOROLOGICAL DATA
Application of atmospheric dispersion models requires meteorological
data, often in a special format. Data suitable for use with the Air
Quality Display Model (AQDM) for each AQCR is available through EPA
Regional Offices. Data in other formats, as required for specific
III-3
-------
DocScan Pro free trial
models, can be obtained by special order from the Environmental Data
Service, National Climatic Center, Federal Building, Asheville, N.C.
28801.
F. GOVERNMENTAL STRUCTURES
One of the most important resources available for the preparation
and implementation of the AQMP is the existing structure of governmental
and quasi-governmental organizations functioning with the AQMA. These
groups and their potential contributions to air quality maintenance have
been thoroughly discussed in chapter II, above, and the need for con-
sidering the product of one-type organization, viz. the planning groups,
has been pointed out.
The preparation of the AQMP should take advantage of the specialized
knowledge, the trained manpower, and the established coordinating mechanisms
available among these organizations. The use of existing structures to
assist in, or to completely carry out, the implementation of specific
control measures is encouraged.
REFERENCES
1. U.S. Environmental Protection Agency, Office of Air and Water
Programs, Office of Air Quality Planning and Standards.
Guide for Compiling a Comprehensive Emission Inventory
(Revised). APTD 1135. Research Triange Park, N.C., March 1973.
2. U.S. Environmental Protection Agency, Office of Air and Water
Programs, Office of Air Quality Planning and Standards
Compilation of Air Pollutant Emissions Factors (Second
Edition). AP-42.Research Triangle Park, N.C., April 1973.
3. David S. Kircher and Donald P. Armstrong. An Interim Report on
Motor Vehicle Emission Estimation. Environmental Protection
Agency, Office of Air Quality Planning and Standards, EPA
450/2-73-003, Research Triangle Park, N.C., October 1973.
III-4
-------
DocScan Pro free trial
Chapter IV: AQMA ANALYSIS
A. INTRODUCTION
As required by 40 CFR 51.12(g)(1), an analysis must be performed
on each of the areas designated as AQMA's to determine the impact of
growth and development on air quality for the period 1975-1985. If the
analysis indicates that NAAQS will not be maintained, the States must
develop a plan to ensure that the standards will be maintained. The
plan must specify a maintenance strategy that provides for control or
accomodation of the increased emissions that will result from growth
and development within the AQMA.
Analysis of the AQMA is required to determine the nature and
extent of the potential air quality problem and to sufficiently quantify
the problem to permit the development of an appropriate maintenance
strategy. Procedures for analysis of AQMA's are presented in subsequent
sections of this chapter. A methodology for the design and selection
of a maintenance strategy is described in chapter V.
B. PROCEDURES
The AQMA analysis entails the following:
Refinement of AQMA boundaries
Projection of emissions to 1985 considering:
Present emissions by source category and, if possible,
by location
Expected growth of each source category, based on past
and probable future trends
Present and probable future emissions of new and
existing sources.
Allocation of the projected emissions to subareas within the
AQMA.
Estimation of 1985 air quality concentrations from projected
emissions.
IV-1
-------
DocScan Pro free trial
Quantification of air quality problems.
The following tasks are required to analyze the AQMA and
accomplish the procedures described above.
1. Develop Growth Factors and Development Patterns
Detailed instructions for the development of growth factors
are contained in Guidelines for Air Quality Maintenance Planning and
Analysis, vol. 4, Projecting County Emissions.
Local sources such as power companies, gas companies, fuel dealers,
economic development planners, chambers of commerce, and land-use
planners are usually the best source of information for the development
of growth factors, especially for major sources. Particular attention
should be paid to power plants because growth in this category can
result in considerable increases in emissions. State finance and budget
departments, large banks, and savings and loan institutions can provide
information on local growth factors. Because emissions from fuel
combustion processes make up a large part of the emissions within an
area, special consideration should be given to the development of
growth factors to provide estimates of future fuel use by type (coal,
light oil, heavy oil, gas, electricity) for each source class
(residential, multifamily, commercial, institutional, small industrial,
large industrial, and power generation). Vol. 7 of this guideline series,
Projecting County Emissions, provides a vehicle for developing such
growth factors. In the absence of local data, growth projections pub-
lished by the Bureau of Economic Analysis, U.S. Department of Commerce,
can be used. As a minimum, growth factors must be developed, on a
county basis, for each of the Nationwide Emission Report (NER) categories
included in the Level 1 Method described in the EPA guideline document
reference above. Growth factors used in the AQMA should be recorded and
reported in the form described in the same document.
2. Refine AQMA Boundaries
Because the initial AQMA designation was based on overall growth
and development factors, refinement may be necessary when more precise
growth factors and development patterns are taken into consideration.
EPA will establish procedures for early revision of AQMA boundaries,
including deletion of areas from the AQMA if the need develops. Until
IV-2
-------
DocScan Pro free trial
such publication, the procedures described below may be used.
The data developed in step 1 above must be analyzed to identify
areas within the initial AQMA geographical area where no growth and
development are expected. In such a case consideration should be
given to the elimination of the area from the AQMA. The decision to
eliminate a portion of the AQMA should be based on whether exclusion
would create islands within the AQMA or changes in the peripheral
boundaries. In the first case, the area must be retained in the AQMA.
De facto exclusion could be accomplished by not applying any specific
maintenance measures to sources within it. In the second case
changing the boundaries to exclude the area from consideration may be
preferable.
The analysis should also be used to identify areas contiguous to
the AQMA in which growth and development may result in emission that,
through transport, would threaten the NAAQS. In such a case consideration
should be given to expanding the AQMA boundaries to include such
areas. The decision to include or exclude such areas from the AQMA will
of necessity be judgmental and subjective. The decision to include or
exclude should be based on whether the area contributes to emissions
that could threaten NAAQS and that could be controlled by measures
available to the agency responsible for plan implementation. For
example, an area from which fugitive dust emissions from open
undeveloped spaces pose a threat to NAAQS would most likely be excluded
from the AQMA because the emissions are natural and are not amenable
to controls. On the other hand, if the fugitive dust emissions are
the result of agricultural or quarrying processes, the area could well
be included in the AQMA if control can be effected through changes in
operating practices.
Changes in AQMA boundaries are reported by narrative and overlayed
maps.
3. Perform Analysis of the Air Quality Situation
The first step in this task is the projection of current
emissions to 1975/1980/1985. These projections are done on a county
basis using the methodology described in Guidelines for Air Quality
Maintenance Planning and Analysis, vol. 7, Projecting County Emissions.
IV-3
-------
DocScan Pro free trial
A Level 2 or Level 3 approach should be used unless prior approval
for use of the more simplistic Level 1 approach is obtained through
consultation with the appropriate Regional Office.
NEDS emission data shall be used as the basis for these emissions
projections. Other emissions data that may be locally available may be
used in lieu of or in addition to the NEDS data, provided that such
data be entered into the NEDS at the next semiannual update. The up-
date is to be accomplished as prescribed in APTD-1135, Guide for Com-
piling a Comprehensive Emissions Inventory. Forms prescribed in the
EPA guideline document covering county emission projection shall be
used for this purpose. Locally available data shall be so identified,
and the AQMP shall contain a statement to the effect that these data
will be entered into the NEDS.
Next, the county emissions projections, except for hydrocarbon and
nitrogen oxides, are disaggregated and distributed to subareas within
the individual counties. A procedure for allocating or distributing
the projected emissions to specific suhcounty land areas is forthcoming.
Pending distribution of these procedures, States may use locally
available or developed techniques after consultation with the appropriate
Regional Office. The emissions distribution step of the analysis is
necessary to define the areas that would have the highest emission
densities and to provide assigned grid coordinates for emission sources
if an atmospheric dispersion model is to be used to estimate pollutant
concentrations. The recommended procedure is outlined briefly below.
The grid system or other subarea division of the counties in the
AQMA first must be established. The emissions are allocated to the
subareas in four different categories:
Stationary area sources
Power plants
Point sources (excluding power plants)
Mobile sources.
Area source emissions may be allocated by a computer-assisted
method (CAASE) if projected growth rate can be input, so that the
allocation process represents the projected conditions rather than
current conditions. CAASE is also described in the above referenced
guideline series. Otherwise, area sources may be distributed manually
IV-4
-------
DocScan Pro free trial
using the same types of emission indicators that are used in CAASE,
such as population and industrial employment.
Emissions from existing and proposed power plants can all be
assigned specific grid coordinates.
Point source emissions from existing facilities and their attendant
expansion can be located by their grid coordinates as reported in the
NEDS. Emissions from undefined new point sources can be distributed
with the aid of land-use plan data and survey results with one of the
following procedures:
A weighting system that evenly distributes emissions among
those industrial zones that the regional planning agency indicates
would be most likely to attract new manufacturing plants.
A weighting system that distributes emissions based on an
industrial growth plan.
The allocated emissions are summarized for input to a dispersion
model or other analysis by specifying point-source emissions (including
power plants) by grid coordinate and totaling the remaining emissions
for each grid. Procedures outline in the EPA guidelines document,
Analytical Framework Guidelines, are used for this purpose.
Hydrocarbon and nitrogen oxides emissions must be aggregated to
arrive at AQMA-wide emissions. This involves simple addition of the
county emission projections. Forms specified in the referenced guide-
line document are used to record and report the results of this subtask.
If suitable measurement methods have been available, emission should
be in terms of nonmethane hydrocarbons. The use of total hydrocarbon
emissions, however, is acceptable.
The projected emissions are now used to drive an air quality
projection model to estimated 1980 and 1985 air quality. The following
are the types of models to be used for the pollutant indicated:
Particulate Matter - Atmospheric Dispersion Model
Sulfur Oxides - Atmospheric Dispersion Model
Nitrogen Oxides - Rollback (total regional emissions)
Hydrocarbons - Appendix J Relationships (Rollback Model
for Texas and California)
Carbon Monoxide - Rollback Model described in Guidelines for
Air Quality Maintenance Planning and Analysis,
IV-5
-------
DocScan Pro free trial
vol. 1, Designation of Air Quality Main-
tenance Areas
Acceptable models for projecting air quality are described
in Guidelines for Air Quality Maintenance Planning and Analysis.
vol. 12, Applying Atmospheric Simulation Models to Air Quality
Maintenance Areas. Locally available models may be used provided
that the AQMP contains a description of the model, procedures
for use, and input data format and requirements. Results of air quality
projections are to be reported using the formats specified in the
referenced guideline document.
If the air quality projections indicate that NAAQS will not be
exceeded through 1985, there is no requirement for further analysis
or the development of a maintenance strategy. The agency responsible
for the preparation of the AQMP should now assemble the AQMP as described
in chapter VI. If the air quality projections indicate that the NAAQS
will be exceeded at some time during 1975-1985, analysis should continue
to identify and quantify the air quality problem.
4. Quantify Air Quality Maintenance Requirements
Maintenance requirements, expressed in emission reduction
required to compensate for growth and development, must be quantified
to serve as the basis for the development of a suitable maintenance
strategy. For oxidants and nitrogen oxides, this quantification is
made on an AQMA-wide basis. Quantification by subareas within the
AQMA, as required by the preceding analysis, must be made for the other
criteria pollutants.
The first step in the quantification process consists of interpo-
lation of emission projections for years other than 1975, 1980, and
1985. A straight-line interpolation may be used for this purpose.
However, it is desirable that power plants be treated individually
with adjustments made for stack height and added to the year in which
they are scheduled to become operational or go out of service. This
procedure can be accomplished using the format presented in table IV-1.
An example using the following dummy information is included in the
table:
1975 Emissions (attainment) 50,000 tons
1980 Emissions (projected) 60,000 tons
1985 Emissions (projected) 80,000 tons
IV-6
-------
Table IV-1. Calculation sheet, quantification of maintenance strategy requirement
o
o
o
CO
o
01
CD
CD
g-
01
AQMA_
, Pollutant
Subareas
Subarea 1
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
Projected emission
Emissions w/o new power plants
Interpolated emission
Power plant emissions
Total projected emissions
Emissions at NAAQS
Maintenance requirement
50000 60000 90000
50000 60000 72000
50000 52000 54000 56000 58000 60000 62400 64800 67200 69600 72000
18000 18000 18000 18000
50000 52000 54000 56000 58000 60000 62400 82800 85200 87600 90000
58000 58000 58000 58000 58000 58000 58000 58000 58000 58000 58000
2000 4400 24800 27200 19500 32000
Subarea 2
-------
DocScan Pro free trial
Power Plant Growth: plant with projected controlled emissions
of 8,000 tons scheduled to go on line in 1982
Emissions associated with NAAQS 58,000 tons.
Using this procedure it can be determined that subarea 1 will
require a maintenance strategy capable of reducing emissions starting
in 1980 by 2,000 tons per year and building up to a 1985 requirement
of 22,000 tons per year with a sharp increase in 1982 due to a new
power plant.
5. Characterize Projected Emissions
Major source categories and timing of increased emissions are
identified in this step. The source of expected emission increases
dictates the type of control strategy that will be required. For
example, if a single source or source category represents the principal
contributor to increased emissions, the use of a source control more
stringent than that currently specified in the SIP may be indicated.
The detail to which source categories will be identified is
dependent on the level to which emissions projections were made
(step 3, above). Using the example shown in table IV-1, it can be
seen that emissions from power plants represent the major contributions
of emissions that would threaten air quality in subarea 1. The
maintenance strategy for this area should be designed with this in mind.
IV-8
-------
DocScan Pro free trial
Chapter V: DEVELOPMENT OF MAINTENANCE STRATEGIES
A. INTRODUCTION
A maintenance strategy is defined as the combination of measures
designed to achieve the aggregate reduction of emissions necessary for
the maintenance of a NAAQS. Maintenance measures are controls that are
applicable to specific source categories, pollutants, and/or air quality
maintenance problems.
Detailed descriptions of several potential air quality maintenance
measures are presented in volume 3 of this guideline series, Control
Strategies. The 18 measures cover a broad range of options but are not
intended to be all-inclusive. Those responsible for plan preparation
are encouraged to devise other measures with special applicability to
the AQMA's in which they are to be employed.
A summary of the descriptions for each of the measures is provided
in appendix D. The first nine listed have been categorized as land-use
and planning measures because they are concerned primarily with planning
for future air quality and with new emission sources. The remaining
nine measures have been categorized as emission control measures, and
involve technological or operational changes that affect both
existing and new sources. The latter measures tend to have a more
direct effect on emissions from individual sources and, hence, their
impacts can be quantified more readily than those of the land-use and
planning measures.
Because of the tenuous relationship between hydrocarbon and
oxidant concentrations, special consideration must be given to the
development of maintenance strategies for oxidant control. Such
strategies should be sufficiently flexible to accomodate any change
in the current relationship that might result from the research and
development programs presently underway. The state-of-the-art does
not permit a quantification of the interrelationships and tradeoffs
V-l
-------
DocScan Pro free trial
in HC/Ow control. Qualitatively, however, it is necessary to reduce
the HC and NOV emissions so that the HC/NOV ratio is below 1. Priority
A A
should be on highly reactive hydrocarbon emissions, especially those
generated during early morning hours. While it is highly desirable
that strategies be developed based on nonmethane hydrocarbon emissions
and measurements, strategies based on the reduction of total hydrocarbon
are acceptable in the absence of suitable measurement methods for
nonmethane hydrocarbons.
The recommended procedure for selecting a preferred group of
maintenance measures, i.e., a maintenance strategy, has two major stages:
Development of alternative maintenance strategies
Selection of preferred strategy based on economic and social
acceptability evaluations.
Each of these stages and associated tasks are discussed in the following
sections.
B. DEVELOPMENT OF ALTERNATIVE MAINTENANCE STRATEGIES
This is essentially a screening procedure by which potential
maintenance measures are evaluated in the light of the air quality
maintenance problem (identified and quantified as outlined in chapter
IV) to generate feasible combinations of maintenance measures, each
of which will provide the requisite aggregate control of emissions.
Current land-use and transportation plans adopted by cities,
counties, metropolitan agencies, and other political jurisdictions
wholly or partly within the AQMA may affect the ability to maintain
air quality. These plans must be analyzed in the development of
alternative maintenance strategies. Should the analysis indicate that
major revision in the transportation and land-use plans are required
in order to ensure that any set of maintenance measures will, in fact,
result in the maintenance of air quality, the appropriate long-range
strategy may be to develop a comprehensive land-use and transportation
plan for the AQMA. In such a case the overall strategy could consist
of a program to develop a comprehensive land-use and transportation
plan with the initiation of a series of temporary emission reduction
measures for the initial portion of the 10-year period. Upon
completion of the comprehensive land-use and transportation plan,
V-2
-------
DocScan Pro free trial
the State would develop an appropriate long-range AQMP. In such a case,
the State must demonstrate the capability of developing a mechanism that
ensures the development of a comprehensive plan that recognizes the
requirement for the maintenance of air quality.
The following tasks are required:
1. Estimate Potential Further Reductions from Existing Sources
Before maintenance measures are examined, an analysis should
be performed to determine whether more stringent controls on existing
sources in the form of a revision in existing emission control regulations
would be adequate to maintain standards. If the analysis indicates that
such a revision alone would be sufficient, preparation of a more
complex AQMP is not required. If this alternative is selected, the
findings must be documented and be submitted as the AQMP. If more
stringent controls on existing sources cannot provide the needed emission
reduction, it may still constitute one of the maintenance measures in
the AQMP.
Emissions projections made during the. AQMA analysis provide
data on projected emissions by NER category. Current control efficiency
can be determined from State and local regulations. Figure V-l provides
a method of tabulating these data and recording potential additional
control.
2. Determine Potential Source Category Candidates
The major contributing source categories, source categories
with additonal control potential, and those with high percentages of
new (from 1975 to projection year) emissions should be identified
as the primary targets of selected maintenance measures. If there are
multiple areas within the AQMA projected to exceed the standards, this
determination should be performed separately for each, insofar as the
resolution of the air quality projections and emission data allow.
3. Determine Maintenance Measure Applicability
This step involves determination of the applicability of the
various maintenance measures that are available. First, measures that
are not effective for the pollutants and source categories of concern
should be eliminated from consideration. Measures that are effective
for control of specific pollutants and types of sources are summarized
in table V-l. Next, the possibility of establishing and implementing
V-3
-------
D
o
o
CO
o
Q>
TJ
o
^
CD
CD
g-
01
Additional control potential
AQMA , Subarea , Pollutant
1975 1980 1985
Source
category
Emission,
tons/yr
Percent
control
Added
control
potential ,
tons/yr
Emission,
tons/yr
Percent
control
Added
control
potential ,
tons/yr
Emission ,
tons/yr
Percent
control
Added
control
potential ,
tons/yr
Fuel combustion:
Point
Area
Industrial processes
Transportation
Solid waste disposal:
Point
Area
Miscellaneous:
Point
Area
Note: The source categories are included as examples only. They should be further disaggregated depending on the
level of analysis used as described in vol. 7 of this guideline series.
Figure V-l. Example format for indicating additional control potential.
-------
D
o
o
CO
o
01
CD
CD
g-
01
Table V-l. Applicability of selected air quality maintenance measures
Pollutants affected
TSP S0? CO HC/0 NO
£• XX
Plan-
ning
Type of action(s)
Implementation
New Existing
Review
Time for impact
< 5
years
> 5
years
Land use and planning
Emissions allocation
Regional development planning
Emission density zoning
Zoning approvals
Transportation controls
Emission charges
Transfer of source location
Indirect source review
Environmental impact statement
Emission control
New source performance standards
Revision of SIP control measures
Phaseout and prohibition
Fuel conversion
Energy utilization
Combination of emission sources
Special operating conditions
Stack height regulations
Control of fugitive dust sources
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X X
X X
X
X X
X
X X
X X
X
X X
X X
X X
X
X
X X
X X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
XX X
X X
X X
X
XX X
X X
X
X
X
X
X
X
X X
X X
X X
X X
X X
X X
X X
X
X X
X X
X
X
X
X X
X X
X X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
x
x
X
x
x
x
X
X
-------
DocScan Pro free trial
each remaining measure under consideration should be evaluated.
Availability of resources necessary to implement and enforce the
measure, time requirements, and legal authority are among the
factors that should be considered.
It should be noted that the list of maintenance measures listed in
table V-2 is not exhaustive. State and local agencies are encouraged
to develop and use such additional measures as may be applicable. The
agency developing the AQMP is responsible for finding the measure or
combination of measures required to maintain NAAQS. State and local
agencies are in a better position to select that combination of measures
most likely to be acceptable and suitable, than if the control stragegy
were developed and prescribed by a higher echelon.
4. Determine Contribution to Emission Reduction and for Air
Quality Impact
Based on the projected emission inventories by source class,
estimates of emission reductions or prevention that would occur as a
result of implementing each applicable measure should be estimated.
For many measures, e.g., emission allocation or stack height limitations,
it is impossible to demonstrate their impact in this format. Instead,
they generally require an atmospheric dispersion model analysis. If
dispersion modeling is used to evaluate individual measures, it should
be the same model and methodology that were used in the air quality
projection step. If the same model is not used in the control measure
evaluation, an explanation should be included in the AQMP. If neither
an emission reduction nor a dispersion modeling analysis can be
performed, a nonquantitative evaluation of the measure's effect should
be prepared. For example, revisions to a regional land-use plan based
on findings of the AQMA analysis may be an effective measure, but can
only be quantified to the extent that accurate emission factors for
different land uses are available. A description of the significance
of the revisions would be more important than hypothetical emission
rates indicating their quantitative impact.
