EPA-450/2-74-016
AN OVERVIEW OF ACTIVITIES
DIRECTED TOWARD
LONG-TERM MAINTENANCE
OF AIR QUALITY STANDARDS
by
John J. Silvasi and Joseph J. Sableski
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
November 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, for a fee, from the
National Technical Information Service, 5285 Port Royal Road, Springfield,
Virginia 22161.
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TABLE OF CONTENTS
BACKGROUND INFORMATION 1
LEGAL REQUIREMENTS 4
Long-Term Air Quality Maintenance 4
Review of Indirect Sources 5
EPA GUIDANCE AND ASSISTANCE 6
AQMA Designation 7
AQMA Analysis 8
10-year Plan Development 9
Review of Indirect Sources 10
Other Relevant Guidelines 10
Air Quality Monitoring Guidelines 10
New Source Evaluation Guidelines 10
Contractual Assistance 11
Example Analyses and Plans 11
Direct Technical Assistance 11
Timetable 12
CONSEQUENCES OF AIR QUALITY MAINTENANCE PROGRAM 12
Control Measures which May be Employed 15
Methods to Control Emissions 17
Methods to Control Activities which Produce Emissions . . 19
Scheduling of Implementation 20
Intergovernmental Coordination 20
Air Quality and Other Functional Relationships 20
Government Agencies 23
Coordination 24
Public Participation 26
Participation from Special Interest Groups 26
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AN OVERVIEW OF ACTIVITIES DIRECTED
TOWARD LONG-TERM MAINTENANCE OF
AIR QUALITY STANDARDS
BACKGROUND INFORMATION
Pursuant to the Clean Air Act, States were required to submit to
the Environmental Protection Agency (EPA) in January 1972 implementa-
tion plans to attain and maintain national ambient air quality standards.
For EPA approval, the plans had to contain, among other provisions, a
demonstration that (1) the primary standards would be attained by June
1975, unless an extension of up to 2 years was granted, (2) the secondary
standards would be attained within an unspecified "reasonable time," and
(3) the standards would be maintained if they were already presently
being achieved or after they were attained. EPA's specific requirements
for the plan form and content appeared in the Federal Register of Novem-
ber 25, 1971, as 40 CFR Part 51. The regulations required that the con-
trol strategy for those areas whose air quality concentrations exceeded
the standards provide for sufficient emission reduction for maintenance
of standards "...including the degree of emission reduction necessary
to offset emission increases that can reasonably be expected to result
from projected growth of population, industrial activity, motor vehicle
traffic, or other factors that may cause or contribute to increased
emissions." £40 CFR 51.12(a)J. For areas whose air quality concentra-
tions were already below a secondary air quality standard, the plan's
control strategy had to be "...adequate to prevent such ambient pollu-
tion levels from exceeding such secondary standard." [40 CFR 51.12(b)].
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EPA published initial approvals and disapprovals of State imple-
mentation plans (SIPs) in the Federal Register of May 31, 1972, as
40 CFR Part 52. In the preamble to the notice, EPA stated that main-
tenance of air quality standards would be accomplished through new
and modified stationary source review procedures, new source perfor-
mance standards, and the Federal Motor Vehicle Emission Control Pro-
gram; also, at any time that EPA finds that a plan is inadequate to
maintain standards, EPA would call for a plan revision.
On January 31, 1973, the U. S. Court of Appeals for the District
of Columbia Circuit decided the case of Natural Resources Defense
Council, Inc. (NRDC), et al. v. Environmental Protection Agency. The
Court's order required EPA to review the air quality maintenance pro-
visions of all SIPs and to disapprove plans "...which do not provide
for measures necessary to insure the maintenance of the primary stand-
ard after May 31, 1975, and those plans which do not analyze the
problem of maintenance of standards on a manner consistent with appli-
cable regulations...." As a result, EPA again reviewed the SIPs.
Most plans had adequately provided for review of new and modified
stationary sources; for those plans which did not have such provisions,
EPA either had promulgated, or would promulgate, such provisions.
However, most plans had considered growth only over the period from
plan development to the date of projected attainment of the primary
standards (1975 or 1977). A few SIPs considered growth for a longer
time period, but none considered growth beyond approximately 1980.
Those few that did consider growth beyond the date of attainment did
not consider all pollutants or all areas of the State, nor did they
provide a mechanism for periodically updating the analysis. Furthermore,
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none of the SIPs adequately provided for review of facilities which,
though they themselves did not emit pollutants, caused activity (mobile
source traffic, increases in electric power generation, and others)
which resulted in emissions; these facilities were termed "complex" or
"indirect" sources. Consequently, on March 8, 1973, EPA disapproved
all SIPs for lacking adequate provisions to maintain air quality
standards.
