EPA-450/3-74-052
DECEMBER 1974
                  DEVELOPMENT
      OF A TRIAL AIR QUALITY
            MAINTENANCE PLAN
    FOR THE ST. LOUIS AQMSA
    U.S. ENVIRONMENTAL PROTECTION AGENCY
       Office of Air and Waste Management
    Office of Air Quality Planning and Standards
    Research Triangle Park, North Carolina 27711

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                                EPA-450/3-74-052
        DEVELOPMENT
 OF  A  TRIAL AIR QUALITY
    MAINTENANCE  PLAN
FOR  THE ST. LOUIS AQMSA
                 by

        Alan M. Voorhees & Associates
          Westgate Research Park
          McLean, Virginia 22101
          Contract No. 68-02-1388
              1'ask Ordei- 5
       EPA Project Officer: T. Donaldson
              Prepared for

     ENVIRONMENTAL PROTECTION AGENCY
       Office of Air and Waste Management
    Office of Air Quality Planning and Standards
      Research Triangle Park, N. C.  27711

              December 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  22151.                                               ''
This report was furnished to the Environmental Protection Agency by the
Alan M. Voorhees & Associates, McLean, Virginia 22101, in fulfillment of
Contract No.  68-02-1388.  The contents  of this report are reproduced herein
as received from the Alan M. Voorhees & Associates.  The opinions, findings,
and conclusions expressed are those of the author and not necessarily those
of the Environmental Protection Agency. Mention of company or product
names is not  to be considered as an endorsement  by the Environmental
Protection Agency .
                            Publication No. EPA-450/3-74-Q52
                                    11

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                         CONTRACTOR DISCLAIMER

     This report was prepared as a trial to test the applicability of
administrative and technical guidance given in the EPA Guidelines for the
Preparation of Air Quality Maintenance Plans.   The study was prepared
prior to the release of these guidelines and therefore may not reflect
the opinions or policies as stated in the final  form of the guidelines or
40 CFR 51.
     Because this was a demonstration exercise,  rather than an official
plan and time and resources were restricted, it was necessary to make
certain compromises in data collection, analysis, and plan preparation.
In using this report, the reader is cautioned  that some numerical results
need refinement before using for policy or control measure justification.
The States of Illinois and Missouri are in the process of updating and up-
grading their data bases and analyses to provide supporting data for an
official air quality maintenance plan.   In addition, the RAPS program is
expected to provide the most accurate representation of air quality in
the St. Louis area.  Therefore, specific numerical results presented
herein may differ from data included in the official State plans.

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                           ACKNOWLEDGEMENTS


     Many individuals and organizations actively participated in the

preparation of this study effort.   Their assistance is gratefully acknow-

ledged.

     Project direction and guidance were provided by Mr.  Tom Donaldson of

the EPA Standards Implementation Branch, and Mr. Dewayne Durst, EPA

Region VII, Kansas City.

     The following is a list of agencies who provided information and

guidance during the preparation of the trial  plan:

     Federal
          EPA Region VII, Region V
          Interagency Task Force on Air Quality Maintenance

     State Agencies

          Missouri  Department of Natural  Resources
          Missouri  Air Conservation Commission
          Missouri  Department of Highways
          Illinois  Environmental Protection Agency

     Regional  Agencies

          East-West Gateway Coordinating  Council
          Southwest Illinois Metropolitan Area Planning Commission
          Bi-State  Development Agency

     Local  Agencies

          St.  Louis County Air Pollution  Control
          St.  Louis City of Air Pollution Control
          St.  Charles County Planning Commission
          St.  Louis City Planning Commission
          Franklin  County Planning Commission
          St.  Louis County Planning Commission

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                           TABLE OF CONTENTS
Chapter                                                          Page

   I      EXECUTIVE SUMMARY 	       1
            Analysis  	       2
            Maintenance Strategy Development  	       7
            Implementation Recommendations  	       8
            Intergovernmental  Coordination and Cooperation   .      11
            Legal  Authority	      14
            Implementation Obstacles  	      15

  II      INTRODUCTION	      17
            A.  Study Area Background and Description   ....      17
            B.  Report Organization  	      20

  III      AIR QUALITY MAINTENANCE AREA ANALYSIS 	      21
            A.  Existing Air Quality and Monitoring  Networks  .      22
              1. Air Quality Data	      22
              2. The RAPS/RAMS Program	      22
              3. Existing Air  Quality	      24
            B.  Emissions Projections  	      26
              1. Baseline Emissions Inventory 	      27
              2. Methodology for Projecting Emissions  ....      28
              3. Projected Emissions  	      30
            C.  Air Quality Projections	      36
              1. Total Suspended Particulates 	      36
              2. Sulfur Dioxide	      37
              3. Carbon Monoxide	      38
              4. Photochemical  Oxidants 	      43
            D.  Summary and Conclusions of the AQMA  Analyses  .      46
              1. Total Suspended Particulates 	      46
              2. Sulfur Dioxide	      49
              3. Carbon Monoxide	      50
              4. Photochemical  Oxidants 	      51
            E.  Limitations of  Analysis and Recommendation
               for Resolving Deficiencies 	      52
              1. Data Base Problems	      52
              2. Analysis Procedures  	      55

  IV      AIR QUALITY MAINTENANCE STRATEGY DEVELOPMENT  ...      59
            A.  Air Quality Attainment Plans 	      61
              1. Particulates	      61
              2. Sulfur Dioxide	      63
                                   vn

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Table of Contents (continued)

Chapter^
              3. Carbon Monoxide and Photochemical  Oxidants.  .     61
            B. Evaluation of Maintenance Strategy
               Alternatives  	     63
              1. Emission Control Measures 	     64
              2. Administrative Procedures .•	     66
              3. Conclusions	     74
            C. Recommended Attainment/Maintenance Strategy .  .     75
              1. Interim Measures  	     75
              2. Recommended Long-Term Comprehensive
                 Approaches to Air Quality Maintenance ....     83
            D. Timetable for Development and Implementation
               of Air Quality Maintenance	     86
            E. Monitoring and Surveillance 	     89
            F. Constraints to AQMP Implementation	     91
              1. Complexity of Planning Process  	     91
              2. Funding	     93
              3. Enforcement	     93
            G. Legal Authority	     94
              1. Existing Legislation  	     94
              2. Additional Regulations Required to Develop,
                 Implement, or Enforce the Air Quality Mainte-
                 nance Plan for the St. Louis AQMA	     96

          INTERGOVERNMENTAL COOPERATION AND COORDINATION  ...     99
            A. Alternative Institutional Arrangements  ....     99
            B. Constraints to Alternative Institutional
               Arrangements  	    100
              1. Time	    100
              2. Jurisdictional Complexity 	    100
            C. Opportunities for Institutional Cooperation
               and Coordination	    103
              1. Existing Coordinating Mechanisms  	    103
              2. Technical Leadership  	    107
              3. Participation   	    107
            D. Recommended Arrangement for AQMP Development
               and Implementation	    109

          BIBLIOGRAPHY 	   113
                                    vi n

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Table of Contents (continued)

Appendices                                                       Page

   A      Method for Distributing Projected Emissions

B
C
n
E
of Particulates and S02 	
Subcorridor Emission Analysis for CO and HC . . . .
St. Louis AQMA Emission Projections for SO
and TSP from Highway Sources 	
Growth Patterns in the St. Louis AQMSA 	
Total Suspended Particulates -- Emission Density
vs. Annual Concentrations 	
A-l
B-l
C-l
D-l
E-l
          Supporting Calculations for Sulfur Dioxide
          Concentrations by Source Category 	     F-l

          Percent Emission Change for Carbon Monoxide in
          Subcorridors Influencing Nine Receptors in the AQMA     G-l

          Appendix J Federal Register 40CFR51 	     H-l

          Missouri Regulations Directly Related to Air
          Quality Maintenance 	     1-1
                                   IX

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                            LIST OF FIGURES
Figure                                                          Page
  1-1     St.  Louis AQMA Emissions Projections   	      3
  1-2     Areas Projected to Exceed TSP,  S02, CO,  and
          Oxidant Standard in 1975 and 1985 in  the
          St.  Louis AQMA	      4
 II-l     St.  Louis Air Quality Maintenance Area	     19
III-l     Regional Air Pollution Study  	     25
III-2     St.  Louis AQMA Emission Projections Total  Suspended
          Particulates, Tons Per Year	     32
III-3     St.  Louis AQMA Emission Projections Sulfur Oxides,
          Tons Per Year	     33
III-4     St.  Louis AQMA Emission Projections Carbon
          Monoxide, Tons Per Year	     34
III-5     St.  Louis AQMA Emission Projections Hydrocarbons,
          Tons Per Year	     35
111-6     1975 Total  Suspended Particulates—Air Quality
          Concentrations  	     39
III-7     1980 Total  Suspended Particulates—Air Quality
          Concentrations  	    40
III-8     1985 Total  Suspended Particulates—Air Quality
          Concentrations  	    41
III-9     S02  Point and Area Locations for  Air  Quality
          Analysis	     44
111-10    CO Receptor Locations for Air Quality Analysis   .  .    47
 IV-1     St.  Louis AQMP Development Timetable	     88
  V-l     Existing AQMA Responsibilities	    101
  V-2     East-West Gateway  Coordinating  Council   	    104
  V-3     MACC Advisory Committee on Transportation
          Control  Plan (TCP)   	    106
  V-4     St.  Louis AQMP Development and  Coordination  ....    110
                                   XI

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                           LIST OF TABLES






Table                                                          Page




 1-1     Overview of Pollutants:  Findings and
1-2
1-3
III-l
III-2
III-3
III-4
III-5
IV-1
Proposed Attainment/Maintenance Strategy 	
St. Louis AQMP Development and Coordination ....
Comparison of Existing Air Quality Data to
Air Quality Standards 	
St. Louis Air Quality Maintenance Area Emission
Projection — Summary 	
Sulfur Dioxide Air Quality Projections 	
Carbon Monoxide Air Quality Projections 	
Photochemical Oxidants Air Quality Projections . .
Proposed Attainment/Maintenance Strateqv 	
9
13
??
31
4?
45
48
76

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                         I.  EXECUTIVE SUMMARY
     This report summarizes the results of a 20-week project to develop a
Trial Air Quality Maintenance Plan (AQMP) for the St. Louis Air Quality
Maintenance Area (AQMA).  Similar studies were prepared for Baltimore,
Denver, and San Diego.  The primary objectives of this study were to:
     •    Prepare a Trial  Air Quality Maintenance Plan for the St.  Louis
          Interstate AQMA.
     t    Critique the EPA Guidelines for the Preparation of Air Quality
          Maintenance Plans

     St.  Louis was selected for study as an example of an interstate Air
Quality Maintenance Area (AQMA).   The states of Missouri  and Illinois
designated the seven counties and St. Louis City which comprise the
Standard  Metropolitan Statistical Area (SMSA) as an AQMA.  The concentra-
tion of diverse industrial process sources, transportation, and commercial
activity  along the river channels provides the potential  for particulates
(TSP), sulfur dioxide (S02), carbon monoxide (CO), and photochemical
oxidants  (0 ) air quality attainment and maintenance problems.
           X
     The  trial AQMP was developed as follows:
     •    Perform a detailed analysis of existing and projected emissions
          and air quality
     t    Select and evaluate a Maintenance Strategy
     •    Determine the intergovernmental cooperation and coordination
          necessary to implement the AQMP

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ANALYSIS


     A detailed analysis of TSP, S02» CO, and oxidants was performed to

confirm the conclusions of the initial  designation and to provide data to

determine the most effective air quality maintenance strategy for each

pollutant.  The analysis included a review of existing air quality,

calculation of baseline and projected emissions for 1975, 1980,  and 1985,
and calculation of projected air quality for 1975, 1980, and 1985.   The

significant findings from each of these analyses are summarized  in

Figures 1-1 and 1-2 and are as follows for the four pollutants evaluated:

     •    Existing Air Quality

               TSP air quality in 1971 and 1972 exceeds the standards at
               several of the eleven monitoring stations in the  AQMA.
               The majority of sites in Missouri record concentrations
               at or below the primary standard.  However, stations are
               identified in St. Louis City, St. Louis County, and the
               East St. Louis area where concentrations are 50 to 75 per-
               cent over the primary standards.  These sites appear to be
               influenced by major point sources or clusters of sources
               in the immediate vicinity.

               S02 air quality in Missouri is currently at or better than
               the annual standards.  However, Illinois reports  several
               site concentrations exceeding the primary standards for
               24-hour measurements.  These sites appear to be influenced
               by major point sources.

               CO values for 8-hour periods were recorded in 1972 that
               were almost twice the 8-hour standard.  Urban "hotspots"
               associated with mobile sources have been identified.

               Oxidant concentrations also exceed the standards  and
               appear to be increasing

     •    Emissions Projections

               TSP areawide total emissions are projected to increase
               through 1985.  Major increases are attributable to point
               sources and are expected to occur in the vicinity of
               existing "hotspots."

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                              FIGURE 1-1
                            ST. LOUIS AQMA
                EMISSIONS PROJECTIONS  (Tons/Year X  103)
160-
140-
120-
100-
80-
60-
40-
20-

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        1975   1980    1985
    Total  Suspended Particulates
                                           1200-
                                           1000-
                                            800-
                                            600-
                                            400-
                                            200-
                           1975   1980   1985
                             Sulfur Oxides
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500-1
400-
300-
200-
100-
        1975   1980   1985
         Carbon Monoxide
                   180-

                   160-

                   140-

                   120-

                   100-

                    80-

                    60-

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                    20-
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               |Mobile
               I Point
                           1975   1980   1985
                             Hydrocarbons
Emissions at Primary Standard
   Source Type
              1 Power Plant
           PHI Area (Non-Mobile)

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                                FIGURE  1-2
    AREAS PROJECTED  TO EXCEED TSP,  S02,  CO AND OXIDANT STANDARD
                IN 1975 AND  1985  IN THE  ST. LOUIS AQMA
* By 1980 All Areas Below Standard
                                                     PHOTOCHEMICAL OXIDANTS
                                              Region Wide Problem Thru at Least 1985

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               S02 emissions projections reflect significant increases in
               power plant capacity projected to occur through 1985.

               CO areawide totals decrease sharply and continuously
               through 1985 due to the impact of the Federal Motor Vehicle
               Control Program (FMVCP).

               Total HC projected emissions reveal an overall decrease
               through 1985.  Point and area source emissions increase
               gradually, while mobile source emissions decrease signi-
               ficantly.

          Air Quality Projections

               TSP projected concentration distribution pattern shows
               "hot-spots" continuing to exceed the standards through
               1985.  Maximum estimated air quality concentration in the
               "hot-spots" is similar to the 1971 and 1972 maximum values.

               S02 air quality concentrations projected at four major
               power plants and two isolated multi-source areas indicate
               a potential to exceed the standards.  Two of the four
               power plant projections show a potential to exceed the
               standards, depending on short-term operating conditions
               and assumed operating characteristics and controls.  The
               area source calculations appear to be highly dependent
               upon the area size selected and show the potential to
               exceed the standards.

               CO projections at several  selected receptor sites exceed
               the 8-hour standard in 1975.  All  selected receptor sites
               are projected to be below the standards by 1980.

               Oxidant values (regionwide) are projected to decrease.
               However, the 1985 projections still exceed the standard.
     The conclusions from the analysis with regard to attainment and

maintenance of standards for each pollutant are summarized in Table 1-1
as follows:

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     •    An attainment and maintenance strategy is required for the
          identified "hot-spots."   A general approach is required to
          maintain the secondary standards, especially in areas adjacent
          to "hot-spots."

     •    S02 standards are expected to be attained and maintained through-
          out the AQMA with the exception of isolated "hot-spots" in the
          vicinity of major point sources.  A regionwide maintenance
          strategy is not required.   However, measures are required to
          attain and maintain standards in the "hot-spots."

     •    Once the 8-hour CO standard is attained, continued decline in
          mobile source emissions will ensure maintenance through 1985.
          A Transportation Control Plan (TCP) is required and is currently
          being considered to provide for attainment—a long-term main-
          tenance plan is advisable.

     •    The Oxidant standard cannot be attained or maintained with
          existing controls.  A TCP  and maintenance strategy are required.
     Any analysis of projected air quality contains a degree of uncer-

tainty, dependent upon the methodologies and assumptions applied.   In the
preparation of this analysis, many simplifying assumptions were made due

to time and data constraints.  The Federal, state, and local air pollution
agencies are currently working on several  programs to resolve deficiencies
in analysis procedures and data.   The RAPS/RAMS program is intended to

provide the most complete analysis of air pollution in the St.  Louis area
over the next five years.
MAINTENANCE STRATEGY DEVELOPMENT

     Emissions control  and administrative measures  were reviewed  for

inclusion in an Attainment/Maintenance plan.   The conclusions  of  the

review are:

     •    Long-term air quality maintenance requires  a  regionwide,  com-
          prehensive approach associated with the community  planning

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          process.   Two administrative  approaches  appear applicable and
          implementable--Emissions  Allocation  and  Regional  Development
          Planning.
     t    Measures which have long-term general  application and  effective-
          ness as part of a comprehensive  approach include:  Indirect
          Source Review and Environmental  Impact Statements (EIS), Trans-
          portation  Control measures,  indirect regulatory  controls, and
          Federal New Source Performance Standards.
     •    Emission Source Control measures which have  short-term or long-
          term effectiveness in the "hot-spot" areas include:  more
          stringent  controls on existing sources,  phaseout of emission
          sources, and control  of fugitive dust.
     The air quality analysis,  the review of the  status  of  existing
attainment plans, and the review of possible maintenance measures  sup-
ported the selection of a proposed Attainment/Maintenance Plan.  The
proposed plan consists of a strategy for each of  the  four pollutants.
     The selected Attainment/Maintenance strategy for each  pollutant  is
summarized in Table 1-2.   The selected strategy for each pollutant in-
cludes attainment measures (where required), a long-term maintenance
approach, and interim measures  to ensure maintenance  during the  period
required for preparation of the long-term plan.
IMPLEMENTATION RECOMMENDATIONS
     The time constraints of this project and the jurisdictional  com-
plexity of the AQMA did not allow for sufficient interaction with con-
cerned agencies to select and evaluate the most appropriate approach to
long-term air quality maintenance.   However, it is apparent from dis-
cussion with agency representatives that no long-term approach involving
land use and transportation control measures or policies can be prepared
or implemented by June 1975.  Therefore, the following three-phase approach

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is recommended for consideration in the  development of a  long-term com-
prehensive approach to air quality maintenance:*

     •    Phase 1 (ending June 1975)  --  Informal  Regional  Development
          Planning, Implementation of Attainment and Interim Maintenance
          Measures

          A cooperative program between  the planning community and air
          pollution agencies to review and evaluate the impact of the
          currently proposed significant land use and transportation
          projects could be implemented  by June 1975.  The results of the
          evaluation would be used to develop policies to be included in
          the updated regional comprehensive plan to represent air quality
          considerations.  In addition,  the air pollution agencies and
          the regional planning body (the East-West Gateway Coordinating
          Council-EWGCC Advisory Board)  could cooperate to persuade new
          significant sources of TSP and S02 to avoid the "hot-spot"
          areas.   All measures required  for attainment and Interim Main-
          tenance should be included in  the AQMP submitted to EPA in
          June 1975.  All Interim Maintenance Measures should be imple-
          mented and enforced by June 1976.

     t    Phase 2 (ending June 1980) --  Interim Maintenance and Develop-
          ment of Long-Term Approach

          If persuasion fails to obtain  the desired control in the "hot-
          spot" area, the source review  procedure requirements relating
          to "hot-spots" can be strictly enforced as an Interim Mainte-
          nance Measure.  In Missouri, this allows the air pollution
          agencies to impose more stringent regulations on existing
          sources to prevent source clusters from causing the standards
          to be violated.  During this period, the administrative struc-
          ture and technical procedures  required to implement an Emissions
          Allocation-type procedure can  be developed.