Consideration of the effect of each measure on the spatial
distribution of emissions is inherent in separate inventory analyses
for each problem area and in dispersion modeling approaches. However,
V-6
-------
Table M-2. Interrelationships among maintenance measures
EMISSION ALLOCATION
REGIONAL DEVELOPMENT PLANNING
EMISSION DENSITY ZONING
ZONING APPROVALS 8 OTHER
INDIRECT REGULATORY CONTROLS
O
0
0
1-
0
z
<
EMISSION CHARGES
NSFER OF EMISSION SOURCE
AT IONS
£3
I
>
o
o
z
\L IMPACT
z: irt
s: z
0 ^
ERFORMANCE
ex a
o a;
"°
2 [-, | LJJ |_
I
TIVE SOURCE
MITATIONS
^
Lu y,
sc £
PROHIBITION OF
URCE CATEGORIES
o to
1— O
SS
« CJ
310.
D_
a:
RVATION AND
z o
u. w
O a:
^g
O
Cf.
t3o
LAND-USE AND PLANNING MEASURES
EMISSION ALLOCATION
REGIONAL DEVELOPMENT PLANNING
EMISSION DENSITY ZONING
ZONING APPROVALS 8 OTHER INDIRECT
REGULATORY CONTROLS
TRANSPORTATION CONTROLS
EMISSION CHARGES
TRANSFER OF EMISSION SOURCE
LOCATIONS
INDIRECT SOURCE REVIEW
ENVIRONMENTAL IMPACT
STATEMENTS
|C,0 A 0
C.O ! C,0
A
0
c,i
0
A
C, 1
1
C,0
A
C.O
0
C
c
A
0
A
0
1 ^ !
0
A
1
1
0
£
C,l
c,o
1
!
C
1
! A
1 C
NEK SOURCE PERFORMANCE
STANDARDS
MORE RESTRICTIVE SOURCE EMISSION
LIMITATIONS
PHASE-OUT OR PROHIBITION OF
SPECIFIED SOURCE CATEGORIES
FUEL CONVERSION
ENERGY CONSERVATION AND
UTILIZATION
COMBINATION OF EMISSION SOURCES
SPECIAL OPERATING CONDITIONS
STACK HEIGHT REGULATIONS
CONTROL OF FUGITIVE DUST SOURCES
c
c.o
c
A
C
C
0
C
C
C
C
C
C
C
A
1
1
1
AAC
C
c
A
C
C
0
C
C
1
[
1
1
1
1
1
1
1
0 A
0
0
0
f%
0
1
c
A
C
1
0
1
1 i
c,i
c
1
1
A
1
1
A
1
A
C
c
C,0
C
1 C C
c
c
c
till
C
1
1
A
1
[
i 0
1 C
1
1
!
1
C
1
1 ! 1
A
C
A
1
1
1
!
1
C
c
c
A
c c
1 I
1
1
1
1
1
1
|
j
v/
1
1
0
1
0
1
1
1
I
1
j
C
1
C
1
c c
1
1
c
1
1
1
\
1
1
1
1
A
EMISSION CONTROL MEASURES
1 1 I
1
i
I
|
1
I
1
1
0
1
1
i
1
1
c
1
c
c
i
i
c
i
i
!
1
1
I
1
1 1
|
|
1
1
1
1
1
1
1
1
1
A
1
1 C
1 i C i
1 II
1
c
1
c
1
1 I 1
1 ! C
1
c
1
1
1
1
1
1
1
C
1
1
1
1
1
1
1
c
A
i
1
1
C
1
C
1
A
1
C
1
[
1
1
1
1
1
c
1
c
c
1
I
1
c
c
1
1
1
1
1
1
1
1
1
D
o
o
CO
o
01
CD
CD
LEGEND: A - MEASURES THAT ASSIST EACH OTHER IN MAINTAINING AIR QUALITY.
C - MEASURES THAT ARE COMPLEMENTARY IN MAINTAINING AIR QUALITY.
I - MEASURES THAT ARE INDEPENDENT OF EACH OTHER IN MAINTAINING AIR QUALITY,
0 - MEASURES THAT MAY OVERLAP OR PREEMPT EACH OTHER IN MAINTAINING AIR QUALITY,
-------
DocScan Pro free trial
if estimates of emission reductions are made from countywide emission
summaries, some further analysis—in the form of estimates of emission
distribution within the county—of the location of the measure's impact
is necessary.
5. Determine Compatibility of Measures
Many of the measures proposed for maintaining air quality
standards are not completely independent of one another but have either
beneficial or detrimental effects if they are implemented concurrently.
It is important that these interactions be recognized when maintenance
strategies are being formulated so that, if combinations of measures
are necessary, those that are compatible can be supported and those
that are not can be avoided.
The proposed procedure utilizes a matrix of all measures under
consideration, such as shown in table V-2. Four symbols are used to
qualitatively describe the different relationships that may exist
between two measures:
A The measures assist each other either by facilitating
implementation or by increasing their combined effectiveness.
C The measures are complementary; they act on different sources
or in a different manner to mutually produce combined
improvements. One measure may be a component or instrument
of the other.
I The measures are independent of each other; neither will
enhance nor deter the effectiveness of the other.
0 The measures have some overlapping in their emission
reduction or location objectives, are competitive, may
preempt each other, or be otherwise incompatible.
Theoretically, two measures could also be counterproductive to each
other. However, none of the maintenance measures were observed to have
this relationship, so it has been omitted.
The interrelationship between emission allocation and emission
density zoning is an example of how one measure can assist in the
implementation of another. Emission allocation prescribes the total
allowable emissions in an area. Emission density zoning provides a
means of implementation by distributing the allowable emissions throughout
V-8
-------
DocScan Pro free trial
the area on the basis of land use. More restrictive source emission
regulations and stack height regulations are examples of complementary
measures. Implementation of the first results in a reduction of
emissions, the second a spatial distribution of the reduced emissions.
An example of measures that are independent of each other is found
in the combination of Environmental Impact Statements (EIS) and New
Source Performance Standards (NSPS). The EIS are applicable during
the planning and preplanning stages, NSPS to the construction and
implementation. Zoning approval and emission charges are examples of
measures that may overlap or preempt each other. Zoning restrictions
could prohibit the construction or modification of a source that, if
built, would produce emissions subject to emission charges.
This approach to evaluation of interactions involves some
subjective categorizations, but it provides a simple method of organizing
the evaluation results for grouping of the measures. Some of the measures
are so broad in scope and may interact in such complex manners that a
single descriptive categorization may not be adequate. For example,
a regional land-use plan could encourage high-density corridor developments
in an urban area to increase mass transit usage and reduce VMT. In one
AQMA, this may be interpreted as assisting transportation controls in
maintaining standards, while in another it may be considered overlapping.
The analysis of interrelationships should be made specifically for each
AQMA based on local conditions. The results may be different from those
shown in table V-2. In general, the same interactions will exist regard-
less of whether the two measures are being used for control of the same
pollutant or for two different pollutants.
Although the following conclusion is not evident from the results of
the matrix analysis, most of the land-use and planning measures (except
the review procedures) represent comprehensive approaches to air quality
maintenance and, as such, are mutually exclusive alternatives. The generali-
zation can also be made that most of the emission control measures act
independently of one another and, hence, can be applied simultaneously
with additive effects. Moreover, the emission control measures can
usually be implemented within the framework of different land-use and
planning measures, and may be the specific actions taken to effect emission
reductions that are needed under a land-use and planning measure.
V-9
-------
DocScan Pro free trial
In cases where implementation of a single maintenance measure
involves several actions, e.g., transportation controls, an analogous
matrix for intrameasure relationships should be developed, so that these
are adequately considered in designating the actual actions to be
implemented. The intrameasure interactions are highly dependent on
local conditions, both in determining which individual controls are
applicable and what the impacts are among them.
6. Develop Alternative Maintenance Strategies.
Maintenance may be demonstrated by several means:
a. Keeping emissions in problem areas below the total
shown to be consistent with maintenance of the NAAQS (emission allocation
approach);
b. Dispersion modeling of combinations of measures; or
c. A less quantified analysis based on an explanation
of how the strategy is able to prevent standards from being exceeded,
projecting and monitoring mechanisms included, and remedial actions
available if standards are exceeded.
During this grouping and composition step, coordination with all
participating agencies, other concerned agencies, and representatives
of the public is especially critical. Agreement should be obtained
on those measures to be eliminated from further consideration and the
combinations of those remaining that appear most acceptable. In many
cases, the screening process described here may reduce the number of
feasible alternatives, and it is conceivable that it may clearly
indicate the superiority of certain measures or strategies.
The proposed procedure for selection of appropriate measures
should be carried through separately for each pollutant for which the
AQMA has been designated. However, when interrelationships among
measures for one pollutant are assessed, potential problems of implementing
a single measure for different pollutants or different measures for each
pollutant should be investigated. Also, as the alternative strategies
for each pollutant are being composed, coordination of strategies for
different pollutants is necessary.
C. SELECTION OF PREFERRED STRATEGY
Each air quality maintenance measure considered for inclusion
in the strategy for air quality maintenance obviously has some beneficial
effect. That is, the implementation of the measure necessarily must
V-10
-------
DocScan Pro free trial
contribute to the prevention, reduction, or temporal and spatial
dispersion of emissions. In addition, each maintenance measure
will affect the community in a variety of ways that can be grouped
as socioeconomic effects. These effects may be beneficial to one
segment of the community and adverse to another, so that their
overall contribution to the community is difficult to ascertain.
In general, socioeconomic effects are difficult to quantify in precise
terms, causing a corresponding difficulty in a mathematical evaluation
of the comparative benefits or detriments of a variety of measures.
However, the agency planning for air quality maintenance must be
capable of performing such an evaluation before formulating its
maintenance strategy.
The implementation of a maintenance strategy can result in a
wide range of socioeconomic impacts. Because the individual measures
comprising a maintenance strategy may interact with one another, it is
difficult to isolate the impacts of specific measures. The problem is
further compounded because the impact of an individual measure is
influenced by the local conditions--socioeconomic environment--!'n which
the measure will be implemented. Interactions and interrelationships
between maintenance measures are discussed in previous paragraphs.
In the following paragraphs, some possible social and economic
effects of maintenance measures are discussed and an overall procedure
leading to an evaluation of these effects is suggested. While social
effects may have severe economic consequences, and conversely, economic
effects may have severe social consequences, these are discussed
separately below, the possible interaction between the two categories,
however, must not be ignored.
1. Social Effects
Social effects are the observable changes in social phenomena
consequent to the implementation of a maintenance measure. Social
effects are difficult to measure in quantitative terms. There is no
generally accepted baseline against which the social impacts of
interventions such as air quality maintenance measures can be evaluated.
Social acceptability of any specific maintenance measure or set of
measures can be determined by attitudinal surveys through interviews
with those segments of the population likely to be affected. However,
V-ll
-------
DocScan Pro free trial
the time constraints on the development of a maintenance strategy for
inclusion in the AQMP may limit the opportunity to use this approach.
While public hearings or discussions of alternative measures could
prove useful, care must be exercised to ensure that undue weight is
not given to opinions of special interest groups.
Perhaps a more promising alternative is a survey of elected
public officials. Politicians frequently stake their political
lives on what they perceive to be the public desires. Therefore,
they should be in a position to assess the social acceptability of
proposed maintenance measures.
While it is highly desirable that social effects of maintenance
measures be quantified, their complexity and current state-of-the-art
make such quantification infeasible. In discussing the welfare costs
of pollution, Dales states: "He [the economist] cannot measure
welfare damages . . . all he has to offer, therefore, so far as
antipollution policy is concerned, is a counsel of perfection" (ref. 1).
This opinion is shared by Joseph L. Fisher who, as President of
Resources for the Future, Inc., stated: "Goals and indicators with
respect to the quality of the environment are difficult to conceive and
more difficult to work with" (ref. 2). He adds that general indicators
and goals are not only difficult to identify but are also not consistent
over time in that they involve interpersonal, intertemporal, and
interregional comparisons. He concluded that probably the basic
indicator for social welfare would be one that deals with the net
benefits that would result from selected and interrelated measures
required for acceptable air quality. Net social benefits are
benefits less costs or losses measured in some manner.
With respect to the methods by which net social benefits can be
determined, Fisher implies that valid measurement techniques are not
currently available. He views the creation of indicators on the trends
of pollution and its effect on people as a task for social statisticians
working with medical scientists; industrial, agricultural, and sanitary
engineers; economists; sociologists; administrators and others.
It is significant to note that Fisher views evaluation of social
impact in terms of trends. Many of the social indicators used in the
V-12
-------
DocScan Pro free trial
study of urban areas are influenced by a wide variety of inputs.
Because evaluation of these indicators in absolute terms provides
no additional information for the evaluation of air quality measures,
impact should be measured in terms of direction of change in the
social indicators and by the relative effects of the different measures.
This approach is among those recommended in a HUD-sponsored study for
comparison of urban indicators (ref. 3).
By assessing the impact of each strategy upon each of the social
indicators, and by local evaluation of the importance of these
indicators, it is possible to achieve a ranking of the strategies in
terms of their social effects. Two procedures for ranking strategies
in terms of their social effects are presented in appendix B. The
first of these is an approach developed by Albert J. Klee while he
was with the Solid Waste Management Office, EPA (ref. 4). The second
is a simplified procedure based on evaluation of the impact of
maintenance strategies on the direction of change of social indicators.
Klee's approach, or one of similar detail, is recommended. However,
lack of time and personnel may preclude its use. In such a case,
the more simplistic approach may be used.
2. Economic Effects
Each feasible alternative air quality maintenance strategy
will provide the same benefits: the control of air pollution. Thus,
the economic effects of alternative strategies can be assessed in terms
of cost per unit of emissions prevented. Since these strategies
typically will involve time periods of several years, the costs should
be expressed in terms of present value. (The present value concept is
simply an expression of the fact that a dollar today is worth more
than a dollar at some future date, because today's dollar can be invested
and earn interest).
The costs of air quality maintenance measures can be divided into
direct and indirect costs. Whether the measure be a technological control-
a device applied to an emission source, a production process change, a
fuel switch, etc.--or an institutional control—a traffic control plan,
V-13
-------
DocScan Pro free trial
emission density zoning, emissions allocations, etc.--direct costs can
be estimated with considerable accuracy.
The direct costs include all expenditures required of a source,
such as investment and operating costs for control equipment, incremental
costs of fuel switching, costs of production process changes, emissions
monitoring costs, administrative costs for accounting and reporting,
costs of supervision of operating personnel, and costs required of the
governmental unit for implementing a measure, such as operating costs
for permit review programs, monitoring of air quality, reviews of source
emission reports, and source surveillance. Indirect costs include the
effects on sectors of the economy that are not required to respond to a
particular maintenance measure, such as price changes for materials or
products, costs associated with changes in behavioral patterns, and
costs of increased solid waste and water pollution control.
Table V-3 lists the various cost elements and associated data sources
that should be considered in assessing the economic effects of a particular
maintenance measure. These cost elements and data sources are not con-
sidered to be all-inclusive, but rather are intended to serve as a guide
for air quality maintenance planners. The list should be modified to
meet the specific requirements of the AQMA and the political environment
of the area. Table V-3 also shows, in matrix form, the costs elements
that usually are applicable to the maintenance measures described in
section B below.
The costs in table V-3 should be estimated for each time period
for which the costs differ or for which the social impact changes. The
appropriate factor(s) can then be applied to convert the costs to present
value. It should be noted that the rate of return (interest rate) used
in computing the present values of the strategies can affect the choice
of stragegy. For this reason, the rate(s) used in comparing the strate-
gies should be consistent with those used by State planning and budgeting
offices. Furthermore, the local planning agency should clearly state the
interest rate(s) used in their calculations. For an example see appendix
C. Because the present value approach is widely accepted, the use of raw
(undiscounted) cost figures is not appropriate.
3. Select Preferred Maintenance Strategy.
For each set of alternative maintenance measures (strategy),
V-14
-------
Table V-3. Maintenance strategy cost elements and data sources
D
o
o
CO
o
Q>
TJ
o
^
CD
CD
g-
01
I
en
Costs borne by public agency,
business firm, or consumer
Public Agency and Business Costs
1 Purchase or rental of land, buildings
2 Purchase or rental of equipment
3 Financing costs
4 Equipment operation
5 Equipment maintenance and repair
6 Wages of personnel required by strategy
7 Training of operatives, supervisors, clerical staff
i
Data source Land use and planning measures [mission control measures
A B'C D LFG h , I A
Dept of Hjbl ic Works
Vendors
Banks
Vendors
Vendors
Personnel Dept
Personnel Dept
8 Facility and system design City/County Enq
9 Program planning i Planning Agency
10 Capital loss due to premature obsolescence , Bus Consultant
Publ ic Agency Costs
to strategy
13 Change in tax revenue
16 Qualification and certification of facilities
Air Pollution Off
Coinptrol ler
Tax Dept
Affected Dept
c £ ^ "^ o. ^ § <"Jo't^ c ^ C c ^ £ "
i - *- . . * * . -
x x xxx
X X X ( X X
* ; , x xxx
x ' x x : x x i
X;X X X XXX X . X
X X X X XXX X ' X
=> e v.
>«- c
x
x
x
X
x
K
x x , x x x
x ' x x x x x x x ' x > x
X i '.XX
x ; x x x ' x x . x x
X 'XX
X ' XX
X X '
8udqet Dept x X X
Air Pollution Off x
!7. Change in public expenditures from general revenues ' Budget Dept X X X X X
18. Interagency coordination Dept of Admin x X X x'xXX X X
Business Costs
19. Emission charges
20. Special taxes on business capital or operations
X
X X
Planning Off X X X X X ' X
Consumer Costs
23 Change in fuel consumption and/or price
* i X
X
1 —
x
24 Auto operation costs * X |
Indirect Costs
26 Driver inconvenience, time and travel cost
* X
X
X
B
1z L-
(U n
l§°
se;
11=
X
X
X
x
x
X
x
X
x
X
x
X
x
x
x
x
X
X
c
0 .0 -
^ .C £
.c i~ E
X
X
X
x
x
X
X
X
x
X
X
x
x
X
X
0
s
X
X
x
x
X
X
x
X
x
x
X
X
X
X
x
X
X
X
E
o
IS
>^ i- ^J
c o c
x
x
X
X
X
X
X
x
x
x
X
X
X
x
F
III
X
X
X
X
X
X
X
X
X
X
X
G
£"0 0
X
X
X
X
X
X
X
X
X
x
X
X
H
If]
- —
X
X
X
X
X
X
I
+J
3
°s «
££ ;
'c 01 :
O 3 1
X
X
X
x
X
X
x
X
X
x
*Items normally (
-------
DocScan Pro free trial
anticipated beneficial or adverse social and economic effects must be
identified and evaluated as described in sections 1 and 2, above;
quantitatively insofar as possible, or qualitatively in sufficient
detail to allow for comparison with the effects of other strategies.
In general, economic effects and costs are quantifiable in terms of
today's dollars; social effects can be expressed quantitatively in
comparison with themselves, based upon the trend changes caused by
the alternative strategies.
Assessment of the socioeconomic impact of individual maintenance
strategies can be accomplished as follows:
a. Determine the economic costs for each measure by
calculating the present value of the costs associated with each measure.
Sources of these data are indicated in table V-3.
b. Summarize impact of each measure comprising the strategy
in terms of emission reduction or redistribution from results of the
screening analysis. For some measures, quantification of the impact
may not be possible. Whenever feasible, information should be made
based on local experience and judgment. As a minimum, a qualitative
evaluation of the measure's effectiveness should be made.
c. For those measures for which impact was quantified,
determine cost per unit of emissions reduced or redistributed.
d. Determine the rankings and evaluation scores of the
social impact of the strategies using the procedure described in
appendix B. Otherwise, enter the rankings based upon subjective
judgment.
e. Prepare a summary sheet for each feasible maintenance
strategy being carried forward for consideration. A suggested format
for this summary is shown in figure V-2. A summary should be prepared
for the entire AQMA and those portions thereof that are receiving
special attention because of a localized pollution situation.
f. Compare economic and social impacts of the strategies
under consideration and select the strategy of choice. From an economic
point of view, the selection can be made by comparing the total present
value of costs. Evaluation from a social viewpoint becomes subjective,
and requires the exercise of considerable judgment. For example,
V-16
-------
DocScan Pro free trial
Area of AQMA where Inapplicable
Pollutant Reduction
or redistribution required
Measure
Land Use and Planning
1 . Emission allocation
2. Regional development
planning
3. Emission density zoning
4. Zoning approval
5. Transportation control
6. Emission charges
7. Transfer of emission
source location
8. Indirect source review
9 Environmental impact
statements
Emission Control
1. New Source Performance
Standards
2. More stringent control
on existing sources
3 Phase out on prohi-
bition
4. Fuel conversion
5. Fuel conservation and
uti 1 uation
6 Combination of sources
7. Special operating
conditions
8. Stack height reg-
ula t ions
9. Control of fugitive
dust
Totals
Applicable
(yes or no)
Sources affected
Emissions
reduced or
redistributed
( tons )
Economic
cost
($)
Cost
S/ton
i
'\
\
\
i
;
[
t
i
Social impact
number of*
— -T 5-
' '
t
j
"".