On April 18, 1973, EPA proposed a regulation requiring SIPs to
provide for review prior to construction of indirect sources. This
proposal was directed primarily at preventing high carbon monoxide
concentrations in the vicinity of indirect sources. Such a review
procedure would not be useful for control of broad area problems asso-
ciated with photochemical oxidants nor carbon monoxide. Furthermore,
the reviews could not be applied to every facility to be constructed
since, in addition to working an administrative hardship, such review
is questionable, since techniques for evaluating the air quality impact
of individual small facilities lack precision. Thus a size cutoff
would have to be selected below which new facilities would be exempt
from review. The possibility would still remain, however, that growth
of facilities smaller than the cutoff could collectively contribute to
future violations of ambient air quality standards. As a result of
these considerations, EPA promulgated on June 18, 1973, a regulation
requiring that SIPs contain provisions, not only for indirect source
review, but also for 10-year plans to ensure maintenance of all air
quality standards where necessary. The following section elaborates
on these requirements.
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LEGAL REQUIREMENTS
LONG-TERM AIR QUALITY MAINTENANCE
Pursuant to 40 CFR 51.12(e) through (h), published in the Federal
Register of June 18, 1973, and subsequently revised on May 8, 1974,
(39 FR 16343), all SIPs are required to "...identify those areas (counties,
urbanized areas, standard metropolitan statistical areas, et cetera) which,
due to current air quality and/or projected growth rate, may have the po-
tential for exceeding any national standard within the subsequent 10-year
period." The State must identify these air quality maintenance areas (AQMAs)
to EPA by May 10, 1974. EPA will then review the designations and, after
making necessary additions or deletions, will publish a list of the areas
by November 1974. The States must then perform a thorough analysis of the
air quality impact of growth and development within the areas. If the
analysis shows that an area will not maintain a standard during the 10-
year period, the State must develop a plan for that area to maintain the
standard, together with a demonstration of the effectiveness of the plan.
The State must then submit to EPA the analysis of the area and, when neces-
sary, the 10-year air quality maintenance plan (AQMP) by June 18, 1975.
Then, every 5 years, the States must repeat the entire procedure: identify
new areas which have the potential for violation of standards within 10
years or "dedesignate" areas identified before, analyze the areas to deter-
mine whether a violation will occur, and develop a plan if necessary to
prevent such a violation.
For areas which are not covered by an air quality maintenance plan
pursuant to 40 CFR 51.12(g), the measures taken to ensure maintenance
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of air quality standards include review of new and modified direct and
indirect sources, and modification or prevention of such facilities if they
will result in a violation of air quality standards. If EPA becomes aware
that such an area is experiencing a growth in emissions greater than that
anticipated and which presents the potential for a violation of standards
within 10 years, EPA would identify the area as a potential problem area
pursuant to 40 CFR 51.12(f) and require of the State an analysis and 10-
year maintenance plan if necessary. Furthermore, if such an area actually
violates a standard, EPA would require an immediate plan revision to correct
such a problem.
REVIEW OF INDIRECT SOURCES
Pursuant to 40 CFR 51.18, which was revised in the Federal Register of
June 18, 1973, all SIPs must provide for the pre-construction review of
new and modified sources, both direct and indirect. As originally promul-
gated, this regulation required the review of only new and modified sta-
tionary sources. As a result of the NRDC suit cited above, § 51.18 was re-
vised to include review of new and modified indirect sources. Under the
regulation, the State must determine whether the source would result in a
violation of either the SIP control strategies or an ambient air quality
standard. If such a violation would occur, the State cannot permit the
facility to be constructed in the configuration or at the location proposed.
In amendments to the court order resulting from the NRDC suit, the
court imposed the following timetable on EPA with regard to submitttl of SIP
supplements providing for maintenance of standards:
August 15, 1973 State submission of regulations
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October 15, 1973 EPA approval or disapproval of State
submittals
December 15, 1973 EPA proposal and promulgation of regula-
tions for States with inadequate regula-
tions.
EPA interpreted the court's order that the regulations which the States
were to submit by August 15, 1973, were the indirect source regulations;
two submittals were totally approved and one partially approved. Subsequent-
ly, the court granted EPA two extensions of the December 15, 1973, deadline,
and EPA promulgated final substitute indirect source review regulations on
February 25, 1974, for all States and territories except Florida and Guam
(because Alabama's plan lacked provision for public comment, EPA promulgated
those provisions for Alabama). Since the date of promulgation, several
States have submitted plans which are being reviewed for adequacy. States
can submit their own regulations at any time; if EPA determines that they
are adequate, EPA will approve them and rescind its own promulgation.
