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                                                     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

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               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

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       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.
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                                             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

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                      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

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                                           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.

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                                               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

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                                           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.
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                    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
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                                       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

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                     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
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                  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

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                       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

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                      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
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                    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
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                     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
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                 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:
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                               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
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                 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.
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                                  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.
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                 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
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                       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.
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                        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
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                      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
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                  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
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                      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
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                     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
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                    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.
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                    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.
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                                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
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                    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

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                       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.
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                             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).

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                                 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.
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                        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;
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                                 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

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                              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
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           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.

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                            Figure II-1.   Checklist for agencies involved  in  preparation
                                       and implementation of AQMP--Continued.

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                                                                        CHECKLIST 2


                                                                 AGENCY REQUIREMENT  CHECKLIST

                                            To Be Filled Out for Each Agency, Governmental Body, or Other Group Involved

                                                            in AQHP Preparation and Implementation
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                                                    Figure  II-2.   Agency  requirement  checklist.

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                        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.
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                                                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.
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                           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.
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                        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
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                       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
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                   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.
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                                        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.
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                             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
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                       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.
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                   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
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                       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,
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                                                  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

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              Table IV-1.   Calculation  sheet,  quantification  of  maintenance  strategy requirement
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    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

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                               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.
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                             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
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                     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,
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                   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
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                                             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.

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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

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                   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

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 Table  M-2.    Interrelationships  among  maintenance  measures

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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,

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                    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

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                     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

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                      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
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                      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

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                    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
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                       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

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                   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

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                                 Table  V-3.   Maintenance strategy cost  elements  and data  sources
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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

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8 Facility and system design City/County Enq
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Publ ic Agency Costs

to strategy

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16 Qualification and certification of facilities
Air Pollution Off
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                     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,
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                                              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



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                                 *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

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                  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

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                                             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.
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                                          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

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                      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
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                           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

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                       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

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                       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

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                                            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

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                                                                                                                       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.

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                       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

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                          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

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                            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

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                                                          VI-12

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                                           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

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                   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

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                    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

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                   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.
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                   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.

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                   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.


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                    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.
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                   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.~


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                              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
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                       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.
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                                      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
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                   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,
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                      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:
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                         •  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
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                    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
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                    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.
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                                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
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                                           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).

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                     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.
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                         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,
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                    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.
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                         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).
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                          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.
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                         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
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                      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.
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                    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.
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                           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.
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                        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.
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                            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
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                   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.
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                                     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
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                   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

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                                    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

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                   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

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                     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

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                                                            A-26

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                                       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

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                        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

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                                   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

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                  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-

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     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

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                                   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
--

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                    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

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                                        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

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                                  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

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                              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

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                    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

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                       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
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                     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
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                  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).
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                        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.
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                             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.

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                           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
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                                     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
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                  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.
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                         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
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                   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
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                      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
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                    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-
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                      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
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                   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;
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                          •  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
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                    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.
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                          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.
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                    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
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                     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.
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                       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
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                     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-
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                  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
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                     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
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                    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
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                      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.
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                                             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

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