*To be used 1f short approach is used.
Cost base year
Total discounted Cost ($):
Emissions Reduced or Redistributed (tons):
Avg. Cost/ton:
Social Evaluation Score:
Rank:
Combined Sodoeconomlc Rank of Strategy:
(Specific remarks or comments on Individual measures or the overall strategy should be appended)
Figure V-2. Suggested format for maintenance strategy summary
V-17
-------
DocScan Pro free trial
consider a situation wherein two maintenance strategies are being
compared, one of which is favored from economic considerations, the
other from social. Final decision requires equating increased costs
and increased social benefits. This judgment can probably best be
made by the governing bodies of the political jurisdictions concerned.
Analyses of impact of maintenance strategies is further complicated
by the possibility that short-term and long-term impacts could differ
significantly. For example, the imposition of more stringent controls
on existing sources could result in reduction of emissions in the
immediate future while at the same time discourage the long-term growth
of the affected source category. Thus, the short-term impacts are
direct while the long-term are indirect and occur as the result of
interaction between the direct impacts and the socioeconomic environment.
Again, judgment will have to be exercised to assess the value of short-
term over long-term benefits.
g. Document the selection decision. The summary table
should be submitted in the AQMP, and supporting data and a description
of the socioeconomic analysis should be available for public hearing
and retained for possible inspection by the Administrator.
REFERENCES
1. J. H. Dales. Pollutions Property & Prices. Toronto: University
of Toronto Press, 1968.
2. J. L. Fisher. "The Natural Environment." The Annals of The
American Academy of Political Social Sciences 371(May 1967).
3. M. J. Flax. A Study in Composition Urban Indicators: Conditions
in 19 Large Metropolitan Areas, The Urban Institute, Washington,
D.C., for the Department of Health, Education, and Welfare,
April 1972.
4. A. J. Klee. "The Role of Decision Models in the Evaluation of
Competing Environmental Health Alternatives." Management Science
(Journal of the Institute of Management Sciences), Vol. 18,
Number 2, October 1971.
V-18
-------
DocScan Pro free trial
Chapter VI: AQMP ASSEMBLY
A. INTRODUCTION
After the AQMA analysis and maintenance strategy development have
been completed, the information should be organized into an AQMP. The
following is a suggested format for the plan. The final format will
be specified in a revision to 40 CFR 51. This format consists of
an introduction, a documentation section, and a section in which the
information about each of the AQMA's within the State is summarized.
If another format is used, an explanation of the rationale for using
it should be included in the introductory section of the AQMP.
In addition to the tables and charts recommended in the following
format, tables and worksheets described in other chapters of this
volume or in other EPA guidelines documents should be included in the
AQMP if they improve the clarity of the presentation.
B. AQMP FORMAT
1. Introduction
a. Background. A general description of the plan and why
it is required.
b. Designation of AQMA's. A list of each AQMA and its
associated pollutants (see figure VI-1).* For each AQMA indicate the
following: whether the AQMA is an interstate or intrastate area; the
cities, counties or political jurisdictional areas within the AQMA;
the pollutants for which the AQMA is designated; and the conclusions
*Figures VI-1 through VI-6 illustrate suggested formats for
the presentation of summarized data. These formats are tentative
and may be changed when 40 CFR 51 is revised. Whatever format is
used, complete data (as opposed to summarized data) shall be
retained by the State for inspection by the Administrator, if
required.
VI-1
-------
DocScan Pro free trial
AQMA's designated by EPA
Political
AQMA Interstate jurisdictions Pollutants Recommended
included action
1.
2.
3.
Figure VI-1. An example format for identifying AQMA's, jurisdictions
involved, pollutants of concern, and recommended action.
VI-2
-------
DocScan Pro free trial
based on analysis of the AQMA, e.g., no plan is needed, or a strategy
has been developed.
c. Plan Contents. A list of documents that constitute the
plan with each document or portion thereof identified according to its
respective pollutant and AQMA.
d. SIP Changes. A list of any documents or portions of the
SIP as it exists immediately prior to the submission of the AQMP that
are being revised, rescinded, or supplemented by the AQMP, and a brief
description of each change. This information should be presented in
the same order as the sections of 40 CFR 51.
e. Plan Review. Present a timetable for performing reviews
in 1980 and 1985 of AQMA designations, and of the effectiveness of the
AQMP in preserving air quality during the intervening periods.
2. Documentation
a. Legal Authority. A demonstration of the legal authority
to adopt and implement the AQMP, pursuant to 40 CFR 51.11, including
a timetable for obtaining any needed authority. Legal authority for
each measure comprising the maintenance strategy must be included.
b. Public Hearings. A certification of public hearings
pursuant to 40 CFR 51.4(d).
c. Intergovernmental Cooperation. Evidence that inter-
governmental cooperation required by CFR 51.21(a) was accomplished,
that the cooperation required by 40 CFR 51.21(c) will occur, and
that the provisions of 40 CFR 51.10(d) relating to the interstate
transmission of pollutants will be followed. Figure VI-2 illustrates
an example format for summarizing the agencies and their involvement
in the AQMP implementation. For each task within the AQMP, list all
participating agencies and the jurisdictional areas they represent.
Also indicate whether the agencies reviewed and commented on the plan,
and name the people in each of the agencies responsible for completing
the AQMP tasks. In the last column of the suggested table, the
supporting documentation indicating agency acceptance of or agreement
with the assignment should be identified by reference.
States should provide evidence that State, regional, and municipal
clearinghouses designated pursuant to OMB Circular A-95 have reviewed
VI-3
-------
DocScan Pro free trial
Summary of agency responsibility for AQMP implementation
AQMP Coordinating Jurisdictional Reviewed or Task
task agencies area ^TanMP assigned to
Figure VI-2: An example format for summarizing agency involvement
in AQMP implementation.
VI-4
-------
DocScan Pro free trial
and commented on the plan, and that the comments were taken into con-
sideration. Comments from these clearinghouses should be included in
this section of the AQMP. Agreements signed by responsible authorities
pertaining to tasks to be performed by governmental agencies as a part
of the AQMP implementation must be included with the plan presentation.
d. Resources. A description of resources available to and
needed by State and local agencies to implement the entire SIP during
the ensuing 10-year period, pursuant to 40 CFR 51.20 (see figures VI-3
and VI-4). For each AQMA, summarize the level of effort, in man-years,
required through 1985 by the agencies responsible for implementing the
AQMP. In addition, summarize the funding requirements for implementing
the AQMP through 1985. The dollar values used for these estimates may
be current (1975) values or discounted values, depending on budgeting
practices within the State. However, the dollar values used must be
identified.
3. AQMA's
For each AQMA published by EPA pursuant to 40 CFR 51.2(f), and
for each pollutant associated with that AQMA, emission and subsequent
air quality should be projected through 1985.
a. AQMA Analysis. If data on emissions and air quality, other
than those obtained from NEDS and SAROAD, are used in the AQMA analysis,
a statement describing the data base should be included in the AQMP.
These data must be entered into the NEDS or SAROAD system at the next
semiannual update. Using these data as a base, the following steps
should be undertaken:
1) Project emissions to 1975/77, or to compliance date.
2) Project growth and development to 1980 and 1985, by
source category. Document the rationale for the projections.
3) Project emissions and air quality to 1980 and 1985,
together with the rationale for the projections.
4) Quantify difference between projected (1980 and 1985)
emissions and NAAQS, in terms of required emission reductions.
For each pollutant in each AQMA, summarize the analysis (fig. VI-5).
Show the current (baseline) emissions, emissions at attainment of the
VI-5
-------
DocScan Pro free trial
Summary of resources: Man-year estimates by function and agency
distribution for the years 1975, 1980, 1985
Year
Function 1975 1980 1985
State Region Local State Region Local State Region Local
Enforcement
Engineering
Technical
services
Management
Totals
Note: For each function, list estimated labor requirements for each
State, regional, or local agency involved. Provide an alphabetical
code for the agencies starting with "A" for the State air quality
control agency. The entry for that agency for 1975 might appear,
for example, as A-6.
Figure VI-3. Suggested format for providing estimates of labor requirements,
by agency, for three key years.
VI-6
-------
DocScan Pro free trial
Summary of resources: Funding estimates* by function
Year
Function 1975 1980 1985
State Region Local State Region Local State Region Local
Enforcement:
Operating funds
Capital funds
Contract funds
Engineering
Technical
services
Management
Total operating funds
Total capital funds
Total contract funds
Total funds
*1975 dollars (or 1975, discounted 1980, and discounted 1985 dollars)
Note: F°r each function, list estimated dollar requirements for each State
regional, or local agency involved. Use the same agency coding as used for'
preparing labor requirement estimates.
Figure VI-4. Suggested format for the presentation of funding required
for years beginning June 1975, June 1980 and June 1985. (Note that
dollar values may be current (1975) or may be discounted, but the values
used must be indicated.)
VI-7
-------
D
o
o
CO
o
Q>
TJ
o
31
CD
g-
01
Summary of AQMA analysis: (pollutant)
Source category
Baseline
emissions
Emissions
at
attainment
Percent
control
applied
Percent
control
remaining
Growth
factors
1980
Emissions
1985
Emissions
Fuel combustion:
Point
Area
Industrial processes:
Chemical manufacturing
Food/agriculture
Primary metals
Secondary metals
Mineral products
Petroleum industry
Wool products
Evaporation
Metal fabrication
Leather products
Textiles
Inprocess fuel
Other
Transportation
Solid waste disposal:
Point
Area
Miscellaneous
Point
Area
Note- The source categories are included as examples only. They should be further
dT^Iggregated depending on the level of analysis used as-described in volume 7 of
this guideline series.
Figure VI-5. Suggested format for summarizing in broad categories the results
of the AQMA analysis. A separate table is required for each pollutant.
-------
DocScan Pro free trial
NAAQS, the percent control to be applied by the attainment date,
a reasonable estimate of the additional control that could be applied,
and the growth factors and projected emissions for 1980 and 1985.
Details of this analysis, such as those resulting from the
procedures outlined in Guidelines for Air Quality Maintenance, vol. 7,
Projecting County Emissions, shall be retained by the State for
examination by the Administrator, if required.
In the event that the detailed analysis of each pollutant within
each AQMA results in the conclusion that the NAAQS will not be exceeded
through 1985, the plan document need include only the information in
sections B.I.a, B.l.b, and B.S.a., above.
b. Maintenance Strategies. For each AQMA for which air
quality will exceed the NAAQS by 1985, alternative strategies for
maintaining standards should be developed. The strategies will be
composed of maintenance measures, each of which must be evaluated on
the basis of its effectiveness and its associated economic and social
cost. A summary of the analysis of alternative maintenance strategies
should be included in the AQMP (see fig. VI-6).
For each maintenance strategy considered, show the maintenance
measures that are included, their cost in dollars, and an estimate
of the social impact. Also explain why a strategy was or was not
selected.
C. STATE REVIEW OF THE AQMP
The internal organization created to ensure coordination and
cooperation during the development and implementation of the AQMP
is probably the best group to properly review the draft of the plan.
Such a review is essential if all of the State and local agencies
having responsibilities for implementing the AQMP are to work together.
Changes in the AQMP draft would be made in accordance with the
comments and suggestions received from the internal review.
D. PUBLIC HEARINGS
The proposed maintenance plan should be made available to the
public, and announcement of public hearings on the AQMP should be made
at least 1 month prior to the hearing date. In order to meet the
prescribed deadline, the hearing should be held by May 15, 1975.
VI-9
-------
DocScan Pro free trial
Summary of strategy evaluation: (pollutant)
"»«$)
Figure VI-6. Suggested format for summarizing strategy evaluations.
The remarks column should be used to explain the basis for acceptance
or rejection of the strategy. A separate table is required for each
pollutant.
VI-10
-------
DocScan Pro free trial
The requirements of 40 CFR 51.4 are applicable to the submis-
sion of the AQMP. As a minimum, States must conduct public hearings
and provide for public availability of the plan in each AQMA that has
been designated in the State. Regional and local agencies that
participated in the preparation of the plan or that have been assigned
a role or responsibility in the implementation are to be included in
the notification list.
E. REVISING. ADOPTING. AND SUBMITTING THE AQMP
After consideration of oral and written public comments, the States
must formally adopt the plan using procedures similar to those used in
the adoption of the SIP. The requirements of 40 CFR 51.5 are applicable
to the submission of the AQMP to the Administrator, EPA. Submission
to the Administrator shall be accomplished by the delivery of five
copies of the plan to the appropriate Regional Office. Plans must be
submitted by the Governor not later than June 18, 1975.
VI-11
-------
DocScan Pro free trial
VI-12
-------
DocScan Pro free trial
Chapter VII: BIBLIOGRAPHY
ENERGY CONSERVATION
Achenbach, P. R., et al. A Feasibility Study of Total Energy Systems
for Breakthrough Housing Sites. National Bureau of Standards,
Report 10 402, Appendix A, August 1971.
This report discusses the advantages and problems associated
with total energy systems (in which electric power for a complex
of buildings is generated locally, and reject heat is used to pro-
vide comfort conditioning and hot water for the same complex) for
use in small power plants of 500 kW or less, suitable for resi-
dential developments of 300 housing units or less.
Berg, C. A. "Energy Conservation through Effective Utilization." Science
181, No. 7 (July 1973): 128-38.
This is a comprehensive discussion of measures that can be
taken with presently available technology to reduce energy con-
sumption in building services (space heating, air conditioning,
illumination, and hot water) and industrial processes. The data
presented indicate that conservation of approximately one-fourth
of national energy consumption may be possible through these tech-
niques.
Gregory, D. P. A Techno- Economic Study of the Cost-Effectiveness of
Methods of Conserving the Use of Energy. Institute of Gas Tech-
nology, Chicago, 111., 1971.
This report describes the effectiveness of several available
heat recovery techniques and thermal management schemes for indus-
trial applications, and data for estimating the costs of each.
Joint Hearings Before Certain Subcommittees of the Committees on Govern-
ment Operations and Science and Astronautics, House of Representa-
tives, "Conservation and Efficient Use of Energy (Part 4)" 93rd
Congress, 1st session, July 12, 1973, pp. 1858-61.
Statement of Caterpillar Tractor Co. to the Committee on Science
and Astronautics. This statement supports the concept of on-site
electrical plants as a means of energy conservation. It implies
that the efficiency of energy use can be increased to over 77 per-
cent by such equipment and their experience in supplying over 14,000
such units as evidence of the practicality of the concept.
VII-1
-------
DocScan Pro free trial
Joint Hearings Before Certain Subcommittees. "Conservation." Part 3.
July 11, 1973, pp. 836-978.
This report is entitled, "Hidden Waste: Potential for Energy
Conservation," edited by David B. Lange. The thesis is that the
amount of fuel and electricity wasted in all sectors of the economy
is much greater than currently available, economically feasible
technology necessitates. The use of trash as fuel to generate space
heat and electricity is one technique given, including some histories
and experiences of municipalities now implementing this energy-from-
trash plan.
Joint Hearings Before Certain Subcommittees. "Conservation." Part 3,
p. 907.
The use of onsite power generation in order to use the waste
heat for space heating/cooling is another technique discussed for
increasing the efficiency of energy utilization.
Moyers, J. C. "The Value of Termal Insulation in Residential Construction."
Economics and Conservation of Energy. Oak Ridge National Laboratory,
Report ORNL-NSF-EP-9, Oak Ridge, Tenn., December 1971.
This report presents a series of nomographs for estimating the
reductions in heat losses that can be obtained from heavy ceiling
and floor insulation, side wall insulation, and/or installation of
storm windows in different U.S. climates.
Perry, H., and Berkson, H. "Must Fossil Fuels Pollute?" Technology
Review 74, No. 2 (December 1971): 34-43.
This paper is presented in a special symposium on Energy Tech-
nology to the year 2,000, Part II: Energy and Pollution. It reviews
the environmental problems associated with the production, trans-
portation, and utilization of fuels. The preferred solution to the
problems of waste are those that turn waste into a useful resource;
for example, waste heat from power generation is an energy source
begging for recovery. Possible schemes for such waste heat recovery
are reviewed along with ideas for using waste products throughout
the fuel production/utilization cycle.
FUGITIVE DUST CONTROL
PEDCO-Environmental Specialists. Investigation of Fugitive Dust—Sources,
Emissions and Control. Prepared for Environmental Protection
Agency, May 1973.
This report identifies significant fugitive dust sources in the
Southwestern United States, develops emission factors by which to
estimate the impact of these sources on total regional particulate
emissions, and evaluates several control methods for each of the
sources.
VII-2
-------
DocScan Pro free trial
INTERGOVERNMENTAL COORDINATION AND COOPERATION
Advisory Commission on Intergovernmental Relations. A Handbook for
Interlocal Agreements and Contracts. Washington, D.C. U.S. Govern-
ment Printing Office, 1966.
The legal foundations and uses of interlocal agreements and
contracts for services. Includes examples of existing agreements
and contracts, model State enabling act. Bibliography may no
longer be current.
Metropolitan Councils of Governments. Washington, D.C. U.S.
Government Printing Office, 1966.
A primer on COG's: origin of movement, legal bases, internal
structures, activities, limitations, prospects. Model State
enabling act.
. Regional Decision Making: New Strategies for Substate
Districts. A-43, Washington, D.C., October 1973.
An excellent and detailed discussion of sub-State programs fos-
tered by Federal, State, and local government. Programs fostering
sub-State agencies and districts are reviewed and their interrela-
tions presented. The basic issues of regional planning and inter-
governmental cooperation at stake in the sub-State level are dis-
cussed. A good presentation of the local and sub-State viewpoint
of government.
. Water Quality Management Planning Guidelines. Washington,
D.C. U.S. Government Printing Office, 1971.
Construction and content of guidelines for intergovernmental
coordination in preparing water quality management plans in
accordance with 18 CFR 601.32-33, grants for water pollution con-
trol.
Argonne National Laboratory and American Society of Planning Officials.
Interagency Cooperation in Cooperative Urban Planning and Air
Quality Maintenance. Prepared for Environmental Protection Agency,
Publication No. EPA-450/3-74-027, March 1974.
This study researched existing and potential relationships
between air pollution control agencies and planning agencies by
means of response to questionnaires sent to 900 public planning
agencies.
Corwin, Edward S. The Constitution and What It Means Today. Twelfth
edition. Princeton, N.J.: The Princeton University Press, 1958.
A paragraph-by-paragraph interpretation of the U.S. Constitu-
tion with a brief discussion of the court cases on which present
interpretations are based. Notable is the material dealing with
interstate compacts: Tennessee vs. Virginia (148 U.S. 503 518
(1893)).
VII-3
-------
DocScan Pro free trial
Croke, E. J., et al. The Relationship between Land Use and Environmental
Protection. Argonne National Laboratory. Prepared for President's
Air Quality Advisory Board and Water Pollution Control Advisory
Board, March 1972.
This overview paper outlines some of the legal, institutional,
organizational, and technical aspects of integrating land-use
planning and regulation with air quality management. It briefly
reviews pertinent legislative and organizational activities of the
past few years and evaluative techniques for assessing the impact
of land-use policies on air quality.
Tryzna, T.C., Environmental Impact Requirements in the States. Office
of Research and Development, EPA, EPA-R5-73-024, July, 1973.
This report reviews the State requirements for Environmental
Impact Statements in the 50 States, Puerto Rico, and the District
of Columbia.
U.S. Environmental Protection Agency, Office of Transportation and Land
Use Policy. Alternative Institutional Options for Implementation
of the Air Quality Maintenance Process. Washington, D.C. To be
published in August 1974.
This paper is concerned with the allocation of State and local
authority and responsibility for preparing and implementing AQMP.
It sets forth three alternatives as stimuli to local decisions on
the preferred institutional arrangement for AQMP planning and imple-
mentation in any particular area.
Zimmermann, Frederick L., and Wendell, Mitchell. The Law and Use of
Interstate Compacts. Lexington, Ky.: Council of State Governments,
1961.
This study reviews the legal nature of interstate compacts,
warrants for their use, criticisms of the compact as an inter-
governmental coordination device, and instructions for compact
drafting.
LAND USE
American Bar Association, Special Committee on Environmental Law.
Development and the Environment: Legal Reforms to Facilitate
Industrial Site Selection. Final Report, 1974.
This report contains the evaluation and recommendations for
legal reforms to improve the decisionmaking process in industrial
site selection. The role of planning in industrial site selection
is discussed. Recommendations are made to improve the institutional
arrangements for site-selection decisionmaking. Legislation reform
recommendations are made for the State and Federal levels.
VII-4
-------
DocScan Pro free trial
California Air Resources Board. A Report to the Legislature on Guidelines
for Relating Air Pollution Control to Land Use and Transportation
Planning in the State of California. August 1973.
This report outlines a proposed legislative program that is
designed to improve and maintain air quality at acceptable levels
(as distinguished from the National Ambient Air Quality Standards)
in California over a 10 to 20 year time frame. Administratively,
the proposed program includes agencies at the State, regional, and
county levels.
Frank, J. E. "The Renaissance in Land Use and its Role in the Solution
of Environmental Problems." Journal of Environmental Systems 3,
No. 3 (Fall 1973):171-87.
This paper summarizes emerging concepts in the areas of land-
use law and planning that have idrect implications for environmental
regulation and planning. It provides detail in the land use plan-
ning aspects, but not on the added environmental protection asso-
ciated with them.