     •    Phase 3 (ending June 1985) --  Long-Term Plan Implementation

          The RAPS/RAMS program and the  procedures developed for a regional
          development planning approach  in Phase 1 and 2 should provide
          sufficient basis for either a  formal Emissions Allocation
*Phase 1 and Phase 2 are approximately consistent with Phase 1 of EPA's
 phased approach.  The St. Louis phased approach was developed prior to
 EPA's current policy on planning.
                                     10

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          program where the emissions ceiling is regulated, or an in-
          formal Emissions Allocation procedure where the emissions
          ceiling serves as a guide for regional development planning.
          Existing source review procedures and regulations should be
          strictly enforced to ensure compliance with the air quality
          constraints of the Regional Comprehensive Plan.  All land use
          and transportation policies or control measures required for
          long-term maintenance should be fully implemented and
          enforced.
     It is recommended that the final form of the administrative approach
and technical review procedure be determined by the cooperative efforts
of air pollution agencies and the community (EWGCC Advisory Board) in
order to ensure coordination of air quality and community planning goals
and policies.
INTERGOVERNMENTAL COORDINATION AND COOPERATION
     The Attainment/Maintenance Plan described above includes source
control, and long-term transportation and land use policies or control.
To be successful, however, the AQMP must realize two administrative
objectives.  First, the plan must facilitate the coordination of land
use and transportation planning with source control measures within an
institutional framework which links planning, implementation, and en-
forcement.  Second, the plan must be developed within the constraints
of time, jurisdictional complexity, and funding imposed on the process.
     Four possible alternative arrangements, or institutional forms,
were evaluated to determine the most appropriate mechanisms to meet these
two administrative objectives as follows:
     •    A regional, interstate agency with planning, implementation,
          and enforcement in each source control area
     t    A cooperative arrangement between two state air pollution control
          agencies, each of which had increased functions to include trans-
          portation and land use planning
                                    11

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     •    A Council  of Governments  (i.e.,  EWGCC)  with  all  functions  and
          authority provided
     •    .A combination or composite  of  existing  institutions coordi-
          nating their particular areas  of responsibility  with  the long-
          range goal of creating an institutional  structure(s)  with
          appropriate enabling powers.
     A review of the existing institutional  structure in the  AQMA suggests
that the capability and authority to satisfy these criteria does  not
currently exist in any one agency.   The state air pollution agencies can
implement source control  measures and they may have the authority to
implement transportation and land use controls.   However, if  such programs
should conflict with community land use and  transportation goals  and
policies, they may not be enforceable.
     The conclusions from the evaluation of  the alternatives  and  issues
in the selection of the most appropriate mechanism for coordination of
AQMP development and implementation are as follows:
     t    Plan development and implementation must be phased
     •    Coordination mechanisms and responsibilities may vary with each
          phase to reflect the significant AQMP elements to be planned or
          implemented
     •    Participation and coordination in  AQMP development  and  imple-
          mentation must reflect the existing jurisdictional  framework,
          legal authority, time, and funding constraints.
   w
     The review of existing institutional structure and evaluation of
alternatives and issues in AQMP development  and implementation suggests
the following recommendations for intergovernmental coordination  and
cooperation as summarized in Table 1-3:
     •    AQMP development and implementation should be a cooperative
          effort among state, county, and local agencies and  regional
          planning agencies.
                                    12

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     t    The state air agencies  should have the primary  responsibility
          for AQMP development and implementation through the completion
          of Phase 2 (1980).
     t    The state air pollution control agencies will retain ultimate
          responsibility for implementation and enforcement of the
          Attainment/Maintenance  Plan through the states'  Air Conservation
          Laws.
     •    The East-West Gateway Coordinating Council  is recommended as
          the agency for technical leadership in the  areas of land use
          and transportation and  could eventually be  responsible for
          development, and coordination of the implementation of the
          long-term comprehensive approach.
     •    The East-West Gateway Council Advisory Board should coordinate
          Interstate (Intraregional)  political  and citizen participation
          in AQMP development and implementation.
LEGAL AUTHORITY
     The enabling legislation given in the states'  implementation plans
forms the basis for implementation of the maintenance plan.   This enabling
legislation is sufficient for implementation and enforcement of all
Attainment and interim maintenance source control  measures.   The long-
term comprehensive approaches to maintenance of air quality are primarily
administrative procedures.   They maintain air quality indirectly by the
application of land use and transportation policies which affect the
distribution of emissions.   Specific land use control regulations may be
adopted to formalize the policies inherent in the procedures.  For example,
Emissions Allocation can be implemented by adopting an emissions ceiling
as a regulation.  However, strict enforcement of existing regulations may
be considered sufficient to support a strong program of comprehensive air
quality and community planning.
                                    14

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IMPLEMENTATION OBSTACLES

     The obstacles to implementation of the Attainment or Interim Main-
tenance measures proposed are limited and primarily reflect technical  or
cost-effectiveness constraints.   However, implementation of the long-term
comprehensive strategies has many obstacles including:  administrative
complexity, jurisdictional  complexity, funding, and opposition to enforce-
ment of strong regulations  which resemble land use control.   Of these,
funding for participation in plan development and implementation is the
most immediate problem.   Jurisdictional  complexity may be the most
difficult obstacle to implementation and enforcement of the long-term
plan.  It is recommended that the East-West Gateway Council  be funded  to
participate in initial AQMP development and actively participate in long-
term plan development and implementation.
                                    15

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                           II.  INTRODUCTION

     All states, pursuant to 40 CFR 51.12(e), are required to identify
areas that have the potential to exceed any National Ambient Air Quality
Standards (NAAQS) over the 10-year period 1975-1985.  For these Air
Quality Maintenance Areas (AQMAs), the states must submit plans to pre-
vent any national standards from being exceeded over that 10-year period.
Where analysis indicates a potential  problem with one or more pollutants,
specific maintenance strategies must be submitted.  These Air Quality
Maintenance Plans (AQMPs) will be prepared, adopted, and submitted in
compliance with the requirements of 40 CFR 51 and guidelines issued by
EPA.
     Restrictions on existing or future point or area source emissions
contained in these plans may carry with them political, economic, and
social  implications.  For this reason, the success of an AQMP will depend
upon cooperation among government agencies in the development of a
realistic, implementable, and enforceable plan.

A.   STUDY AREA BACKGROUND AND DESCRIPTION
     Historically, Illinois and Missouri have submitted separate air
quality control plans for their respective portions of the St.  Louis Air
Quality Control Region (AQCR).  St.  Louis was not among the original list
of urban areas required to submit a Transportation Control Plan to pro-
vide for the attainment of carbon monoxide (CO) and photochemical oxi-
dant (0 ) standards.  However, data from the expanded monitoring network
for these pollutants indicated a potential attainment problem.   There-
fore, the Missouri Air Conservation Commission has established  an advi-
sory committee to study the problem and prepare a Transportation Control
Plan for the AQCR by February 1975.   A study was prepared by PEDCo,
Environmental  Specialists, Inc., which presented proposed strategies for
                                    17

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the attainment of CO and 0  standards.   The  development  of  the  final
maintenance strategy for these pollutants  is highly  dependent upon  the
selected attainment strategy and its  implementation  schedule.
     In March 1974, Missouri designated  the  St.  Louis  SMSA  as a Mainte-
nance Area for total suspended particulates  (TSP)  and  photochemical
oxidants (0 ).  During the preparation of  this  final report,  Illinois
           X
also designated the three Illinois counties  in  the SMSA  as  an AQMA  for
particulates, sulfur dioxide, and oxidants.   The AQMA  includes  St.  Louis
City, St. Louis County, St.  Charles County,  Franklin County,  and Jeffer-
son County in Missouri.  In Illinois, Madison,  St. Clair, and Monroe
Counties comprise the AQMA (see Figure  II-l).
     St. Louis was chosen as an example  Air  Quality  Maintenance Area
because it is an interstate, interregional Air  Quality Control  Region
(AQCR) with a diversity of pollution  sources and problems.   St. Louis  is
a transportation center with river traffic (largest  inland  waterway port)
and rail traffic second only to Chicago.   St.  Louis  is also one of  the
most commercially active cities in the  U.S.   It boasts an extremely
diverse industrial base of food processors,  metal  processors  and fabri-
cators, oil refineries, foundries, and  chemical  processing  plants.
     The St. Louis area has a multifaceted political structure.  The AQMA
is comprised of two states—Illinois  and Missouri—seven counties,  one
independent city, and over 185 municipalities,  each  with its  own zoning
power.  Planning activities are equally  complex.  A  council of  govern-
ments, the East-West Gateway Coordinating  Council  (EWGCC),  is responsible
for A-95 Review and comprehensive transportation planning.   Participation
in the EWGCC is voluntary on the part of the seven counties and St.  Louis
City and therefore lacks implementation  power.   The  three  Illinois
counties have formed the Southwest Illinois  Metropolitan Area Planning
Commission (SWIMPAC) which provides local  planning and cooperative  input
to the EWGCC.  The City of St. Louis  and the Counties  of St.  Louis  and
                                    18

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                              FIGURE II-l  -

               ST. LOUIS AIR QUALITY MAINTENANCE AREA
                        ST. CHARLES   ,/(
                          COUNTY    /
                                                    MADISON
                                                    COUNTY
ST. LOUIS METROPOLITAN AREA
                                              UNITED STATES

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St. Charles have active planning agencies.   Federal  environmental  planning
activity emanates from the Federal  Regional  Centers:   Chicago for  the
Illinios jurisdictions and Kansas City for  Missouri  jurisdictions.

B.   REPORT ORGANIZATION
     Chapter I is an Executive Summary which provides an overview  of the
significant findings and conclusions of the study.   It also describes the
background, approaches, and limitations of  the study.  The Air Quality
Maintenance Area Analysis procedures and conclusions are presented in
Chapter III.
     Chapter IV describes the review and evaluation  of maintenance
measures for inclusion in the Maintenance Strategy and presents a  recom-
mended Attainment/Maintenance strategy for  TSP, S02, CO, and 0 .   The
                                                              X
legal authority and constraints to implementation of the proposed  strategy
are also discussed.
     The recommended long-term maintenance  strategy  is highly dependent
on effective long-term community planning and development.  Therefore,
intergovernmental cooperation and coordination become significant  factors
in the success of the maintenance plan.  Chapter V discusses the issues
and alternatives in intergovernmental cooperation and coordination and
presents a recommended approach to providing such coordination.
     The Appendices contain descriptions of the detailed methodology and
assumptions employed in the analysis and strategy development.  Two
regulations of significance to AQMP implementation are also reproduced.
                                    20

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              III.  AIR QUALITY MAINTENANCE AREA ANALYSIS
     The preparation of an Air Quality Maintenance Plan requires a de-
tailed analysis of existing and projected air quality to determine where
and to what extent the air quality standards may be exceeded within the
AQMA during the 10-year maintenance interval.  The analysis presented in
the following sections provides a trial evaluation of existing and
projected emissions and air quality for total suspended particulates
(TSP), sulfur dioxide (S02), carbon monoxide (CO), and photochemical
oxidants (0 ).
           X
     Much of the analysis described is an extension or extrapolation of
previous studies of the St. Louis AQCR.  Where problems of data deficiencies
or conflicts arose, a "worst-case" estimate was applied for the purpose
of continuing with the example plan development. The following sections
summarize the methodology and results of the analysis of existing air
quality, projected emissions, and projected air quality.  The limita-
tions to the analysis and recommendations for resolving deficiencies are
also described.

A.   EXISTING AIR QUALITY AND MONITORING NETWORKS
     All states are required by law (40 CFR 51) to identify areas which
exceed or are projected to exceed the National Ambient Air Quality Stan-
dards (NAAQS) within the 10-year period 1975 to 1985.  Therefore, avail-
able monitoring data from Missouri and Illinois were reviewed to deter-
mine trends in air quality.
                                   21

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1.   Air Quality Data
     Monitoring data from 11 stations in the AQMA were reviewed.  The
Regional A.ir Pollution Study (RAPS) will add 25 new monitoring stations
to this network during the next two years.
     Trend calculations were available from selected sites for total
suspended particulates, sulfur dioxide, carbon monoxide, and oxidants
from the Plan Revision Management System (PRMS) Summary reports.*
Results of the trend analysis indicate that most of the TSP problems are
related to the 24-hour standard.  Three sites were identified as
"potential problems."  One major "potential problem" with respect to CO
was identified near downtown St. Louis.  An oxidant problem appeared at
four sites distributed throughout the AQMA.
     Existing air quality data and air quality projections were reviewed
by the Missouri Air Conservation Commission (MACC) and by the Illinois
Environmental Protection Agency (IEPA) in order to designate the St.
Louis Air Quality Maintenance Area.  Table III-l summarizes the compari-
son of air quality data with the air quality standards.

2.   The RAPS/RAMS Program
     The St.  Louis Regional  Air Monitoring System (RAMS), currently
being constructed by Rockwell International Corporation under an EPA
contract for a Regional Air Pollution Study (RAPS) will provide contin-
uous data on air pollutants during the next five years.  The goal of
this program is to gather sufficient information on air pollutants to
enable air quality planners to monitor the effectiveness of air quality
implementation planning.
*
 The Plan Revision Management System - Region VII, U.S. EPA, CPDD,
 Research Triangle Park, March 1974.
                                    22

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                                                                                                                          c:
                                                                                                                          CO
                                                                                                                         •r-
                                                                                                                          U
        3
        00
        c
                                                             23

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     The 25 air monitoring stations are being located on sites selected
according to precise criteria to ensure that a comprehensive study of
air quality conditions can be developed.   Stations will  be located in
both the Missouri and Illinois portions of the greater St. Louis area.
Figure II I- 1 illustrates selected monitor sites.
     Each of the stations is equipped with a minicomputer which controls
and acquires data from the advanced electronic air monitoring equipment
and meteorological instruments and transmits the information to the
central computer at the RAMS main operations facility.
     There, data are analyzed by EPA and Rockwell personnel engaged in
the program.  The central facility is also equipped with a laboratory
for analysis of air samples.
     In addition to the automated RAMS station, the program will employ
helicopter measurements, mobile laboratories, ballon sounding stations,
aircraft monitoring and photography, and related sophisticated measure-
ment devices.
     Development of the remote RAMS station marks a significant advance-
ment in air monitoring, since the system is the first to provide a wide
variety of information on a real-time basis.
     This program will advance the degree of air monitoring sophisti-
cation in the St. Louis area, and provide the data to determine AQMP
effectiveness.

3^ _ Existing Air Quality
     The following statements summarize the conclusions from the review
of all existing air quality data from the St. Louis AQMA:
     •    TSP, S02, CO, and oxidants all currently exceed the primary
          standards at some point in the AQMA.
                                     24

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-------
     •    TSP and oxidants exceed the criteria for designation of a
          maintenance problem.
     •    S02 currently exceeds the standards in isolated areas in the
          Illinois portion of the AQMA.   However, current ambient values
          are below the primary standard at all  sites on the Missouri
          side.
     t    CO ambient readings exceed the 8-hour standard at several
          sites  in the urban area and trend data from a central urban
          site indicate the standard may not be achieved by 1975.
     As a result of these findings, TSP and oxidants are subject to
detailed analysis requirements.   Analysis of CO and S02 provide an
example and confirm the initial  conclusions from the ambient data.

B.   EMISSIONS PROJECTIONS
     The general approach to projecting emissions for all four pollutants
applied the following procedure:
     1.   Estimate a 1975 baseline inventory of all sources, assuming
          the sources are in compliance with existing regulations
     2.   Develop growth factors for each source category from available
          growth data
     3.   Apply the growth factors to the 1975 baseline inventory to
          obtain projected emissions from each source category

     The development of the baseline emissions inventory, the specific
methodology for projecting emissions for each pollutant and source cate-
gory, and the results of the emissions projections are described below.
The growth factors used and the rationale for their selection are
detailed in Appendix D.
                                     26

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1.   Baseline Emissions Inventory
     Existing inventory data in the St.  Louis Air Quality Maintenance
Area were found to vary both in the year-of-record for a particular
source type and in completeness of information.   To overcome the varia-
tion in year-of-record, existing inventories were projected to 1975 (year
of attainment) for each pollutant.   This procedure aligns all  emissions
data to a baseline year and assumes that all sources will be in compliance
and controlled by the 1975 attainment date.   To eliminate discontinuities
in information, existing information was supplemented by special analyses
to provide a complete data baseline.
     The information used in the development of the baseline emission
inventory was extracted from the following sources:
     t    Illinois State Implementation  Plan
     •    Missouri State Implementation  Plan
     t    Environmental Protection Agency—National Emissions  Data
          System (NEDS)
     t    East-West Gateway Coordinating Council  1970-1995 Traffic
          Assignment Data
     •    "Study on Attainment of National Air Quality Standards for
          Carbon Monoxide and Oxidants in the St. Louis Air Quality
          Control Region" prepared by PEDCO Environmental Specialists,
          Inc. (cited hereafter as the Attainment Study)
     •    Union Electric Company and Illinois Power Company
     •    St.  Louis Standard Metropolitan Statistical  Area (SMSA)
          statistics
     •    Bureau of Economic Analysis (BEA)  statistics
     The special analyses undertaken were:
     •    Primary Source Emissions  at Compliance  (TSP, S02)
                                    27

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     •    Point and area source distribution (for TSP and SO  only)
                                                            X
     •    Subcorridor-VMT emission analysis (for CO and HC only).   Both
          these analyses are discussed in detail in the Appendices.
2.   Methodology for Projecting Emissions
     Once the complete data baseline was established, emissions were
projected for four source categories:  point, area, power plants, and
mobile sources.  The specific methodology applied to each source category
is discussed in the following sections.

a.   Point Source -- Point source emissions data were broken down into
primary (sources greater than 100 tons/year) and non-primary sources for
each pollutant.  For the primary point sources for TSP and SO , summaries
                            >                                X
of source emissions at compliance, prepared by the Illinois Environmental
Protection Agency and the Missouri Air Conservation Commission, were
used.  For the non-primary source emissions, the emissions were assumed
to be uncontrolled (except as stated in the SIP) and were taken from
NEDS.  The CO and HC 1975 point source emissions were taken from the
Attainment Study (as corrected by Illinois EPA).
     The preferred method for projecting point source emissions for 1980
and 1985 was to obtain growth rates for each company, power plant, and
institution that represents a primary point source.  BEA growth statistics
were used for non-primary point sources and in cases where actual growth
rates could not be obtained for a primary point source.  Accordingly, a
survey was conducted of the primary point sources to gather information
on growth rates, productivity increase estimates, and expected increases
in capacity.  Responses were received from approximately 35 percent of
the sources contacted.  Once the baseline point source inventory and the
growth factors for all the sources were developed, the 1980 and 1985
                                     28

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emissions were generated by multiplying the baseline emissions by the
annually compounded growth factors.

b.  Area Source — 1970, 1972, and 1974 area source emissions data were
gathered and projected to 1975 by applying the percent emission control
as required by the State Implementation Plan and growth factors for each
area source.
     The method used for projecting area source emissions for 1980 and
1985 was to obtain growth rates from BEA growth statistics and local
estimates.  Projections were generated by individual area source category
(residential, industrial, and commercial) and summarized to give total
area source emissions for each pollutant.

c.   Power Plant — Individual plant data were provided by Union Electric
Company, Illinois Power Company, Missouri Air Conservation Commission,
and the Illinois Environmental Protection Agency.  Compliance schedules,
control equipment, stack emissions, and growth factors were applied by
MACC and IEPA to the power plants data to generate an inventory of
controlled emissions in 1975.
     To project power plant emissions for 1980 and 1985, the growth
factors and the scheduled changes in new and old plants were applied to
1975 baseline controlled emissions.   The primary point sources and major
power plants (emissions over 100 tons) are shown on the TSP and SO
source distribution maps in Appendix A.

d.   Mobile Source — Mobile source emissions were divided into two
categories:  highway and off-highway vehicles.  Highway vehicles include
both light- and heavy-duty vehicles; off-highway vehicles include rail-
roads, vessels, aircraft, and other vehicles not operated on roads.  For
                                    29

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highway vehicles, mobile source emissions data were obtained from the
Attainment Study for the baseline year of 1975.  For off-highway vehicles,
mobile source emissions data were gathered from NEDS and the Missouri
and Illinois State Implementation Plans.  Off-highway emissions were
projected using a three percent average growth rate, which parallels the
national average.  This growth rate was applied to the four pollutants.
     Highway emissions for TSP and SO  were generated by applying TSP
and SO  emissions factors to projected annual VMT (vehicle miles of
      X
travel) (see Appendix C).  Highway mobile source CO and HC emissions for
1980 were taken from the Attainment Study for the Air Quality Control
Region and extrapolated to reflect the Air Quality Maintenance Area.
The 1985 emissions were calculated in the special analysis (Subcorridor-.
VMT Emissions Analysis) for the St. Louis urban-in-fact area by inter-
polating the 1970 and 1995 traffic network data for each subcorridor and
link type and extrapolating to reflect the entire Air Quality Maintenance
Area.   The distribution of VMT and emissions by subcorridor and link
type was calculated in this analysis.  The procedure is explained in
detail in Appendix B.

3.   Projected Emissions
     Figures 111-2 to II1-5 and Table 111-2 summarize the St. Louis Air
Quality Maintenance Area emissions projections.  Emissions are projected
for 1975, 1980, and 1985 for each pollutant and source category.
     These projections illustrate the relative impact of the four emission
source categories on the levels of various pollutants over the 10-year
projection period:
     t    With respect to TSP emissions, major increases are projected
          to be attributable to point sources  (see Figure III-2).
                                     30

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                         Table III-2
           ST. LOUIS AIR QUALITY MAINTENANCE AREA
                EMISSION PROJECTION - SUMMARY
Source Category
Point Sources
Area Sources
Power Plants
Mobile Sources
Highway
Off-highway
TOTALS
Point Sources
Area Sources
Power Plants
Mobile Sources
Highway
Off-highway
TOTALS
Point Sources
Area Sources
Power Plants
Mobile Sources: Highway
                Off-highway
                TOTALS


Point Sources
Area Sources
Power Plants
Mobile Sources: Highway
                Off-highway
                TOTALS
                                  Emissions, Tons per year
1975
Total
50
18
20
8
3
101
194
40
577
2
3
797
46
28
1
476
31
585
40
30
1
82
11
165
9
9
9
i
»
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
».
9
329
955
348
383
647
662
046
155
190
065
624
080
821
808
641
242
891
403
208
389
191
502
217
507
1980
1985
Suspended Particulate
57
20
34
9
4
126
Sulfur
204
44
864
2
4
1,119
Carbon
50
27
1
241
36
9
9
9
J
^
9
9
9
9
9
9
9
9
9
9
9
9
972
404
064
622
228
71
23
34
10
4
290 145
Dioxide
013
510
748
371
202
218
50
873
2
4
844 1149
Monoxide
870
565
641
459
972
59
27
1
146
42
358,507 278
Hydrocarbons
50
32
1
39
13
136
9
9
9
9
9
9
330
153
395
217
004
009
55
35
1
25
15
133
9
9
9
9
^
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
617
563
863
823
902
768
452
063
000
666
872
053
734
799
700
070
859
162
009
370
666
956
076
085
                              31

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                               FIGURE  III-2

                SAINT LOUIS AQMA EMISSION PROJECTIONS

       .160-1  TOTAL SUSPENDED PARTICULATES, TONS PER YEAR
       140'-
      120 -
ai


5i

O
O
LU

LU
13
O

I-
tr
<
a.