EPA GUIDANCE AND ASSISTANCE
To assist the States in complying with the regulations pertaining to
air quality maintenance, EPA intends to issue guidelines for acceptable
techniques of analysis and to provide technical assistance to States. The
following are the titles of guidelines which EPA will issue:
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
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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
Other volumes will be added as necessary; for example, work is progressing
on developing a volume which will describe a methodology for projecting and
allocating emissions on a sub-county basis.
A discussion of the guidelines by subject matter follows.
AQMA DESIGNATION
EPA issued these guidelines on January 11, 1974, as OAQPS Guidelines
Document No. 1.2-016 entitled, Guidelines for Designation of Air Quality
Maintenance Areas. These guidelines present techniques which the States can
use to determine which areas should be designated as AQMAs. The document in-
dicates that, as a minimum, the States must consider the Standard Metropoli-
tan Statistical Areas (SMSAs). The reasons for choosing SMSAs are:
1. SMSAs historically exhibit higher growth rates of population than
non-SMSA areas.
2. SMSAs exhibit higher concentrations of population and industry than
non-SMSA areas.
3. Projections of population and economic activity are available on
an SMSA basis.
4. Areas of SMSAs change with time as population density increases,
facilitating future changes in the designation of AQMAs.
5. SMSAs account for roughly 70 percent of the nation's population but
only about 10 percent of the total land area.
The guidelines document offers a set of "initial designation criteria"
by which the States can identify fairly obvious problem areas and eliminate
from consideration fairly obvious non-problem areas without performing any
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detailed calculations. Those areas which are not in either category must
then undergo a preliminary projection of emissions and air quality to the
year 1985. The guidelines present techniques for performing these rough
projections. If an air quality standard is projected to be violated by
1985, then the area must be designated as an AQMA for that pollutant. In-
cluded with the guidelines to the States were projections of population and
economic activity for each SMSA. The guidelines also address the geogra-
phical areas to be considered, assumptions which must be made concerning
emission and air quality baselines, procedural requirements, and other items.
AQMA ANALYSIS
As required under 40 CFR 51.12(g)(l), States must perform an analysis
of the growth in emissions and their impact on air quality of the designated
AQMAs for the following 10-year period (1975-1985). If the analysis indi-
cates that an area will not be able to maintain standards over that time
period, the State must develop a plan to ensure that the standards will be
maintained. EPA will issue a guidelines document to provide the States with
techniques to perform the AQMA analysis. The following techniques will be-
included in the document:
1. Projection of emissions to 1985, considering
a. Present emissions by source category and, if possible, by
location,
b. Expected growth of each source category based on past and
probable future trends,
c. Present and probable future emission restrictions on new and
existing sources.
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2. Allocation of the 1985 projected emissions to the area in both a
most probable manner and a manner which would be indicative of the
least desirable air quality, given the current zoning (to be sure
that air quality concentrations are not underestimated).
3. Estimation of 1985 air quality concentrations from the projected
emission distributions through the use of atmospheric dispersion
models .
EPA has scheduled the issuance of these guidelines for August through
October 1974.
10-YEAR PLAN DEVELOPMENT
By August 1974 EPA will issue guidelines to States on the preparation
and submittal of 10-year air quality maintenance plans. These plans, which
the States must submit to EPA by June 1975, will pertain only to those AQMAs
which are determined by analysis to present a problem in maintaining stan-
dards. The guidelines will cover four subject areas:
1. Mechanics of preparing and implementing the plan. Topics will
range from plan format to procedures for categorizing emission
sources.
2. Evaluation of the air quality implications of local land use and
transportation plans.
3. Maintenance strategies. This portion will discuss such measures
as emission allocation, transportation controls, and fuel and
energy conservation methods, and will present procedures to esti-
mate quantitatively their impact on air quality.
4. Coordination of air quality maintenance plans with other environ-
mental planning activities. These activities include water quality
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planning and the review of environmental impact statements.
REVIEW OF INDIRECT SOURCES
The guidelines will contain methods for estimating emissions from
seven types of indirect sources: shopping centers, airports, sports com-
plexes, parking facilities, amusement parks, major highways, and recrea-
tional areas. The guidelines will also present methods to relate air
quality with certain traffic parameters such as traffic volume, traffic
demand, roadway capacity and roadway type.
OTHER RELEVANT GUIDELINES
Air Quality Monitoring Guidelines
To aid in the proper selection of air quality data for use in project-
ing air quality and in the improvement of air quality monitoring networks,
EPA will issue guidelines in September 1974 which will discuss the follow-
ing topics:
1. Validation of air quality data.
2. Interpretation of air quality data as it relates to the national
ambient air quality standards.
3. Evaluation and selection of air quality monitoring instruments for
criteria pollutants.