Goldberg, A. A., Chairman. "Land-Use, Regulation." Real Estate Law and
Practice, Course Handbook Series, No. 69, Practicing Law Institute,
New York, 1973, 595 pp.
This is a course handbook for practicing attorneys reviewing
the legal aspects of zoning and other land-use controls.
Hagvik, G., Mandelker, D., and Brail, R. Air Quality Management and
Land-Use Planning: Legal, Administrative and Methodological Per-
spectives. Rutgers University, EPA Contract 68-02-0278, New
Brunswick, N.J., February 1973.
This is a lengthy report dealing primarily with land-use
planning implications of the Clean Air Act. Practical problems of
relating land-use planning to air quality management at the state
level are discussed. Administrative review procedures for relat-
ing land-use planning and air quality management are examined.
Buffer zones, selected local controls, and the uncertainty of pro-
jecting growth and related air pollution are discussed.
Harbridge House, Inc. Identification and Evaluation of Key Land Use
Issues Facing the U.S. Environmental Protection Agency. Volume I.
Draft. Boston, Mass. Prepared for The Environmental Protection
Agency, Washington, B.C., December 1973.
Key land-use issues facing The Environmental Protection Agency
are identified and analyzed in terms of the nature of the environ-
mental impacts involved and the projected magnitude of the problem
over time. General growth and development issues include concen-
tration versus dispersion, rural-urban interfaces nondegradation,
critical areas, and new construction. Siting issues include air-
ports, highways, waste treatment facilities, solid waste disposal,
energy facilities, petroleum refineries, industries covered by New
Source Performance Standards.
VII-5
-------
DocScan Pro free trial
Livingston and Blayney, City and Regional Planners. A Report on Guide-
lines for Relating Air Pollution Control to Land Use and Transpor-
tation Planning in the State of California. Prepared for State of
California, Sacramento, July 1973.
This is an excellent report addressing the relation of air
pollution control to land-use and transportation planning in
California. The current status of air quality planning is reviewed;
current technology application and limitations to air quality plan-
ning and limitations of local air pollution control elements are
discussed. Two alternative governmental frameworks for relating
land-use and transportation planning to air quality goals are pre-
sented and evaluated for California.
Rutgers University Center for Urban Policy Research. The Contribution of
Urban Planning to Air Quality. Draft. New Brunswick, N.J. Pre-
pared for Environmental Protection Agency, Office of Air Quality
Planning and Standards, Research Triangle Park, N.C., January 1974.
This is an in-depth discussion of how land-use controls may be
used to achieve and maintain clean air, and as such this should be
a primary reference for plans that propose any of these controls
for maintenance. The report is directed specifically at require-
ments of the Clean Air Act of 1970, but it was drafted prior to the
EPA decision to require 10-year maintenance plans and therefore
presents the land-use controls in the context of desirable programs
for forward-looking control agencies to consider rather than as
leading options of required control strategies.
MISCELLANEOUS
Bower, B. T., and Sewell, W. R. D. Selecting Strategies for Air Quality
Management. Canadian Department of Energy, Mines, and Resources,
Resource Paper No. 1, 1971.
This monograph describes a systems analysis approach, called
environmental quality-residuals management, for identifying and
examining the effectiveness of a number of alternative strategies
for air quality management. It also presents technical, economic,
and institutional criteria for evaluating these alternative strate-
gies.
SOCIOECONOMIC
Dales, J. H. Pollution, Property, and Prices: An Essay in Policymaking
and Economies. Toronto: University of Toronto Press, 1968.
This document identifies the aspects of pollution that makes
them perplexing and difficult to control. The economics of air
pollution are discussed in terms of linkages among prices, property
law, and property rights. The author discusses these linkages in
philosophical terms and proposes an "economics-legal" approach for
dealing with pollution problems.
VII-6
-------
DocScan Pro free trial
Lamson, Robert W. "Policy Considerations for Environmental Management."
in_. Blumenslun, Alfred et al., eds., System Analyses for Social
Problems. Washington Operations Research Council, Washington, D.C. ,
1970, pp. 266-83.
This paper explores environmental problems, environmental
management, and environmental goals in terms of social values,
goals, and principles. Principles for managing technology and
the environment are developed, and specific value problems are
discussed. Policy questions are raised concerning the selection
and pursuance of values, goals, and principles and the activities,
techniques, and institutions for application to environmental
management.
Stanford University Project on Engineering-Economic Planning. Socio-
Economic and Community Facotrs in Planning Urban Freeways.
Research and Development Report, U.S. Department of Transportation,
Federal Highway Administration, Washington, D.C., September 1970.
This report presents several socioeconomic factors that may be
used to evaluate proposed freeway locations and quantitative indi-
cators that are appropriate to measure each of the factors. Some
of these,factors and their associated measurement indicators may
be applicable in evaluating alternative air quality maintenance
strategies.
The Urban Institute. A Study of Urban Indicators: Conditions in 18
Large Metropolitan Areas. Prepared for Department of Housing and
Urban Development, Washington, D.C., NTIS Access No. PB-220938,
April 1972.
This study evaluates quantitative indicators for 14 different
urban quality categories and recommends readily available statis-
tical data for use in each category. However, most of the cate-
gories (e.g., racial equality, educational attainment, public order)
are not significantly affected by air quality maintenance strate-
gies, so the report is of limited use as background for the socio-
economic evaluation of strategies.
STACK HEIGHT CONTROLS
National Air Pollution Control Administration. Tall Stacks, Various
Atmospheric Phenomena, and Related Aspects. U.S. Department of
Health, Education, and Welfare, Publication No. APTD 69-12, May
1969.
This document includes a brief summary of the effect of tall
stacks on atmospheric dispersion and resulting ground-level con-
centrations of air pollutants, followed by a compilation of
abstracts of recent published articles on these subjects.
VII-7
-------
DocScan Pro free trial
TRANSPORTATION CONTROLS
Alan M. Voorhees and Associates, and Ryckman, Edgerley, Tomlinson, and
Associates. A Guide For Reducing Automotive Air Pollution. Pre-
pared for Environmental Protection Agency, November 1971.
This document describes traffic limitation techniques and
traffic flow improvements that may reduce automotive emissions and
presents examples of past and current applications of those measures
that have been used.
GCA Corporation and TRW Inc. Transportation Controls to Reduce Motor
Vehicle Emissions in Major Metropolitan Areas. Prepared for
Environmental Protection Agency, Publication No. APTD-1462,
December 1972.
This report describes the procedures that were employed and
the results of transportation control strategy development for the
initial 14 metropolitan areas found to need transportation control
plans to meet carbon monoxide and/or oxidant standards. Most of
the information in the report is in the form of summaries of more
detailed presentations from the individual reports published for
each metropolitan area investigated.
Holmes, J., et al. The Clean Air Act and Transportation Controls: An
EPA White Paper. Environmental Protection Agency, Washington, D.C. ,
August 1973.
This position paper discusses the feasibility and impact of
important transportation control measures being proposed. It
includes some cost/effectiveness data.
Institute of Public Administration, Tekmekron, and TRW, Inc. Evaluating
Transportation Controls to Reduce Motor Vehicle Emissions in Major
Metropolitan Areas. Prepared for Environmental Protection Agency,
Publication No. APTD-1364, November 1972.
This report evaluates transportation controls to reduce motor
vehicle emissions in urban areas that can be implemented within a
few years. It includes estimates of effectiveness in reducing
regional and small-area emissions and costs.
Organization for Economic Co-operation and Development. Environmental
Implications of Options in Urban Movility. Paris, France, September
1973.
This report discusses transportation controls that have been
employed in European countries to reduce air pollution and noise
levels. It presents air quality data that were taken prior to and
during the testing of many of the transportation control measures.
Schwartz, S. I. "Reducing Air Pollution by Automobile Inspection and
Maintenance: A Program Analysis." Journal Air Pollution Control
Association 23, No. 10 (October 1973):845-52.~
VII-8
-------
DocScan Pro free trial
This article presents a general procedure for estimating the
effectiveness of an automobile inspection/maintenance program in
reducing carbon monoxide, hydrocarbon, and nitrogen oxides emissions.
It also includes data and an analytical procedure for determining
the costs of such a program.
Thompson, J. M. Methods of Traffic Limitation in Urban Areas. Working
Paper No. 3, Organization for Economic Co-operation and Development,
Paris, France, September 1972.
This paper describes many different methods of limiting traffic,
most of them based on experience in previous applications. For each
method, the effectiveness in traffic limitation, the drawbacks, and
the situations in which the method is best applied are discussed.
No coverage of the effect of the methods on automotive air pollutant
emissions is included.
TRW, Inc. Prediction of the Effects of Transportation Controls on Air
Quality in Major Metropolitan Areas. Prepared for Environmental
Protection Agency, Publication No. APTD-1363, November 1972.
This report includes evaluations of the effectiveness of alterna-
tive transportation control strategies. The format and descrip-
tions of data collection procedures provide good examples for
corresponding sections of air quality maintenance plans.
U.S. Environmental Protection Agency, Office of Air and Water Programs.
Control Strategies for In-use Vehicles. Washington, D.C., November
1972.
This report presents findings and conclusions on the techno-
logical feasibility, effectiveness, and costs of reducing auto-
motive emission rates by inspection/maintenance, retrofit systems,
and gaseous fuel conversion.
URBAN GROWTH
Alan M. Voorhees and Associates and Ryckman, Edgerley, Tomlinson and
Associates. A Guide For Reducing Air Pollution Through Urban
Planning. Prepared for Environmental Protection Agency, Publica-
tion No. APTD-0937, October 1973.
This document is directed primarily to urban planners. It
evaluates several land use/public facility planning strategies for
potential value in reducing air pollution impacts, and includes
data from case studies.
Argonne National Laboratory. Interagency Cooperation in Comprehensive
Urban Planning and Air Quality Maintenance. Prepared for The Environ-
mental Protection Agency, 450/3-74-027, March 1974.
Results of a questionnaire survey of urban and regional planning
agencies are presented. Entires in the questionnaire include if and
VII-9
-------
DocScan Pro free trial
how air quality considerations are incorporated into planning, use
of performance standards, organizational relationships between
planning agencies and air pollution control agencies, attitudes
regarding the relationship between comprehensive planning and air
quality control, and planning agency use of EDA air quality data.
Kaiser, E. J., Elfers, K., Cohn, S., Reichert, P. A., Hufschmidt, M. M. ,
and Stanland, Jr., R. E. Promoting Environmental Quality Through
Urban Planning and Controls. Research Report done at the Center for
Urban and Regional Studies, University of North Carolina at Chapel
Hill for EPA under Grant R801376, June 1973.
This study deals with the changing awareness and current
practices in promoting environmental quality through urban planning
and controls in local and metropolitan planning agencies. It con-
tains the results of a national survey of urban and regional plan-
ning agencies. Reviews the most promising approaches to land-use
and comprehensive planning, planning and controls for the water
resources-land use interface, urban design and controls, and resid-
uals management. Presents concept of land-use guidance planning.
McGivern, W. C. "Putting a Speed Limit on Growth." Planning 38, No. 10
(November 1972):263-65.
This article describes municipal and environmental problems
created by the rapid growth of the suburban community of Petaluma,
Calif., and the controlled-development program undertaken to com-
bat these problems.
Northeastern Illinois Planning Commission. Managing the Air Resources
of Northeastern Illinois. Technical Report No. 6, August 1967.
Three different regional development patterns--a fingers pl.an,
a multitowns plan, and a satellite cities plan—were evaluated on
the basis of emissions estimates. The land-use-emissions projec-
tion technique is described.
Yocum, J. E., et al. Air Pollution Study of the Capital Region. Pre-
pared for the Capital Region Planning Agency, Hartford, Conn.
December 1967.
This study investigated different development patterns for the
Hartford area and modeled the expected air qualities for the alter-
native patterns. Conclusions were drawn as to most desirable land-
use plans from an air quality standpoint.
VII-10
-------
DocScan Pro free trial
Appendix A: FUNCTIONAL PROGRAMS
This appendix discusses existing programs that are related to air
quality maintenance through their land-use or transportation dimension.
Land-use and transportation considerations are described in detail in
Guidelines for Air Quality Maintenance and Planning, Vol. 4, Land Use
and Transportation Considerations. These programs can be divided into
environmental programs and those programs that have a strong land-use
planning function. The environmental programs are generally focused on
environmental protection and are single purpose; each is concerned with the
control of a specific environmental problem. For the most part, these two
types of programs have evolved independently at all levels of government.
For completeness and continuity, a brief description of air pollution
programs is given in paragraph A.I below. Although these programs have
land-use and growth dimensions, they are not primarily concerned with
the long-range effects of population and industrial growth. In preparing
an AQMP then, air programs must be viewed in the context of possible
land-use and transportation strategies, and conversely. An important
example is that greater control by those strategies listed in paragraph
A.I could allow greater leeway in growth.
A. ENVIRONMENTAL PROGRAMS
1. Air Programs
a. State Implementation Plans (SIP). The designation of
Air Quality Control Regions (AQCR's) by the 1967 amendments to the
Clean Air Act initiated the concept of coordinated State and local
action to control air pollution to thereby achieve air quality
standards. Under the 1967 amendments, the Federal role in the SIP
process was limited to the designation of AQCR's, issuance of criteria
and control-technology documents, review of State-adopted ambient
standards, and review of adopted SIP's. The 1970 amendments to the
Clean Air Act expanded the Federal role in the SIP process by re-
quiring that AQCR's be designated for the Nation's entire land area
and that SIP's be prepared to meet newly authorized National Ambient
A-l
-------
DocScan Pro free trial
Air Quality Standards (NAAQS) for the criteria pollutants—part-
iculate matter, sulfur oxides, oxidants, carbon monoxide, nitrogen
dioxide, and hydrocarbons. The amendments also established statutory
deadlines for the submission of SIP's and mandated EPA to propose
plans in those situations where the State plan was inadequate. A
statutory deadline was established for Federal promulgation of such
plans if the State did not take appropriate corrective action. The
regulations to facilitate SIP development, submission, and review
that were promulgated on August 14, 1971, (ref. 1) required the
development of control strategy(ies) that, in addition to resulting
in the aggregate reduction in emissions required to attain the NAAQS,
would also maintain them. Measures and procedures that could be
included in the SIP were:
• Stationary Source Review
• New Source Performance Standards (NSPS)
• Federal Motor Vehicle Control Program (FMVCP)
• Transportation Controls
• Indirect Source Review, added by amendment on June 18, 1973
(ref. 2).
b. Stationary Source Review. Stationary source review
procedures discussed in this paragraph are applicable to the review
of existing sources to determine current status of compliance with
applicable State and local regulations, and the review of new or
modified sources, not covered by NSPS, to set compliance schedules and
emission limitations. The review of new and modified sources for
which NSPS have been promulgated is covered in subparagraph c, below.
1) Existing sources. Review of existing sources
consists of surveillance to determine status of compliance with
applicable regulations. Owners and operators of stationary sources
are required to install, maintain, and use control equipment, or
employ such measures as are required to attain and maintain NAAQS.
Additionally, owner/operators are required to install, maintain, and
use monitoring equipment to determine the effectiveness of control
equipment or measures.
The State agency is required to establish a system of scheduled
inspections for major stationary sources. The SIP must specify the
sources expected to be inspected periodically. This, incidentally,
A-2
-------
DocScan Pro free trial
provides a source of information on major emitters in an AQMA for use
in air quality maintenance planning. The purposes of the periodic
inspection of stationary sources include but are not necessarily
limited to:
• Inventory and register of sources of air pollution
• Determination of compliance with the permit system
• Check of compliance with conditions of variances
• Inspection of monitoring devices and a check of monitoring
records for accuracy
• Sample of fuels, raw materials, air contaminants, etc.; e.g.,
sample of fuels if control strategy includes sulfur limitations.
Thus, it can be seen that stationary source review is a part of
the enforcement program. It can also serve as a source of information
and experience that can be used as input to SIP revision and air
quality maintenance planning.
2) New and modified sources. States are required by
40 CFR 51.18 to establish procedures that will enable the State or
local air pollution control agency to determine whether the construction
or modification of a facility, building, structure, installation, or
combination thereof will result in violation of the SIP control
strategy or interfere with the attainment or maintenance of NAAQS.
The primary purpose of this review is to set compliance schedules
and emission limitations. Following are potential responsibility modes
for accomplishing this review:
• State agency responsible for review of all sources throughout
the State
• State agency responsible for review of certain large sources,
and Regional agency composed of local agencies responsible
for others
• Regional and local agencies responsible for review of all sources.
Obviously, other arrangements are possible. The approach used must
provide for a review of all new and modified sources. The State agency
retains ultimate responsibility for this review.
Review of new and modified sources is accomplished through
permit or other system by which the owner/operator submits such
information as:
A-3
-------
DocScan Pro free trial
• The nature and amounts of emissions to be emitted
• Location, design, construction, and operation information as
may be necessary to permit the State or local agency to make
determination as to compliance with the appropriate control strategy
and the impact on NAAQS.
Upon the receipt of this information, the agency having review
responsibility approves or disapproves the proposed construction or
modification. Approval of the proposed construction or modification
does not absolve the owner/operator from the responsibility for
compliance with applicable State and local regulations. This compliance
is policed through the procedures described in subparagraph 1, above.
c. New Source Performance Standards. Section 111 of the
Clean Air Act authorizes the EPA Administrator to establish national
standards of performance for new or modified stationary sources of
air pollution. Stationary sources are defined as any building,
structure, facility, or installation that emits any air pollutant.
Modification is defined as any physical change in, or change in method
of operation of, a stationary source that increases the amount of any
air pollutant emitted by the source or results in the emission of any
air pollutant not previously emitted. Increase in production up to the
design capacity of an installation is not considered to be a modification
and is therefore not subject to NSPS.
While NSPS also can be promulgated for noncriteria pollutants,
only those pertaining to criteria pollutants are applicable, at this
time, to air quality maintenance.
NSPS are designed to prevent new air pollution problems instead
of having to correct problems after they surface. Under NSPS, best
demonstrated technology is required for new and modified plants,
thereby reducing the impact of rapidly growing industries and of
plant or process modifications that would result in increased emissions.
Because air quality maintenance problems are the result of growth, NSPS
should play an important role in the air quality maintenance strategy.
Owner/operators of new or modified sources for which NSPS have
been promulgated are required to notify EPA of the anticipated and
actual date of initial startup. Within 60 days after achieving the
A-4
-------
DocScan Pro free trial
maximum production rate at which the facility will be operated, the
owner/operator is required to conduct performance tests and submit the
results to the Administrator.
States may be delegated authority to apply and enforce NSPS under
the provision of section 111 (c) (1) of the Clean Air Act by submitting
an approvable procedure for implementing and enforcing NSPS for new
sources within the State. The States also have the option of adopting
the emissions requirements of the NSPS, or more stringent ones, as
part of their regulations. In such a case owner/operators of new and
modified sources within the State under the latter option are required
to comply with the Federal requirements for NSPS as well as State
regulations.
d. The Federal Motor Vehicle Control Program (FMVCP). The
FMVCP establishes emission criteria for HC, CO, and NO that must be met
A
by all new motor vehicles. Since the 1968 model year, automobile
manufacturers have been required to ensure that automobiles produced
during a given model year will result in the required emission control
and that the selected control systems will be reasonably durable over
the life of the vehicle. This assurance is achieved through the
testing of a specified test fleet by the manufacturer in conjunction
with verification of test results by EPA and subsequent certification
of vehicles that meet the Federal standards. The Clean Air Act also
authorizes EPA to test vehicles coming off the assembly line beginning
with the 1975 model year.
The FMVCP is expected to result in substantial reductions in
nationwide emissions of HC, CO, and NO . A portion of this reduction
A
results from the elimination of older vehicles from the national
motor vehicle fleet. The other portion is attributable to the
increased control capability of new models. Inspection/maintenance
programs are essential to ensure that these control systems are properly
operated and maintained so that emission standards are achieved by in-use
vehicles.
e. Transportation Control Measures. "Transportation
controls" is the generic term applied to a diverse group of measures
A-5
-------
DocScan Pro free trial
that, either directly or indirectly, have the potential of reducing
emissions from motor vehicles through either one of two broad
mechanisms:
• Reduction of the emission rate per vehicle-miles
of travel (VMT)
• Reduction in the total number of VMT.
Transportation controls also can include certain stationary source
control measures such as service station vapor controls as part of the
overall control strategy for hydrocarbons and oxidants. Transportation
controls are necessary to bridge the gap between technology and the
attainment of NAAQS in those areas where the reduction of emissions
from FMVCP are not sufficient to ensure the attainment and maintenance
of NAAQS.
Transportaton control plans developed to date have been designed
to attain standards over the relatively short-term range of 2 to 5
years. These plans have generally employed measures aimed at both
emission rate and VMT reductions. However, for the maintenance of
standards over the longer range, measures that reduce emissions from
in-use vehicles will become progressively less effective unless new
control or vehicle-power technology breakthroughs occur. Retrofit
and inspection/maintenance have only a minor impact on emissions from
vehicles that meet the 1977 Federal emission standards. As a result
transportation control strategies for the maintenance of air quality
will most likely rely heavily on measures that reduce VMT. Probably,
the most promising transportation control for producing lasting and
significant reduction in automotive emissions is greater use of mass
transit or other means of increasing passenger load per VMT. Cities
that provide high quality mass transit have demonstrated that this
mode of travel can attract a high percentage of the travelers,
especially when combined with measures that make individual automobile
usage comparatively difficult or expensive.