O
u
Q

UJ
a.
V)

V)
                                     1980
                                                      1985
                                              OFF-HIGHWAY

                                              MOBILE SOURCES



                                              HIGHWAY MOBILE

                                              SOURCES

-------
                             FIGURE  III-3
                SAINT LOUIS AQMA EMISSION PROJECTIONS
                     SULFUR OXIDES, TONS PER YEAR
       1200 -
       1000 -
 tr
 <
 LLJ
 o
m
 o
 U)
 O
 55
 —
 5
 HI
 LU
 O
 X
 o
 tr
       800 -
600  -
       400 -
       200 -
         0  -
                        1975
                                         1980
                                                           1985
                           SOURCE TYPES

                         AREA

                         POWER PLANTS

                         POINT
                                           OFF-HIGHWAY
                                           MOBILE SOURCES

                                           HIGHWAY MOBILE
                                           SOURCES
                                  33

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                                FIGURE III-4
                  SAINT LOUIS AQMA EMISSION PROJECTIONS
                     CARBON MONOXIDE, TONS PER YEAR
       600 -1
       500 -
 CC
 <
 tu
 >
 OT
 o
n
 o
 ^
 GO
 O
 GO
 —
 UJ
 til
 Q
 X
 O
 O

 o
 m
 DC
 <
 o
400 -
300  -
200  -
       100 ~
        0 -
                                                 OFF-HIGHWAY
                                                 MOBILE SOURCES
                                                 HIGHWAYiMOBILE
                                                 SOURCES
                                34

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       780 -1
                                  FIGURE III-5
                   SAINT LOUIS AQMA EMISSION PROJECTIONS
                       HYDROCARBONS, TONS PER YEAR
       160 -
       140 -
       120 -
 oc
 <
 UJ
 z
 o
n
 o
 LU

 O
 CD
 CC
 <
 O
 O
 OC
 Q
       100 -
        80 -
        60 —
        40-
        20  -
                        1975
                           SOURCE TYPES

                         AREA

                         POWER PLANTS

                         POINT      35
                                         1980
                                                          1985
OFF-HIGHWAY
MOBILE SOURCES

HIGHWAY MOBILE
SOURCES

-------
     t    Projections for SO^ emissions reveal significant increase in
          power plant emissions relative to other sources (see Figure III-3),
     •    CO emission projections show a major decrease in emissions
          from mobile sources (see Figure 111-4).
     •    Total HC projected emissions reveal a downward trend in which
          emissions from point and area sources increase slightly while
          highway mobile sources decrease significantly (see Figure III-5).
C.   AIR QUALITY PROJECTIONS
     A number of techniques are available for the projection of air quality
from emissions data.   These techniques  range from statistical  relationships,
such as roll-forward or emission density relationships, to air quality
diffusion models, such as the Air Quality Display Model (AQDM), Cli-
matological Dispersion Model (COM), etc.
     In developing air quality projections to 1975, 1980, and 1985 for
the St. Louis AQMA, certain general considerations guided the selection
of projection techniques.  These considerations included the availability
of techniques recently applied to St. Louis where forecasts need only
be extended to longer time intervals, the availability of a calibrated
model for St. Louis based on current data, the availability of data to
facilitate the application of a specific technique, and the time con-
straints posed by this particular report.
     Those techniques selected for projecting air quality for total sus-
pended particulates, sulfur dioxide, carbon monoxide, and photochemical
oxidants are discussed in the following sections.

1.   Total Suspended Particulates
     The projection of annual concentrations for TSP was accomplished
through application of statistical relationships between TSP emissions
                                     36

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density and concentration.*  The relationship is displayed as a curve
(where 1964 TSP sampling data had been plotted against emissions densities
for various land areas larger than 20 square miles).  This curve is
shown in Appendix E.
     The projection method required the summary of emissions from all
sources within selected subareas (36 square miles or greater) of the
St. Louis AQMA and then determination of emission density values by
division of total emissions for each subarea by area size.  The estimated
annual concentration was then found from the curve and recorded at the
center of each selected subarea in the AQMA.  Isopleths were drawn,
based on concentrations at subarea centers.  These isopleths display the
mean annual TSP concentration distribution in the St. Louis AQMA.
Figures III-6, III-7, and III-8 show distribution of TSP mean annual
concentrations for 1975, 1980, and 1985, respectively.  Background
concentration was estimated at 40 micrograms per cubic meter.**

2.   Sulfur Dioxide
     The projection of air quality concentrations for S02 was accom-
plished by applying two air quality diffusion models:  Miller-Holzworth
for the St. Louis central urban area and the Wood River refinery complex,
and Pasquill-Gifford plume dispersion for four significant point sources.
     These two projection methods required calculation of concentrations
from given equations.   The Miller-Holzworth equation calculates annual
average areawide concentrations of S02 from emissions density, mixing
depth, urban size, and mean annual  wind speed.   The Pasquill-Gifford
*
 U.S. Department of Health, Education, and Welfare, Interstate Air
 Pollution Study: Phase II Project Report, December 1966.
**
  Source:  Missouri State Implementation Plan
                                    37

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plume dispersion calculates a maximum 24-hour average concentration of
S02 from wind speed, plume rise, emissions rate, stack parameters,
meteorological stability, and assumes a Gaussian plume.
     Table III-3 summarizes the results of the air quality projections
for both point source concentrations and selected area source concentrations,
Maximum 24-hour and annual concentrations are given for 1975, 1980, and
1985.  Figure II1-9 gives the locations for point and selected area
sources in the St. Louis AQMA.  It can be seen that point source number 2
(Sioux Power Plant) is projected to exceed the 24-hour standard of
365 micrograms per cubic meter in 1980 and 1985.  Selected area sources
may also exceed the annual standard of 80 micrograms per cubic meter.
Area source projections, however, must be carefully evaluated due to the.
fact that projection calculations are highly dependent upon the size of
the area considered and the subsequent derivation of emissions density.
Refer to Appendix F for detailed modeling parameters and equations used
in projection calculations.

3.   Carbon Monoxide
     As recently as March 1974, the APRAC 1A Diffusion Model had been
applied to carbon monoxide projections for the St. Louis AQMA (the
Attainment Study).  Estimates of 8-hour CO concentrations were calculated
for 1975 at nine selected receptor sites.  CO concentrations in 1980 and
1985 at these receptors were extrapolated from the 1975 estimates using
the following procedure:
     t    Assume worst case meteorological conditions do not vary
     •    Assume concentrations of CO are directly proportional to
          emissions of CO under constant worst-case meteorological
          conditions
                                     38

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39

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40

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41

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                         Table  III-3
           SULFUR DIOXIDE AIR QUALITY PROJECTIONS
Point Source
Location
1
2
3
4
Area Source
1A 144 sq. mile
Maximum 24 hour
(standard
1975
38
322
221
308
Maximum annual
(standard
1975
101.6
concentration
- 365 ygm/m3)
1980
145
400
243
308
concentration,
- 80 ygm/m3)
1980
89.8
, ygm/m3
1985
145
400
262
308
ygm/m3
1985
98.5
   central urban
   area

IB 182.25 sq.  mile   80.3
   central urban
   area
2  36 sq. mile       66.2
   (Wood River)
71.0
82.4
 77.8
105.0
 See Appendix F for supporting calculations.
                              42

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     •    Calculate 1975, 1980, and 1985 CO emissions in the vicinity of
          the selected nine receptors using the subcorridor VMT analysis
          (see Appendix G)
     •    Calculate the change in emissions in the vicinity of each re-
          ceptor from 1975 to 1980, and 1980 to 1985.
     •    Apply the corresponding percent change in emissions to the
          1975 concentration at each receptor to obtain 1980 and 1985
          concentrations.
     This procedure is equivalent to a "roll-forward" type of calculation
using the results of a calibrated diffusion model to represent baseline
air quality.
     Table II1-4 shows the maximum 8-hour CO concentrations for the
selected receptors for 1975, 1980, and 1985.  Significantly, the pro-
jections for 8-hour carbon monoxide concentrations generally exceed the
standard in 1975; by 1980 and 1985, concentrations are well below the
standard.  Figure 111-10 shows the location of the receptor sites listed
in Table III-4.

4.   Photochemical Oxidants
     The projection of air quality concentration for photochemical
oxidants was accomplished by applying Appendix J of the Federal Register
40 CFR 51, Regulations on Preparation of Implementation Plans.  Appen-
dix J presents the relationship between percent reduction in hydrocarbon
emissions and maximum one-hour photochemical oxidant concentrations.
See Appendix H for the curve representing this relationship.
     The EPA has defined oxidants as an areawide problem.  Consistent
with this definition, areawide hydrocarbon emissions from Table III-2
were used to determine percent emission reductions from the air quality
                                     43

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                                      §
44

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                         Table III-4
           CARBON MONOXIDE AIR QUALITY PROJECTIONS

                     Maximum Eight Hour Concentration, ppm
Receptor  Location   	(Standard - 9 ppm)
1
2
3
4
5
6
7
8
9
CAMP
1-70 & 1-270
1-70 & Shreve
Lindbergh &
Linferry
Hunter Ave.
& Clayton
St. Ann
1-244 &
Manchester
S.L. airport
U.S. 40 &
Grand
1975 (a)
10.8
7.2
9.6
12.8
10.5
9.9
10.8
8.8
10.9
1980 (b)
5.44
3.75
4.90
6.95
5.46
5.25
5.88
4.60
4.52
1985 (b)
3.15
2.37
2.80
4.30
3.22
3.19
3.69
2.76
2.37
(a)   1975 concentrations were generated using APRAC-IA urban
     diffusion model
(b)   1980 and 1985 are extrapolations  of the APRAC-IA 1975
     data using percent change in emissions from mobile
     sources  generated from the subcorridor emissions analysis
                              45

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baseline year of 1972 to 1975, and 1980 to 1985.  The 1972 second
highest 1-hour concentration of 300 micrograms per cubic meter was used
as the baseline.
     Table 111-5 shows the projected 1-hour oxidant concentration for
1975, 1980, and 1985.  Note that the oxidant concentrations are approach-
ing the standard by 1985 but do not attain it.

D.   SUMMARY AND CONCLUSIONS OF THE AQMA ANALYSES
     The conclusions of the air quality and emissions analyses follow
for each pollutant considered.

1.   Total Suspended Particulates (TSP)

a.   Air Quality ~ Ambient concentrations currently exceed the primary
standards at several monitoring stations.  The projected concentration
distribution pattern changes very little over the 10-year period.  "Hot-
spot" areas can be identified which have the potential to exceed the
standards during the 1975 to 1985 period.

b.   Source Contribution -- Point sources and power plants are the
primary contributors to the existing problem.  However, increases are
projected in all source categories.  Growth in emissions is expected to
be concentrated at existing sources or in the vicinity of existing
sources.  Growth accounts for less than 20 percent of projected total
emissions in 1985.   The contribution of fugitive dust to ambient con-
centrations is not known at this time.

c.   Attainment and Maintenance of Standards — The primary standards
are projected to be attained by 1975 and maintained throughout the
                                     46

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47

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                         Table III-5

                   PHOTOCHEMICAL OXIDANTS
                   AIR QUALITY PROJECTIONS
                            Peak one hour Concentration ugm/m3
                                (Standard - 160 ygm/m3)

Location                         1975       1980      1985

Area wide highest value           240        190       180
*
 Application of Appendix J. Federal Register 40 CFR 51 to
 percent total hydrocarbon emission reductions for the
 St. Louis AQMA.

-------
following 10-year period in most of the AQMA.  However,  "hot-spot"
areas are identified where the primary standards are projected to be
exceeded beyond the 1975 compliance schedule.  Because the growth in
emissions is projected to be concentrated in these "hot-spot" areas,
maintenance of the standards will be a problem.  Secondary standards are
projected to be exceeded throughout the 10-year period in large portions
of three counties and the city of St. Louis surrounding the "hot-spot"
areas.

d.   Actions Required — An attainment and maintenance strategy is
required for the "hot-spot" areas.  A strategy is needed to maintain the
secondary standard for TSP in the area immediately surrounding the "hot-
spots."

2.   Sulfur Dioxide (S02)

a.   Air Quality — Ambient concentrations of S02 on the Missouri  side
of the AQMA are all below the standards.   Concentrations at isolated
sites in the Illinois portion of the AQMA do currently exceed the primary
standard.   Air quality projections are highly dependent on the sulfur
oxide emissions from isolated sources and indicate that a "potential" to
exceed the standards exists only in the vicinity of these sources.  No
regionwide maintenance problem is projected.

b.   Source Contribution -- Power plants  and several  large industrial
point sources account for all significant contributions to existing and
projected  emissions of sulfur oxides.   Growth in emissions is projected
to be significant due to power plant expansions.
                                    49

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c.   Attainment and Maintenance of Standards -- S02 standards are expected
to be attained and maintained throughout the AQMA.   Exceptions may recur
in the vicinity of major power plants or specific point sources.

d.   Actions Required -- A regionwide maintenance strategy is not required.
However, more extensive monitoring and surveillance of major sources is
required to ensure maintenance of the short-term standards in the vicinity
of sources.  Interim measures may be required to attain and maintain in
the "hot-spots."

3.   Carbon Monoxide (CO)

a.   Air Quality — Eight-hour standards are currently exceeded at
several monitoring stations throughout the AQMA.  Projected concentrations
indicate several areas will exceed the eight-hour standard in 1975.  All
selected receptor sites are projected to be well below the standards by
1980.  Maximum concentrations are associated with major highways and
intersections.

b.   Source Contribution -- Mobile sources are the primary contributor
to CO emisssions in the AQMA and will still account for more than
50 percent of total emissions by 1985.

c.   Attainment and Maintenance of Standards -- Once the 8-hour CO
standards are attained, the continued decline in mobile source emissions
will assure maintenance to at least 1985.

d.   Actions Required — A Transportation Control Plan (TCP) is currently
in preparation to provide attainment of the CO standards.  The TCP is
                                    50

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expected to be adopted by February 1975.  A regional maintenance strategy
is not required at this time.

4.   Photochemical Oxidants (0 )
a.   Air Quality -- Peak-hour oxidant concentrations currently exceed
the standard and limited air quality trend data indicate increasing
values.  Oxidant values are projected to decrease due to decreases in
total hydrocarbon emissions.  However, the decreases are projected to be
insufficient to attain the standard.

b.   Source Contribution -- Mobile sources are currrently the most
significant contributor to total regional hydrocarbon emissions.  However,
stationary point and area sources become more significant by 1985 as
mobile source controls become more effective.

c.   Attainment and Maintenance of Standards -- The oxidant standard
cannot be attained or maintained with the existing SIP control measures.
Uncontrolled (no TCP) projected oxidant concentrations exceed the standard
beyond 1985.

d.  Actions Required -- A Transportation Control Plan (TCP) is required
for Attainment and a Maintenance Strategy is required.
                                    51

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 E.   LIMITATIONS OF ANALYSIS AND RECOMMENDATION FOR RESOLVING
      DEFICIENCIES

     The review of available baseline data,  projection data,  and pro-
jection techniques revealed many deficiencies.   In order to develop a
sample AQMP within given constraints, the best available information was
used and recent analyses were modified or extrapolated where possible.
Overall, many simplifying assumptions were made because data are either
unavailable or limited in nature.  These assumptions and deficiencies
should be verified or corrected where possible before plan submittal.
     The state and local air pollution control  agencies are currently
working to resolve many of these deficiencies or conflicts and a revised
emissions inventory is expected to be completed by January 1975.  In
addition, the RAPS/RAMS program is intended to provide a very complete
analysis of air pollution and source contribution in the St.  Louis area
over the next five years.
     The following paragraphs describe some of the linfiting factors or
assumptions in the sample analysis.  Recommendations for resolution of
these limitations are given where appropriate.

1.   Data Base Problems
     Many air pollution studies have been conducted in St. Louis over
the past decade.  Each of these studies produced some analysis of emissions
or air quality based on the state-of-the-art in ambient monitoring and
emission estimation.  However, a review of these studies and available
air quality and emissions inventories for the AQCR concluded that no
consistent, complete, and current data base exists for the entire AQMA.
The major reason for this is that the detailed studies which were performed
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were not updated on a continuing basis as new emission factors or moni-
toring methods were available.

a.   Air Quality Data — EPA's SAROAD data bank was the primary source
of air quality data.  The latest annual data available and verified at
the time of this project was the 1972 annual summary.  No 1972 Illinois
station data were available in SAROAD.
     The trend in particulate ambient data does not appear to be explained
by the existing emissions inventory (as explained in the PRMS Region VII
Summary).  The City of St. Louis has increased monitoring frequency and
listed additional sources of TSP not in NEDS which may be affecting the
trend data.  Photochemical oxidant values are increasing as monitoring
of this pollutant is expanded.  This will markedly affect requirements
for emission reductions if this trend continues.
     The RAPS/RAMS monitoring program will certainly expand the accuracy
and representativeness of the air quality data network.  It is recommended
that TSP and S02 monitoring priorities be placed on sites in the "hot-
spot" areas and around power plants.

b.   Emissions Data Base -- No complete 1972 emissions inventory was
available for the AQMP with the exception of NEDS.  The NEDS data included
old emissions data which had been converted into the NEDS format inter-
mixed with new emissions data.  Incorrect site locations and plant
closings errors were among the inaccuracies noted.  Illinois does not
currently maintain its inventory in NEDS format and the IEPA considers
the NEDS data for Illinois to be inaccurate.
     The RAPS program will provide detailed emissions baseline data for
St. Louis.   However, it will not be in NEDS format.  It is highly
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recommended that the detailed data base format used for the RAPS program
be maintained and updated periodically and be used to update the NEDS
listing for St. Louis.   The MACC and IEPA are cooperating with local and
Federal agencies in a program to update the emissions inventory.  This
effort should be complete by January 1975.  It is recommended that a
fugitive dust inventory be performed to supplement the efforts already
under way by the City of St. Louis in this area.
     The mobile source emissions data in NEDS are on a county basis.
This is considered inadequate for CO modeling purposes.  The Federal
Highway Administration SAPOLLUT emissions model is recommended as the
minimum format required for CO modeling.  The EWGCC is currently studying
the feasibility of using this program.

c.   Emissions Projections ~ In order to obtain a consistent controlled
data base from which to project 1980 and 1985 emissions and air quality,
the available data on emissions sources were first projected to 1975 to
obtain the inventory at full compliance with SIP regulations.  This
assumes that all sources will be in compliance by 1975.  The "controlled
inventory" was then projected to 1980 and 1985 using available growth
and trend data.
     The growth factors were based on population trends, employment and
industrial earnings projections, and traffic projections.  Land use and
distribution trends were used to distribute the projected growth in
emissions.  The use of such trend data as growth factors first assumes
that growth in emissions is directly proportional to these growth factors.
However, new and more efficient manufacturing techniques and control
equipment may cause this assumption to be adjusted.
     Population forecasts served as growth and distribution factors.
The latest unpublished estimates show a marked decrease from previous
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projections for the urban area.  Since the land use plans do not as yet
reflect this change, further adjustment may be necessary.  The land use
plans also represent projected patterns of industrial and commercial
growth and development.
     There are four studies currently under way which could significantly
alter the growth patterns in the area.  They are:
     •    A railroad relocation study
     •    An airport study
     i    A port feasibility study
     •    A mass transportation plan

     However, these plans will probably not be complete within the re-
quired time frame for initial AQMP submittal but should be included
in further plan analysis.

2.   Analysis Procedures
     Some simplified procedures for emissions projection and disaggre-
gation were developed as part of this project.   They are described in
the Appendices.  The major drawback to utilizing any sophisticated
modeling procedures at this time is the inconsistency and inaccuracy in
the emissions data base and the demographic growth rate data.
     As these deficiencies are resolved, an effort should be made to
coordinate the collection of data in a form useful for input to the
analysis techniques.  Point source data a>fe currently collected in a
                                           t
form suitable for input to models for particulates and S02.   However,
more short-term operational data would be useful.  Area source data for
these two pollutants are collected on a county basis which is not a
sufficiently detailed scale to input to a model such as AQDM or COM.
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 The  CAASE  program  may  provide  adequate detail  if CAASE distribution
 factors  can  be  projected.   Fugitive dust emissions must also be collected
 for  input  to the model for  particulates.
      Projected  mobile  source emissions data are currently available only
 on a  county  basis  and  are not  suitable for input to any carbon monoxide
 air quality  model  which illustrates the pollutant distribution.
     The results of the RAPS program will be invaluable to upgrading the
emissions inventory and analysis procedures for the St. Louis area.
However, they will not be available within the proposed time frame for
AQMP submittal.  Therefore, interim analysis approaches must be used.
 It is recommended  that priority for all  such interim analyses be given
to the "hot-spot"  areas.   Recommended analysis procedures for each
pollutant are described below.

a.   Particulates  — A diffusion model such as AQDM or COM can be applied
to an updated and  upgraded emissions inventory.  This inventory should
include fugitive dust.   The assumptions  concerning control factors used
should be carefully evaluated.   The RAPS program should provide the best
available inventory and ambient data for such modeling.

b.   Sulfur Dioxide —  S02 is a point source problem in St.  Louis with
ten sources contributing  more than 90 percent of the AQMA total emissions.
These sources should be modeled independently to determine their con-
tribution to ground level  S02 concentration.   Again,  the emissions data,
stack data, and control information are  critical and require a careful
inventory or stack testing data.
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c.   Carbon Monoxide — The technique developed to evaluate subcorridor
growth indicates the potential to exceed the standards beyond 1980
exists only at the microscale or roadside level (assuming the Federal
Motor Vehicle Control Program (FMVCP) is effective).  If a demonstration
of maintenance at this level is desired on an AQMA-wide or regional
basis, a detailed traffic network for the year of interest is required
to support the modeling effort.  A site-by-site analysis could be required
through indirect source control or highway Environmental Impact State-
ment (EIS) requirements.

d.   Photochemical Oxidants — Regionwide application of Appendix J is
the only approved methodology for modeling oxidants at this time.
Oxidants currently exceed the standards and the levels are apparently
increasing in St. Louis.  Therefore, a more sophisticated analysis is
required to support a control strategy.  It is recommended that reactive
oxidant modeling be applied as the techniques become available.   In
order to support such a modeling approach, efforts must begin now to
obtain a detailed inventory of reactive and non-reactive hydrocarbon
emissions on a detailed (sub-county) basis.
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           IV.  AIR QUALITY MAINTENANCE STRATEGY DEVELOPMENT

     The air quality analysis indicates that attainment of the primary
standards for TSP, S02, CO, and oxidants can not be achieved by 1975.  In
addition, maintenance strategies are required for TSP, S02, and oxidants.
The development of a maintenance strategy, therefore, requires a review
of existing and proposed attainment plans and an evaluation of alternative
maintenance strategies.  The following sections provide a brief review of
the status of attainment plans and the evaluation of alternative mainte-
nance measures.  A proposed maintenance strategy is outlined and the
constraints to implementation of the selected strategy are described.
     The comments of the technical and administrative representatives of
the St. Louis air pollution control and planning agencies have been
included where possible.  However, it should be recalled that all  find-
ings are presented as an example, or trial plan, and are subject to the
limitation described in Chapter III.