4. Network design and instrument siting.
5. Calculation and evaluation of air quality trends.
6. Evaluation and interpretation of air quality data.
New Source Evaluation Guidelines
These guidelines are being designed for use in evaluating the indivi-
dual impact of new sources once their location and design characteristics
are known. The methodology is expected to incorporate the effects on
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pollutant dispersion of increased turbulence and roughness encountered in
urban areas as well as the impact of multiple sources.
CONTRACTUAL ASSISTANCE
In addition to technical consultation through the Regional Offices,
EPA will offer two kinds of contractual assistance to States concerning
the air quality maintenance program: (1) the performance of example
analyses and development of example plans for selected areas, and (2) direct
contractual aid.
Example Analyses and Plans
Before the guidelines on the development of 10-year plans are distri-
buted to the States in final form, EPA will develop trial air quality main-
tenenace plans for selected areas to obtain a working knowledge of the
maintenance plan development process. This work will be done under con-
tract. The purposes of this exercise are:
1. To discover deficiencies in the draft guidelines so that they can
be corrected before the final guidelines are published.
2. To provide an example from which States can pattern the format of
their analyses and plans.
3. To provide through the process of data collection, indications of
the sources of information which could be consulted.
4. To provide the selected areas with a start in collecting data,
performing the analyses, and developing plans.
Direct Technical Assistance
During all three phases of the long-term air quality maintenance pro-
gram (AQMA designation, AQMA analysis, 10-year air quality maintenance
plan development), EPA will provide assistance to States which need it.
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During the analysis and plan development phases, such assistance could include:
1. Consultation on the methods of analysis and plan preparation.
2, Assistance in updating and formulating the State's emission inven-
tory.
3. Assistance in collecting and assembling pertinent demographic,
economic, and developmental projections and other information
needed to project emissions and air quality.
4. Assistance in projecting emissions and air quality.
5. Assistance in analyzing various air quality maintenance strategies
for their effect on air quality in the State.
6. Assistance in preparing 10-year air quality maintenance plans. In
rendering this assistance, specialized contractors may be employed.
TIMETABLE
The overall schedule of events relating to long-term air quality main-
tenance is presented in Figure 1.
CONSEQUENCES OF AIR QUALITY MAINTENANCE PROGRAM
Through the regulations published on June 18, 1973, EPA intends to
enable State and local governments to integrate air quality considerations
into plans for growth and development so that air quality standards will
be maintained. EPA has neither the intention, nor the desire, nor the
capability of assuming control over land use for every area of the country.
Nor does EPA intend for air pollution control agencies to effect the only
control over land use. The maintenance of ambient air quality standards
is EPA's primary objective in this matter. EPA's mandate for maintenance
of standards is also> however, a mandate to employ, where necessary,
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FIGURE 1
ACTIVITY SCHEDULE FOR MAINTENANCE OF
AIR QUALITY STANDARDS
JAN. EPA ISSUES GUIDELINES FOR DESIGNATING AQMAs
MAY STATES SUBMIT AREAS TO BE DESIGNATED AS AQMAs
JUL./AUG. EPA PROPOSES AQMA DESIGNATIONS
1974
SEPT. EPA ISSUES PLAN DEVELOPMENT GUIDELINES TO STATES
AND PROPOSES REGULATIONS ON SAME IN FEDERAL REGISTER;
EPA BRIEFS REGIONAL OFFICES ON GUIDELINES
OCT. EPA PUBLISHES FINAL LIST OF AQMAs
NOV./DEC. EPA PUBLISHES FINAL REGULATIONS ON PLAN DEVELOPMENT
IN FEDERAL REGISTER
FEB. STATES COMPLETE DRAFT OF AQMPs
APRIL STATES ANNOUNCE HEARINGS; MAKE DRAFT PLANS AVAILABLE
MAY STATES HOLD PUBLIC HEARINGS
STATES REVISE PLANS, AS NECESSARY, BASED ON PUBLIC
HEARINGS
JUNE STATES SUBMIT PLANS TO EPA
EPA STARTS PREPARING PLANS FOR STATES THAT DID NOT
SUBMIT PLANS OR SUBMITTED INADEQUATE PLANS
1975
SEPT. EPA PUBLISHES PROPOSED APPROVAL/DISAPPROVAL ACTION
ON AQMPs
OCT. EPA APPROVES/DISAPPROVES AQMPs; PROPOSES PLANS FOR
STATES THAT DID NOT SUBMIT ADEQUATE PLANS
EPA ANNOUNCES HEARINGS ON PLANS FOR STATES THAT DID
NOT SUBMIT PLANS OR SUBMITTED INADEQUATE PLANS
NOV. EPA HOLDS PUBLIC HEARINGS ON PLANS DEVELOPED FOR
STATES THAT DID NOT SUBMIT PLANS OR SUBMITTED
INADEQUATE PLANS
DEC. EPA PROMULGATES PLANS FOR STATES THAT DID NOT SUBMIT
PLANS OR SUBMITTED INADEQUATE PLANS
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techniques which have not been traditionally used in air pollution control
endeavors. As stated in Section 110 of the Clean Air Act, these techniques
specifically include land-use and transportation controls. Thus, the main-
tenance of air quality is only another constraint on emissions and their
distribution which, in turn, constrain, but by no means determine, land
use. Since the primary responsibility for the development of the State
implementation plans rests with the States, and since the submittals re-
quired .by 40 CFR 51.12 are to be a portion of the SIP, the primary respon-
sibility for applying land-use and transportation controls rests with the
States. The States, of course, can delegate responsibility for the entire
plan, or portions thereof, to local agencies or governments, as long as the
States retain ultimate responsibility should the local agencies or govern-
ments later be unwilling or unable to implement the plan. For areas where
a State does not adequately provide for the maintenance of air quality
standards, EPA must, under law, impose measures which would provide for
such maintenance.