A-6
-------
DocScan Pro free trial
f. Indirect Source Review. Requirements (currently under-
going revision) for indirect source review were added to the provisions
of 40 CFR 52 in February 1974 (ref. 3). Indirect source review
requirements were introduced specifically for ensuring the maintenance
of national standards by reducing the automobile-related pollutants
resulting from the attraction of mobile source activity to any facility,
building, structure, or installation. This maintenance measure is
implemented through the review of applications submitted by the owner
or operator of any proposed new indirect source. Federal regulations
require review of indirect sources shown in table A-l. These require-
ments are applicable to States that lack indirect source regulations.
Some States with approved plans may have different requirements.
Indirect source review is directed primarily toward carbon monoxide
emissions. However, airports and major highways are also reviewed for
their impact on areawide oxidant levels. On a microscale, indirect
source review alone should be effective in preventing the carbon monoxide
standards from being exceeded as a result of motor vehicle emissions.
Its impact on carbon monoxide levels is best described as "peak-shaving";
i.e., it acts to limit concentrations in potential hot spots, or isolated
areas of high traffic density.
A significant feature of the Federal Regulations governing
indirect source review is the changes that authorize delegation of
review authority to other than an air pollution control agency or
activity. Such delegation can be made to a State agency other than
the air pollution control activity, or to appropriate units of local
government. Appropriate EPA guidance on delegation will be forth-
comi ng.
2. Water Planning and Control
Water resources management is one of the earliest governmental
natural resource programs, dating back to the delegation of respon-
sibility for development and maintenance of rivers and harbors for
navigation. The specific areas of interest are covered by sections
201, 208, 303, and 402 of the Federal Water Pollution Control Act
amendments of 1972 (Public Law 92-500).
a. Background and Purpose of the Legislation. Sections
303, 208, and 201 suggest a nested planning sequence based on
A-7
-------
Table A-l. Indirect sources requiring approval
o
o
o
CO
o
01
CD
CD
g-
01
Location
Sources
Minimum size for review of impact of
carbon monoxide air quality standards
Minimum size for review of impact
on photochemical oxidant and
nitrogen oxides air quality standards
Urban area
(SMSA)
>
co
Nonurban area
New roads and
highways
Modified roads
and highways
New airports
Modified airports
Other indirect
sources, new
Other indirect
sources, modified
Airp-rts
Other indirect
sources, new
Other indirect
sources, modified
20,000 vehicles per day (average)
10,000 vehicles per day over
existing traffic (average)
50,000 operations or 1.6 million
passengers per year
50,000 operations per year
increase over existing level,
or increase of 1.6 million
passengers per year
Parking for 1,000 cars or more
Parking for 500 cars or more
over existing number
Same as in urban areas
Parking for 2,000 cars of more
Parking for 1,000 cars or more
over existing number
50,000 vehicles per day (average)
25,000 vehicles per day over
existing traffic (average)
50,000 operations or 1.6 million
passengers per year
50,000 operations per year
increase over existing level,
or increase of 1.6 million
passengers per year
No analysis required
No analysis required
Same as in urban areas
No analysis required
No analysis required
Source: 40 CFR 52.22 (b) (2), (February 25, 1974).
-------
DocScan Pro free trial
geographical area proceeding from river basin planning to sewage
treatment plant construction in conformance with basin plans. These
sections are discussed in the order of decreasing area! extent.
1) Section 303. Section 303 requires continuing
basinwide water pollution control planning and provides a framework
for all other pollution control activities so as to meet water
quality standards. Basinwide plans are prepared by the State and must
be updated yearly.
Basin plans must include among other elements:
• An assessment of total maximum daily pollutant loads for
streams,
• An assessment of nonpoint pollution sources and, where appli-
cable, needed control measures,
• An inventory of significant individual dischargers,
• Compliance schedules for abatement of significant discharges.
A method of coordinating water quality management planning with
related State and local comprehensive and functional project planning
activities, including land-use and other natural resources planning
activities, must be provided.
Stream seaments in a basin must be classified according to the
current and expected water quality. In this classification, consid-
eration must be given to anticipated economic and demographic growth
over at least a 5-year period. Consideration should be given to
economic and demographic projections utilized by other State programs.
Essentially, 303 plans constitute the framework within which 208
plans designed for specific portions of a basin with complex pollution
control problems are developed.
2) Section 208. Section 208 provides for the design-
ation of certain portions of a water basin as requiring areawide waste
treatment management. These are areas having a water quality control
problem that cannot be alleviated without an areawide approach aimed
at integrating controls over municipal and industrial waste water,
storm sewer runoff, nonpoint source pollutants, land use, and growth.
Areas requiring 208 planning may be designated by the Governor
or by the chief elected officials of general local purpose government
in the area.
A-9
-------
DocScan Pro free trial
Section 208 plans must be certified annually by the Governor as
being consistent with applicable basin plans and as being incorporated
in the State Continuing Planning Process of section 303.
Section 208 plans must comply with solid waste disposal guidelines.
3) Section 201. Section 201 is concerned with the
planning and construction of municipal waste water treatment works.
Planning under this section consists of facilities planning for the
area and must be consistent with the areawide waste treatment manage-
ment plans required by section 208.
Section 201 also requires that waste treatment management include
"control or treatment of all point and nonpoint sources of pollution....
No construction grant assistance may be awarded within a 208
planning area with an approved plan unless the project is included in
the 208 plan.
4) Section 402. Section 402 deals with the implement-
ation of a permitting system for pollutant discharges. It is an imple-
mentation tool of the 208 and 303 plans. No permits may be issued for
point sources in conflict with the 208 plan.
Local planning and management to provide for growth effects on
waste loads can be required in municipal permits.
b. Institutional Responsibilities. State agencies
responsible for 303 planning have been designated by the Governors.
Local or interstate agencies may be designated to conduct all or
part of the planning within each basin.
The 208 planning agency must be a representative organization
whose membership includes, but is not limited to, elected officials of
local governments having jurisdiction in the planning area. Typically,
A-95 review agencies and COG's have been designated.
Agencies involved in 201 planning are typically municipal single
purpose districts—sewer and water departments. Water permits issued
under section 402 are issued either by the State water pollution control
agency or by EPA.
c. Effective Time Schedules. States must comply with the
section 303 continuing planning process by June 30, 1975. February 3,
A-10
-------
DocScan Pro free trial
1974, was the deadline for the initial designation of areas subject
to 208 planning.
d. Interfaces with Air Quality. AQMP's and 208, 303, and
402 plans involve projections of land use and land activity. Growth
projections prepared for SIP's, and therefore, AQMP's, must be consistent
with growth projections prepared for these water plans.
Agencies designated for 208 planning may also be the agencies
involved in air quality maintenance. If not, the local 208 planning
agency can serve as a valuable source of technical planning talent,
information and knowledge of local land-use and transportation programs.
Water plan implementation affects air quality indirectly.
Construction or extension of sewer treatment facilities may induce growth
that, in turn, may increase point and areawide emissions. Direct effects
such as sludge incineration are subordinate to the indirect effects.
Waste water treatment facility permit conditioning, water planning
and construction, grant application guidelines, EIS preparation require-
ments, and modification of the indirect source review procedure in SIP's
may limit the size and capacity of waste water treatment capacity in the
interest of air quality attainment or maintenance.
e. Special Considerations and Problems. Land-use relations
to water quality are required in the development of plans under
sections 303, 208, and 201. Concepts and approaches developed in such
water planning/land-use analysis may be of interest to air quality
maintenance activities that must relate air quality and land use. Also,
208 planning agencies should be aware of the wide variety of land-use
controls that may be applicable in an area.
3. Solid Waste
a. Background and Purpose of the Legislation. The Solid
Waste Disposal Act as amended (P. L. 91-512) is directed primarily at
the loss of natural resources represented by solid waste. This act
authorizes a research and development program to promote the demonstration,
construction, and application of solid waste management and resource
recovery systems. Financial and technical assistance is also provided
to States and local governments for planning and developing resource
recovery and solid waste disposal programs.
A-ll
-------
DocScan Pro free trial
Authority to regulate or promote land-use planning as a solid
waste management strategy is limited to Federal facilities and to
contingency agreements exacted through Federal grant programs (ref. 4),
EIS's are required on proposed Federal activities.
Planning and demonstration grants to States, contingent on their
abandoning open burning and dumping and developing comprehensive solid
waste plans, are available from EPA. Otherwise, EPA has no authority
to close open dumps, override local zoning, or establish solid waste
facilities where communities fail to do so.
Open burning can be controlled through Clean Air Act regulations
and dumping in surface water can be controlled through the Refuse Act
of 1899.
b. Institutional Responsibilities. Solid waste activities
at the State level will generally be the responsibility of the State
health or environmental agency.
At the county level, responsibility for solid waste activities
usually resides with the county or regional health office. Activities
consist of enforcing State solid waste regulations.
At the city level, solid waste activities are those of collection
and disposal and are usually performed by the department of public
works or sanitation department.
c. Effective Time Schedules. None.
d. Interfaces with Air Quality. Solid waste disposal may
contribute to air pollution; e.g., incineration. However, the most
important interaction is probably the increased amount of solid waste
that may be generated as a result of air pollution control techniques.
Byproducts of these techniques, such as limestone from scrubbers,
could contribute extensively to the solid waste load of a metropolitan
area. The air quality planner must be aware of the impact of such
solid waste on sanitary land fills.
e- Special Considerations and Problems. Initial draft
guidelines for areawide waste management planning require 208 planning
agencies to comply with solid waste disposal guidelines (40 CFR 204,
205, 207, 208, and 241).
A-12
-------
DocScan Pro free trial
4. Other Environmental Programs.
Certain other programs and activities concerned with environ-
mental protection or presentation may have a growth dimension. One of
these is noise abatement programs, particularly at airports. The
Department of Housing and Urban Development has guidelines for
evaluating site exposure to aircraft and has formulated a comprehensive
airport planning methodology. Certain land-use and land activities,
such as open air theaters, schools, and hospitals, are not consistent
with high noise levels. EPA will be proposing to the Federal Aviation
Administration regulations for the control of noise at and around
airports. These regulations will provide for land-use controls where
appropriate.
Many city programs have land-use dimensions, both at the planning
and the implementation stage. These city programs generally have
control mechanisms that the air quality maintenance agency should be
aware of. Examples of the types of activities and land-use controls
covered by these programs are:
• Zoning
• Flood plain zoning and management
• Recreational parks
• Greenbelts
• Performance standards
• Subdivision regulations
Planned Unit Development regulations
• Buffer zones
Easements, especially coordination easements
• Housing and premises codes
• Building codes
• Hillside development regulations
• Grading regulations
• Taxation policies.
Such land-use activities and controls form an overall framework
within which air quality maintenance strategies with land-use
dimensions must be evaluated.
A-13
-------
DocScan Pro free trial
Many local governments have initiated and implemented air
pollution control activities that would exist even in the absence of
Federal requirements. Some of these programs predate the Federal
requirements for such activities. Other cover noncriteria pollutants
to cope with problems specific to the area. The air quality mainte-
nance planner should familiarize himself with these programs and
consider using the existing local air pollution control structure for
implementation of that part of the AQMP within the local government's
jurisdiction. Such action takes advantage of the already existing
expertise and knowledge as well as already established and legally
enforceable enforcement power.
B. TRANSPORTATION
1. Background and Purpose of the Legislation
United States Code, Title 23, section 109(j) requires
that the Secretary of the U.S. Uepartment of Transportation (DOT)
issue guidelines to ensure that highways are constructed consistent
with any approved plan for the implementation of ambient air quality
standards (ref. 5).
The Federal Highway Administration has specified that for any
proposed project on a Federal Aid System, final decisions on the
project shall take into consideration the costs of eliminating or
minimizing air pollution. The guidelines require that:
• Environmental effects be identified and studied early enough
to permit analysis and consideration while alternatives are being
formulated and evaluated,
• Other agencies and the public be involved in project
development early enough to influence technical studies and final
decisions, and
• Appropriate consideration be given to reasonable alternatives,
including the alternative of not building the project.
These guidelines apply to all Federal Aid System projects in the
stages of system planning, route location, and highway design. They
also apply to planning decisions made in the urban transportation
planning process for urbanized areas of over 50,000 population. The
3C planning process—referring to the continuing, comprehensive
A-14
-------
DocScan Pro free trial
cooperative transportation planning process carried on between the
State and local communities required by the Federal Aid Highway Act
of 1962--must include inventories of land-use and land activity,
future demands for all modes of transportation, and the development
of a comprehensive multimodel transportation plan. It should be
emphasized that all modes of transportation—highways, airports, and
mass transit—are considered in the 3C planning process.
Air quality coordination is effected through the State Highway
Agency and the 3C planning agency. The 3C planning agency must
establish a continuing review procedure with the cognizant air
pollution control agency. This review focuses on assessment of the
consistency of transportation plan with the SIP and the resolution
of differences.
The 3C planning agency Policy Committee must determine annually
the consistency of the current transportation plan and program with
the approved SIP. This determination along with comments from the
cognizant air pollution control agency and the Policy Committee's
disposition of these comments must be furnished to the Federal
Highway Administration. Conflicts between the transportation plan
and the SIP are grounds for withholding certification of the
transportation plan.
2. Institutional Responsibilities
In the past the State Highway Departments have done most of
metropolitan and regional transportation planning. However, new
statutes (Highway Act amendments of 1973) require Governors to designate
a metropolitan areawide transportation planning agency. About 85 percent
had done so by April 1974. Typically, COG's have been designated.
Planning for all modes of metropolitan transportation—highways, airports,
and mass transit—is accomplished by these agencies.
The areawide planning agency has approval authority on all
transportation plans and the responsibility for ensuring that individual
projects conform to the areawide plan. Their recommendations are binding
on the Secretary of DOT. In addition, the areawide agency may have the
authority to withhold Federal funds. Such authority is not statutory
and depends on agreement among DOT, the State, and the local agency.
A-15
-------
DocScan Pro free trial
Some Federal money will go to the areawide planning agency for metro-
politan and areawide transportation planning.
Coordination of urban transportation planning between the city/
county and State levels is through the Urban Transportation Study
(UTS) Policy Committee which is composed of elected officials.
Technical capability is supplied from the professional staffs
at the State and local level in the form of the UTS Technical
Coordinating Committee (TCC). The goals of the UTS Policy Committee
is the formulation of long-range and immediate action plans for
transportation programs within urban areas.
3. Effective Time Schedules
All metropolitan areawide planning agencies must be
designated by 1975. Another important consideration, previously cited,
is the annual review for consistency of the transportation plan and
the SIP.
4. Interfaces
Transportation affects air quality both directly by the emissions
from automobiles, airplanes, and other vehicles, and indirectly by the
inducement of industrial development and population growth.
Mass transit affects air quality by reducing the vehicle miles
necessary to transport a given quantity of people. However, a
certain population density is necessary to support mass transit.
Dispersion of population and industrial sites in order to reduce
emission density may run counter to the objectives of mass transport-
ation inducements.
Air quality planners should be knowledgeable of highway designs
that improve air quality; e.g., exclusive bus lanes and ramps, fewer
stops, etc., and the extent to which such designs can be expected to
improve air quality. Other technical assistance and information is
available from the metropolitan planning agency; e.g., land-use and
land-activity inventories and projections. Metropolitan Planning
Agencies are also eligible for grants from DOT for planning imple-
mentation procedures for transportation strategies related to air
quality.
A-16
-------
DocScan Pro free trial
Parking facilities, highways, and airports will be subject to
review by EPA or the State air pollution control agency as indirect
sources effective in the near future.
5. Special Considerations and Problems
To be effective, air quality maintenance strategies,
particularly land-use and transportation controls, must be planned
and implemented on a regional basis. Guidelines requiring consideration
of environmental effects in all highway projects have results in well-
established transportation systems and highway planning, review, and
implementation procedures. Sufficient opportunities exist to ensure
that planned improvements in transportation services are consistent
with air quality standards. The basic problem is how to take advantage
of these opportunities early enough in the urban transportation studies
and in the regional transportation system planning to avoid bringing
unsuitable alternatives into the route location and the highway design
stages prior to processing through the EIS and A-95 review processes.
Once these stages have been reached, attitudes and interests are
often polarized and may be difficult to change.
The well-defined planning and review structure of State departments
of transportation suggest several specific recommendations for achieving
effective early coordination. States should establish formal channels
for coordinating objectives in statewide, regional, and local elements
of the State AQMP and of the State Highway Action Plan. These channels
can be used to coordinate formulation and updating of the plans,
application of the plans in implementing strategies "for attaining
acceptable levels of air quality, and programming of highway projects.
To achieve coordination at the State level, the State air pollution
control agency and the State department of transportation could adopt
a joint program management policy thac prescribes communication pro-
cedures to be followed to ensure consistency in objectives of the
State AQMP and of the State Highway Action Plan. Furthermore, the
two agencies could assign responsibility to specific positions or
individuals for maintaining continuing contacts concerning the goal
of securing consistency in program objectives.
A-17
-------
DocScan Pro free trial
At regional level, a closer association in the process of coor-
dinating the development of highway and mass transit projects with
the implementation of transportation control strategies is required
so that new projects and the general transportation plan do not
conflict with the AQMP. The-agency responsible for preparation of
the AQMP should designate staff planners to coordinate with the
transportation planning division of the State department of transport-
ation, UTS project staff, and the TCC of each UTS in setting criteria
for air quality and assessing environmental effects of alternative
highway and mass transit proposals. The thrust of this cooperative
arrangement is full consideration of environmental effects of alter-
natives at their inception in the transportation planning process and
in the system planning stage. At a minimum, the representatives
of the State air pollution control and AQMP preparation agency should
prepare, through a traffic corridor analysis, a preliminary study
report dealing with the environmental effects (air quality) of each
highway and mass transit proposal that becomes a candidate for
advancement into the route location stage. Objectionable air quality
impacts that might lead to definitive opposition in the hearings
required during the route location and the highway or mass transit
design stages can be identified and documented by such a study.
State and local air quality control agencies should designate
staff planners to work with key transportation agencies in local
governments within an AQMA and assist community planners in under-
standing the air quality implications associated with elements of
community development plans and transportation programs.
State and local air pollution control agencies should seek to
have advisory representation on the policy and technical committees
of local planning groups responsible for:
• Formulating land-use policies,
• Developing community long-range plans,
• Determining transportation needs and goals, and
• Conducting transportation studies.
A-18
-------
DocScan Pro free trial
It is recognized that the first two groups listed above do not
directly cause transportation projects to emerge, yet in fact these
two groups are the decision makers who influence the shape and
character of the community in a manner that generates travel demand
and associated transportation requirements, e.g., planning activities.
The last two groups represent the source of decisions leading directly
to the programming of transportation facilities for the community,
e.g., implementation activities.
C. LAND-USE PROGRAMS
1. Background and Purpose of the Legislation
The prevalent approach to land-use planning and implementation
of the plans through zoning is based on the Standard Zoning Enabling
Act of 1926 (SZEA) and the Standard Planning Enabling Act of 1928
(SPEA) (ref. 6). These two acts set the stage for consideration of
interactions among land-use planning and environmental control
activities. Perhaps the crux of the problem of coordinating air
quality maintenance activities with other environmental protection
activities and land-use and transportation planning activities lies
in two features of these two acts. The first feature is that all
development control and planning authority are delegated to the city/
county level. The tacit assumption is that all interests can be
satisfied at this level. No mechanism is available for consideration
of other than city/county interests or for resolution of inter-city/
county development conflicts (ref. 6). Air quality is an interest
that inherently transcends city/county boundaries. Regional or
air-basin-wide planning is required to consider the effects of land-use
and transportation strategies in maintaining air quality. On the
other hand, implementation of air quality strategies through land-use
measures by air quality maintenance agencies impinges on traditionally
city/county authority.
The second feature actually deals with the interpretation of the
acts. Although the SZEA called for the zoning plan to be "made in
accordance with a comprehensive plan...", judicial interpretation
A-19
-------
DocScan Pro free trial
has eliminated the necessity for zoning regulations to be consistent
with the planning. Furthermore, permissive wording in the act has
resulted in separation of responsibilities for planning and plan
implementation in many States (ref. 6). Such controls as zoning and
building permits are not required to be in conformance with any
general growth and development plan. Only a few States require
that local zoning regulations be based on a comprehensive plan
(ref. 7).
As a result of these practical difficulties in the SZEA/SPEA
planning and control framework, some States have directly entered
the land-use field in order to implement development controls and
environmental protection measures (refs. 8, 9). Such actions
generally have been in response to specific and unique problem areas
in each State. As a result a wide variety of approaches and inter-
governmental frameworks are in existence.
To a considerable extent, land-use planning and environmental
control programs have developed separately at all levels of govern-
ment. Environmental protection programs have been determined to a
considerable extent by Federal legislation and have been fragmented
by single-purpose programs directed at specific environmental
problems—including air pollution, water pollution, solid waste,
and noise.
Land-use plans represent the desired or long-range conceptual-
ization of a community or region. As such they are planning tools and
serve as inputs to the decisionmaking process. The actual configuration
that a community or region will take in the future is strongly
influenced by land-use actions (zoning, public utility extension,
tax structure, etc.) at the city level. Thus, air quality maintenance
activities must be coordinated with land-use planning and implementation
in the development of the AQMP to ensure the use of compatible growth
and development projections, and during the implementation to determine
the impact of proposed variances on air quality.