A.   AIR QUALITY ATTAINMENT PLANS
     A first step in developing the air quality maintenance strategy is
to review the existing air quality plans to determine if they are sufficient
to attain and/or maintain the standards.  Since all four pollutants were
projected to attain the standards in the original  SIPs, some discussion
of the status of these plans is required.

1.   Particulates (TSP)
     The original projections included in the Missouri and Illinois SIPs
predicted attainment of the TSP standards by 1975.   These projections
were dependent upon data base, analysis, control technique, and compli-
ance schedule assumptions.   In addition, it was assumed that the relation-
ship between emissions and air quality was adequately defined by the
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analysis technique and the meteorological  conditions  given as represen-
tative of the "worst case."
     Any one of these assumptions or conditions could have been too
optimistic.   However, because the current  analysis  given in Chapter III
is subject to the same conditions, it cannot be assured that the 1975 air
quality will exceed the standards.
     It would not be justifiable to require additional  TSP control  mea-
sures to attain the standards at this time until  it can be determined
whether the existing controls are achieving the expected results.   There-
fore, the only additional  attainment measures recommended at this  time
are measures directed at expanding the monitoring and surveillance pro-
grams.
     Compliance schedules  and source review procedures  are currently
being reviewed by EPA and  state air pollution agencies.  The City of
St. Louis has increased the frequency of monitoring in  order to provide  a
more accurate assessment of ambient air quality.   Monitoring has also
been expanded in Illinois.  In addition, the RAPS program will eventually
provide detailed ambient data and emissions data to determine the relation-
ship between emissions and ambient concentrations.
     The City of St. Louis has also compiled a list of  sources of parti-
culates not included in the existing inventory.  This program could be
expanded to include a regionwide compilation of "fugitive dust" emissions.
     In summary, although  current trends in air quality indicate the
particulate standards will not be attained by 1975, the cause of this
trend cannot be isolated.   Therefore, no new attainment measures can be
justified unless 1975 ambient data confirm this trend.   Monitoring and
surveillance programs are currently being  expanded in order to verify the
effectiveness of the existing attainment plan.  It is recommended that a
fugitive dust inventory be completed for the region as  a part of this
monitoring program.
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2.   Sulfur Dioxide (S02)
     The SIPs for Illinois and Missouri both projected attainment of S02
standards by 1975.  Current air quality is below the primary and secon-
dary standard in Missouri.  However, 1972 air quality exceeded the pri-
mary standards at several sites in the Illinois portion of the AQMA.  The
Illinois EPA feels these violations are related to individual sources.
     The analysis in Chapter III concluded that the primary standards
would not be attained by 1975 at several points in the AQMA due to source
oriented problems.  In addition, scheduled expansions at power
plants provide the "potential" for short term standards to be violated
depending upon individual source operational  characteristics.
     It is concluded that attainment of the S02 standards is a specific
source oriented problem and efforts are currently underway to determine
source compliance with existing regulations.   No new attainment measures
are required at this time.  However, short-term violations of the primary
standards are expected to occur in the vicinity of specific sources until
compliance is achieved.

3.   Carbon Monoxide and Photochemical  Oxidants (CO and 0 )
                                                         X
     St.  Louis was not among the original  group of cities required to
submit Transportation Control  Plans to attain and maintain the NAAQS for
CO and oxidants.   Recent ambient data from the expanded monitoring net-
work suggest an attainment problem does exist for CO and oxidants.
Therefore, the MACC in cooperation with the Illinois EPA and area trans-
portation planning community representatives  is currently preparing a
Transportation Control Plan (TCP).
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     A study was performed by PEDCo Environmental  Specialists,  Inc.,  on
the attainment of CO and oxidant standards* (referred  to as  the "Attain-

ment Study") in March 1974.   The results of this  study are summarized
briefly as follows:

     Carbon monoxide and oxidant air quality data  collected  during 1972
     indicates that maximum eight-hour CO concentrations must be reduced
     by 46 percent and maximum one-hour oxidant concentrations  must be
     reduced by 47 percent in order to attain the  NAAQS throughout the
     AQCR.  The Federal Motor Vehicle Control Program  (FMVCP) will not be
     sufficient to attain either standard by 1975  or 1977.  Therefore,
     additional measures are needed.   Three strategies were  evaluated in
     the Attainment Study as follows:

          Strategy I -- Actions that will occur with the stimulus of  a
          plan including:  use of lighter-weight motor vehicles, reduced
          non-essential travel due to higher gasoline  prices, improved
          mass transit, lower mass transit fares,  and  transit bus retro-
          fit.

          Strategy II -- An active carpool incentive program plus the
          actions of Strategy I.

          Strategy III -- Application of maximum technically demonstrated
          stationary source controls plus Strategy II  actions.

     When these strategies were evaluated and the results compared to the
     NAAQS, it was observed that Strategy II for CO and Strategy III  for
     hydrocarbons would attain the standards by 1977.   It appears im-
     possible to attain the standards by 1975 without  "highly disruptive
     and socially unacceptable control measures such as gasoline ration-
     ing or mandatory restrictions on gasoline-powered vehicle usage  in
     the core area of the AQCR."
     The results of this study were presented at public hearings in St.

Louis. The hydrocarbon stationary source controls received the greatest

opposition.  This is significant to both attainment and maintenance of
*PEDCo-Environmental Specialists, Inc.  Attainment of National Air Quality
 Standards for Carbon Monoxide and Oxidants in the St.  Louis AQCR.  Cin-
 cinnati, Ohio:  March 1974.
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the oxidant standard because the analysis in Chapter III (which does not
assume any of the suggested control strategies) indicates the most signi-
ficant source of increased hydrocarbon emissions is the stationary point
and area sources categories.   If Strategy III above is adopted and imple-
mented, both attainment and maintenance will be assured at least through
1985.  The problems of implementing this strategy are discussed below.

B.   EVALUATION OF MAINTENANCE STRATEGY ALTERNATIVES
     The maintenance strategy must provide sufficient emission reduction
to account for the projected growth or prevent that growth from occuring
in areas where the ambient air quality is at or near the standards.
     The maintenance problem in the St. Louis AQMA is characterized  by  a
number of areas where existing sources are expected to continue to emit
pollutants at rates that virtually preclude the influx of additional
emission sources into these areas without violation of ambient air qua-
lity standards once they are attained.  Maintenance strategies for these
areas must include further emission reductions from the existing sources
and/or effective methods of preventing new sources from locating in  these
areas.
     The potential maintenance strategies outlined in Volume 3 of the EPA
guidelines series for Preparation of Air Quality Maintenance Plans were
reviewed and evaluated for application in the St.  Louis AQMA.   These are
divided into two classes:  emission source control measures  and adminis-
trative approaches.   In the following discussion those measures considered
applicable to the St.  Louis AQMA are described and the reasons for in-
cluding or excluding the measure are discussed.
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1.    Emission Control  Measures

     •    New Source Performance  Standards  (EPA)

               Description  -- Standards  applicable  to  new or modified
               sources in specific  stationary  source categories  proposed
               and promulgated  by EPA.

               Applicability -- In  St. Louis AQMA,  only  two of  the  source
               categories will  be affected—petroleum  refining  and  petro-
               leum storage.

               Implementation Obstacles  ~  The Clean Air Act defines
               these as a "standard for  emission  limitation achievable
               through the  application of the  best  system of emission
               reduction which  the  administrator  determined had  been
               adequately demonstrated."  Some questions have been  raised
               for the commercial  availability of these  "best systems."

               Impact -- This measure  is not projected to have  a signi-
               ficant impact in the "hotspot"  areas of St. Louis during
               the ten-year maintenance  period.

               Legal  Authority  -- Federal Regulations  are adopted.

     •    Revision of Existing  SIP  Control  Measures

               Description  -- More  stringent emission  limitations on
               existing source  or new  sources  as  a  new or modified  state
               regulation

               Applicability -- Most of  the major emissions sources have
               recently installed control equipment to meet SIP  require-
               ments by 1975.   An emission  regulation was found  which
               would provide additional  emission  reductions in  the  prob-
               lem areas.   However, any  reduction that might be  obtained
               would impose an  inequitable  requirement on sources that
               have just completed  installation.

               Two major source categories  are not  controlled under
               present regulation in all parts of the AQMA:  fugitive
               dust and some stationary  sources of  HC.   Fugitive dust has
               not been completely  inventoried as yet  for the AQMA  and
               its impact on ambient concentrations is not known. Optimum
               control of stationary source hydrocarbon  and carbon  monox-
               ide emissions has  been  proposed as an attainment measure.
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     Impact -- Reductions in excess of 90 percent in 1972
     hydrocarbons and CO could be obtained from such require-
     ments (as described in the Attainment Study).   This would
     more than account for the projected growth in  hydrocarbon
     and CO stationary source emissions in the AQMA.

     Legal Authority -- Existing legislation exists in the
     permit systems for Illinois and Missouri.  The control
     agencies would have to negotiate revised compliance sche-
     dules with affected sources as provided for in the state
     Air Conservation Laws.

     Implementation Obstacles — Costs to industry  is the
     primary obstacle.   Total capital costs for optimum control
     of hydrocarbon and CO stationary sources is estimated at
     $70 million.   The specific feasibility of individual
     systems is undetermined.

Phaseout or Prohibition of Emission Sources

     Description— Certain  emission sources are eliminated  by
     prohibiting their incorporation into new development.
     Existing sources are not affected until they require
     replacement.

     Applicability — Emission projections have already included
     the elimination of residential  hand fired coal  heaters.
     The disposal  of solid waste in electric power  plants
     provides an opportunity to phase out all on-site incin-
     erators.

     Impact — The reduction of TSP due to elimination of on-
     site incinerators  will  depend  upon how much of this solid
     waste would have gone to sanitary land fill  as opposed  to
     burning it.   It does not appear to be a significant factor
     in "hot-spot" TSP  reduction.   However, initial  experimen-
     tal  results indicate S02 emissions reductions  at the power
     plant of 5 to 10 percent can be achieved.   If  S02 com-
     pliance schedules  are enforced at the power plants, this
     additional  reduction may be sufficient to ensure mainte-
     nance in  the  vicinity of these sources.

     Legal  Authority --  Existing regulations defining the fuel
     limitations  for power plants can be modified to allow the
     burning of solid waste.
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               Implementation Obstacles -- The success of experimental
               results should eliminate opposition.   The only real  ob-
               stacle is the availability of supply.

          Control of Fugitive Dust Sources

               Description -- Control  of dust resulting primarily from
               construction activity

               Applicability -- Fugitive dust has not been inventoried
               throughout the St.  Louis AQMA, although the measure is
               applicable.

               Impact -- The City of St. Louis is currently listing small
               sources of particulates not included  in the point source
               inventory.  If these sources contribute significant amounts
               to the particulate concentrations in  the central  urban
               area, control of these sources could  be important to
               attaining the standards in this hot-spot area.  Paving and
               oil treatment of roads is already used to some extent to
               control fugitive dust.

               Legal Authority -- If new sources are  not covered by
               existing regulations, new regulations  must be added or
               existing particulate emission regulations tightened.

               Implementation Obstacles — Cost-effectiveness of small
               source control may be an obstacle.  The major obstacle at
               present is the lack of a completed fugitive dust source
               inventory.
2.   Administrative Procedures


a.   Emissions Allocation -- The Emission Allocation system requires that
emissions of pollutants be limited to ensure the NAAQS levels are met

within the AQMA.   The purpose of the emission allocation is to utilize

land use policies or control measures to maintain air quality levels
through the comprehensive land use plan.

     Thus, if future levels of land development in a region can be pre-

dicted, the type of air quality maintenance policies that would be neces-
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sary to ensure that air quality standards will not be violated could be
determined.  The revised comprehensive plan would provide a description
of the nature of future development and the policies required to maintain
air quality.
     The state air pollution agencies could delegate responsibility for
development of an emissions allocation scheme to the regional planning
agency (EWGCC).  The regional planning agency would then act in an ad-
visory capacity to the state air pollution agencies to inform them of
areas which are likely to exceed the emissions limitation.
     This administrative procedure can be based on the Regulation XXIII
described in Appendix I.  The regulation allows the pollution control
agency to adopt more stringent regulations in areas which exceed the
standards or exceed certain emissions limitations.  This regulation would
have to be strengthened to provide a variable emissions limitation
ceiling to prevent emissions from one jurisdiction which does not exceed
the limitation from causing an adjacent area to exceed its  ceiling due to
atmospheric transport of pollutants.  A regional emissions  allocation
system based on the assimilative capacity of the atmosphere would be the
best approach.
     The EPA Guidelines documents describe  six steps to integrate air
quality goals into the land use and transportation planning process under
the emission allocation procedures as follows:
     •    Compile detailed inventories of air pollution emissions in
          planning subareas of an AQMA or air basin.   Emission data must
          be obtained for each planning subarea and not disaggregated
          from county or AQMA totals.
     •    Designate maximum emissions allowable in each planning subarea
          to achieve and maintain air quality standards, based on an
          analysis of present air quality and the assimilative capacity
          of the air to absorb pollutants and still  maintain air quality
          standards.
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     •    Estimate planning subarea  emissions  likely to be  generated  by
          sources indicated in land  use  and  transportation  plans  for
          designated future time periods and compare these  emissions  with
          the allowable emission limits.

     •    Evaluate and revise regional land  use and  transportation  plans
          so that prescribed emissions limits  would  not be  exceeded.

     t    Adopt and implement regional land  use and  transportation
          plans, emission controls,  and  other  measures  that are  prepared
          to meet air quality goals  and  standards.

     •    Monitor public and private development through a  refined  en-
          vironmental impact assessment  process in which emissions  pro-
          jected directly or indirectly  from proposed projects are  ac-
          counted for.
     The key to this process is the concept of allocating air pollutant

emissions within an AQMA.   As long as plans and projects  conform to

prescribed emission limits, air quality standards should  be maintained.

     The Guidelines document suggests an appeal process  would permit

deviation from prescribed  limits where technical  information is available

to demonstrate that air quality standards will not be exceeded by the

proposed deviation.  The state air pollution agencies would create such

an appeal process.

     Some limitations of this strategy include:

     •    The assignment of powers over land use to a regional or state
          agency.  Municipalities will feel that they have lost some
          control over land use decisions to any agency  removed from
          direct popular control.

     •    The possibility that the regional agency will  make land use
          decisions ignoring other important social needs.  Comprehensive
          planning agencies will argue that "the tail is  wagging the dog"
          in regional land use planning, since air pollution control
          should be just one of the factors that influence regional land
          use decisions.
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     •    Using Regulation XXIII as the enforcing mechanism requires the
          area to exceed the NAAQS as the emissions limitation before
          corrective action begins.
     •    It may require an extensive EIS review process.
     •    It provides no assurance that the policies developed during the
          preparation of the air quality maintenance segment of the
          comprehensive plan will be implemented.

     The major advantage to this approach is that it can operate within
the existing institutional  structure with very little additional legal
authority required.

b.   Regional Development Planning -- This administrative procedure
requires that air quality considerations become an integral  part of the
regional planning process,  and that constraints on development be shown
in regional  plans if they are indicated to be necessary to maintain air
quality standards.   Regional  development policies by themselves may have
a significant effect on the location of pollutant emission sources and
the exposure of the populace to them.
     Several major  studies  are currently underway in St.  Louis that could
significantly impact regional  growth and development and the resultant
air quality.  Three such studies are described briefly below:
     •    Port Facilities Plan -- In late February 1974, a Phase I report
          on the study of the Port of Metropolitan St.  Louis was presented
          to the Council.   This report summarized the results  of the six
          objectives of Phase I of the study:
               Identify the role of the waterways and the impact of the
               Port on the  regional  economy
               Identify current and potential markets and the  Port
               characteristics to serve them
               Identify existing Port facilities
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          Identify constraints to Port development and needs

          Present findings, conclusions, and recommendations

          Prepare objectives and plans for Phase II

     Phase II, to be completed in late 1974, will  provide specific
     recommendations for actions to enhance the position of the St.
     Louis Port.  More details will be given as to the location of
     new and improved facilities, the organization of a regional
     port authority, and the location and type of industries that
     can be attracted to St. Louis with the new and improved port
     facilities.  The output of this study could affect the location
     of new industrial land and on the type of industry and amount
     of employment that can be expected from the industry.   All
     these factors will affect the development of the AQMP.

•    Railroad Relocation Study -- A draft of the results of this
     two-year study was represented to the Council  in late Spring
     1974.  The draft presented three proposals for relocating the
     maze of railroad tracks and yards in the St.  Louis region.  A
     total of 63 yards exist within the region.  The most ambitious
     and most costly plan calls for the creation of an 8-mile long
     main classification yard supplemented by 8 industrial  support
     yards.   The proposal, which has been generally backed by both
     government and business leaders, would free 1200 acres of land
     for development.  Much of this land would be along the river-
     front and would be desirable for industrial development.   This
     would have a dramatic effect on potential new point source
     emissions and on the AQMP development.  In addition, many of
     the 98 at-grade railroad crossings on the Illinois side of the
     region would be eliminated.   This would help to increase vehicu-
     lar traffic flow and should have an effect on the mobile source
     pollutants.  The final report of the study is expected by the
     end of 1974.

•    Airport Master Plan -- There is presently a controversy in the
     region concerning new airport facilities.  One faction wishes
     to keep the existing airport, Lambert-St. Louis International,
     as the main facility until the year 2000.  The second faction
     wishes to build a new 18,000-acre airport along the St. Clair-
     Monroe County boundary between Columbia and Waterloo, Illinois.
     Applications for master plans of both facilities have been
     filed with the Federal Aviation Administration; it appears that
     a short-range study with no land acquisition will  be approved
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          for Lambert and that a full study of the Illinois site will be
          approved.  Estimates are that the Lambert master plan would be
          completed by the end of 1974 or early 1975 and that the Illinois
          site planning would commence shortly thereafter.  These are
          vital to the AQMP development because of the drastic change
          that the Illinois site would make in land use and transportation
          activities.
     The conclusions  from  these  studies can  represent  regional  policy.  The
impact of these policy decisions on air quality could  be evaluated as
part of a revised regional comprehensive plan development.  For example,
the proposed railroad relocation could free many acres of land for re-
development.  If this land is developed for heavy industrial use, it
could have a significant impact on air quality.
     Regulation Number XVIII - Approval of Planned Installations, Land
Use Plans, and Zoning Regulations, requires the Executive Secretary of
the MACC to review all land use plans and zoning regulations and proposed
changes in zoning classifications prior to formal regulations and prepare
recommendations (see Appendix I).  No such plans or regulations may be
adopted without the approval of the Secretary.
     This regulation could form the basis of a review  process between the
state air pollution control agencies and the regional  planning body (EWGCC)
to ensure air quality maintenance through the comprehensive plan develop-
ment process as follows.   The state air pollution agencies could review
the revised comprehensive plan for consistency with the SIP and in parti-
cular air quality maintenance.
     The state air pollution agencies could delegate their responsibilities
under paragraphs B and C of Regulation Number XVIII to the regional
planning body to review the local land use plans and zoning regulations
for consistency with the air quality maintenance policies of the revised
regional  comprehensive plan.
     The planning agency (EWGCC)  would then inform the air pollution
control  agencies and the local  communities of its review.  In the case of
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inconsistency, EWGCC could advise the community and  request  a  revision  be
submitted for review.
     Since the community planners would participate  in  the development  of
the revised regional comprehensive plan,  conflict should  be  minimal.  A
variance board could resolve conflicts.
     This administrative procedure requires the development  of a  revised
regional comprehensive plan with air quality consideration and the periodic
review of regional  development programs or zoning regulations  for their
consistency with the air quality maintenance policies  of  the revised
regional comprehensive plan.
     It must be recognized that regional  plans, as well as community
master plans, rarely carry any legal enforcement. They are  dependent upon
zoning or other land use or ordinances for implementation.  Therefore,  the
review and revision of comprehensive plans or regional  development actions
alone would not provide for enforcement of these policies.
     Some action must be taken by the air pollution  control  agencies  if the
actual source development is not consistent with air quality maintenance
policies of the community plans.  This action could  be  part  of the existing
source review procedures.

c.   Emission Density Zoning — Requires that emissions of a pollutant be
limited to prescribed levels within a definite spatial  area.  This measure
is related to emissions allocation and is generally  applicable.  Special
application might be to the "hot-spot" areas.  As in emissions allocation,
the impact is dependent on the ability of this administrative approach  to
prevent the standard or allowable emissions level from being exceeded.   If
fully and accurately implemented, it should allow all  areas  to maintain the
standards.
     Since each municipality in the St. Louis area has  its own zoning
ordinance which cannot be overriden by the County, it is  assumed that
implementation would have to be at the local level.   This would require
a new zoning ordinance in each municipality. To implement at a regional
                                    72

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level would require each State to delegate responsibility for this parti-
cular zoning ordinance to a regional agency and the local zoning boards
to relinquish their authority in this area.  There would be strong politi-
cal opposition to such a move.

d.   Zoning Approval and Other Indirect Regulatory Controls -- This
involves controlling and directing urban growth through such techniques
as zoning, subdivision regulation, capital facilities ordinances, develop-
ment timing controls, moratoriums, policies for critical areas, and A-95
review process.   These measures are generally applicable at the local
level as part of any long-term community planning and development program.
These measures can be used to channel growth into areas that are not
overburdened from a pollution standpoint.
     Currently,  the authority to implement exists at the municipal level
for this class of measures.   However, it is not directed at controlling
air pollution.  All such indirect growth controls may be in direct oppo-
sition to many growth and development policies in the central  urban area.
As long as environment is not a community priority in these areas, social
and political  opposition to growth controls must be considered.

e.   Transportation Controls -- This term applies to a diverse group of
measures that directly or indirectly reduce emissions from mobile sources.
All such measures were considered in the attainment study for CO and
oxidants and are currently being reviewed  for inclusion in the Transpor-
tation Control Plan for St.  Louis to be submitted in February 1975.  The
reader is referred to these studies for a  review of the applicability of
these controls to St. Louis.

f.   Indirect Source Review and Environmental  Impact Statements -- These
are Federal  regulations as given in 40CRF  51 and NEPA Section 102(2)(C).
                                    73

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They provide requirements for reviewing and determining the impact of

proposed projects.   EISs are performed as required  by law.   However,  they

do not prevent the  completion of a project with  adverse air pollution

impact.  The Indirect Source Review agency has not  been designated as yet

in Missouri.
     The impact of  these measures in maintaining air quality is  indirect.