There are many techniques for maintaining standards. In the guide-
lines on the development of 10-year air quality maintenance plans, there
are a number of possible alternatives. For example, one possible adminis-
trative mechnism would be to approve a general community development plan
which has been found to provide for maintenance of air quality standards,
and then to approve any specific development consistent with the general
plan (as regards air pollution) after also checking the localized air
quality impact of the proposed new development. The mechanism, of course,
requires a review procedure which will burden the agency which administers
this mechanism, but this scheme permits any agency or organization, public
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or private, to know in advance where development can occur without causing
air pollution problems.
CONTROL MEASURES WHICH MAY BE EMPLOYED
EPA's guidelines on the development of 10-year air quality maintenance
plans will discuss a number of control measures which States can employ in
their plans.
Depending on the nature and magnitude of the problems in maintaining
standards, the analysis of an area and the plan to provide for maintenance
will vary in complexity from location to location. If the analysis shows
that one particular area may not violate the standards until, perhaps, 1983,
that area's plan may call for only minimal additional control measures until,
perhaps, 1981 or 1982. On the other hand, another area may be more populous
and be experiencing more growth than the first area. The analysis of such
an area may be more difficult to perform since the distribution of emissions
may be more complicated, and the application of the projection technique to
these emissions will further compound the difficulty. Furthermore, this
area's plan may well have to contain a majority of the control measures men-
tioned below, and the area may have to start implementing some of those
measures immediately or in the very near future.
The type of violation of air standards which is projected may demand
a particular approach to a solution. For instance, if the projected vio-
lation is expected at a few "hot spots" caused by the projected expansion
of a few sources, then the strategy may concentrate on controlling the
emissions from or the expansion of those few sources. The new source
review procedure is expected to prevent the construction or modification
of significant stationary emission sources in such "hot spots." On the
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other hand, if the projected air quality standard violation is not restricted
to limited locations, but prevails, throughout an area, then the strategy
would have to provide for either a general tightening of existing regulations,
or control of growth which induces new emissions, or both.
Also, the type of pollutant may determine the type of strategy to be
employed. For instance, there may be relatively few areas designated as
AQMAs for carbon monoxide because significant reductions in carbon monoxide
emissions are expected through the Federal Motor Vehicle Emission Control
Program and new source performance standards for stationary sources. The
areas that are designated for CO, however, may require additional transpor-
tation control strategies to eliminate traffic congestion which would lead
to local high CO concentrations, With regard to particulate matter and
sulfur dioxide, the measures taken to maintain standards may entail further
control of emissions from area source fuel combustion or control over the
growth of such sources. Such measures will be difficult to implement.
Photochemical oxidants have already presented a significant problem in the
development of attainment strategies for some areas. Strategies to main-
tain the oxidant standard would have to provide further reductions in
mobile source emissions, at least until the Federal Motor Vehicle Emission
Control Program's effect on hydrocarbon reduction becomes more significant.
The oxidant strategy may also require additional control over stationary
hydrocarbon sources. With regard to nitrogen dioxide, the few areas which
appear to present a problem will probably have to curtail stationary as
well as mobile source emissions to a greater extent.
The guidelines document will discuss methods used to control emissions
and methods used to control activities which produce emissions. These
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methods are listed and briefly defined below:
Methods to Control Emissions
1. Emission density zoning, a regulatory system in which the maximum
legal rate of emissions of air pollutants from any given land area
is related to the size of the area. Such a system employs an
emission limitation in terms of mass of emissions per unit area
per unit of time. The area of consideration can be the property
of the source, a predetermined area of a region, or a "floating
radius" in which the source cannot exceed the emission density
limit of the area within a certain distance from the source.