Several legislative acts and proposed acts have recently arisen
in an effort to establish a national land-use policy.
A-20
-------
DocScan Pro free trial
a. Coastal Zone Management Act. The Coastal Zone
Management Act of 1972 (CZMA) establishes a national policy for the
development of a program to manage the land and water resources of
the coastal zone (ref. 10). The act recognizes the multiplicity of
uses and values ascribed to lands and waters within the coastal
zone and encourages the management of these lands through an approved
plan that incorporates important ecological, cultural, esthetic,
and economic values. States are encouraged to rely upon and coordinate
their activities with appropriate local governments and regional
agencies in the development of a CZMP. Incentives to prepare and
administer a comprehensive CZMP are provided, but no specific land/or
water-use decisions are made. States submitting grant requests for
programs that impinge on the CZMP must show that these programs are
consistent with the approved plan. Further, according to section 307(f)
of the act, requirements of the Clean Air act as amended and subsequent
Federal regulations shall be incorporated into the CZMP. An important
point of the act is that the State land-use control authority, when
necessary, can supersede local governmental authority. This is in marked
contrast to the tradition under which all 50 States have delegated land-
use regulation power to local city/or county governments (ref. 11).
b. National Land-Use Policy. National land-use policy
legislation has so far failed to pass. Some States have enacted and
many are considering their own versions of land-use planning legislation.
Much of this legislation is single purpose, directed toward controlling
specific problems of development.
2. Institutional Responsibilities
a. Coastal Zone Management. Each coastal State (those on
the Seaboard plus those bordering the Great Lakes) has created or is
in the process of creating an agency to accept responsibility for
development and administration of the CZMP (as of March 1974). This
agency may well be a part of an existing agency responsible for some
or all of the activities related to environmental management.
National Land-Use Policy. H.R. 10294 encourages the
use of general purpose local governments to implement the comprehensive
A-21
-------
DocScan Pro free trial
planning process of the act. S.R. 268 provides that a State land-use
planning agency be advised by an intergovernmental advisory council,
including chief elected officials of general purpose local governments.
3. Effective Time Schedules
Since the Coastal Zone Management Act does not make CZMP's
mandatory—only providing incentives for their preparation—no deadline
is applicable.
H.R. 10294 has failed to reach the House floor for action.
Therefore, it is uncertain whether tay Federal land-use legislation will
be forthcoming in 1974.
4. Interfaces
As with the development and implementation of the AQMP, the
development and administration of the CZMP requires an in-depth
examination of the future uses of the area, the likely development as
a result of population growth, and the desired environmental quality.
Thus, the activities required for air quality maintenance and coastal
zone management are much the same—legal, zoning, planning, development,
economic analysis, air resource management, and water resource management.
5. Special Considerations or Problems
Perhaps the most significant feature of the CZMA is that land-
use planning and control authority is placed in the same State agency.
When necessary, the State land-use control program within the coastal
zones of coastal States is required to supersede local authority.
Furthermore, air quality requirements must be incorporated in the
development of the CZMP. Thus, a State air quality agency working within
the agency framework of the CZMP could have land-use control authority
preemptive over local authority. However, the land-use controls
would be exercised by the State coastal zone management and not by
the State air pollution control agency.
c. Other Programs. Table A-2 taken from Regional
Decision-Making: New Strategies for Substate District (ref. 11)
summarizes Federal areawide programs. The programs discussed above
with major interaction with air quality programs are included. Many
of these programs are optional as indicated by the second column.
A-22
-------
DocScan Pro free trial
Table A-2. Operational approaches of Federal areawide programs: 1972
Areawide coordi native mechanisms used
Name of program
Air pollution Control
Airport System Planning
Appalachian Local Devel.
Dist. Asst.
Areawide Comp. Health
Planning (3145)
Areawide Comp. Ping
Asst. (701)
Areawide Haste
Treatment Management
Community Action (CAP)
Economic Development
Planning
New Commumties
Open Space
Project Notification &
Review (A-95)
Regional Medical Program
& Development
Rural Development Planning
Rural Industrialization Asst
Solid Waste Planning Grants
Urban Mass Transportation
Ping
Urban Transportation Planning
Water/Sewer Facilities
Water & Sewer Planning for
Rural Commumties
Water & Waste Disposal Systems
for Rural Communities
Water Quality Management
PI anni ng
Some States have given th
i s honored by ARC .
. . . Special
Areavnde areawlde
usej* organizational
program requirements
(1)
Optional
Optional
Optional
Optional
Required
Requi red
Optional^
Optional
Optional
Optional
Optional
Required
Optional
Optional
Optional
Optional
Optional
Requi red
Optional
Requi red
Optional
Required
(2)
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
No
No5
Yes
Yes
Yes
No
No
No
No
Yes
No5
No
No
Yes
is authority to their local
Functional
components
of areawide
programs
other than
land use
(3)
Single
Single
Multiple
Single
Multiple
Single
Multiple
Multiple
Multiple
Single
Multiple
Single
Multiple
Multiple
Multiple
Single
Single
Single
Si ngle
Single
Single
Si ngle
development
Required plan
Coord.
A-95 Areawlde fundTnq
^ Review authority channeled
and to veto through a
comment funding sin lesarea.
wi de agency
(4)
State
State
State & area
State 4 area
Area
State & area
Area
Area
None
Area
None
Area
Area
"~
None
Area
Area
Area
Area7
Area6
State a area
districts (LDD1
(5)
No
No
Yes
Yes
No
No
Yes
Yes
No
No
No
Yes
Yes
No
No
Yes
No
No
No
No
s). In
(6)
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
-Undetermined--
Yes
Yes
Yes
Yes
Yes
Yes
Yes
(7)
No
No
No1
No
No
Yes
Yes
No
No
No
Yes
Yes
No
Yes
No
No
No
No
Yes
(8)
No
Yes
Yes2
Yes
Yes3
Yes
No
Yes2
No
No
Yes
Yes
Yes
Yes
Yes^
No
Yes8
Yes
Yes
such cases, the LDD veto
^Action projects do not follow this pattern.
-^Except some interstates.
^Although a community action agency is required, it need not be areawide. Indeed, a large number of them are single
county or single city in coverage.
=>An areawide planning organization {of the 701 type) is required, but not an areawide implementation organization.
As of 1971, approximately 185 metropolitan planning organizations and 149 nonmetropolitan planning organizations were
certified as meeting the open space and water/sewer planning requirements In a few very exceptional cases, a State
agency has been recognized on a temporary basis as the planning organization.
"Required only if USOA/FHA funding involves a grant {rather than a loan) for water and waste disposal system
?Most of these plans are countywide, but they may be multicounty.
8This agency has usually been the county, but a preference is now stated for multicounty substate districts.
Sources. Catalog of Federal Domestic Assistance^, Federal Register, and program guides and directories.
A-23
-------
DocScan Pro free trial
Table A-2 indicates whether a Federal areawide program is mandated
(column 1), whether organization requirements exist (column 2), whether
it is single-or multipurpose (column 3), and the mechanisms that can
be used to promote areawide coordination (columns 4-8).
States frequently play an important role in determining regional
participation in programs that are Federally optional on a regional
level.
The table indicates a strong institution-building desire by the
Federal government; funding is often channeled through a single
areawide agency and veto power over funding is often given to the
agency. However, the agency can be either single-or multipurpose.
A technique used to strengthen planning is the use of coor-
dination councils (column 5) with representatives from all agencies
and interests affected by a proposed program.
Areawide programs may or may not include planning and imple-
mentation authority (veto and review over funding).
REFERENCES
1. Federal Register 36, 15486.
2. Federal Register 38, 15958.
3. Federal Register 39, 7270.
4. E. J. Croke, K. G. Croke, A. S. Kennedy, and L. J. Hoover. The
Relationship Between Land Use and Environmental Protection,
NTIS PB-209642, 1972, p. 51.
5. Federal Highway Administration, Interim Regulations and Procedures,
Federal-Aid Highway Program Manual, vol. 7, ch. 7, sec. 9,
November 14, 1973.
6. J. E. Frank. "The Renaissance in Land Use and Its Role in the
Solution of Environmental Problems." Journal of Environmental
Systems, 3, No. 3 (1973).
7. L). R. Mandelker. The Zoning Dilemma, 1971, pp. 57-63.
8. Frank. "Renaissance," pp. 16-17.
9. Croke. Relationship, pp. 38-40.
A-24
-------
DocScan Pro free trial
10. Frank. "Renaissance".
11. Croke. Relationship, p. 21.
12. Advisory Commission on Intergovernmental Districts. Regional
Decision-Making: New Strategies for Substate Districts, October
1973, pp. 180-81.
A-25
-------
DocScan Pro free trial
A-26
-------
DocScan Pro free trial
Appendix B: EVALUATING SOCIAL IMPACT
OF MAINTENANCE STRATEGIES
A. INTRODUCTION
This appendix describes how A. J. Klee's approach to evaluating
alternatives (ref. 1) can be used to evaluate the social impact of the
various air quality maintenance strategies. A simplified trend approach
is also presented in the event since the availability of personnel pre-
cludes the use of Klee's model. The simplified approach may be used.
in such a case with prior approval of the Regional Office. This approach
can be used to evaluate each individual measure of a maintenance strategy,
which would give more reliable results. The agency planning for air
quality maintenance may feel that a very detailed approach is required
because of the contrasting social impacts of several measures constitu-
ting a maintenance strategy. However, in general, because of the time
required to analyze each measure, it is recommended that Klee's approach
be applied at the level of air quality maintenance strategies. By uti-
lizing this approach, the agency planning for air quality maintenance
can develop an estimate of the relative social impact of the strategies.
A discussion of the theoretical justification of the approach is pre-
sented at the end of this appendix.
The approach consists of six basic steps:
1. Choose the social factors that the planning agency feels are
important.
2. Determine the relative importance to the planning agency of
the social factors; use the relative importance to obtain a weighting
factor for each social factor.
3. Analyze the weights developed in step 2 by means of a consist-
ency check.
4. Estimate the trend effect of each strategy on the social
factors: Will a strategy have a beneficial effect, no effect, or an
adverse effect?
B-l
-------
DocScan Pro free trial
5. (a) For each social factor, determine the relative importance
of the alternative strategies (in a manner similar to that of step 2).
(b) Use consistency check on number developed in part (a).
6. Combine the numbers developed in steps 2 and 5 to determine
the quantitative evaluation of each strategy.
The remainder of this appendix gives a detailed explanation of
steps 1-6, including a numerical example.
B. DESCRIPTION
1. Step 1
The agency planning for air quality maintenance should decide
upon a list of the social factors or phenomena that may undergo change
in response to the various, feasible air quality maintenance strategies.
These social factors should include any factor that cannot be evaluated
in terms of cost. (Note: Increased usage of resources and raw materials
may be an adverse effect of some strategies. If these resources are
scarce, the planning agency should consider the possibility that increased
demand will cause increased prices. Such effects should be included under
costs. However, the planning agency may decide that increased usage of a
resource will not cause a price increase, although such increased usage
is felt to be undesirable with respect to conservation measures. This
type of effect should be included as a social factor.)
Examples of some social factors are given in table B-l. The example
list is not intended to be exhaustive or include all of the relevant
social factors; the planning agency must be the judge of the factors it
wishes to include. Community goals and objectives provide the best
source of these factors.
Insofar as possible, the social factors should be mutually exclu-
sive. Factors that will respond in an identical or very similar fashion
to the strategies should be replaced by a single overall social factor.
This should be done to avoid overemphasizing an area of concern. For
example, rather than have separate entries for ease of access to cultural
and historic sites and for ease of access to educational facilities,
both entries should be combined.
2. Step 2
Next, the importance of these social factors to the locality
B-2
-------
DocScan Pro free trial
Table B-l. Examples of social factors
Transportation
Ease of access to:
places of employment
• educational, cultural, and historical facilities
recreational facilities
• commercial (shopping) areas
Equitable distribution of cost
Population
• size
• distribution
• density
• mobility
Institutional relationships
• maintenance of traditional political authority
• maintenance of the informal community structure
Employment
• mobility
• growth
• distribution
Quality of life
• change in water quality or supply
loss of open space
• impact on ecologically critical areas
• impact on regional noise levels
Other
B-3
-------
DocScan Pro free trial
should be determined. This can be done in the following manner. List
the factors in some arbitrary manner (see table B-2). The order of the
factors should not affect the final weighting factors (the Wi's, although
intermediate results will be altered. Fill in the R. column: next to
the first factor, enter R, = (importance of factor 1) T (importance of
factor 2), i.e., R, is an indication of the relative importance to the
local planning agency of the importance of factor 1 as compared to
factor 2. R? is the relative importance of factor 2 compared to factor
3. Thus R. = (importance of factor i) * (importance of factor -+-i)-
There is no entry for the last factor. To fill in the K. column, start
at the bottom of the column and enter the figure 1.0. The next-to-last
row will have K , = K • R = R To compute K _2> multiply K ,
by Rn_2- Continue this "zig-zag" approach, K. = K. + -| • R.. Each row
will contain an entry for K.. After entering K,, sum all of the entries
in the K. column, obtaining K. Each R. is the relative importance of the
ith factor compared to the i + 1st factor. Each K. is the relative impor-
1
tance of the ith factor compared to all the other factors. It is felt
that for small sets of factors (say 4 or less), the agency planning for
air quality maintenance could skip the R. column and begin with the K.
column. However, for larger sets of factors, it is too difficult to con-
sider all the factors simultaneously; thus, the pairwise approach of
filling in the R. column will be easier to implement. Finally, to fill
in the W. column, simply divide the corresponding 1C by the sum K, i.e.,
W-j = K] T K, W2 = K, etc. The sum of the W.. should be 1.0.
Table B-2. Derivation of the «
Social factor
Factor 1
Factor 2
Factor 3
R.
i
Rl
R2
R3
K.
i
K1
K2
K3
W.
i
K-, -r K
K I/
rt . I\
K3 - K
Factor n-1 R^ K^ K^ -
Factor n 1.0 1.0 t-
-------
DocScan Pro free trial
As an example, consider Anycounty, U.S.A. Its local planning agency
has decided that the following social factors are of importance: ease of
access to employment, ease of access to recreation, density of population,
and mobility of employment. These factors are listed in arbitrary order
in table B-3. After some discussion, the planning agency has decided on
the figures entered in the R. column: mobility of employment is consi-
dered to be 3.0 times as important as ease of access to recreation, while
ease of access to recreation is only one-fourth as important as population
density, and population is felt to be equally important as ease of access
to employment. Next, the K. column is computed, starting with K. = 1.0.
Then K0 = K. • R, = 1.0 • 1.0. Similarly, K. = K, • Rn = 1.0 • 0.25 =
J '
0.25 and KI
0.75 + 0.25 + 1.0 + 1.0 = 3.0.
dividing each ^ by K, so that W] = K] v K = 0.75 v 3.0 = 0.25, etc.
3. Step 3
Once table B-2 has been completed, a consistency check on the
values of the W. should be performed. This can be done by using table
B-4. Enter the factors in the order of their computed W^'s, the one with
the largest W- at the top. To compute the C. column, start at the bottom.
No entry is entered for the last row. For the next-to-last row, C -j
R3 = 1.0 • 1.0. Similarly,
RI = 0.25
3.0 = 0.75. The sum of the KI is K =
Finally, the W. column is computed by
is computed from C
n_-| = Wn-
Next, C
n_2
+ W
n_-j •
zagging; in general, C. = C.+, + W. + ,. Finally, C-, = C« + W2-
Continue zig-
Tne
Table B-3. Consistency check
Social factor (ordered)
Factor 1
Factor 2
W C.
i i
Wl Cl
Wo C
2 U2
Factor n-1
Factor n
n-1
B-5
-------
DocScan Pro free trial
Table B-4. Example of derivation of
Social factor
Mobility of employment
Ease of access, recreation
Population density
Ease of access, employment
Ri
3.0
0.25
1.0
—
Ki
0.75
0.25
1.0
1.0
K = 3.0
W.
0.250
0.083
0.333
0.333
1 .000
consistency check then asks the planning agency to compare a factor with
all of the factors appearing below it. Suppose W, is greater than C-j.
Then it should be the opinion of the planners that factor 1 is more
important than all the other factors combined. Similarly, W2 < C2
would imply that the agency felt that factor 2 was not as important as
factors 3, 4,..., n combined. If any inconsistency is noted, redo the
calculations of the W, and check (again) for consistency.
For a consistency check of the W. computed by Anycounty, see table
B-5. According to the calculated W., the Anycounty planners consider
mobility of employment more important than ease of access to recreation;
ease of access to employment is equally as important as mobility of
Table B-5. Example of consistency check
Social factor (ordered)
Population density
Ease of access, employment
Mobility of employment
Ease of access, recreation
Wi
0.333
0.333
0.25
0.083
Ci
0.667
0.333
0.083
--
-------
DocScan Pro free trial
employment and ease of access to recreation combined, and population
density is less important than all of the other factors combined.
4. Step 4
Next, calculate the subscores of the maintenance strategies
for each social factor, using figure B-l as a worksheet. If the local
planning agency considers that a strategy will have different effects,
depending on the time served, calculations should be made for these
time periods. For factor 1, the local planning agency should decide the
relative importance of the effect of each of the strategies. Fill out
the R. column for factor 1, where R-, = (importance of effect of strategy
1) T (importance of effect of strategy 2). Complete the R. column,
J
noting that no entry is required for the last row. Next compute the K.
J
by setting K = 1.0 and then K -, = K • R ,. Continue zig-zagging up,
finding K. = K-+, • R.. After finding K-, , sum the K. to obtain K.
Finally, compute the S, . by dividing each K. by K. Now duplicate this
process for factor 2, factor 3, etc.
Assume that the Anycounty planners have determined that there are
five feasible strategies, and their effects on the social factors do
not change significantly through time. Table B-6 shows example sub-
scores for their maintenance strategies.
Note that the size of the figure 1 worksheet (as shown by the
example table B-6) is very dependent upon the number of alternative air
quality maintenance strategies. Thus, the more strategies that can be
eliminated from consideration early in the process by screening, the
simpler the evaluation of the stragegies will be.
If desired, the calculation of the social factor-maintenance
strategy subscores can be checked for consistency by a procedure similar
to that used for checking the social factor weights.
5. Step 5
Finally, the subscores are combined with the factor weights to
determine the overall social effect of each alternative strategy. This
should be done for each of the time periods that was used for table B-6.
Tables B-7 and B-8 should be used for this purpose. Enter the appro-
priate weighting factor (W.) in each column of table B-7 (see table B-2),
and then enter the appropriate subscores in the S.. columns (see table
' J
5-7
-------
DocScan Pro free trial
Worksheet for evaluation of subscores
Time period: From to
Social factor R. K, S,,
J J ' J
Factor 1 :
Strategy 1 RI KI
Strategy 2 R2 K2
Strategy m — 1.0
K
Factor 2:
Strategy 1 R-| KI
Strategy 2 R2 K2
Strategy m — 1.0
K
sn
S12
slm
1.0
S21
S22
S2m
1.0
.
Factor n:
Strategy 1 RI K]
Strategy 2 R2 K2
Strategy m -- 1 .0
K
nl
n2
nm
1.0
Figure B-l. Worksheet for social evaluation of maintenance measure.
B-8
-------
DocScan Pro free trial
Table B-6. Example of subscore evaluation
Social factors
Ease of access, employment
Strategy 1
Strategy 2
Strategy 3
Strategy 4
Strategy 5
Ease of access, recreation
Strategy 1
Strategy 2
Strategy 3
Strategy 4
Strategy 5
Population density
Strategy 1
Strategy 2
Strategy 3
Strategy 4
Strategy 5
Mobility of employment
Strategy 1
Strategy 2
Strategy 3
Strategy 4
Strategy 5
R.
0
3.0
0.5
1.0
0.5
--
0.4
2.0
1.0
2.5
--
0.70
0.70
3.5
0.6
—
1.0
0.7
1.0
4.0
--
K.
J
0.75
0.25
0.50
0.5
1.0
3.0
2.0
5.0
2.5
2.5
1.0
13.0
1.029
1.47
2.1
0.60
1.00
6.199
2.8
2.8
4.0
4.0
1.0
s. .
ij
0.250
0.083
0.167
0.167
0.333
0.154
0.385
0.192
0.192
0.077
0.166
0.237
0.339
0.097
0.161
0.192
0.192
0.274
0.274
0.068
14.6
B-9
-------
DocScan Pro free trial
Table B-7. Computation of evaluation scores
Maintenance
strategies
Strategy 1
Strategy 2
Strategy m
Time
period:
From
Social factor 1
W
1
Wl
Wl
Wl
sn
lj
Sll
S12
Slm
Prod.
Wl XS11
Wl x S12
Wl x Slm
to
Social factor n Evaluation
W S Prod scores
n nj (A.)
Wn Snl WnxSnl Al
Wn Sn2 Wn x Sn2 A2
Wn Snm Wn x Snm Am
Table B-8. Summary, ranking of evaluation scores
Maintenance
strategies
Strategy 1
Strategy 2
Evaluation
From
to
Al
scores bv time period
From
'•• to
Al
A2
Average
evaluation
s core
Avg]
Avg2
Rank
Strategy m
m
B-10
-------
DocScan Pro free trial
B-7). The product column is simply the product of the W^ entry with the
S.. entry. Finally, the evaluations scores A. are found by summing the
"1 J
product columns across each row. Use table B-8 to summarize the eval-
uation scores by time period. Enter the Evaluation scores from table
B-7 into the appropriate column in table B-8, and then compute the
average evaluation score for each strategy. Finally, rank the strategies
by assigning the highest rank (one) to the strategy with the largest
average evaluation, etc.