They act as a monitoring and surveillance program and are dependent upon

adherence to conclusions of these reviews.


3.   Conclusions

     The following  criteria were applied to the  generally applicable

measures described  above:

     •    Long-term effectiveness

     •    Effectiveness in preventing the location  of new sources in
          "hot-spot" areas.
     •    General application to the potential  problem or "hot-spot
          areas"

     •    Implementation obstacles


The conclusions from this evaluation are as follows:

     t    Long-term air quality maintenance requires a regionwide,
          comprehensive approach associated with the community planning
          process.  Two administrative approaches appear applicable and
          implementable--Emissions Allocation and Regional  Development
          Planning.

     t    Measures which have long-term general application and effec-
          tiveness as part of a comprehensive approach include:  indirect
          source review and EIS, transportation control measures, and
          indirect regulatory controls, Federal New Source Performance
          Standards.
                                    74

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     •    Emission source control measures which have short-term or long-
          term effectiveness in the "hot-spot" areas include:  more
          stringent controls on existing sources, phaseout of emission
          sources, control of fugitive dust.
C.   RECOMMENDED ATTAINMENT/MAINTENANCE STRATEGY
     The air quality analysis, status of attainment plans, and evaluation
of maintenance strategy alternatives indicate that the best available
approach to the attainment and maintenance of air quality in the St. Louis
AQMA is a program which includes:
     t    Full implementation and enforcement of all attainment plan
          measures included in the state implementation plans
     •    Expanded monitoring and surveillance through the RAPS/RAMS
          programs
     •    Long-term comprehensive approach to air quality maintenance
     •    Interim measures to ensure maintenance during the period
          required for development and full implementation of the long-
          term approach.

     A summary of the proposed plan elements for each pollutant is shown
in Table IV-1.  The following sections describe the recommended Interim
Measures and Administrative Approach which could be used as the basis
for the long-term comprehensive plan.  The Intergovernmental  Cooperation
required to implement this plan is described in Chapter V.

1.   Interim Measures
     As indicated in the previous section, immediate interim measures may
be the best avenue for air quality maintenance in St.  Louis until  the
AQMP can be incorporated into a comprehensive plan in the late 1970s.
Several of these interim measures are described below.
                                    75

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a.   Municipal Refuse (S02 Control at Power Plants) -- Approximately
three years ago, the EPA, Union Electric, and the City of St. Louis
embarked on a pilot project to determine the feasibility of using muni-
cipal solid wastes as a fuel in power plant generators.  The results of
the experiment were made public in early 1974.  They indicated that it
was feasible and, in fact, economically profitable for Union Electric.
Discussion with Union Electric officials and newspaper reports indicate
that by 1977, Union Electric will have a system organized whereby all the
public and private refuse collectors will take the refuse to a sorting
station, where the burnable refuse will be separated from the nonburnable.
The nonburnable, principally metals, will be sold as scrap while that
which can be burned will be taken to the main power plants.  It will be
used as almost 10 percent of the fuel requirements for the generators,
with 90 percent of the fuel being coal.  This use of refuse as a fuel
should reduce S02 emission by a minimum of 5 percent and a maximum of
10 percent at the power plants.  The trial data indicates TSP emissions
at the plant are not significantly increased.  This measure does not
provide a significant additional decrease in TSP emissions in the "hot-
spot" areas due to decreased use of municipal incinerators, because most
of this solid waste burning is being phased out due to use of sanitary
landfill.

b.   Sulfur Dioxide Emission Reductions at Three Major Power Plants --
The projected emission inventory data for the Labadie, Meramec, and Sioux
power plants of Union Electric do not contain a future reduction to
account for S02 control  of stack gases, even though the three plants
would be in violation of Missouri state regulations for allowable S02
emission rates in the St.  Louis area (2.3 pounds per 106 BTU input).
Recently,  EPA issued a notice to Union Electric Company which indicated
that these three plants may prevent attainment of NAAQS.  The notice
                                    77

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called for a conference with the company to determine S02 compliance
schedules for the three plants, which would subsequently be enforceable
by EPA.
     If emission reductions are required, they will  probably occur prior
to 1978 and, therefore, may be considered as interim maintenance measures.
     These potential  reductions represent a large portion of total  pro-
jected regional  S02 emissions.  Compliance with the  existing regulations
would bring about the following percentage reductions (from the 1975
projected emissions), according to calculations performed by EPA:
     t    Labadie --  56 percent
     •    Meramec —  6 percent
     t    Sioux  -- 53 percent

     This is equivalent to approximately 383,000 tons/year of S02
eliminated for all three plants, or 38 percent of projected 1975 S02
emissions in the AQMA.
     Reductions  at two of the plants probably could  not be achieved just
by using lower sulfur coal.  If control  equipment is installed to remove
S02 from the stack gases, even higher control efficiencies than those
required by the  regulations might be obtained.

c.   Indirect Source  Review (Carbon Monoxide Control) -- The Transportation
Control Plan for the  St. Louis area, scheduled to be submitted in Feb-
ruary 1975, will provide for attainment of CO and oxidant standard by at
least 1977.  The emission analysis in Chapter III indicates that total
emissions of CO  for the AQMA, individual counties, and the individual
subcorridors, should  decrease from the attainment date until 1985.   This
continuing reduction  in emissions primarily reflects the greater impact
of the Federal Motor  Vehicle Control Program (FMVCP).
                                    78

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     Based on the projected decrease in emissions and on assumptions that
a Transportation Control Plan is approved, the only remaining problems
with maintenance of the CO air quality standard through the year 1985
should be a microscale or individual indirect source level.
     Significant new and modified indirect sources in the AQMA are sub-
ject to a prior analysis of their local impact on CO concentrations by
EPA or its designated review agency.  This review procedure should ensure
that no new or modified indirect sources cause the CO air quality stan-
dard to be exceeded locally in the interim period until an air quality
analysis can be incorporated into the regional transportation planning
process, and should be equally effective thereafter.   Thus, indirect
source review is capable of preventing all of the near-term potential
microscale problems not considered in the Transportation Control Plan.
The FMVCP, and indirect source review provides a comprehensive approach
to CO control and maintenance in this interim period.
     The requirements and general activities of the review process are
described in 40 CFR 52 of the Federal regulations.  At the time of
preparation of this report, Missouri had not yet designated the agency(s)
responsible for the review in the St. Louis AQMA, nor had it established
the detailed procedure for submitting applications for approval or review
of these applications.   Therefore, the mechanics of the review and pro-
cedures for coordination with the agencies implementing the Transportation
Control Plan cannot be described herein.
     According to the Federal  regulation, approval of a proposed indirect
source is to be based on the following two criteria:
     •    No violation of the applicable control  strategy of the Trans-
          portation Control  Plan
     •    No violation of the carbon monoxide standard or no delay in the
          attainment if the date specified for attainment has not been
          reached
                                    79

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     Both of these determinations will  require data on existing CO con-
centrations at proposed sites of indirect sources.   It is anticipated
that this data would eventually be available from the transportation
planning agency as part of their ongoing program.  However, during the
interim period, this information would  need to be generated for each
specific location by the applicant or the designated review agency.

d.   Exclusive Bus/Carpool Lanes (Carbon Monoxide Control) -- This
measure would help reduce the number of vehicle trips made in the AQMA,
especially during the morning and evening peak traffic hours.  One
freeway in St. Louis, 1-70, is well suited for such a conversion to
bus/carpool lanes.  The freeway has two center reversible lanes that are
used as express lanes for vehicles in the peak hours.  The traffic flow
in these lanes is with the major flow of the particular peak hour--
inbound to the central business district (CBD) in the morning and out-
bound in the evening.  The lanes could  be converted to bus/carpool lanes
with a minimum of effort.  They would operate similarly to the Shirley
Highway (1-95) bus/carpool lanes in the northern Virginia suburbs of
Washington, D.C.   Prior to the energy emergency in the winter of 1974 a
six percent reduction in automotive VMT had been realized on this facility.*
     Since traffic volumes along 1-70 in St. Louis approach 100,000
vehicles per day, a six percent reduction, especially during the morning
and evening peak hours is significant.   Using an estimate of a.m. peak-
hour volume of 12,000 vehicles on a six mile stretch of 1-70, an exclu-
sive bus lane along six miles of the facility would produce 72,000 VMT.
A six percent reduction would mean 4,320 less automotive VMT on the free-
way during an a.m. peak period.
*Fisher, R.  Shirley Highway Express Bus on Freeway Demonstration Project.
 Prepared for presentation at Highway Research Board 51st Annual Meeting,
 January 1972, p. 11.
                                    80

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     There should also be some thought given to providing preferential
bus usage of curb lanes on major city streets.   This measure would
increase the speed of buses, thereby making them attractive to the
public as a means of transportation.  This should increase ridership and
reduce the overall number of vehicle trips made in the AQMA.  This action
would help reduce the amount of HC and CO emissions for the AQMA and
thereby improve air quality in the heavily traveled corridors.
     Analysis in the Attainment Study report indicated that approximately
160,000 VMT per day would be eliminated along major routes through the
increased use of mass transit.   A report of the Bi-State Transit System
suggested controlled curb lane usage along four routes and the possibility
of such usage on two other routes.*  The total  mileage of the six routes
equaled 40, thus, the VMT reduction per mile equalled 4,000.  The routes,
their length, and subsequent VMT reduction follow:
               Route              Length (miles)      VMT Reduction
     Natural  Bridge/N.Florissant/
     12th Street                       8.0               32,000
     Lindell/Olive Street              4.5               18,000
     Southwest Ave./Vandeventer/
     Market Street                     6.0               24,000
     Gravois/12th Street               7.0               28,000
     Kings Highway                     8.0               32,000
     Del mar                            6.5               26,000
               TOTAL                  40.0               160,000
*Transit Improvement Program, 1971-1975.   Bi-State Development Agency,
 St.  Louis, Missouri, January 1971, p.  48.
                                    81

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      Additional  routes  will  be developed  during  the master  plan  update
 that the City of St.  Louis  is  preparing and  in the regionwide  mass  tran-
 sit study that East-West  Gateway  will  initiate by the  end of the summer.
•     Once these routes  have been  decided,  legal  authority must be exer-
 cised in order to implement them.  Along  1-70 and any  other freeway that
 may be used,  the Missouri Highway Department must be consulted since  they
 own the right-of-way for  the freeway and  provide all maintenance for it.
 The Highway Department  must agree to any  exclusive use of the  freeway
 lanes irrespective of local  jurisdiction.
      Within the City of St.  Louis, an ordinance  must be passed that will
 spell out the uses of the freeway lanes and  the  preferential curb lanes
 for each street.   This  ordinance  must specify the street, the  section of
 the street, the time of day,  and  what vehicles are permitted to  use the
 lane.  Penalities and/or  fines must  also  be  included in the ordinance.
 St. Louis County is developing an arterial road  system. Should a pre-
 ferential curb lane that  is on the system be required  on the street over
 which the County has jurisdiction, an ordinance  must be passed.   If the
 lane is on a  street that  is not on the system, then the local  community
 has jurisdiction and must pass the ordinance.

 e.    Cost-Effective Stationary Source Hydrocarbon Controls  (Oxidant
 Reduction)  -- The Attainment Study for CO and oxidants described optimum
 control  by major stationary sources  in the St. Louis area.* The major
 objection to  this measure is  the  $70 million cost estimate.  These
 controls are  described  as "maximum,  technically  demonstrated,  control
 technology."   If these  controls are  adopted  as part of proposed  Trans-
 portation Control  Plan  Strategy III, they  will provide sufficient control
 together with Federal New Source  Performance Standards for  these sources
 *PEDCo-Environmental  Specialists,  Inc.
                                     82

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to attain and maintain the oxidant standard through at least 1985.  If,
however, they are not adopted, some form of stationary source HC control
will be required as a maintenance measure to account for the projected
growth in this category of sources.  In this case, it is recommended that
a cost-effective level of control be negotiated with each source.  This
would require the least-cost systems which would provide for maintenance
of regional HC emissions at the level of the standard or below.  That is,
once the standard is attained by the TCP, any expansion at the source
must be counteracted by an equivalent reduction due to increased control
of existing emissions.

2.   Recommended Long-Term Comprehensive Approaches to Air Quality
     Maintenance
     A regional  comprehensive approach to air quality maintenance for the
St.  Louis AQMA is required if long-term land use and environmental
objectives are to be attained.   While air quality considerations can be
incorporated into local planning efforts, the overall  guidance must be
provided from a  regional perspective.  The technical and administrative
problems of using local planning to achieve air quality support the need
for a regional approach to develop policies related to air quality
maintenance.  For example:
     t    Local  efforts to improve air quality in existing problem areas
          cannot be accomplished without comparable efforts in other
          areas, because of the interjurisdictional transport of pollutants.
     •    Local  land use plan impacts on air quality cannot be quantified
          without a regional  approach.
     •    Local  land use plan impacts on traffic volumes and transpor-
          tation system needs cannot be evaluated except within the
          context of regional multimodal models.
     t    Oxidant is an areawide pollution problem that requires region-
          wide policies for control.
                                    83

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     Due to these and other factors,  the development of a regional  compre-
hensive approach to air quality maintenance appears to be the primary
long-term maintenance strategy for the St.  Louis AQMA.   To be approveable
and effective, such a strategy must be shown to be both implementable and
enforceable.  This requires the integration of air quality maintenance
and comprehensive planning.  In fact, specific long-term measures  which
may be adopted as part of such a regional plan will be dependent on the
plan for effective analysis and implementation.
     A first step in the implementation process requires the development
of a revised or updated regional comprehensive plan using air quality
maintenance as a constraint.
     This could be accomplished by an evaluation of alternatives for
environmental and, in particular, air quality impact.   The existing re-
gional plan could be quantified to provide a baseline for comparison of
alternatives.  A maximum effort would require a detailed quantification
of the land use and transportation plans.
     Four major studies are currently under way, the results of which
could have a significant impact on development of policy, and thus on
the urban structure.  These are:
     t    The railroad relocation study
     •    The airport feasibility study
     •    The port feasibility study
     •    The mass transit study with the transportation planning  process

     The impact of changes in these facilities on air quality must be
evaluated.  This provides an opportunity to develop the methods to evaluate
alternatives.  It also provides an opportunity to develop techniques to
quantify the effects of policies or policy decisions on air quality.
                                    84

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     Air quality maintenance policies may be developed in an attempt to
ensure that various alternatives meet the air quality constraints.  These
policies should be incorporated into the body of policies and goals which
are part of the comprehensive plan.
     The next step in the implementation and enforcement process would be
to follow and enforce an administrative procedure developed to ensure ad-
herence to the policies developed.  Two alternative administrative pro-
cedures were described above which are considered applicable.   The State
Air Pollution Agencies, the regional planning agencies, and local and
public agency representatives should select the most appropriate method.
The selected approach must be presented to the public together with the
revised comprehensive plan at public hearings.  The comments from the
public hearings must be considered in the plan.
     Emissions allocation appears to be the best administrative approach
for long-term air quality maintenance from a standpoint of adequacy and
enforceability.  However, the administrative structure and procedures
required to implement this approach will take considerable time and
effort to establish.   It is therefore recommended that Regional Develop-
ment Planning be implemented until the optimal procedure and structure
for implementing an Emissions Allocation approach can be determined and
implemented.
     A review of the  impact of the four land use and transportation
projects described above can be used as the first step in implementing
this regional  development planning.  In addition, the Air Pollution
Agencies and the EWGCC Advisory Board should cooperate to "persuade"  new
significant sources of TSP and S02 to avoid the "hot-spot" areas.
     If persuasion fails to obtain the desired results, the "hot-spot
regulation" (see Appendix I) and new source review regulations can be
strictly enforced to  formalize the planning procedure.   The deterrent to
strict enforcement of these two regulations is that they are applied
                                    85

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after many decisions and commitments have been made by the source.
Community priorities or pressures may also be involved at this point,
creating political  opposition to the enforcement of these regulations.
     As the administrative structure and technical  review procedures
needed for an Emissions Allocation system are developed, they can be
phased in by application to the "hot-spots."  The RAPS program should
provide the data and techniques needed to determine an emissions ceiling
in each planning area of the community.   Emissions  allocation can then be
used as a technique to justify strict enforcement of the existing or
modified "hot-spot regulation" and Source Review Regulations; or the
Emissions Allocation can be formalized by adopting  regulations estab-
lishing regional and/or local area emissions ceilings.
     It is recommended that the final form of the administrative struc-
ture and technical  review procedures be determined  through the coopera-
tive efforts of air pollution agencies and community planning represen-
tatives in order to ensure the incorporation of air quality maintenance
into comprehensive community planning and community goals and objectives.

D. '  TIMETABLE FOR DEVELOPMENT AND IMPLEMENTATION OF AIR QUALITY
     MAINTENANCE
     The major feature of the proposed longterm maintenance strategy is a
comprehensive approach which incorporates air quality maintenance into
the community planning process.  There are many issues and constraints
which must be resolved before such an approach can  be implemented.   Dis-
cussions with planning community and air pollution  agency representatives
suggested that the interagency coordination required to implement a long-
term comprehensive approach would take two to three years to establish
(see Chapter V).  If a formal or mandatory control  program, such as
emissions allocation, is selected as the desired administrative approach,
some additional legal authority will be required in order to implement
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this program on a regional basis.  These constraints are discussed in
detail in the following section.  The conclusion is that the recommended
comprehensive approach cannot be fully implemented for three to five
years and "stop-gap" measures are therefore required to maintain the
standards during the interim period.
     It is therefore recommended that the development and implementation
of the maintenance plan be phased.  Figure IV-1 shows the suggested
timetable for development and implementation of the comprehensive air
quality maintenance plan.  The key milestones are indicated.  The chart
suggests that the maintenance plan consists of three primary elements:
     •    Source control measures
     0    Transportation policies or measures
     •    Land use policies or measures

     There are three major phases shown for AQMP development and imple-
mentation:
     t    Phase 1 -- now to June 1975
     •    Phase 2 — June 1975 to June 1980
     •    Phase 3 -- June 1980 to June 1985

     During Phase 1, the attainment measures (including the TCP) and the
interim measures would be finalized and submitted to EPA in June 1975.
The task descriptions, agency responsibilities, and funding requirements
for the long-term comprehensive plan development would also be submitted
to EPA in June 1975.  In addition, interagency memoranda of understanding
would be obtained stating the agency responsibility in plan development
and agreements to persuade new industry with significant TSP or S02 emis-
sions to avoid the "hot spot" areas.  Any transportation system improve-
ments or review procedures, mobile source controls, or indirect source
                                    87

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control programs which are required for attainment or maintenance will
be delineated and presented in the Transportation Control Plan or the
Maintenance Plan submitted in June 1975.
     Phase 2 consists of the selection and development of the long-term
comprehensive approach; the implementation of all TCP measures, trans-
portation policies or measures required for maintenance, interim source
control measures required for maintenance, and voluntary compliance with
the "hot-spot" land use policy.  If voluntary compliance with the
"hot-spot" policy is not effective, the MACC "hot-spot" regulation can
be strictly enforced for existing sources.  Any SIP revisions will also
be completed during this time period.
     By 1980, it is expected that all administrative programs, legal
authority, and monitoring and surveillance requirements of the comprehen-
sive long-term plan can be implemented.  The AQMP development can then
become a five-year review and revision cycle, as proposed in the EPA
Guidelines.

E.   MONITORING AND SURVEILLANCE
     In order to ensure that air quality and emissions standards are
maintained, the regional planning agency (EWGCC) must monitor development
and the state air pollution control  agencies must monitor air quality.
Maximum allowable emissions can be set according to calculations
from current air quality levels in the AQMA.   This can be accomp-
lished with a diffusion model  that establishes a relationship between
total  air pollutant emissions in a region and the assimilative capacity
of the ambient air.   The input data for this calculation must be supplied
by both the planning agency and the state air pollution control  agency.
The allowable emissions in AQMA should be recalculated during the five-
year update of the comprehensive plan and whenever there are significant
changes in development and urban growth.   Therefore, continuous  review of
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ambient air quality data and environmental  impact of new development will
create a mechanism to monitor the effectiveness of the air quality main-
tenance plan.

     The Interim Measures required to ensure attainment and maintenance
of the NAAQS through 1978 or 1980 can be monitored with the expanding
monitoring program (RAPS/RAMS).   Long-term comprehensive approaches will
require additional surveillance.   If Emissions Allocation is selected as
the means of implementing the strategy, the state air pollution control
agency should perform the following monitoring duties:
     t    Establish allowable emissions for each pollutant
     t    Provide emissions factors for land use and transportation plans
     t    Review emissions limits periodically and adopt amendments when
          new data indicates changes in air quality
     •    Monitor ambient air quality and source emissions

The regional planning agency should perform the following duties:
     t    Determine that the comprehensive plan is consistent with the
          allocation of emissions limits
     t    Provide a report of projected emissions from the comprehensive
          plan alternatives
     •    Coordinate with the state air pollution control agency in
          approving a comprehensive plan for the AQMA

     The overall responsibility for monitoring and surveillance of the
AQMP is retained by the state air pollution control agency to ensure
compliance with the NAAQS.
     In regional development planning, no formal EIS is required to be
reviewed by the state air pollution control agencies.  Therefore, monitor-
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ing and surveillance of the effectiveness of the strategy is limited to
the following:
     •    Review of local land use plans and zoning regulations for
          consistency with the regional comprehensive plan
     •    Review of regional development policies for consistency with
          the regional land use and transportation plans
     •    Ambient air quality monitoring
     t    Monitoring of demographic, economic, and social activity trends

F.   CONSTRAINTS TO AQMP IMPLEMENTATION
     In general, it may be noted that there are few constraints to imple-
mentation of the Interim Measures.  This is true because measures have
been selected which are considered implementable or already underway
by June 1975.  One notable time constraint is the feasibility or avail-
ability of S02 controls for power plants.  EPA has filed several suits
requiring these controls.  The outcome of these suits will  determine how
soon the S02 controls can be implemented.
     Implementation of the long-term comprehensive plan, however, will
have many obstacles or constraints including the complexity of the
planning process, funding, and opposition to enforcement of strong
legislation.