2. Emission allocations, a regulatory system in which the total
tolerable emissions for an entire region are determined, and the
maximum allowable rate of emissions of air pollutants from any
given political jurisdiction or other sub-area is assigned through
a democratic process. Suitable procedures are provided to ensure
that allowable emissions are not exceeded for any sub-area.
3. Transportation controls, including measures discussed in the pre-
amble to State implementation plan transportation controls
published in the Federal Register on November 6, 1973. These
measures are designed to increase the attraction of various forms
of mass transit and to discourage the low-occupancy use of auto-
mobiles. Such measures include: on-street and off-street parking
reductions, regulatory parking fees for mass transit augmentation,
vehicle-free zones, bus and carpool programs stressing preferential
treatment (such as free parking), bikeways and heavy-duty vehicle
restrictions.
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4. A procedure for ensuring that proposed new or modified buildings,
structures, facilities, or installations, including municipal
waste-water-treatment facilities, will not lead to a development
pattern in which air quality standards would be exceeded. Such a
procedure would entail a review of projected development induced by
the facilities, the vehicle trips induced by the construction of
such facilities, and the increase in load on electrical generation
and solid waste disposal facilities.
5. Fuel and energy conservation measures. These would include measures
such as revision of building codes to reduce thermal loss, reduc-
tion of heating and cooling requirements, greater use of multiple-
family structures, revised scheduling of industrial activities,
vehicle use restraints, and fuel consumption restrictions on new
vehicles.
6. District heating, a more efficient heating method than individual
unit heating. For instance, the waste heat from an electric power
generation station (which can account for 60 percent of the heat
in the fuel used) could be piped to industrial, commercial, and
residential buildings for space heating or for process heat.
7. Regulatory and other types of strategies to guide the development
of area, point, and line sources, including regulations for zon-
ing, subdivisions, location of water treatment facilities, capital
improvement programming, open space reservations, and use of
schemes such as green belts, satellite cities, and finger develop-
ments.
8. More restrictive emission controls for both stationary and mobile
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sources and new source performance standards.
9. Application of emission charges, which would provide an incentive
to control emissions for the sake of economy. Such a system could
have a variable rate structure to inhibit sources from locating in
areas at or slightly below the air quality standard concentrations.
10. Tighter control over construction activities, including grading and
burning, road dust, erosion of soil onto roads, truck terminal dust,
etc.
11. Any other pertinent strategies which are found to be necessary and
applicable, including all gas or all electric heating.
Methods to Control Activities which Produce Emissions
An AQMA or localities within an AQMA may have plans for transportation,
land use, waste water treatment, solid waste disposal, and other functions.
These plans would be analyzed for their impact on air quality. This
analysis may indicate that one or more plans will not ensure the maintenance
of ambient air quality standards. These plans would have to be revised so
that air quality standards would not be violated. Where an area's plans are
compatible with air quality, legal mechanism would then be employed to ensure
that any new development would occur in accordance with the plan. This
approach would be an ideal one since, once the analysis of air quality im-
pact indicates that a plan ensures the maintenance of air quality standards,
no further analysis of impact of individual facilities is needed if the
facilities are built in accordance with the plan (some new facilities would,
of course, still have to undergo stationary and indirect source review where
appropriate). This approach, however, is long-range and would probably not
be available for immediate implementation. Prior to its implementation,
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short- and medium-range approaches, such as those mentioned above, would have
to be applied.
SCHEDULING OF IMPLEMENTATION
EPA will accept several forms of scheduling the implementation of control
measures. The following are examples of such implementation scheduling:
1. Progressive phased action, a scheme by which the State institutes
a number of measures but implements them one or a few at a time as
necessary. Thus, as air quality concentrations approach some pre-
determined level (below the standard, of course), the first measure
or set of measures is implemented; as subsequent growth in emissions
occurs and concentrations once again approach the predetermined
level, the next measure or set of measures is implemented. The
process is continued for as long as necessary. This scheme assumes
that the State has the legal authority to implement the measures.
2. Future-effective-date laws, a scheme whereby the State schedules
for the future various control measures and the acquisition of the
necessary legal authority to implement them.
3. Area-by-area application, whereby the State schedules control measures
for different areas of a single AQMA at different times if the situa-
tion warrants such scheduling. For instance, for two areas of an
AQMA whose emissions are growing at different rates, the State may
institute a given set of control measures for the faster-growing
area on an earlier schedule than for the slower-growing area.