Averaging the evaluation scores implies that social impact occurring
in the future is as important as impact occurring at the present time.
However, because of uncertainty about the future, the agency planning
for air quality maintenance may feel that immediate, more predictable
consequences are more important than long-term uncertain outcomes. In
such a case, immediate consequences should be considered more important,
and a careful comparison of the evaluation scores through time should be
made. (In fact, the agency may want to multiply evaluation scores for
more long-range time periods by factors less than one (1.00) to give a
type of present value, somewhat similar to the approach discussed in
appendix C below. However, such a procedure introduces a new problem:
exactly what factors should be used? The resolution of this problem is
not at all obvious.) See table B-9 for an example. Although strategy 3
has the highest average through time, the agency might feel that social
impacts in the period 1975-1980 are more important than those in 1980-
1985 and 1985-1990. Hence they could select strategy 1 as being the
most desirable and strategy 2 as being next most desirable.
Table B-9. Example of differences through time
Maintenance
Strategies
Strategy 1
Strategy 2
Strategy 3
From 1975
To 1980
0.200
0.180
0.180
From 1980
To 1985
0.180
0.200
0.185
From 1985
To 1990
0.170
0.190
0.190
Avg.
Evaluation
Score
0.183
0.190
0.195
Rank
3
2
1
B-ll
-------
DocScan Pro free trial
The evaluation scores and the ranking for the Anycounty example are
shown in table B-10. Only one table is needed because no changes through
time occurred in the example. Thus, it was not necessary to average.
C. THEORETICAL BASES
Theory
formula
Mathematically, the evaluation scores are found from the
A. =
1=1
for alternative air quality maintenance strategies j = l,2,...,m. Implicit
in this approach are the assumptions that the utilities of the social
factors are all measured on a single utility scale, and that the utility
of combinations of the factors can be found by adding the individual
utilities. This assumption of additivity would be violated if the
local planning agency felt that the utility of some combination of social
factors was affected by an interaction among the factors. The require-
ment that the social factors be mutually exclusive is required to ensure
additivity.
Another assumption required for the linear additive model is that
over the area of relevance, the isopreference curves (substitution
curves) that relate the utilities of the social factors are essentially
linear. Such an assumption would be violated if a local planning agency
felt that beyond a certain point, it would not be willing to trade
improvement in factor A for a decline in factor B. However, the screen-
ing of alternative air quality maintenance strategies before evalua-
tion should remove strategies that would have too severe an effect on
Table B-10. Example of computation of evaluation scores
Strategies
Strategy 1
Strategy 2
Strategy 3
Strategy 4
Strategy 5
Ease of access
to employment
Wl
0.333
0.333
0.333
0.333
0.333
su
0.250
0.083
0.167
0.167
0.333
Prod.
0.083
0.028
0.056
0.056
0.111
Ease of access
to golf
w2
0.083
0.083
0.083
0.083
0.083
S2j
0.154
0.385
0.192
0.192
0.077
Prod.
0.013
0.032
0.016
0.016
0.006
Population
densi ty
W3
0.333
0.333
0.333
0.333
0.333
S3j
0.166
0.237
0.339
0.097
0.161
Prod.
0.056
0.079
0.113
0.032
0.054
Mobility of
employment
W4
0.25
0.25
0.25
0.25
0.25
W4J
0.192
0.192
0.274
0.274
0.068
Prod.
0.048
0.048
0.069
0.069
0.017
Evaluation
scores of
alternatives
0.200
0.187
0.254
0.173
0.188
Rank
2
4
1
5
3
B-12
-------
DocScan Pro free trial
one or more of the social factors. Thus, the assumption of linearity in
the isopreference curves can probably be satisfied by the preliminary
screening of strategies.
It should be noted that approaches more rigorous than that of Klee
can be adopted. For example, Keenly (see ref. 2) presents an analysis
of proposed airport sites for Mexico City. The analysis begins by esti-
mating the joint probability density function of the possible impacts of
each of the various alternatives. The utility functions for each of the
factors that will be impacted are then developed, along with the requisite
scaling factors and constants to determine if an additive or multipli-
cative model is appropriate. Finally, the various alternatives are com-
pared by computing their expected utilities.
Klee's approach assumes that the social impacts will occur with
certainty, that an additive utility function is appropriate, and that a
common utility scale is approximate. Thus, his approach can be placed
somewhere between a purely subjective one and the more rigorous decision
analysis approach of Keeney. Should the agency planning for air quality
maintenance feel that sufficient expertise and time are available, then
it may use Keeney's approach. Of course, this is optional and not
required. For further discussion of these points, see references 1, 2,
3, 4, 5 and 6.
D. SIMPLIFIED TREND APPROACH
This simplified approach for evaluating the social impact of a
maintenance strategy is based on direction of change in the social factors,
i.e., expected to improve, no change, not applicable, or expected to
worsen.
The first step in this simplified approach is the same as the first
step in Klee's approach, described in preceding sections of this appen-
dix.
Next, the air quality planner, in conjunction with political figures
and other experts, should determine its impact on direction of change of
the social indicators. A "+" can be used to signify that the direction
of change is favorable, "0" to indicate that no change will take place
or that the measure is not applicable, and "-" that the impact on the
direction of change is unfavorable. Adding the pluses and minuses pro-
vides an index for the comparison of alternative measures. The various
B-13
-------
DocScan Pro free trial
elements can be weighed if desired to place greater or less weight on
any specific social indicator. Decision to use weighting factors
necessarily rests with the agency(ies) responsible for the preparation
of the AQMP. A suggested worksheet for accomplishing this evaluation
is presented in figure B-2.
REFERENCES
1. A. J. Klee. "The Role of Decision Models in the Evaluation of Com-
peting Environmental Health Alternatives." Management Science,
Journal of the Institute of Management Sciences 18, No. 2
(October 1971).
2. R. L. Keeney. "A Decision Analysis with Multiple Objectives: The
Mexico City Airport." Bell Journal of Economics and Manage-
ment Science, Spring, 1973.
3. G. P. Huber. "Multi-Attribute Utility Models: A Review of Field
and Field-Like Studies." Management Science, Journal of the
Institute of Management Sciences 20, No. 10 (June 1974).
4. R. L. Keeney. "Utility Functions for Multiattributed Consequences."
Management Science, Journal of the Institute of Management
Sciences 18, No. 5, Part I (January 1972).
5. D. H. Stimson. "Utility Measurement in Public Health Decision
Making." Management Science, Journal of the Institute of
Management Sciences 16, No. 2 (October 1969).
6. E. Turban and M. L. Metersky. "Utility Theory Applied to Multi-
variable System Effectiveness Evaluation." Management
Science, Journal of the Institute of Management Sciences 17,
No. 12 (August 1971).
B-14
-------
DocScan Pro free trial
AQMA
Source factor evaluation
Maintenance strategy
Transportation
Ease of access to:
• places of employment
• educational, cultural,
and historical facilities
• recreational facilities
• commercial (shopping) areas
Equitable distribution of cost
Population
• size
• distribution
• density
• mob i1i ty
Institutional relationships
• maintenance of traditional
political authority
• maintenance of the informal
community structure
Employment
• mobility
• growth
• distribution
Quality of life
• change in water quality or supply
• loss of open space
• impact on ecologically critical areas
• impact on regional noise levels
Other
Impact
Weighting
factor
Figure B-2. Worksheet for evaluating social impact
of a maintenance measure.
B-15
-------
DocScan Pro free trial
B-16
-------
DocScan Pro free trial
Appendix C: EXAMPLE OF PRESENT VALUE CALCULATIONS
Suppose the local planning agency of Anytown, U.S.A., is comparing
two different air quality maintenance strategies. The time period will
be 20 years, and the planners have decided to consider the possibilities
of 7% and 10% interest. All costs are assumed to occur on December 31
of the year in which they are incurred (If a cost will occur in January
or February, the Anytown planners assume that it will have occurred the
preceding year). The data for the alternatives are:
Alternative I
Capital Costs: $1 million in years 1, 5, 20
Operating Costs: $10 thousand per year
Alternative II
Capital Costs: $0.5 million in year 1
1.0 million in year 10
2.0 million in year 20
Operating Costs: $50 thousand per year
The total undiscounted costs for the alternatives are $3.2 million and
$4.5 million, respectively. However, the present value of these costs
are shown in table C-l. At an interest rate of 7 percent, there is
little economic advantage in either alternative. However, at a rate
of 10 percent, alternative II is more acceptable.
-------
DocScan Pro free trial
Table C-l. Examples of present value calculations
Alternatives, Cost
years
Alternative I
Year 1 $1 million
Year 5 $1 million
Year 20 $1 million
Operating $10 thousand
Total present value
Discount factor, costs
7 percent
Factor* Di scounted
hactor cost
0.93458 $934,580
0.71299 712,990
0.25842 258,420
10.59400 105,940
$2,011,930
10 percent
Factor* Dis^ted
0.90909 $909,090
0.62092 690,920
0.14864 148,640
8.51360 85,136
$1,763,786
Alternative II
Year 1 $0.5 million
Year 10 1.0 million
Year 20 2.0 million
Operating 50 thousand
Total present value
0.93458 $467,290
0.50835 508,350
0.25842 516,840
10.59400 529,700
$2,022,180
0.90909 $454,545
0.62092 385,540
0.14864 297,280
8.51360 425,680
$1,563,045
*Factors can be obtained from any standard reference book such as
Principles of Engineering Economy by E. L. Grant and W. Grant Ireson,
Ronald Press, N.Y.
Note: The factors for discounting single amounts can be computed
from the formula
Present Value = Cost • (1 + i)-t
and the factors for discounting constant amounts incurred over a period
of years can be computed from the formula
Present Value = Annual Cost
1 - (1 + I
where i = Interest rate
t = Number of years
C-2
-------
DocScan Pro free trial
Appendix D: MAINTENANCE MEASURES
Detailed descriptions of several potential air quality maintenance
measures are presented in volume III of. this guideline series, Control
Strategies. The 18 measures included in that document cover a broad
range of options, but are not intended to be all-inclusive. Those
responsible for plan preparation are encouraged to devise other measures
with special applicability to the AQMA's in which they are to be
employed.
A summary of the descriptions for each of the measures is provided
in this volume. The first nine listed have been categorized as land-use
and planning measures because they are concerned primarily with plan-
ning for future air quality and with new emission sources. The remain-
ing nine measures have been categorized as emission control measures,
and involve technological or operational changes that affect both
existing and new sources. The latter measures tend to have a more
direct effect on emissions from individual sources and, hence, their
impacts can be quantified more readily than those of the land-use and
planning measures.
A. EMISSION ALLOCATION PROCEDURES
Emission allocation is a maintenance measure that requires emis-
sions of pollutants be limited to prescribed levels within an airshed,
air basin, AQMA, or portion thereof. The allocation limit is specified
based on some relationship between the total pollutant emissions in
the area of concern and the assimilative capacity of the ambient air in
the area. The assumption is made that this relationship can be pro-
jected to establish the total acceptable amount of emissions that can
be allowed at a future time.
Emission allocation procedures form an administrative, enforce-
ment, and analytical framework within which emission control measures
and specific planning actions can be applied. By itself, this measure
usually does not provide emission reductions, so it is dependent on
D-l
-------
DocScan Pro free trial
the ability of other appropriate measures to provide reductions shown
to be needed in particular areas. However, it does provide control
over the admittance of new sources into areas that are approaching or
at their emission allocation limit.
The necessary "rejections of future emissions -rre obtained frrri
-jsbinates of future areas and types of development combined with land-
use-based emission factors for these developments. Therefore, land-
use and transportation plans for the area are critical to the establish-
ment of emission allocation procedures. Participation by the land-use
planning agency is necessary for implementation.
The measure may be applied to all pollutants and to both existing
and new point, line, and area sources. It provides a transition
between the plans for attainment (SIP) and maintenance (AQMP) of NAAQS
by prescribing a single level of emissions for each subarea that is
applicable for both plans.
B. REGIONAL DEVELOPMENT PLANNING
Identical groups of air pollutant emission sources placed in
different configurations can result in significantly different ambient
air quality concentrations. This premise is the basis for including
regional development planning as a maintenance measure. Air quality
considerations may be made an integral part of the regional planning
process; and constraints on development may even be stated in regional
plans if they are indicated to be necessary to maintain standards.
This is not presently done. Over a long period of time, regional
development policies by themselves may have a significant effect on the
location of pollutant emission sources and on the exposure of the
populace to them.
From a practical standpoint, it must be recognized that regional
plans, as well as community master plans, rarely carry any legal en-
forceability. They normally constitute a statement of the goals and
aspirations of a region or community. Because they lack enforce-
ability, comprehensive regional plans are dependent on measures such
as zoning and other land-use ordinances for their implementation.
Notwithstanding, a comprehensive regional plan is a prerequisite if
implementation measures are to be coordinated for the attainment of
the long-term land-use and environmental objectives.
D-2
-------
DocScan Pro free trial
Four principal elements of regional planning can be used to assist
in maintaining air quality: a) regional form, b) open space planning,
c) stationary source location, and d) transportation planning. Evalu-
ation of existing regional plans for compatibility with future air
Quality maintenance requires nrojections of the emissions associated
with different land uses and atmospheric dispersion node!ing of these
projected emissions to estimate ambient air quality. The current
state-of-the-art for projection and modeling procedures is not
sufficiently advanced to permit accurate determination of the rela-
tionship between land use and air quality in many cases. As modeling
techniques improve and more planning agencies incorporate environmental
criteria into their planning process, this measure is expected to
have widespread use.
C. EMISSION DENSITY ZONING
Emission density zoning is a maintenance measure that requires
emissions of a pollutant to be limited to prescribed levels within a
defined spatial area. A limit would be established in terms of the
amount of emissions per area per time period, such as pounds of partic-
ulates per acre per year. Such a limitation may be administered by an
air pollution control agency in conjunction with planners and zoning
administrators.
Emission density zoning may be applied to existing and new
sources. For example, it may be estimated that a heavy industrial
zone could contain only those plants that would emit no more than 3
tons of total suspended particulates per square mile of lot size per
day. A light industrial zone might have a ceiling of no more than 1
ton per square mile per day. Similar limits might also be established
for commercial, institutional, and residential areas.
The purpose of such a spatially defined emission limitation tech-
nique would be: (a) to ensure that concentrations of pollutant emis-
sions in a small area ("hot spot") would be avoided, and (b) to main-
tain local and regional air quality at prescribed levels.
Emission density zoning could probably only be administered for
stationary source emissions, so the measure is most applicable for
sulfur oxides and particulate pollutants. There is no conceptual
reason why emission density zoning could not be applied to other
D-3
-------
DocScan Pro free trial
pollutants, such as carbon monoxide, hydrocarbons, or oxides of nitro-
gen, for the portion of total emissions produced by stationary sources.
For example, the emissions of hydrocarbons from petroleum refining and
storage might be regulated through emission density zoning. Rather,
the problem is an operational one, related to how the emission rates
would be set.
Emission density zoning can be implemented either as a secondary
requirement for new and modified sources (in addition to point source
regulations) or as a replacement for point source regulations. In most
cases, it is unlikely that existing regulations would be abandoned.
Hence, projected violation of either point source or emission density
zoning requirements would usually be grounds to deny construction or
operation of the source.
D. ZONING APPROVALS AND OTHER INDIRECT REGULATORY CONTROLS
Regulatory land-use management techniques are primarily concerned
with the larger issues of controlling and directing urban growth and
only indirectly with the long-term maintenance of air quality. None-
theless, they may have significant impact if air quality is used as a
criterion in setting land-use policy. The regulatory land-use controls
include:
• Zoning
• Subdivision regulations
• Capital facility ordinances
• Development timing controls
• Moratoria
• Transferable development rights
• Tax policy
• Capital improvement programming
• Critical environmental area controls
• A-95 review process
These implementation measures can be used to channel growth into
areas that can contain it, while discouraging growth in already over-
burdened areas. Because the land-use management measures act primarily
to restrict or direct urban growth, they are not feasible techniques
for AQMA-wide application. Implementation of any of these land-use
management techniques obviously must be preceded by an air quality
D-4
-------
DocScan Pro free trial
analysis that provides a framework and direction for the program. It
is assumed that the effect of these regulatory controls on air quality
can be accurately determined. Only if this is the case can the imple-
menting agency know where within the AQMA to discourage and where to
channel development.
L. TRANSPORTATION CONTROLS
Transportation controls include a diverse group of measures that,
either directly or indirectly, can potentially reduce emissions from
motor vehicles by one of two broad approaches: (a) reducing the
pollutant emission rate per vehicle-mile of travel (VMT), or (b)
reducing the total number of VMT. Because of the wide range of
available measures, a plan for control of automotive emissions may
be tailored or designed specifically for problem areas within an AQMA,
whether they are extensive or extremely localized. Proper selection
from the numerous available measures can minimize the social and economic
impacts that are inevitably linked to all transportation controls. It
should be noted that gasoline rationing is currently considered to be
infeasible and that it can be assumed that existing transportation
control plans based primarily on gasoline rationing will not result in
attainment of NAAQS.
Transportation control plans, initially developed to attain standards
over the relatively short-term range of 2 to 5 years, have employed
measures aimed at reducing both emission rate and VMT. However, -for
maintenance of standards over the longer range, measures that reduce
the emission rates from in-use vehicles will become proportionately less
effective unless new control or vehicle-power-technology breakthroughs
occur, because measures such as retrofit and gaseous fuel conversions
will be inapplicable to post-1975 model year vehicles. As a result,
transportation control strategies needed for maintenance will have to
rely heavily on measures that reduce VMT. An areawide parking management
plan, a part of an overall mass transit incentive plan, can contribute
to a reduction in VMT.
Inspection/maintenance (I/M) is an important control measure
because not only is it capable of achieving large carbon monoxide and
hydrocarbon emission reductions, but also it helps ensure that the
D-5
-------
DocScan Pro free trial
emission reductions claimed by the Federal Motor Vehicle Control
program are in fact achieved. The Clean Air Act specifically
anticipates that I/M programs will be included in transportation
control plans for regions having automobile-related air quality
problems.
Many of the measures designed to reduce VMT have already been
employed by traffic agencies for the purpose of eliminating undesir-
able congestion in high traffic density areas. It is important that
transportation control measures have obvious accompanying benefits
such as reduced congestion, time and money savings to commuters,
better public transportation services, or energy savings, because
experience has shown that significant restrictions of personal mobility
are not likely to be accepted solely to improve air quality.
The most promising transportation control for producing lasting
reductions in automobile use is probably improved mass transit. In
the major urban areas where long-range transportation controls will be
needed to maintain standards, only about 14 percent of work trips are
now handled by mass transit. Cities that provide high quality mass
transit have demonstrated that this mode of travel can attract much
higher levels of ridership, particularly it auto use is comparatively
difficult or expensive.
F. EMISSION CHARGES
Two types of emission charges have been suggested as control
measures for air pollution. One is a charge on each point source,
proportional to its emissions, that would be set at a rate related to
the type of emission, the type of damages attributable to that
pollutant, and the concentration of that pollutant in the ambient air
of the AQMA. The other is a tax on the emitters of a pollutant,
either at a flat rate for the entire State or Nation or at a rate
adjusted for each AQMA.
Both types of charges are designed to internalize the external
costs of pollution; that is, to place an economic burden on the
individual or firm responsible for the emissions that will make the
cost of pollution a part of the cost of doing business or of con-
D-6
-------
DocScan Pro free trial
suming goods. Air pollution is normally an economic burden on the
general public but is free to the pollution source. T lerefore, to
provide an economic incentive for control, these costs must be allo-
cated to the pollutant sources, who then will find it economical to
control emissions and who will, in turn, include these costs in
prices to be paid by the beneficiaries of production rather than by
the general public.
Emissions charges or taxes may also be imposed as a secondary
measure in addition to ordinary source control regulations. This is
the most probable application for air quality maintenance.
Effluent charges on the sources of water pollution can be charged
in proportion to the cost of water treatment downstream from the source.
This procedure obviously does not apply to air pollution emissions.
Air pollution emission charges might be set at rates that are above
the cost of control and thus induce polluters to reduce emissions.
Because 100 percent control is not possible for most sources of pollu-
tant emissions, any such system of charges will tend to ration the
remaining emissions to those sources for which control costs are
highest or available control technology is least effective.
Taxation of pollutant emissions is yet to be tested in practice
in this country. However, a tax on sulfur emissions has been proposed
in the U.S. Congress. Its probable effect would be to induce controls
to the level where the combined cost of the control system and the tax
is least. Tax payments would continue to be made on the portion of
emissions that remain after application of controls. Theoretically,
an emissions tax could be implemented on an adjustable basis, with the
rate being changed periodically until the desired level of total
emissions is achieved and maintained.
G. TRANSFER OF EMISSIONS SOURCE LOCATION
The air quality in an AQMA is determined not only by the total
emissions within its boundaries, but also by the spatial configura-
tion of the sources. The purpose of this measure is to move selected
major sources out of hot spot areas to different locations, in or out
D-7
-------
DocScan Pro free trial
of the AQMA, where the air quality standards are less likely to be
exceeded. It redistributes emissions without necessarily reducing
them.