1.   Complexity of Planning Process
     The complexity of the government and planning community is described
in Chapter V.  Air quality planning and implementation are  distributed
among three agencies with concurrent jurisdiction on the Missouri side,
and the Illinois EPA on the Illinois side.   Two strong planning agencies
exist in the area--the East-West Gateway Coordinating Council  and the
South-West Illinois Metropolitan Planning Area Council--with the former
covering the entire AQMA.   The SWIMPAC represents the three Illinois
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counties only.  However, they have no authority to do air quality planning
and no funding to carry out such planning.
     The comprehensive plan including the land use and transportation
components provide major input to the development of the AQMP.   At the
present time, numerous parts of the comprehensive plan are being pre-
pared, however, several components will  not be completed in time for the
AQMP development.

a.   Land Use Plans -- Of the eight political  jurisdictions under the
East-West Gateway Coordinating Council,  only St.  Charles County has an
approved land use plan.  Franklin County has a land use component of its
Sewer and Water Plan but not a complete  land use plan.  St. Louis County
is in the process of revising the land use plan based on new population
projections—the plan will be presented  for approval late in 1974.  The
City of St. Louis has a plan which is presently awaiting action before
the planning commission.  Jefferson County eliminated planning and zoning
in 1971 and therefore has no land use plan and apparently does not intend
to develop one.  In Illinois, Madison and St.  Clair Counties' plans are
being updated by SWIMPAC, based on new population projections.   Monroe
County is awaiting a Federal decision as to the location of a new airport
before developing a land use plan.
     Most of these plans are expected to be completed by the end of 1974
and can then be incorporated by the Council into the region's comprehen-
sive plan.

b.   Transportation Plans -- The transportation plan for the region is
divided into two portions:  streets and  highways, and mass transit.  The
streets and highways portion has been approved and adopted by the Council;
the mass transit portion has been deferred, pending a new study.  This
study is scheduled to begin in the summer or early fall of 1974 and
                                    92

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requires approximately nine to twelve months to complete.  It is important
to the AQMP development because of the impact it will have on the distri-
bution of person trips in the region between highway and transit modes.

2.   Funding
     In order to ensure that environmental considerations are integrated
into the comprehensive planning process, a funding mechanism should be
established.  This mechanism would provide both the designated compre-
hensive planning agency and the designated control agency with sufficient
funds to ensure proper consideration and enforcement of environmental
aspects of the long-term comprehensive maintenance plan.
     As with many other programs of other Federal  agencies, notably DOT
and HUD, EPA could set up a program of providing direct grants for
incorporating environmental consideration into the planning process and
for enforcement of environmental controls.  These grants could be dis-
tributed in two ways:  directly to the designated air pollution control
agencies or directly to the local  planning agencies through contract with
the state air agencies.
     For the situation in the St.  Louis AQMA, possibly the best solution
would be to set up a mechanism that is basically a combination.   Funds
for comprehensive transportation and land use elements could be given to
the EWGCC and funds for overall AQMP development,  implementation and
enforcement could be given to the two state agencies; the Missouri Air
Conservation Commission and the Illinois Environmental Protection Agency.

3.   Enforcement
     Opposition to enforcement of regulations will remain the most diffi-
cult obstacle to implementation.   If alternative growth plans are to be
evaluated solely on the basis of air quality impact, then air quality
goals will  continue to conflict with other community goals with the
                                    93

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result that variances may continue to be the rule rather than  the excep-
tion.  If, on the other hand, air quality is incorporated into community
goals through the comprehensive planning process, conflict can be mini-
mized, if not eliminated.   The role of waste water treatment planning
should be considered simultaneously.   This incorporation of air quality
considerations is a complex process which may require considerable time
and effort to institute.   The time to implement such planning  considera-
tions will be extended by the complexity of the governmental structure
and the lack of funding.

G.   LEGAL AUTHORITY
     The enabling legislation given in the State Implementation Plans is
sufficient basis for the implementation of all source control  measures
required for attainment and maintenance of the standards.
     The long-term comprehensive approaches to air quality maintenance
described above are administrative approaches.  They are intended to
maintain air quality indirectly by the application of land use and trans-
portation policies which tend to minimize emissions, especially in the
"hot-spot" areas.  Specific land use control regulations may be adopted
to formalize these policies.  For example, emissions allocation can be
implemented as a regulation calling for a ceiling on emissions within
each small community or geographic area within the AQMA.
     The following sections describe existing legislation directly re-
lated to air quality maintenance and the modifications or extensions to
existing regulations which would be required to implement specific source
controls or land use measures.

1.   Existing Legislation
     The Air Quality Implementation Plans and related regulations as
adopted by Missouri and Illinois form the enabling legislation for the
                                     94

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 St.  Louis AQMA.  Attainment of  the  standards will rely on  implementation
 and  enforcement of  these regulations.  Any regulations adopted as a
 result of the Transportation Control Plan currently being  prepared will
 become part of this body of regulations.
     Two regulations  included in the Missouri SIP are particularly appli-
 cable to the maintenance of air quality once the standards are attained.
 These regulations are summarized briefly below.  (See Appendix I for
 complete regulation).

 Regulation XVIII.  Approval of  Planned Installations. Land Use Plans,
 and  Zoning Regulations Required —  This regulation is the  basis for
 permit system for new sources.  Paragraph B of this regulation requires
 the  executive secretary of the  MACC to review all land-use plans prior to
 formal adaption and local areas and prepare recommendations according to
 the  regulations.  No local plan may be adopted without the approval of
 the  executive secretary.  Paragraph C places similar requirements on the
 review and approval of zoning agency regulations and proposed changes in
 zoning classifications.
     This regulation is not currently implemented in the AQMA and because
 no penalties are stated for non-compliance, the agency has no enforcement
 authority.  However, it could serve as the basis for monitoring all
 planned community growth and development.

 Regulation XXIII.   Additional Air Quality Control Measures May be Required
when Sources are Clustered in a Small Land Area — This regulation applies
 to particulate and S02 emission sources in areas which exceed a given
allowable emission density.  The MACC may prescribe more restrictive
 requirements in such areas than are provided in the regulations of general
applicability.
     This is referred to as a "hot-spot" regulation.   It provides for
more restrictive controls where source clustering may cause the standards
                                     95

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to be exceeded although all  emissions limitations  are being met.   This
regulation is not currently being implemented because many compliance
schedule deadlines have not been reached.   However this  regulation could
be applied to maintain emission density levels below that level  estimated
to exceed the standards for particulates and sulfur dioxide.   This would
require an accurate estimate of the relation between emission density and
ambient concentration in a given area.   This relationship may vary due to
source-receptor characteristics of an area.   The RAPS program should
provide sufficient data for this determination.   Short-term emissions
limitations would be the most difficult to establish.

2.   Additional Regulations Required to Develop, Implement, or Enforce
     the Air Quality Maintenance Plan for the St.  Louis  AQMA
     The air quality maintenance strategy described in Chapter IV consists
of (1) a package of Interim Measures to ensure air quality maintenance
during the period from AQMP submittal (June 1975)  to June 1978,  and (2)
options for a comprehensive approach to long-term air quality maintenance
to be developed and implemented from June 1978 to 1980.   A brief summary
of the additional legal authority required (if any) to implement each
segment of the air quality maintenance strategy is given below.

a.   Interim Measures — The Interim Measures described  above rely on
enabling legislation as adopted by Missouri  and Illinois and described in
the State Implementation Plans.  In addition, the following minor revisions
or additions to the existing regulations may be required to implement and
enforce these interim measures.
     •    Strict Enforcement of Power Plant Compliance Schedules may
          require clarification of the interpretation of existing regu-
          lations.  However, no new regulations are required.
                                    96

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          Indirect Source Control regulations have not been adopted by
          the states as yet.  The designation by Missouri of the Indirect
          Source Control Agency and adoption of regulations is expected
          by January 1975.

          Stationary Source Hydrocarbon Control at least to the level  of
          cost-effecti veness.
b.   Long-Term Comprehensive Air Quality Maintenance Planning and
Implementation -- Two alternatives are described as mechanisms to imple-
ment and enforce a comprehensive approach to air quality maintenance.

Enabling legislation and regulations will be proposed as the selected
approach is defined.
     The two major administration approaches to air quality maintenance
and the legal authority required are described briefly below:

     •    Emission Allocation Procedure ~ A relationship is established
          on a regional level between the assimilative capacity of the
          ambient air and the amount of emissions that would violate the
          standards.  Regulations are required to establish emissions
          ceilings.   MACC Regulation No.  XXIII (See Appendix I) could be
          modified to form the model regulation.

          The administration of an emissions allocation system must be
          regionwide to account for transport of pollutants across juris-
          dictional  boundaries.   This would require that a regional
          or-ganization such as the East-West Gateway Coordinating Council,
          or Bi-State Development Agency be delegated the authority by
          each state to implement such a system.   The authority to enforce
          the regulations would remain with the air pollution control
          agencies.

     •    Air Quality Maintenance as a Constraint in Regional Development
          Planning -- This option requires the regional planning agency
          to develop a revised comprehensive plan incorporating air
          quality maintenance as a constraint in the evaluation of
          alternatives.

          MACC Regulation No.  XVIII requires the  review of land use plans
          and zoning regulations for consistency  with the State Imple-
          mentation  Plan before adoption of such  plans or regulations.
                                    97

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Therefore, there is some existing authority to support such a
revision to the comprehensive plan.   However, it would be
desirable to provide a mechanism to enforce the policies
developed.

The State air pollution agencies could adopt the policies
employed to represent air quality maintenance in the revised
comprehensive plan as revisions to the SIPs to enforce air
quality maintenance.  To implement and enforce such policies,
the existing source review procedures must require compliance
with these policies.
                          98

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          V.  INTERGOVERNMENTAL COOPERATION AND COORDINATION

     The Air Quality Maintenance Plan described above consists of a
set of goals, policies and actions needed to preserve air quality.   To
be successful, however, the AQMP must realize two major administrative
objectives.   First, the plan must facilitate the coordination of land
use and transportation planning with source control  measures, and within
an institutional  framework which directly links planning, implementation,
and enforcement.   Second, the plan must be developed within the constraints
of time and jurisdictional complexity.   The special  problem in the St.
Louis area focuses on the complexity of developing,  administering,  and
enforcing such a  plan in a situation involving two states and two Federal
regional  jurisdictions.

A.   ALTERNATIVE  INSTITUTIONAL ARRANGEMENTS
     The administrative objectives suggest possibilities for alternative
institutional arrangements and new institutional forms, as well  as, limit
the scope of any  new possibilities.   Specifically, coordinated land use,
transportation planning, and source control  measures suggest the possi-
bility of several  alternative institutional  arrangements.   These include:
     •    A  regional, interstate agency with planning,  implementation,
          and enforcement powers in land use and transportation planning,
          and source control.
     •    A  cooperative arrangement between two state agencies, each
          of which would have increased current air  quality functions
          to include land use and transportation planning.  (This assumes
          these agencies presently have enforcement  powers.)
     •    An arrangement to increase the technical capabilities of  the
          East-West Gateway Coordinating Council, to include air quality,
          as well  as provide the Council  with powers of implementation
          and enforcement for land use  and transportation planning  and
          source  control.
                                    99

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     •    A composite arrangement of existing institutions  coordinating
          their particular areas of responsibility  with  the long-range
          goal  of creating an institutional  structure(s)  with  the  appro-
          priate enabling powers.
B.   CONSTRAINTS TO ALTERNATIVE INSTITUTIONAL ARRANGEMENTS
     Viewed .from the vantage of current constraints,  particularly  time
and jurisdictional  complexity, it is doubtful that all  but the latter
          e, i.e., to coordinate existing institutions, will  be attained.
1.   Time
     With respect to time, the June 1975 deadline for  the  AQMP  does  not
allow sufficient time for the passage of appropriate enabling  legislation
for new agencies or for additional  functions  and  powers  for  existing
agencies, at least for the first phase.   Significantly,  the  June  1975
deadline, even if new agencies did  exist, would limit  the  development
of adequate information, appropriate analyses of  the data, and  proper
technical, citizen, and political  participation.

2.   Jurisdictional Complexity
     Similarly, in the context of jurisdictional  complexity, the  respon-
siblity for land use, transportation and source control  plan elements
is widely dispersed throughout the  various jurisdictions involved,  in-
cluding the state and local governments  (see  Figure V-l).
     In the area of planning for source  controls, the  states have prime
responsibility.  In the case of land use, the prime responsibility lies
with the city or county, while in the transportation planning  field, it
rests with the East-West Gateway Coordinating Council.
     Many other jurisdictions are involved in the planning process,  pri-
marily in an advisory role.  In the area of source control,  the Federal,
city, and county governments are involved.  In the case  of land use,
                                    100

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the states and the East-West Gateway Coordinating Council  have advisory
roles.   In transportation, the Federal,  state,  and local  governments  play
an advisory role, although the states play a very important role in
highways and the Federal  government in transit, since they largely control
the capital funds.
     In the area of implementation, the  primary responsibility for source
control rests with the states, although  in Missouri,  because of the com-
petence available at the City of St. Louis and  the County of St.  Louis
levels, the state had assigned this responsibility to the air pollution
agency in those jurisdictions.  In the area of  land use,  the primary
responsibility for enforcing and controlling development  rests with the
city or the county, except the county does not  have jurisdiction in those
sections which are incorporated within its boundaries.   In the area of
transportation, highways are major facilities developed by the state,
while local facilities are provided by the city or county.   In transit,
major improvements are primarily developed by the Bi-State Development
Agency, which is an interstate agency created some time ago primarily to
develop the transit system.  It operates the existing metropolitan area
bus service.
     In connection with the control or enforcement related to transpor-
tation, the authority for highways rests with the state,  the city, or the
county.  For transit, it primarily rests with the Bi-State Development
Agency, although the East-West Gateway Coordinating Council is often
concerned with policy issues related to the operation of the system.
     Needless to say, institutional patterns such as those outlined
above are not easily altered, particularly when long standing institu-
tional prerogatives are at stake.  Such wide dispersion of authority
and division of labor minimizes any significant chance for major in-
stitutional consolidation/reorganization in the short run, especially
by the June 1975 deadline.
                                    102

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C.   OPPORTUNITIES FOR INSTITUTIONAL COOPERATION AND COORDINATION
     The preceding discussion of constraints suggests that the most reason-
able approach to meeting administrative objectives relative to the AQMP
rests in the coordination of and cooperation between existing institutions
servicing the AQMA.

1.   Existing Coordinating Mechanisms
     The primary coordinating mechanisms in the St. Louis metropolitan
area is the East-West Gateway Coordinating Council.  This Council was
established about 10 years ago, primarily to respond to the highway
requirement to set up a continuing, comprehensive, and cooperative
planning process in the metropolitan area, referred to as the 3-C Process.
Through this process, and the East-West Gateway Coordinating Council
(EWGCC), various transportation and land use plans have been developed
for the metropolitan area.   The Council is also responsible for programs
related to open space, recreation, health, housing, and more recently,
some of the environmental issues.
     Another responsibility that has been delegated to the East-West
Gateway Coordinating Council  is the A-95 review.  This review stems from
the Office of Management and Budget Circular No. A-95, which requires
that all Federal projects be reviewed by appropriate agencies that might
be affected by such projects.   The East-West Gateway Coordinating Council
is considered the clearinghouse for such reviews in St. Louis.
     Figure V-2 outlines the East-West Gateway Coordinating Council struc-
ture.   It is headed by a Board of  Directors, which includes the key
political  leaders in the St.  Louis Metropolitan Region as members:
     Supervisor, St.  Louis  County
     Chairman, Madison County Board
     Presiding Judge, Franklin County
     Major, City of St.  Louis
                                    103

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     Mayor, City of East St. Louis
     Chairman, St. Clair County Board
     Presiding Judge, St. Charles County
     President, Board of Aldermen, City of St. Louis
     President, Southwestern Illinois Council of Mayors
     President, St. Louis County Municipal League
     President, Southwestern Illinois Metropolitan Area Planning
     Commission
     Vice-President, Southwestern Council of Mayors
     Presiding Judge, Jefferson County
     Chairman, Board of Commissioners, Monroe County
     Chairman, Bi-State Development Agency
     Chief Engineer, Missouri State Highway Commission
     Chief, Bureau of Planning, Illinois Department of Transportation
     Director, Missouri Department of Community Affairs
     Director, Illinois Department of Local Governmental Affairs

     Because of this strong political representation the Council can
be influential, even though it has very little authority.   It seeks to
get things done by review and persuasion.
     In an effort to further involve more people in the planning process,
the Council has established a series of technical committees, such as the
Transportation Technical Committee.   In addition to these technical
committees there are various citizen task forces, including transportation,
solid waste, environment, criminal justice, and education.   Membership
includes commerce and industry as well as citizens.
     In August 1974, the Missouri Air Conservation Commission established
an Advisory Committee on Transportation Control Plan.   Figure V-3 shows
the membership of this committee--the purpose of which is to develop a
transportation control plan by February 1975.  It includes  representatives
of transportation agencies at the state and local levels, as well as
                                    105

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MACC ADVISORY COMMITTE
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certain planning and air pollution agencies.  It also includes represen-
tatives from industry and from the public sector.  This is an important
element in coordinating and developing a transportation control  plan for
the area.

2.   Technical Leadership
     In the development of an Air Quality Maintenance Plan, the legal
responsibility for the technical phase of the plan rests with the states.
The Federal, regional, and local governments play an advisory role.
Present patterns of responsibility in the St. Louis area indicate that
these responsibilities could be moved toward the East-West Gateway
Coordinating Council  so that the Air Quality Maintenance Plan can be
coordinated with other plans and goals for the region.
     The separation between the states and the metropolitan region is parti-
cularly significant in implementation of land use and transportation
measures.  Although the power for implementation rests  with the states
now, the local areas  could be more involved, as in Missouri, where the
Missouri Air Conservation Commission has delegated some of its respon-
sibilities to the City of St.  Louis and the County of St.  Louis.   For
the long-term maintenance plan, implementation of transportation and
land use measures could rest with the East-West Gateway Coordinating
Council and the local  jurisdictions, under the guidance of the state
air pollution agency.

3.   Participation
     Participation in  the long-term maintenance plan development and
implementation must be viewed from three sectors—technical, political,
and citizen.   Each is  critical  in developing intergovernmental cooperation.
                                    107

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a.   Technical  -- The state air pollution agencies  are responsible  for
the development of the Air Quality Maintenance Plan and are  also  involved
in the implementation of it, except in those areas  where the responsibi-
lity has been delegated to the local  level—the City of St.  Louis and the
County of St. Louis.   However, if the plan is going to be successful, it
should have considerable input from the local and regional agencies, not
only in plan development, but in implementation as  well.
     At the present time, there is no machinery to  involve the East-West
Gateway Coordinating Council in AQMP development.   The Missouri Air Con-
servation Commission Advisory Committee on Transportation Control Plan
could be expanded, however, to cover all  elements of the Air Quality
Maintenance Plan.
     Because of the strong role of the City of St.  Louis and some of the
other jurisdictions in the metropolitan area, the State should bring
these people in on the development of the AQMP through establishment of
an advisory committee.  Generally, the review process has proven  to be
an ineffective way of coordinating plan development in the metropolitan
area, because it does not call for active participation and  the local
agencies do not think they have an impact on the outcome.
     Participation in plan implementation is an important issue,  parti-
cularly in the land use area where the local jurisdiction is the  only
authority that can regulate land.  It is not very likely that the power
to regulate land use will be relinquished to a regional agency or to the
state.  However, the MACC has the authority to review and approve or dis-
approve land use area zoning regulations.

b.   Political  — Political participation is very critical,  since the
implementation of the plan may not agree with local jurisdictional  objec-
tives.  This can easily be accomplished through the East-West Gateway
Coordinating Council.  A special task force of political leaders
                                    108

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might be set up to study air quality maintenance for the area.  This task
force could develop the regulations that will be needed for long-term
plan implementation.

c.   Citizen -- It is becoming more and more apparent that any plan or
program that has an impact upon the citizens should be developed through
a citizen participation process.  The earlier these kinds of programs are
initiated, the better, even before any alternatives are developed.
Certainly, citizens should have a role in the development and evaluation
of alternatives and in making recommendations to the political leaders.
At the present time, the East-West Gateway Coordinating Council has moved
ahead in this direction in establishing citizen participation in its plan-
ning process, and there is now a citizen task force on environment.

D.   RECOMMENDED ARRANGEMENT FOR AQMP DEVELOPMENT AND IMPLEMENTATION
     The proposed air quality maintenance strategy discussed in Chapter IV
recommends a phased approach.  Successful plan development and the attain-
ment of maintenance objectives thus requires intergovernmental cooperation
and coordination; such cooperative efforts must be structured around the
phased approach and fulfill the following conditions:
     t    Coordination mechanism must reflect the existing jurisdictional
          framework, legal authority, and time and funding constraints.
     t    Coordination mechanisms should vary with each phase to reflect
          significant changes in responsibility or new program develop-
          ments.