INTERGOVERNMENTAL COORDINATION
Air Quality and Other Functional Relationships
As discussed above, an approach which may be included in the air quality
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maintenance plan calls for the development of plans for transportation, land
use, waste water treatment, open space,..and solid waste disposal which are
consistent with air quality standards. This approach requires a knowledge
of the relationships between air quality and these functions. Examples of
such relationships are discussed below.
Air Quality and Transportation - A planned transportation system which results
in additional usage of individual mobile sources will increase emissions over
a situation where no such result occurs. Conversely, a transportation system
which causes a decrease in the use of mobile sources will effect a consequent
decrease in emissions. Such relationships must be tempered by consideration
of several factors such as the effects of speed and the Federal Motor Vehicle
Emission Control Program on emissions and the spatial arrangement of the
transportation system. Section 109(j) guidelines which implement section
136(b) of the Federal Aid Highway Act of 1970 require that the cognizant air
pollution control agency certify that the transportation plan for each ur-
banized area of over 50,000 population is consistent with the State imple-
mentation plan for clean air.
Air Quality and Land Use - A land use plan for an area describes a projected
or desired pattern of locations of various activities in the area. The
manner in which the land is used has an impact on air quality. Population
density, for instance, affects emission density. If an urban area has a
low population density, it would not be economical to have an extensive mass
transit system since the population would be dispersed. Because people
would have to rely on automobiles for transportation, a greater amount of
emissions would probably result than for an area •/nth tne same population, oul
wnose population density and reliance on mass transit were greater. Also, tne
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spatial distribution of open spaces would affect air quality concentrations.
In the development of land use plans, therefore, the region would have to
consider alternative population densities, spatial arrangements, and other
factors which would minimize air quality impact.
Air Quality and Waste Water Treatment - Waste water treatment can affect air
quality either directly or indirectly. Incineration of treatment plant sludge
can result in direct emissions; construction or extension of treatment facili-
ties can stimulate industrial, commercial, and residential growth which, in
turn, may result in an increase of emissions from stationary sources themselves
or from increased mobile source use. Section 208 of the Federal Water Pollu-
tion Control Act Amendments of 1972 requires that areawide waste management
planning consider possible impacts of facilities on air quality.
Air Quality and Open Space - Because of the roughness over urban areas due to
the concentration of buildings, wind speeds over urban areas are generally
less than in the surrounding countryside and therefore are not as efficient in
the dispersion of air pollutants. Another phenomenon aggravating the air
quality problem is the "urban heat island" effect, in which the atmosphere
over the urban area is generally warmer than the surrounding countryside due
to the predominance of heat-retaining buildings and streets. This heat
island produces air currents which rise over the center of the city, spread
outward, subside at the edge of the urban area, and flow along the ground to-
ward the center and then rise again. Such an air circulation system entrains
pollutants within itself and inhibits their transport away from the urban
area. Both the urban roughness and the heat island effect can be partially
alleviated by the use of lower concentrations of buildings and streets and
more vegetation. Open spaces, such as parks, can be of help in this matter.
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Air Qualityand Solid Haste Disposal - New incinerators which are planned to
dispose of additional solid waste generated or to replace existing outmoded
facilities will have to meet stringent emission requirements so that they
will not violate ambient air quality standards or new source performance
standards.
Government Agencies
Ten-year air quality maintenance plans will affect areas over which
State and local governmental agencies other than air pollution control agen-
cies have jurisdiction. To avoid any conflict over functions, the State
will have to develop its plan with the ongoing assistance and coordination
of these other agencies. Indeed, these agencies will probably play impor-
tant roles in the development and implementation of the air quality mainte-
nance plan. Specific governmental (and quasi-governmental) bodies which
will probably have an interest in maintenance plan development and imple-
mentation include:
1. State level
a. Environmental protection and natural resource agencies.
b. General planning agencies.
c. Economic development agencies.
d. Transportation agencies.
e. Utility commissions.
2. Local level
a. Environmental protection agencies.
b. General planning agencies.
c. General purpose governments.
d. Health departments.
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e. Highway departments.
f. Mass transit authorities.
g. Sanitation departments.
h. Solid waste collection and disposal departments.
i. Parks commissions.
j. Zoning boards.
3. Regional level
a. Planning agencies.
b. Councils of governments.
c. Transportation agencies.
EPA guidelines on the development of the 10-year AQMPs will discuss
possible mechanisms for effecting coordination among the governmental
bodies.
Coordination
To be effective, coordination of air quality maintenance activities
with other environmental protection and comprehensive planning activities
must occur at the regional level. Air quality is.inherently a regional
problem that transcends city-county political boundaries. At this level
there has been a traditional separation of planning and environmental pro-
tection activities. Time constraints on the preparation and submission of
AQMPs preclude, for the most part, significant local agency reorganization.