The primary application for this measure is power plants. In
this case, an existing plant is not actually replaced by a new plant
in a more acceptable location, but air quality maintenance considera-
tions are integrated into the planning mechanism for the electrical
utility company involved. The utility must continually plan to meet
short-term and long-term power demands in its service area by the
most economical combination of its available production units.
Although air quality considerations could influence the daily assign-
ment of operating units to meet the system load, they would more
likely be a factor at two points in long-term planning:
• Site selection for new power plants, in areas that can
accommodate these major sources plus other planned development; and
• Determination of reduced usage or shutdown of an existing
unit located in an unfavorable area.
This measure is usually already employed to the maximum extent
practicable in new site selection. New power plants rarely go into
built-up areas; siting of new plants is much studied, with air
quality impacts one of the primary concerns. With lead times for
power plant construction now exceeding 10 years, effective use of
this measure requires long-range projections of air quality levels
throughout the AQMA.
H. INDIRECT SOURCE REVIEW
Unlike most of the other maintenance control measures, indirect
source control is a required, integral part of every AQMP.
The types of new or modified sources that are to be reviewed for
approval under this measure are cited in the regulation for maintenance
of national standards, 40 CFR 52.22. The sources subject to review
include, but are not limited to, the following:
• Highways and roads;
Parking facilities;
• Retail, commercial, and industrial facilities;
• Recreation, amusement, sports, and entertainment facilities;
D-8
-------
DocScan Pro free trial
• Airports;
• Office and government buildings;
• Apartment and condominium buildings;
• Education facilities.
The above sources include most public and large commercial building
projects.
The review procedure is limited, however, to developments above
certain sizes, which are also stated in regulation 40 CFR 42.22 (b)(2).
These size thresholds are specified in terms of daily traffic volumes
for highways, annual aircraft operations for airports, and number of
parking spaces for most other facilities. Indirect sources smaller
than the threshold sizes are assumed to be evaluated and controlled
as part of overall growth by other maintenance measures.
The indirect source review procedures apply only to the automobile-
related pollutants and are primarily effective in maintaining carbon
monoxide air quality standards in the local area surrounding the
proposed indirect source. The intent of this review procedure is to
ensure good traffic design so that motor vehicle emissions in the
vicinity of the indirect source are minimized. With few exceptions,
the review should not result in a limitation on the size of the
facility or influence its location.
On the AQMA scale, the resultant effect of the indirect source
review process on carbon monoxide concentrations is best described as
peak-shaving; i.e., it acts to limit concentrations in potential "hot
spots", or isolated areas of high traffic density, but probably has
no measurable impact on CO emissions or ambient concentrations in
most parts of the AQMA.
Emission reductions are achieved through disapproval of deficient
initial development plans, by requiring that modifications be made
to the internal or access traffic handling facilities to improve
projected traffic flow.
I. ENVIRONMENTAL IMPACT STATEMENTS (EIS's)
Section 102(2)(C) of the National Environmental Policy Act (NEPA)
of 1969 requires all Federal agencies to submit an EIS to the Council
on Environmental Quality (CEQ) prior to taking major actions that
may significantly affect the human environment. Furthermore, the act
D-9
-------
DocScan Pro free trial
requires that an EIS be prepared in consultation with those Federal
agencies that have juridisdiction by law or special expertise with
respect to any environmental impact involved. In general, the pro-
visions of NEPA apply to projects that are administered or funded by
the Federal Government; an EIS must accompany a proposal for action
through the existing agency review process.
Although NEPA does not explicitly state that a project's effect
on air quality is to be discussed in an EIS, both CEQ guidelines and
agency regulations for the preparation of EIS's stipulate that air
quality impacts are to be considered. Probably the most significant
air pollution emission sources requiring EIS's are proposed Federal
or federally assisted highways and airports, and power plants. The
primary consideration in an EIS air quality analysis is whether
the project adversely affects attainment or maintenance of air
quality standards.
The sole purpose of an EIS is to alert decision makers and the
general public to the environmental risks involved in major Federal
actions. If the final EIS indicates that there are adverse air
quality impacts including nonconformance with a State's implementa-
tion plan, of which the AQMA is a part, associated with what is con-
sidered to be the best alternative action, decision makers must
evaluate whether these adverse environmental effects outweigh the
benefits of proceeding with the project. NEPA, however, does not
provide veto power over the decision that is finally made.
In addition to Federal environmental legislation, 17 States and
the Commonwealth of Puerto Rico have legislatively adopted or adminis-
tratively promulgated policies and provisions similar to NEPA. While
most of the jurisdictions make use of an EIS in one way or another,
the applicability and scope of the EIS requirement varies.
J. NEW SOURCE PERFORMANCE STANDARDS
These measures encompass two distinct programs that have the
common characteristic of requiring stringent controls on new sources:
Federal New Source Performance Standards (NSPS), and State and
local requirements for lower allowable emissions for new or modified
sources than for existing ones.
D-10
-------
DocScan Pro free trial
Responsibility for development, implementation, and enforcement
of the Federally promulgated NSPS rests with EPA. Authority for
implementation and enforcement may be delegated to the States upon
submission and approval by the Administrator of adequate procedures for
these purposes. NSPS are applicable only to new or modified sources
in specific stationary source categories proposed and promulgated by
EPA. The procedure requires testing of the source after startup to
determine compliance.
State regulations usually have provisions for review of new
sources prior to construction and call for disapproval if the appli-
cable emission regulations or NAAQS would be violated. A State or
local regulation with more stringent emission limitations on new or
modified sources would be implemented through this review procedure.
The NSPS generally provide more restrictive controls than SIP
regulations for existing sources, thereby ensuring minimal impact from
new sources in the specified categories. Another aspect of this
measure's air quality maintenance action is the reduction in emissions
that results from obsolete sources being modified or replaced by
comparable new ones that are subject to the lower allowable emission
rates of the NSPS. As more source categories are included under the
provisions of the NSPS, this measure will increase in scope and effec-
tiveness in reducing emissions. Upon promulgation, the emission
limitations of the NSPS are mandatory on all subsequent new or modified
sources. Therefore, this measure is present in all areas independent
of AQMP provisions and should be considered as an integral component
of all AQMP's.
Under the Federal program, NSPS are adopted according to nationwide
priority, which may or may not be the same as that required for any
specific AQMA. Nothing in the Federal regulations precludes the States
from prescribing lower allowable emissions limitations on new sources
in categories not covered by Federal NSPS. This would be considered
as a maintenance measure and would permit the tailoring of a program
specific to the AQMA. Should Federal NSPS be subsequently developed
and promulgated, the State-developed emission limitations would con-
tinue to be applicable if they are at least as stringent as the NSPS.
If the State-developed emission limitations are less stringent, the
NSPS requirements would take precedence.
D-ll
-------
DocScan Pro free trial
K. REVISION OF EXISTING SIP CONTROL MEASURES
An early step in the development of the AQMP is the determination
of whether more stringent emission limitations on existing sources in
the form of an SIP revision would be adequate to maintain air quality.
If routine SIP revisions alone would be sufficient, an AQMP is not
required. Amendment of pertinent State regulations, revision of the SIP,
and demonstration that the revised control measures would result in the
maintenance of air quality is sufficient to satisfy the air quality
maintenance requirements.
Should more stringent controls not be feasible and/or should such
an analysis indicate that these measures would not, by themselves,
provide the control required to maintain NAAQS during the period 1975
through 1985, an AQMP would be required. Revision of the existing SIP
emission limitations then becomes one measure among many that should be
considered in the development of an appropriate maintenance strategy.
The extent to which such a measure could be implemented would depend on
the existing level of control and the types of emission sources present
in the area.
L. PHASEOUT OR PROHIBITION OF EMISSION SOURCES
Phaseout of emission sources is a measure whereby certain emission
sources are eliminated by prohibiting their incorporation into new con-
struction or by prohibiting operation of existing sources. Unless operation
is prohibited, those sources already in operation are not affected until
obsolescence requires replacement, at which time they become subject to
the provisions of this measure. Phaseout of existing emission sources
can occur as the result of a business decision, as a result of manda-
tory prohibition by a specified date, as a result of the imposition of
performance specifications on emission sources, or as a result of
legislation prohibiting operation of specific types of equipment.
To be successful, acceptable alternative equipment or services
must be available for whatever is to be phased out or prohibited.
These alternatives should be cost competitive in addition to offering
reduced pollutant emissions.
Two desirable applications of this control measure are the phase-
out of inefficient domestic oil-fired furnaces and the prohibition of
D-12
-------
DocScan Pro free trial
onsite incinerators. In an AQMA where greater emission reductions are
needed to accommodate expected growth, an extreme application would be
the prohibition of new fossil-fuel-fired space heating units in a
specified area where maintenance action is required.
Phaseout measures are appropriate for forcing shifts toward desired
technology or equipment when more direct or drastic action is imprac-
tical. These conditions frequently exist when large amounts of capital
investment are involved or when the equipment is pervasive throughout
society so that changes can only be made gradually without causing
unacceptable disruption or hardship.
M. FUEL CONVERSION
This measure is defined as all processes in which one fuel is con-
verted to another form that has a lower pollutant emission rate per Btu.
Fuel switching by individual sources, the ultimate result of increased
availability of cleaner fuels from fuel conversion processes, is
described under another measure, Energy Conservation and Utilization.
Processes in which fuels are converted directly to thermal, electrical,
or kinetic energy also are not considered as fuel conversion. Some
of the conversion processes currently of interest—most of which
involve coal conversion—are:
• Coal gasification
• Coal liquefaction
• Coal desulfurization
• Oil desulfurization.
Additional processes may become prominent within the initial 10-year
air quality maintenance planning period or thereafter.
Within the initial 10-year planning period for AQMP's, there are
several critical limitations on the application of this maintenance
measure. Most importantly, the technology for many of the coal con-
version processes is still in the research and pilot plant stages,
and design and construction lead times for available processes average
5 years. Therefore, the measure connot be implemented on a signifi-
cant scale within the next 10 years. Secondly, the cost of clean fuels
produced by the processes is generally not competitive with current
costs of available natural fuels of comparable quality. Until the eco-
nomics of fuel conversion change or fuel prices increase, conversion is
not economically attractive.
D-13
-------
DocScan Pro free trial
From the standpoint of implementation and enforcement, planning
and control agencies have no direct powers to require private energy
resource companies or public utilities to build fuel conversion
facilities, nor to specify the amount or type of clean fuels to be
produced. Stringent regulatory requirements on emission rates or
allowable fuel characteristics may promote the introduction of fuel
conversion practices, but only if they are economically justifiable in
comparison with the use of acceptable natural fuels or emission con-
trol systems. Even if converted fuels were produced for a metropolitan
area, mechanisms would not be readily available to allocate this
cleaner fuel to areas within an AQMA where it would be of most benefit
for air quality maintenance. On the other hand, longer term applica-
tions of fuel conversion are almost unlimited, especially in view of
the recently increased emphasis on fuels research.
Fuel conversion, as an industrial process, may have direct
impact on air quality within an AQMA. Economics normally dictates that
the conversion process take place at the source of coal, oil shale, or
other new material. The buildup associated with the plant and the
plant itself may generate emissions that could threaten NAAQS in areas
where present air quality is much better than secondary standards.
Some of these remote areas have been proposed as natural resource AQMA's.
N. ENERGY CONSERVATION AND UTILIZATION
Optimum use of fuel and energy resources to reduce air pollution
emissions encompasses both energy conservation and the redistribution of
currently available fuels to combustion sources. Conservation measures
are aimed at the reduction of energy demands through more efficient use
of energy; e.g., better insulation of buildings to reduce thermal
losses. A reduction in energy requirements will decrease the quantity
of fuels used by combusion sources, thereby reducing the emissions of
pollutants to the atmosphere.
A fuels redistribution policy is not intended to reduce the total
quantity of fuel used by combustion sources, but rather to reduce the
pollutant emissions directly through the use of emission control
devices. This can be accomplished through the use of incentives
whereby those combustion sources for which control devices are readily
available are encouraged to use so-called dirty fuels. Clean fuels
D-14
-------
DocScan Pro free trial
are directed to those sources for which control devices are either not
available or are economically impractical.
Specific measures that may be considered in the development of
an overall energy utilization policy are listed below. This list
should not be considered to be exhaustive, as additional measures may
be appropriate for a specific AQMA.
Energy Conservation Measures
• Revision of building codes to reduce thermal loss
• Reduction of heating and cooling requirements
• Greater use of multiple family structures
Energy conservation in industrial processes
Revised scheduling of industrial activities
• Vehicle use restraints
• Fuel consumption restrictions on new vehicles.
Fuels Redistribution Measures
• Incentives to change fuel type
• Prohibition of specific fuels.
Energy utilization measures are not clearly in the domain of a
single regulatory agency. Therefore, extensive intergovernmental co-
operation would be required to implement an energy utilization program
exclusively or primarily for air quality maintenance.
0. COMBINATION OF EMISSION SOURCES
The underlying assumption of the combination of emission sources
measure is that it may be beneficial from an air pollution viewpoint
to combine a large number of small, uncontrolled emission sources into
one large, well regulated, and well monitored emission source. Such
combinations not only result in better emission control but also
simplify enforcement as well. Combination of emission sources may
produce an economic advantage because of the increased efficiency that
usually results from economies of scale. As a part of sound air
quality management, however, it must result in a net emissions reduc-
tion of pollutants into the atmosphere.
Two applications of this measure are emphasized: district heat-
ing and use of municipal refuse as a fuel in steam-generating boilers.
These applications are complementary in that the facility used to
provide one service may also provide the other; e.g., a district
power plant can be built that furnishes heat, hot water, and elec-
D-15
-------
DocScan Pro free trial
tricity to a neighborhood and at the same time uses the solid waste
of that neighborhood as part of the fuel charge to generate these con-
sumable energies. This combination of emission sources involves
dissimilar types of sources (power generation emissions and solid waste
disposal emissions). A more conventional combination of sources
involves the replacement of a large number of similar sources by a
single source of the same generic type.
District heating generally can be implemented only in new con-
struction and therefore requires a long lead time for full impact. The
heat distribution system requires high-pressure plumbing and compati-
bility with fixtures in the individual buildings, so retrofitting of
existing neighborhoods is not feasible.
Combination of emission sources in the applications described
above would be most effective for urban areas with high population
densities or clustered development. This maintenance measure may also
influence growth patterns in an AQMA--developments incorporated into
the service areas for proposed total energy systems would probably
develop more rapidly than those that are not.
P. SPECIAL OPERATING CONDITIONS
Two principal types of actions are included under this heading:
supplementary control systems and procedures applicable to malfunction,
startup, and shutdown operations.
Supplementary control systems are predetermined procedures whereby
the rate of emissions from a source is curtailed when meteorological
conditions conducive to high ground-level pollutant concentrations
exist or are anticipated. A proposed revision to 40 CFR 51
would permit the selective use of supplementary control systems
only where adequate constant emission reduction techniques are not
available to attain and maintain NAAQS, and where permanent production
curtailment, shutdown, or delay in attainment of NAAQS are the only
other alternatives. The proposed regulation also requires that a
source must be isolated from other emission sources to qualify for
this type of control. This requirement for source isolation greatly
limits the potential application of supplementary control systems in
D-16
-------
DocScan Pro free trial
AQMA's. Provisions for widespread short-term curtailment of sources
are already included in implementation plans for emergency episode con-
trol, but these are generally designed to combat pollutant concentra-
tions higher than the NAAQS, not to maintain short-term standards.
Specific operating procedures frequently must be followed in order
to minimize pollutant emissions' from certain processes during periods
of startup or shutdown or when malfunction of the process or its
pollution control equipment occurs. Careless operation during these
periods or inadequate maintenance may result in short-term air quality
standards being exceeded in the vicinity of these sources. To reduce
this possibility, sources may be required to demonstrate the adoption
and use of proper maintenance and operating procedures. This particu-
lar measure would probably have a negligible effect on maintenance
of long-term NAAQS.
Q. STACK HEIGHT REGULATIONS
The use of tall stacks as a maintenance measure is intended to be
applied in addition to, rather than in lieu of, stationary source
emission regulations. It is recognized that, even though all sources
may be operating in compliance with allowable emission rates, it may
be necessary to effect a further reduction of ground-level concentra-
tions of air pollutants as growth in the AQMA results in some locally
high emission densities. The use of a tall stack to decrease ground-
level pollutant concentrations is based on the following fact:
Under any given set of meteorological conditions, the ground
level concentrations of a gaseous pollutant emitted at a
constant rate into the atmosphere will become smaller as the
effective height of emission of the pollutant into the air
is increased (ref. 1).
While tall stacks can be effective in the maintenance of acceptable
air quality on a localized basis in an AQMA, they do distribute
emissions over larger areas. If air quality maintenance is also a
problem in some of these more distant areas, emissions from tall stacks
add to the existing pollutant burden in these areas.
Tall stacks are sometimes divided into two categories in evalu-
ating their effectiveness in air quality improvement—stack heights
based on good engineering practice and those higher than judged to be
good engineering practice. "Good engineering practice" requires that
D-17
-------
DocScan Pro free trial
stacks be high enough to prevent the plume from being engulfed in
wakes, eddies, and aerodynamic downwash associated with the facility,
nearby structures, and terrain features; and high enough to prevent
short-term NAAQS from being exceeded (as a result of the single source)
during periods of neutral stability and high wind speeds.
Stack heights associated with good engineering practice could be
ensured by specifying minimum stack heights in the emission regulations
for different types and sizes of sources. Stack heights beyond those
considered to be good engineering practice are not recommended as a
maintenance measure in AQMA's.
R. CONTROL OF FUGITIVE DUST SOURCES
Construction activity is the most significant fugitive dust source
in most AQMA's. The primary construction sources are highway, resi-
dential, commercial, and industrial construction projects. In addition,
fugitive dust emissions from unpaved roads and agricultural activities
indigenous to the arid and semi arid areas of the Great Plains, Far
West, and Southwest can have a considerable effect on the air quality
of AQMA's in these regions. Total suspended particulates is the only
pollutant resulting from fugitive dust sources.
Several methods have been employed to reduce the dust emissions
from construction sites, including those listed below. Expected
average control efficiencies are shown in parentheses.
Watering (50%)
Chemical stabilization of completed cuts and fills (80%)
Treatment of temporary access and haul roads on or adjacent to
site (50%)
Minimal exposure periods for active construction areas
(50%)
While these measures have relatively low control efficiencies compared
to other particulate controls, they are proven techniques that can be
enforced as regulatory requirements. Rigorous control of construction
activities and other fugitive dust sources provide emission reductions
from a source category that is presently regulated through nuisance
D-18
-------
DocScan Pro free trial
provisions. Hence, it can be considered as a maintenance measure.
Most of the techniques to reduce air pollution in highway con-
struction or building construction could be implemented by additional
provisions to construction specifications and building codes or by air
pollution control regulations. Several agencies have passed regula-
tions requiring permits to construct on a site. In order to obtain and
keep a permit, the contractor must have an approved plan to control
dust. This is an enforcement aid, because the permit can be revoked
if a dust problem is observed on the site.
REFERENCES
1. National Air Pollution Control Administration. Tall Stacks, Various
Atmospheric Phenomena, and Related Aspects.Pub!. APTD 69-12
Arlington, Va., May 1969.
D-19
-------
DocScan Pro free trial
-------
DocScan Pro free trial
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
REPORT NO
EPA-410/4-74-002
3. RECIPIENT'S ACCESSION-NO.
TITLE AND SUBTITLE
Guidelines for Air Quality Maintenance Planning and
Analysis, Volume 2, Plan Preparation
5. REPORT DATE
July 1974
6. PERFORMING ORGANIZATION CODE
AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
PERFORMING ORGANIZATION NAME AND ADDRESS
Environmental Studies Center
Research Triangle Institute
P. 0. Box 12194
Research Triangle Park, N. C. 27709
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-1386
Task No. 1
2. SPONSORING AGENCY NAME AND ADDRESS
U. S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, N. C. 27711
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
5. SUPPLEMENTARY NOTES
Part of a 12 volume series.
6. ABSTRACT
This report describes the procedures to be followed and analytical methods
to be employed in developing an Air Quality Maintenance Plan (AQMP) for those
areas that have been identified as having the potential of exceeding the National
Ambient Air Quality Standards (NAAQS), because of present air quality or projected
growth, over the 10-year period, 1975-1985. Procedures are described for
projecting air quality through 1985, estimating associated air quality, and
identifying and quantifying any potential air quality maintenance problem. Using
this analysis as a base, procedures for developing alternative maintenance
strategies and selecting a feasible strategy for the AQMA are presented.
Methods of evaluating social and economic impact of maintenance strategies are
included in the document. Content and format of an acceptable AQMP are included
along with suggested intergovernmental cooperation arrangements and a suggested
time schedule for development and submission of the AQMP by June 18, 1975 as
required in 40 CFR 51.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
COSATI Field/Group
Local Governments
State Governments
Regional Planning
Urban Planning
Land Use Zoning
Atmosphere Contamination Control
Air Pollution
Air Quality Maintenance
Plans
Intergovernmental Cooper-
ation for Air Quality
Maintenance
[3-B
13. DISTRIBUTION STATEMENT
Unlimited
19 SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
162
20 SECURITY CLASS (This page)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
E-l
-------
|