     The recommended responsibility of different agencies for the various
phases is shown in Figure V-4.   The timeframe and funding constraints for
AQMP preparation do not provide for the active participation of agencies
other than the state and local  air pollution agencies in the initial
                                    109

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formulation of the AQMP.  Because land use planning and transportation
planning agencies will not be able to actively participate at this stage,
it  is doubtful that appropriate control measures in these areas can be
proposed in Phase 1.
     The Transportation Control Plan Advisory Committee to the MACC has
just been established after approximately one year of effort and is ex-
pected to prepare and submit a TCP by February 1975.  This advisory
committee could be expanded in membership and scope to initiate AQMP
preparation or it could be replaced by a newly appointed AQMP advisory
committee which would be responsible for preparing alternative approaches
for long-term AQMP plan development.
     Phase 2 includes the timeframe from proposed AQMP submittal in
June 1975 to the first AQMP review period in 1980,  This time period in-
cludes revisions to the SIPs due to failure to attain any of the primary
standards by the proposed attainment dates and incorporation of the
Transportation Control Plan.   The state air pollution agencies will
provide the primary technical leadership for SIP revisions during this
phase.
     During this period, the AQMP should be revised to include the land
use and transportation aspects.  The EWGCC is therefore recommended as
the technical leader for this first major AQMP revision.   To do this, the
EWGCC powers must be expanded to include appropriate land use policies
for the St.  Louis AQMA and be delegated the agent responsible for revision
and continuous update of the air quality maintenance plan.  However, the
state agencies would retain responsibility for implementing and enforcing
the AQMP.
     Phase 3 represents the ongoing 5-year review and revision cycle.   At
this point,  it is assumed that all  available source control  technology
will have been implemented and the emphasis in air quality maintenance
will be on land use and transportation alternatives.  Therefore, EWGCC is
                                    111

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recommended as the technical  coordinator for AQMP revisions.   The State
Air Pollution Control Agencies could then concentrate efforts on new
technology and source control  programs, and enforcement of existing
control programs.
                                     112

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                              BIBLIOGRAPHY
Bappert, Joseph  and Associates, Population and Economic Study St.  Charles
     County, Missouri, Manchester,Missouri, By Author, December 1969.

	, Housing Analysis: St. Charles County, Missouri, Manchester,
     Missouri, By Author, December 1969.

Bartholomew, Harland and Associates, Community Facilities Plan St.  Charles
     County, Missouri, St. Louis, Missouri, By Author, November 1973.

	, Land Use Plan and Transportation Plan St. Charles County,
     Missouri (Final Report), St. Louis Missouri, By Author. March  1973.

BEA Statistics - BEA code 471 - St. Louis and U.S. Totals - Table 1.

Bi-State Development Agency, Missouri - Illinois Metropolitan District,
     Transit Improvement Program 1971-1975 for the St. Louis Missouri-
     Illinois Metropolitan Area, By Author, January 1971.

East-West Gateway Coordinating Council, Housing Conditions, Needs,  and
     Programs in Franklin, Jefferson, and St. Charles Counties, St.  Louis,
     Missouri, By Author, December 1970.

          _, Land Use Component Technical Report 1: Areawide Planning:  An
     East-West Gateway Coordinating Council  Position Paper, St.  Louis,
     Missouri, By Author, September 1972.

    	, Land Use Component, Technical  Report 2:  Land Use Objectives
     and Policies, St. Louis, Missouri, By Author, September 1972.

          _, Land Use Component, Technical  Report 3:  Relative Land Develop-
     ment Potentials, St. Louis, Missouri, By Author, June 1973.

    	, Land Use Component, Technical  Report 4:  Economic  Study of the
     St. Louis Region, St. Louis,Missouri, By Author, June 1973.

          _, Land Use Component, Technical  Report 5:  Land Use  Update and
     and Analysis, St.  Louis, Missouri, By Author,  June 1973.

    	, Land Use Component, Technical  Report 7: Basic Land Use Mapping
     Color Manual, St.  Louis, Missouri, By Author,  June 1973.

    	, The Proposed 1995 Highway and  Transit Plan for St. Louis:  A
     Review and Update  (Draft Report). St. Louis, Missouri, By Author,
     March 1974.

    	, The 1995 Regional Land Use Plan for Metropolitan St.  Louis.
     St. Louis, Missouri, By Author, June  1973.


                                    113

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East-West Gateway Coordinating Council,  et al.,  St.  Louis Area Trans-
     portation Study:  Streets. Highways  &  Transit.  St.  Louis, Missouri,
     By Author, 1973.

Environmental  Studies  Center,  Research Triangle  Institute,  Guidelines
     for 10-year Air Quality Maintenance Plans,  Draft  Report Volume  I
     Plan Preparation, Triangle Park, North Carolina,  ESC,  June  1974.

Holzworth, George C.,  Mixing Heights, Wind Speeds,  and Potential  for
     Urban Air Pollution Throughout the  Contiguous  United States,
     Research Triangle Park, North Carolina, U.S. Environmental
     Protection Agency, Office of Air Programs,  January 1972.

Illinois EPA, Illinois State Implementation Plan, 1972.

Illinois, Environmental Protection Agency, Air Pollution Control  in
     Illinois, By Author, ND.

Kearney, A. T., Inc.,  Study of Metropolitan St.  Louis: Phase One
     (Executive Summary), Chicago, By Author,  February 28,  1974.

Kircher and Armstrong, An Interim Report on Motor Vehicle Emission
     Estimation. EPA,  450/2-73-003, October 1973.

Larsen, Ralph I., A Mathematical  Model  for Relating Air Quality
     Standards, Research Triangle Park,  North Carolina, U.S. Environmental
     Protection Agency, Office of Air  Programs,  November 1971.

Missouri Air Conservation Commission,  Air  Quality Standards and  Air
     Pollution Control Regulations for  the St.  Louis Metropolitan
     Area Revised September 18. 1970.

	, Missouri State Implementation  Plan,  1972.

	, Air Quality Maintenance Area Evaluation for Boone  and Greene
Parsons, Brinckerhoff - Tudor-Bechtel- Sverup and Parcel, St.  Louis
     Metropolitan Area Rapid Transit Feasibility Study Long Range
     Program, St. Louis, Missouri, By Author, August 1971.

	, St. Louis Metropolitan Area Rapid Transit Feasibilty Study
     Long Range Program (Supplemental ReportTTSt. Louis, Missouri,
     By Author, August 1971.

PEDCo-Environmental Specialists, Inc., Attainment of National  Air Quality
     Standards for Carbon Monoxide And Oxjdants in the St. Louis AQCR,
     Cincinnati, Ohio, By Author, March 1974.

Regulations, Air Conservation Law - Revised 1972 - Missouri Air
     Conservation Commission.
                                    114

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Regulations, City of St. Louis - Air Pollution Ordinances - see page 28.

RTI, Computer Assisted Area Source Emissions Gridding Procedure (CAASE)
     User's Manual, January 1974, EPA Contract No. 68-02-1014.

Saint Louis City Plan Commission, Concept for a New Town in the City,
     St. Louis, Missouri, By Author, January 1973.

St. Louis City Plan Commission, St. Louis Development Program (Summary),
     St. Louis, By Author, June 1973.

St. Louis County Department of Planning, The General Plan:  Summary
     Document (Draft), St. Louis County, Missouri, By Author, August 1973.

Turner, Bruce D., Workbook of Atmospheric Dispersion Estimates, Cincinnati,
     Ohio, U.S. Department of Health, Education, and Welfare, 1967.

U.S. Environmental Protection Agency, Environmental Protection Agency
     Regulations on Preparation of Implementation Plans Effective
     June 6, 1974, Washington, D. C., Bureau of National Affairs, Inc.,
     1974.

          _, Office of Air Quality Planning and Standards, The Plan Revision
     Management System (Rough Draft), Research Triangle Park, North Carolina,
     EPA, September 1973.

	, Office of Air Quality Planning and Standards, The Plan Revision
     Management System: Region VII, Research Triangle Park, North Carolina,
     EPA, March 1974.

Voorhees, Alan M., and Associates, Short Range Operations and Financial
     Study of the Bi-State Transit System, Vols.  1  and 2, McLean, Virginia,
     By Author, July -973.

Williams, J. D., et.al., Interstate Air Pollution Study Phase II Project
     Report. Vol. VIII: A Proposal for an Air Resource Management Program,
     Cincinnati, Ohio, U.S. Department of Health,  Education, and Welfare,
     May 1967.
                                    115

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            APPENDIX A








METHOD FOR DISTRIBUTING PROJECTED



EMISSIONS OF PARTICULATES AND S02

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METHODOLOGY FOR DISTRIBUTING PROJECTED EMISSIONS OF PARTICIPATES AND S02
      Projected emissions of  TSP and S02 for the St. Louis AQMA were
allocated to a sub-county grid using the available land use data for
the portion of the AQMA contained within the East-West Gateway study
area.  The 1980 general land use plan was selected as the most consistent
base.  This plan was extrapolated to reflect the growth between 1975 and
1985 using the available existing detailed land use (1970) plan and the
1995 forecast general plan which resulted in land use estimates for the
three time periods considered for a major portion of the area under study.
      For the remaining portions of the AQMA, without detailed land use
forecasts, the worst possible emission allocation was selected.  That is,
all emission growth was assumed to occur at existing sites.
      The land use projections to be used were then distributed to a grid
system.    Since the area source emissions were grouped in three categories
(residential, commercial, and industrial), only these three land use types
were used.  For residential  and commercial emissions, the corresponding
land use  was transferred directly to the grid maps, one map for each of
the three time periods projected.
      Industrial  area source emission allocations required three
determinations before the land use projections were transferred to the
grid system.   The area source emissions for industrial sources were
defined as those sources which emit less than 100 tons per year.
  The selected grid was derived from the CAASE grid network for
  St. Louis.  The CAASE grid was simplified to decrease computer costs.
                                   A-l

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Industrial sources areas emitting  greater than  100 tons  per year were
considered point sources and were projected independently on a  source by
source basis.   The remaining industrial  land use was then separated into
light and heavy industry for allocation  purposes.   Heavy  industry was
defined as primary and secondary manufacturing industry with less than
100 tons per year emissions.  Light industry was defined  as  tertiary
and other non-manufacturing industries.
      The emission level for each grid within the system  was then
calculated.   For commercial and residential emissions, an average
emissions rate per square kilometer was  calculated for each  county.
This was done using the county total  yearly emission projections
and the total  land area by category determined in the previous  step.
The industrial emission rates were calculated at two levels  for each
county, one for light industry and one for heavy industry.  For the
purposes of this analysis, it was assumed that a rate of  five tons
per year heavy industrial emissions for  each ton per year of light
industrial emissions would be suitable.   This was used only  in  lieu
of substantiating data and is not recommended for general use.
      The county industrial emission rates were then calculated using
the following equations:
                                     (total county industrial emissions)
tons per square kilometer     _      square kilometer light  industry +
     light industry                  5 (square kilometer  heavy industry)

tons per square kilometer     _      5(tons per square kilometer light
     heavy industry                  industry)
These rates where then allocated to the appropriate sections of the grid
system.
                                   A-2

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      Finally, total area source emissions for each grid within the
AQMA were determined.
      To facilitate data analysis, a computer plotting program, CALFORM,
was used.  This program was prepared by the Laboratory for Computer
Graphics and Spatial Analysis, Harvard University.  This technique was
selected for the cost and time benefits obtainable.
      The point source projections, which were determined independent
of the area source projections, were then manually plotted on the area
source grid maps.  This resulted in a composite map of TSP and SC^
emissions which distinguished between source type.  Figure A-l shows the
St. Louis SMSA which was to be gridded.  Figure A-2 is the detailed
grid.  Figures A-3 through A-8 show the results of gridded emissions.
Tables A-l  and A-2 list TSP emissions by source category and jurisdiction.
                                   A-3

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A-10

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A-ll

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                                Table A-l

              TSP Emissions  by Jurisdiction (Tons/Year)


   Jurisdiction              1975           1980            1985
St. Louis City

  Power Plants                 250             250             250
  Pt. Sources                8,967          10,212          11,950
  Area Sources               5.793           6,892           8.097
  Total                     15,010          17,354          20,297

Franklin County

  Power Plants               2,900           2,900           2,900
  Pt. Sources                    000
  Area Sources               1,872           2,192           2,548
  Total                      4,772           5,092           5,448

Jefferson County

  Power Plants               4,417          17,668          17,668
  Pt. Sources                1,020           1,207           1,397
  Area Sources                 381             433             485
  Total                      5,818          19,308          19,550

St. Charles County

  Power Plants                 600           1,370           1,370
  Pt. Sources                    000
  Area Sources                 326             371             420
  Total                        926           1,741           1,790

Madison County

  Power Plants               6,643           7,176           7,975
  Pt. Sources               25,629          29,450          38,534
  Area Sources               3,349           3,762           4.305
  Total                      35,621          40,388          50,814

St. Clair County

  Power Plants               1,038               0               0
  Pt. Sources               12,261          14,441          16,719
  Area Sources               2,817           3,090           3,444
  Total                      16,116          17,531          19,623
                                    A-12

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Table A-l (continued)


   Jurisdiction                1975           1980            1985

Monroe County
  Power Plants                    000
  Pt. Sources                   801            881             952
  Area Sources                  167            119             128
  Total                         968          1,000           1,080

St. Louis County
  Power Plants                4,700          4,700           4,700
  Pt. Sources                 1,325          1,781           2,065
  Area Sources                4.250          3,545           4.136
  Total                      10,275         10,026          10,901

St. Louis Area Total
  Power Plants               20,348         34,064          34,863
  Pt. Sources                50,329         57,972          71,617
  Area Sources               18.955         20.404          23.563
  Grand Total                89,632        112,440         130,043
                                    A-13

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                               Table A-2
              S0x EMISSIONS  BY JURISDICTION (Tons/Year)


   Jurisdiction               1975           1980            1985
St. Louis City

  Power Plants                4,380          4,380           4,380
  Pt. Sources                15,744         18,390          21,399
  Area Sources                8,672         10,100          11.725
  Total                      28,796         32,870          37,504

Franklin County

  Power Plants              488,000        464,000         464,000
  Pt. Sources                     000
  Area Sources                1,398          1.615           1.867
  Total                     489,398        465,615         465,867

Jefferson County

  Power Plants               23,725         90,200          90,200
  Pt. Sources                41,500         45,650          49,302
  Area Sources                1.333          1,519           1,720
  Total                      66,558        137,369         141,222

St. Charles County

  Power Plants              200,000        434,200      '   434,200
  Pt. Sources                     000
  Area Sources                  117            102              98
  Total                     200,117        434,302         434,298

Madison County

  Power Plants               47,107         51,231          57,418
  Pt. Sources                41,732         45,874          50,074
  Area Sources                6,344          6.277           6,598
  Total                      95,183        103,382         114,090

St. Clair County

  Power Plants               19,278              0               0
  Pt. Sources                14,070         17,149          20,727
  Area Sources                8,858          9,111           9.572
  Total                      42,206         26,260          30,299
                                    A-14

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Table A-2 (continued)


   Jurisdiction               1975           1980            1985

Monroe County
  Power Plants                    000
  Pt. Sources                     000
  Area Sources                  230            190             172
  Total                         230            190             172

St. Louis County
  Power Plants                9,700         11,737          13,967
  Pt. Sources                81,000         76,950          76,950
  Area Sources               13,203         15.596          18.311
  Total                      103,903        104,283         109,228

St. Louis Area Total
  Power Plants               792,190       1,055,748       1,064,165
  Pt. Sources                194,046        204,013         218,452
  Area Sources               40,155         44,510          50.063
  Grand Total              1,026,391       1,304,271       1,332,680
                                     A-15

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                APPENDIX B
SUBCORRIDOR EMISSION ANALYSIS FOR CO AND HC

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SUBCORRIDOR EMISSION ANALYSIS FOR CO AND HC
      The development of mobile source emission factors as required for
the detailed link models was virtually impractical since the data for
the target years was not available. It was concluded, however, that a
detailed subcorridor VMT listing for 1970 and 1995 highway assignments
within the study area for the region's transportation planning area
would give an indication of trends in emission levels previously assumed
constant for the entire county.  The following paragraphs describe
briefly this process.

Input VMT Data
      The East West Gateway Coordinationg Council has recently completed
a new highway assignment (95002) that represents the selected level of
proposed construction of highway facilities.   This network represents
approximately a demand of 956,000 hours of vehicle travel or, at 3.3
trips/hour, 2.154 million trips per day.   Although the transit alter-
native 95003 was selected, the exact definition of the alignments and
vehicle technology appears to require additional study.
      VMT summaries were available for 1970 and 1995 by corridor,
subcorridor and link type.  The 25 radial subcorridors and 18 circum-
ferential subcorridors for the Missouri area  of the region and 11 radial,
11 circumferential subcorridors for Illinois  provide VMT data for a total
65 geographical units of the region. (Actually only 36 radial or 29
circumferential subcorridors can be described independently since they
overlap each other in the region.)  Each of these unit areas is represented
by all the links within it, and data by link  type was coded from these
                                    B-l

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 1970 and 1995 summaries.  From this data it was possible to calculate the
 25-year growth ratio and simple annual growth rate compounded.  Also from
 this data the 1975, 1980, and 1995 growth rates were calculated.  (See
 Figure B-l and B-2).
 Speed Adjustment
       The methodology  for calculating emissions   factors as defined  by  Kircher
 and  Armstrong was  followed*.   The  basic emission factor  is adjusted by a  speed
 correction factor.   The  traffic data available assigns average  speeds to  each link
 type.     The  baseline emission rates established by  EPA  are given  for
 19.6 mph  (Approximately  20 mph) and an adjustment  curve  is given for
 increases for slower estimates of  speed and  decreases for higher estimates
 of speeds.  Since  the detailed link assignments are  not  available  to  provide
 the  estimated  speeds some general  level of service that  is to  be provided
 will yield typical  speeds on  each  facility type.
       The 65  geographic  subcorridors were classified as  one of the follow-
 ing: urban; suburban and rural; and the 6 link types within each area
 were assigned an estimated speed.  The results of  this analysis are
 shown in  Table  B-l.  It  should be  noted that these speeds are  average
 24-hour  figures that reflect  both  peak and off-peak  speed.

 Vehicle  Age
       The second relevant factor  is the estimate of  the  actual  rates  of
 HC and CO emissions for the average vehicle  type  in  each of the projected
 years.   These emission  rates  are  based on the assumed distribution
 between  light duty (LDV) and  heavy duty  (HDV) vehicles and  the assumed
 pollution reductions to be  effected from  the Federal Motor  Vehicle Control
 Program  (FMVCP).
 *  Kircher and Armstrong, An Interim Report on Motor Vehicle Emission
Estimation, EPA, 450/2-7-003, October 1973.
                                      B-2

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      The figures in the Attainment Study were generally utilized without
any change for 1975 and 1980.  For 1985 a new estimate was derived based
on the continued implementation of the same level  of control  devices from
1976 to 1985 vehicles.  Table B-2 summarizes the adjusted emission factors
These are then multiplied by VMT for each link calculated from traffic
assignment data to obtain the emissions for each year.  The results of
the emission projections are given in Tables B-3 to B-19.
                                    B-3

-------
                                                             ST LOUIS AREA TRANSPORTATION STUD*
                                                                    NETWORK 9OO4
                       Figure B-1
Location of  Radial  Sub-Corridors  in Tables B-3 to B-19
                          B-4

-------
                                                                  ST LOUIS AREA TRANSPORTATION STUDY
                                                                         NETWORK 9O04
                                                                            LEGEND
                            Figure B-2
Location of  Circumferential  Sub-Corridors  in Tables B-3  to B-19
                                 B-5

-------
                                           Table B-l
                                        LINK TYPE FACTORS
                                Estimated  24-hour  speed  (average)
Facility Type Code      0

Development           Local
Urban                  15
Suburban               20
Rural                  25
Jurisdiction 1
(Missouri)
Jurisdiction 2
(Illinois)
              Collector
                 20
                 30
                 30
       Minor
     Arterial
        25
        30
        35
 Princ.
Arterial
   30
   35
   40
X-Way
 40
 40
 50
  5
Free-
way
 45
 50
 55
Inter-
state
 45  '
 50
 60
                         Corridors & Subcorridors Development Assumption
                             (x-y, where x=corridor,  y=subcorridor)
  Urban
1-0,1-7
2-4,2-5
3-4,3-5
4-4
5-4
8-2,8-3,8-4,8-5,8-6
9-1,9-2,9-3
1-4,1-5

3-3,3-4

5-3,
6-2
         Suburban
1-5,1-6
2-2,2-3
3-2,3-3
4-2,4-3
5-2,5-3
6-1,6-2,6-3,6-4,6-5,6-6,6-7
7-1,7-2,7-3,7-4,7-5
8-1

1-1,1-2,1-3,1-6,1-7
2-1,2-2,2-3,2-4
3-2
4-2,4-3,4-4
5-2
6-1
                                                                            Rural
              1-1,1-2,1-3,1-4,1-8
              2-1
              3-1
              4-1
              5-1
                                                                      3-1
                                                                      4-1
                                                                      5-1
                                                B-6

-------
                                      Table B-2

                                   ST. LOUIS AQMA

                  HYDROCARBON AND CARBON MONOXIDE EMISSION FACTORS
136
(7.78)
65.9
(62.1)
133
(7.58)
46.3
(43.7)
131
(7.46)
18.7
(17.6)
130
(7.41)
6.8
(6.5)
                                       Grams/VMT/(Adjusted Contribution)

                                  1972           1975           1980           1985


Carbon Monoxide

HDV
  5.7 percent of VMT

LDV
  94.3 percent of VMT

Subtotal  (CO)                    (69.9)         (51.2)          (25.1)         (13.9)

Hydrocarbon

HDV
  Exhaust
  Crankcase and Evaporation

  5.7 percent of VMT

LDV
  Exhaust
  Crankcase and Evaporation

  94.3 percent of VMT

Subtotal  (HC)                     (9.780)        (7.062)        (3.263)        (1.982)
Source:   PEDCo>  Attainment Study
16.6
5.1
21.7
(1.238)
6.1
3.0
~9TT
(8.542)
15.7
4.0
19.7
(1.123)
4.4
1.9
6.3
(5.939)
13.8
3.4
17.2
(.982)
2.0
.4
2.4
(2.281)
13.3
3.0
TO"
(.928)
.92
.20
1.12
(1.054)
                                         B-7

-------
                                Table B-3
              ST.  LOUIS  URBAN AREA (MISSOURI SUBAREA)
                         SUMMARY OF DAILY TONS
                     OF CARBON MONOXIDE EMISSIONS
                         FOR THE YEAR 1970
CORRIDOR