Therefore, arrangements between existing regional and organizational coopera-
tive agencies will have to be made for air quality maintenance planning.
Existing coordination mechanisms include the A-95 review and the Environ-
mental Impact Statement (EIS) preparation processes. A-95 review refers to
the State and regional review of federally-funded projects through a system
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of clearinghouses. The review process and clearinghouses were established
by Office of Management and Budget's Circular No. A-95, the most recent
edition of which was published in the Federal Register of November 28, 1973
(38 FR 32874). Existing coordinating agencies include councils of govern-
ments (COGs) and regional planning councils (RPCs).
Coordination Mechanisms - Because State air pollution control agencies nor-
mally have Federal program grants and the ultimate responsibility for the
development of the AQMP, there appears to be justification for requiring
that the AQMP be coordinated through the A-95 review system. Agencies involved
with the A-95 clearinghouses should be involved early in the development of
the AQMP to ensure the identification and resolution of problem areas prior
to the formal processing of the AQMP through the A-95 system.
The procedures used for review of environmental impact statements can
also be used for the coordination of the AQMP. Subject to the specific legal
requirements of the State, the EIS process may also be required for private
activities. Such a requirement would provide a valuable tool for the agency
implementing the AQMP in that it will permit early review of private projects
to determine their compatibility with the AQMP and their impact on air
quality.
Coordinating Agencies - COGs and RPCs, which represent an approach by city and
county governments to resolve regional problems, have inherent limitations
that must be considered prior to using these agencies for coordination of
air quality maintenance activities. These limitation are:1
1. In most cases, a lack of an air quality element in the existing
structures.
2. Input to the A-95 review process occurs late in the planning cycle.
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3. COGs and RPCs are primarily designed to serve in an advisory capa-
city or as a forum for communications.
4. Participation of city and county governments is voluntary.
Coordination Framework Alternatives - Two types of arrangements seem to present
the essential coordination framework alternatives. The first of these would
incorporate air quality objectives in a basic comprehensive planning agency;
the second would authorize a single-purpose air quality agency to review and
evaluate land use and transportation plans submitted by local governments in
its jurisdiction. EPA's guidelines will discuss these concepts and present
advantages and disadvantages of each.
PUBLIC PARTICIPATION
As required under the Clean Air Act, the State must subject its im-
plementation plan to public hearing before submitting it to EPA. Since the
plan will ultimately affect the general public by possibly influencing the
manner in which communities develop and grow, it is necessary to determine
community purposes and goals in order to establish acceptable objectives
and programs. So that the public may have a thorough knowledge of the im-
pact of the plan in order to participate effectively in the decision-making
process, the State should disseminate information as widely as possible in
the areas to be affected. In addition to the minimum public hearing and
plan availability regulations of 40 CFR 51.4, the State should attempt to
sponsor open forums on the plan by means of the various communication media.
PARTICIPATION FROM SPECIAL INTEREST GROUPS
In addition to coordination among governmental agencies and the soli-
citation of public participation, the State should attempt to obtain and
consider the legitimate concerns of various special interest groups which
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may be affected by an air quality maintenance plan. Such groups include,
on one hand, chambers of commerce, electric utility companies, natural gas
suppliers, and the like, and, on the other hand, environmental, consumers',
and other public organizations. Such consultation may serve to avert later
confrontation with these same organizations.
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1 REPORT NO.
EPA--450/2-74-016
3. RECIPIENT'S ACCESSION-NO.
4. TITLE ANDSUBTITLE
AN OVERVIEW OF ACTIVITIES DIRECTED TOWARD LONG-TERM
MAINTENANCE OF AIR QUALITY STANDARDS
5. REPORT DATE
November 1974
6. PERFORMING ORGANIZATION CODE
7 AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
John J. Silvasi and Joseph J. Sableski
9. PERFORMING ORGANIZATION NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. 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, NC 27711
13. TYPE OF REPORT AND PERIOD COVERED
FINAL
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The report describes the Environmental Protection Agency's program concerning
long-term maintenance of the national ambient air quality standards.
Background information describes the historical development of and the
rationale for the program. The report presents the legal requirements for
States and discusses EPA's guidance and assistance available to States.
The consequences of the program include the application of various kinds
of measures, consideration of the scheduling of the measures, and the need
for intergovernmental coordination, public participation, and participation
from special interest groups.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
quality maintenance area
quality maintenance plan
ional ambient air quality
standards
te implementation plan
an Air Act
c. COSATI Field/Group
Air pollution
Atmosphere contamination control
Urban planning
Regional planning
Air
Na1
Stc
Cld
13-8
13 DISTRIBUTION STATEMENT
Release unlimited
19. SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
32
20 SECURITY CLASS (This page)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
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