    0
    1
    2
    3
    4
    5
    6
    7
    8
    9

TOTALS
211
153
290
19
45
                                                        173
                                                  TOTAL
0
14
14
14
16
21
37
24
65
6
0
1
0
0
1
0
0
0
6
0
0
5
6
8
10
12
30
27
54
0
0
32
35
34
23
32
36
17
69
11
0
1
2
4
1
2
0
0
9
0
0
0
0
39
0
0
0
6
0
0
0
55
0
1
16
35
54
0
0
11
0
108
57
100
68
102
159
74
204
28
                                                    901
                              Table B-4

              ST.  LOUIS  URBAN AREA (MISSOURI SUBAREA)
                         SUMMARY  OF DAILY TONS
                    OF CARBON MONOXIDE EMISSIONS
                         FOR  THE  YEAR 1975
CORRIDOR

    0
    1
    2
    3
    H
    5
    6
    7
    8
    9

TOTALS
                                                              TOTAL
0
11
11
12
13
16
30
18
39
5
0
1
0
0
1
0
0
0
5
0
0
4
5
7
8
8
24
21
41
0
0
24
28
26
16
24
27
13
52
8
0
1
2
3
1
2
0
0
7
0
0
0
0
30
0
0
0
5
0
0
0
42
0
1
14
28
44
0
0
9
0
83
45
79
52
78
126
57
144
22
155
117
218
16
35
138
                                                    686
   * See Table B-l for Link Type Description
                                  B-8

-------
                                Table B-5
               ST.  LOUIS URBAN AREA (MISSOURI  SUBAREA)
                         SUMMARY OF DAILY  TONS
                     OF CARBON MONOXIDE  EMISSIONS
                         FOR THE YEAR 1980
CORRIDOR
TOTALS
78
      60
      109
               19
                                                 TOTAL
0
1
2
3
4
5
6
7
8
9
0
6
5
7
7
9
16
9
16
2
0
0
0
0
1
0
0
0
2
0
0
2
3
4
4
3
13
11
21
0
0
12
14
13
7
12
14
7
26
4
0
1
1
2
1
1
0
0
4
0
0
0
0
16
0
0
0
3
0
0
0
23
0
1
8
15
24
0
0
4
0
43
24
42
28
40
68
30
69
11
               354
                                 Table B-6
               ST,
                  AREA (MISSOURI SUBAREA)
                 iY  OF DAILY TONS
                  MONOXIDE EMISSIONS
                 HE  YEAR 1985
CORRIDOR
TOTALS
45
2.
36
62
12
46
                                                 TOTAL
0
1
2
3
4
5
6
7
8
9
0
4
3
4
4
5
10
5
8
1
0
0
0
0
0
0
0
0
1
0
0
1
2
2
3
2
8
6
12
0
0
7
9
8
4
7
8
4
14
2
0
1
1
1
0
1
1
0
2
0
0
0
0
9
0
0
0
2
0
0
0
14
0
0
5
9
15
0
0
3
0
26
14
25
17
23
41
17
38
6
210
   * See Table B-l for Link Type  Description
                                   B-9

-------
                                Table B-7
              ST. LOUIS  URBAN  AREA (MISSOURI SUBAREA)
                         SUMMARY  OF DAILY TONS
                    OF HYDROCARBONS    EMISSIONS
                         FOR  THE  YEAR 1970
CORRIDOR

    0
    1
    2
    3
    4

    6
    7
    8
    9

TOTALS
                                                              TOTAL
0
2
2
2
2
3
5
3
9
1
0
0
0
0
0
0
0
0
1
0
0
1
1
1
2
2
5
4
8
0
0
5
6
5
4
5
6
3
11
2
0
0
0
1
0
0
0
0
1
0
0
0
0
6
0
0
0
1
0
0
0
9
0
0
3
6
9
0
Q
2
0
17
9
16
10
16
24
11
30
4
29
              24
                                   46
27
137
CORRIDOR
    0
    1
    2
    3
    4
    i
    7
    8
    9

TOTALS
                                Table B-8
               ST.  LOUIS URBAN AREA (MISSOURI  SUBAREA)
                         SUMMARY OF DAILY TONS
                     OF HYDROCARBONS    EMISSIONS
                         FOR THE YEAR 1975

0
0
2
1
2
2
2
4
2
5
1
L
1
0
0
0
0
0
0
0
0
1
0
I N K
2
0
1
1
1
1
1
4
3
6
0
T Y
3
0
4
4
4
2
4
4
2
8
1
P E *
4
0
0
0
0
0
0
0
0
1
0

5
0
0
0
5
0
0
0
1
0
0

6
0
7
0
0
2
4
7
0
0
1

TOTAL
0
13
7
12
8
12
19
9
21
3
21
        1
                            18
21
103
    * See Table B-l for Link Type Description
                                    B-10

-------
                                 Table B-9
               ST.  LOUIS URBAN AREA (MISSOURI SUBAREA)
                         SUMMARY  OF DAILY TONS
                     OF HYDROCARBONS    EMISSIONS
                         FOR THE  YEAR  1980
CORRIDOR

    0
    1
    2
    3
    4
    5
    6
    1
    8
    9

TOTALS
                                                 TOTAL
0
1
1
1
1
1
2
1
2
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
1
0
2
2
3
0
0
2
2
2
1
2
2
1
4
1
0
0
0
0
0
0
0
0
1
0
0
0
0
2
0
0
0
0
0
0
0
3
o .
0
1
2
4
0
0
1
0
6
3
6
4
6
10
4
10
2
10
                    16
                                                         11
                                                    50
ST. LOUIS
                                 Table B-10
                        jjj S-S^g^
                                               SUBAREA)
                     OF HYDROCARBONS    EMISSIONS
                         FOR  THE  YEAR 1985
 CORRIDOR

     0
     1
     2
     3
     4
     5
     6
     7
     8
     9
 TOTALS        6       0       6     10
    * See Table B-l for Link Type Description
                                                               TOTAL
0
1
0
1
1
1
1
1
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
1
2
0
0
1
1
1
1
1
1
1
2
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
0
0
0
0
0
0
0
2
0
0
1
1
2
0
0
0
0
4
2
4
3
4
7
3
6
1
                                                     33
                                    B-ll

-------
                                Table 8-11
               ST.
                 AREA  (ILLINOIS SUBAREA)
                 ?Y OF  DAILY  TONS
                 MONOXIDE  EMISSIONS
                 HE YEAR  1970
CORRIDOR

    0
    1
    2
    3
    4
    5
    6
    7
    8
    9

TOTALS
                                                 TOTAL
6
47
11
8
6
8
11
0
0
0
2
7
3
0
2
5
2
0
0
0
8
10
2
5
5
6
22
0
0
0
5
70
17
5
2
17
12
0
0
0
0
0
o-
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
19
13
0
0
0
0
0
21
135
33
38
29
37
47
0
0
0
99
21
59
128
32
340
                                 Table B-12
               ST
                  AREA (ILLINOIS  SUBAREA)
                 *Y OF DAILY  TONS
                  MONOXIDE EMISSIONS
                 HE YEAR 1975
 CORRIDOR

     0
     1
     2
     3
     4
     5
     6
     7
     8
     9

 TOTALS
                                                 TOTAL
5
38
10
6
5
7
9
0
0
0
2
5
2
0
2
4
2
0
0
0
6
8
1
4
4
3
16
0
0
0
3
43
13
4
2
11
7
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
15
10
0
0
0
0
0
16
96
26
30
23
25
34
0
0
0
80
 17
 43
  84
    See Table B-l  For Link Type Description
 26
 251
                                    B-12

-------
                                Table  B-13
              ST.  LOUIS  URBAN AREA (ILLINOIS SUBAREA)
                         SUMMARY OF DAILY TONS
                     OF CARBON MONOXIDE EMISSIONS
                         FOR THE YEAR 1980
CORRIDOR

    0
    1
    2
    3
    4
    5
    6
    7
    8
    9

TOTALS
                                                              TOTAL
2
21
5
3
3

5
0
0
0
1
3
1
0
1
2
1
0
0
0
3
5
1
2
2
1
8
0
0
0
1
18
7
2
1
5
3
0
0
0
0
1
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
8
6
0
0
0
0
0
8
48
14
16
12
13
16
0
0
0
44
22
37
15
128
                                 Table B-14
               ST.
                  AREA (ILLINOIS SUBAREA)
                 JY  OF DAILY TONS
                  MONOXIDE EMISSIONS
                 IE  YEAR 1985
CORRIDOR

    0
    1
    2
    3
    4
    5
    6
    7
    8
    9

TOTALS
27
13
19
   See Table B-l  For Link Type Description
                                                         10
                                                 TOTAL
1
13
3
2
2
3
3
0
0
0
1
2
1
0
1
1
1
0
0
0
2
3
0
1
1
1
4
0
0
0
1
9
4
1
1
3
1
0
0
0
0
1
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
1
0
5
3
1
0
0
0
0
5
29
9
10
8
8
9
0
0
0
        77
                                 B-13

-------
                              Table B-15
              ST
 AREA (ILLINOIS SUBAREAj
*Y  OF DAILY TONS
\RBONS    EMISSIONS
HE  YEAR 1970
CORRIDOR

    0
    1
    2
    3
    4
    5
    6
    7
    8
    9

TOTALS
                                                               TOTAL
1
7
2
1
1
1
2
0
0
0
0
1
0
0
0
1
0
0
0
0
1
2
0
1
1
1
3
0
0
0
1
11
3
1
0
3
2
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
3
2
0
0
0
0
0
3
20
5
6
4
6
1
0
0
0
     20
52
                                Table B-16


               ST. LOUIS URBAN  AREA (ILLINOIS SUBAREA)
                         SUMMARY  OF DAILY TONS
                     OF HYDROCARBONS    EMISSIONS
                         FOR  THE  YEAR 1975
 CORRIDOR

     0
     1
     2
     5
     6
     7
     8
     9

 TOTALS       11       3      7     13
     See Table B-l for Link Type Description
                                                               TOTAL
1
5
1
1
1
1
1
0
0
0
0
1
0
0
0
1
0
0
0
0
1
1
0
1
1
1
2
0
0
0
0
7
2
1
0
2
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
2
0
0
0
0
0
2
14
4
5
3
4
5
0
0
0
                                    37
                                     B-14

-------
                                Table e-17
              ST.  LOUIS  URBAN AREA (ILLINOIS  SUBAREA;
                         SUMMARY OF DAILY TONS
                     OF  HYDROCARBONS    EMISSIONS
                         FOR THE YEAR 1980
CORRIDOR

    0
    1
    2
    3
    4
    5
    6
    7
    8
    9

TOTALS
                                                              TOTAL
0
3
1
0
0
1
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
1
0
0
0
0
3
1
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
1
0
0
0
0
0
1
7
2
2
2
2
2
0
0
0
                                                                 18
                                 Table B-18


               ST.  LOUIS URBAN AREA  (ILLINOIS SUBAREA;
                         SUMMARY OF  DAILY  TONS
                     OF HYDROCARBONS    EMISSIONS
                         FOR THE YEAR  1985

                        LINK      TYPE*
               0123^5
CORRIDOR

    0
    1
    2
    3
    4
    5
    6
    7
    8
    9

TOTALS
   See Table B-l  for Link Type Description
TOTAL
0
2
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
1
0
0
0
0
1
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
1
0
0
0
0
0
1
4
1
2
1
1
1
0
0
0
                                                                  12
                                   B-15

-------
                                 Table B-19

                 ST.  LOUIS  URBAN AREA (MISSOURI SUBAREA)
                     ESTIMATES  OF CARBON MONOXIDE EMISSIONS

                      LINK*    DAILY TONS EMITTED       5-YEAR GROWTH RATE
CORRIDOR SUBCORRIDOR TYPE   1970  1975  1980  1985     1975   1980  1985
    1
    1
    1
    1
    1
    1
    1
    1
    1
    1
    1
    1
    1
    1
    1
    1
    1
    1
    1
    1
    1
    1
    1
    1
    1
    1
    1
    1
    I
    I
    1
    1
    2
    2
    2
    2
    2
    2
    2
    2
    2
    2
    2
    2
    2
    2
    2
    3
      * See Table B-l for Link Type Description

                                     B-16
1
2
3
5
6
7
8
1
8
0
1
2
ij
5
8
2
3
4
5
6
7
8
1
2
3
4
8
1
2
3
4
5
6
7
1
2
3
4
5
1
2
5
1
2
3
4
5
1
2
1
0
0
0
0
0
0
0
1
1
2
2
2
2
2
2
3
3
3
3
3
3
3
4
4
4
4
4
6
6
6
6
6
6
6
0
0
0
0
0
2
2
2
3
3
3
3
3
4
4
0
0.25
0.69
0.06
3.00
5.38
3.10
1.87
0.37
0.69
0.06
0.05
0.18
0.46
0.69
3.42
0.04
1.70
1.04
8.91
7.38
11.52
1.50
0.04
0.04
0.04
0.04
0.61
4.30
4.63
3.77
3.87
9.47
20.54
8.54
1.81
2.62
4.85
3-78
0.48
0.55
4.62
0.75
1.41
8.72
17-63
6.37
0.85
0.18
1.99
4.74
0.20
0.69
0.05
2.36
4.14
2.27
1-53
0.37
0.49
0.05
0.05
0.16
0.34
0.57
2.51
0.04
0.74
0.77
6.90
5.86
8.32
1.30
0.06
0.07
0.07
0.07
0.49
3.68
3.93
3.16
1.09
8.30
15-54
6.71
1.54
2.09
3.67
2.93
0.30
0.47
3.99
0.65
1.19
6.91
13-61
5.11
0.72
0.15
1.58
4.48
0.11
0.46
0.03
1.23
2.13
1.11
0.84
0.25
0.23
0.03
0.03
0.09
0.17
0.31
1.23
0.02
0.21
0.38
3.57
3.10
4.01
0.75
0.07
0.09
0.10
0.09
0.26
2.10
2.22
1.77
0.21
4.86
7-85
3-52
0.87
1.11
1.85
1.52
0.12
0.27
2.30
0.38
0.67
3.66
7.01
2.74
0.41
0.08
0.84
2.83
0.06
0.35
0.02
0.73
1.23
0.62
0.52
0.19
0.12
0.02
0.03
0.06
0.10
0.19
0.68
0.02
0.07
0.21
2.08
1.86
2.19
0.49
0.10
0.12
0.15
0.13
0.16
1.35
1.42
1.12
0.04
3.22
4.49
2.09
0.56
0.67
1.06
0.89
0.06
0.17
1.50
0.25
0.43
2.19
4.09
1.66
0.26
0.05
0.50
2.02
0.96
1.01
0.97
0.96
0.95
0.94
0.97
1.01
0.94
0.97
1.01
0.97
0.95
0.97
0.95
0.99
0.85
0.95
0.96
0.96
0.94
0.98
1.12
1.14
1.15
1.14
0.96
0.97
0.97
0.97
0.78
0.98
0.95
0.96
0.97
0.96
0.95
0.96
0.91
0.97
0.98
0.98
0.97
0.96
0.95
0.96
0.97
0.97
0.96
0.99
0.89
0.93
0.90
0.88
0.88
0.87
0.89
0.93
0.87
0.90
0.94
0.90
0.88
0.89
0.87
0.91
0.79
0.87
0.88
0.89
0.87
0.90
1.04
1.05
1.07
1.06
0.89
0.90
0.90
0.90
0.72
0.90
0.88
0.88
0.90
0.89
0.88
0.88
0.84
0.90
0.90
0.90
0.90
0.89
0.88
0.89
0.90
0.89
0.89
0.92
0.91
0.95
0.92
0.91
0.90
0.89
0.91
0.95
0.89
0.92
0.96
0.92
0.90
0.91
0.89
0.93
0.81
0.89
0.90
0.91
0.89
0.92
1.06
1.08
1.09
1.08
0.91
0.92
0.92
0.92
0.74
0.93
0.90
0.91
0.92
0.91
0.90
0.90
0.86
0.92
0.92
0.93
0.92
0.91
0.90
0.91
0.92
0.91
0.91
0.94

-------
                            Table B-19 (Continued)

                 ST. LOUIS  URBAN AREA  (MISSOURI  SUBAREA)
                    ESTIMATES OF CARBON  MONOXIDE EMISSIONS

                     LINK    DAILY  TONS  EMITTED       5-YEAR GROWTH RATE
CORRIDOR SUBCORRIDOR TYPE   1970  1975   1980   1985    1975  1980  1985

    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    4
    4
    4
    4
    4
    4
    4
    4
    4
    4
    4
    4
    4
    4
    4
    4
    4
    4
    4
    4
    5
    5
    5
    5
    5
    5
    5
    5


                                    B-17
2
3
4
5
5
1
2
3
4
5
1
2
3
4
5
3
1
2
3
4
5
5
1
2
3
4
1
2
1
2
3
4
1
2
3
4
1
2
1
2
3
4
1
2
3
4
1
3
4
1
0
0
0
0
1
2
2
2
2
2
3
3
3
3
3
4
5
5
5
5
5
6
0
0
0
0
1
1
2
2
2
2
3
3
3
3
4
4
6
6
6
6
0
0
0
0
2
2
2
3
3-
3.
1.
0.
0.
1.
2.
2.
0.
1.
8.
7.
4.
10.
3.
3-
4.
10.
15.
7.
0.
1.
5.
2.
5.
2.
1.
0.
1.
3-
2.
2.
6.
9-
6.
1.
0.
0.
15.
0.
0.
0.
3.
1.
7.
7.
9.
1.
1.
8.
85
54
16
97
15
85
60
23
62
18
22
25
06
83
77
53
98
67
55
38
04
15
98
54
23
71
27
05
29
03
81
80
69
18
46
06
04
83
12
98
04
04
99
08
85
85
28
11
68
56
2.94
2.69
0.89
0.72
0.11
1.83
2.22
1.77
0.29
0.66
6.44
5.62
3.16
8.18
2.67
3.01
4.62
8.53
11.29
5.57
0.06
1.00
5-15
2.08
3.92
2.00
1.06
0.04
1.27
2.47
2.24
2.02
3.67
6.90
4.52
0.77
0.08
0.71
12.24
1.17
0.08
0.08
3.49
0.86
6.07
5.81
5.41
0.87
1.29
6.59
1.50
1.36
0.46
0.36
0.06
1.21
1.27
0.94
0.09
0.25
3.37
2.91
1.64
4.13
1.26
1.72
2.86
4.55
5.48
2.81
0.06
0.58
2.96
1.14
1.96
0.99
0.59
0.03
0.83
1.35
1.20
0.97
1.35
3.46
2.11
0.37
0.11
0.41
6.62
0.93
0.13
0.10
2.04
0.45
3.14
2.87
2.11
0.45
0.66
3.38
0
0
0
0
0
0
0
0
0
0
1
1
0
2
0
1
2
2
3
1
0
0
1
0
1
0
0
0
0
0
0
0
0
1
1
0
0
0
4
0
0
0
1
0
1
1
0
0
0
1
.87
.78
.26
.20
.03
.90
.82
.56
.03
.11
.99
.70
.97
.36
.68
.11
.00
.75
.00
.60
.08
.38
.92
.71
.11
.55
.37
.02
.62
.83
.72
.53
.56
.96
.11
.20
.19
.26
.04
.84
.22
.15
.35
.27
.83
.60
.93
.27
.38
.97
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
1
0
0
1
1
1
0
0
0
0
0
0
0
0
.95
.95
.95
• 95
.94
.00
.97
.96
.86
.90
.96
.96
.96
.95
.94
.97
.99
.96
.94
.95
.10
.98
.98
.97
.95
.95
.97
.97
.00
.97
.96
.94
.89
.95
.94
.94
.17
.97
.96
.04
.19
.15
.98
.96
.96
.95
.90
.96
.95
• 95
0.88
0.88
0.88
0.88
0.87
0.93
0.90
0.89
0.8o
0.83
0.88
0.88
0.88
0.88
0.87
0.90
0.91
0.89
0.87
0.88
1.02
0.90
0.90
0.89
0.88
0.87
0.89
0.90
0.92
0.89
0.89
0.87
0.82
0.88
0.86
0.87
1.08
0.90
0.89
0.96
1.09
1.06
0.90
0.89
0.88
0.87
0.83
0.88
0.88
0.88
0.90
0.90
0.90
0.90
0.89
0.95
0.92
0.91
0.82
0.85
0.91
0.90
0.90
0.90
0.89
0.92
0.94
0.91
0.89
0.90
1.04
0.92
0.92
0.91
0.90
0.89
0.92
0.92
0.95
0.91
0.91
0.89
0.84
0.90
0.89
0.89
1.11
0.92
0.91
0.98
1.12
1.09
0.93
0.91
0.90
0.89
0.85
0.90
0.90
0.90

-------
                           Table B-19  (Continued)

                 ST. LOUIS URBAN AREA  (MISSOURI  SUBAREA)
                    ESTIMATES OF CARBON MONOXIDE EMISSIONS

                     LINK    DAILY TONS EMITTED       5-YEAR GROWTH RATE
CORRIDOR SUBCORRIDOR TYPE  1970  1975  1980  1985    1975  1980  1985

    5
    5
    5
    5
    5
    5
    5
    5
    5
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    7
    7
    7
    7
    7
    7

                                     B-18
2
3
4
1
2
1
2
3
4
1
2
3
4
5
6
7
1
5
1
2
3
4
5
6
7
1
2
3
4
5
6
7
2
3
4
5
6
1
2
3
4
5
6
7
1
2
3
4
5
2
3
3
3
4
4
6
6
6
6
0
0
0
0
0
0
0
1
1
2
2
2
2
2
2
2
3
3
3
3
3
3
3
4
4
4
4
4
6
6
6
6
6
6
6
0
0
0
0
0
1
2.22
7-57
13.53
0.87
1.45
10.25
5.71
6.22
12.73
2.69
8.54
5.92
3.77
4.31
8.23
3.85
0.11
0.27
0.16
14.65
3.24
3.87
4.41
3.82
0.16
0.78
12.55
3.37
3.37
7.85
5.91
2.17
0.04
0.04
0.04
0.04
0.04
3.87
17.82
6.94
8.89
9.11
7.52
0.33
4.08
5-77
7.31
4.46
1.92
0.16
1.77
5.78
9.50
0.89
1.16
8.78
4.54
4.82
9-93
2.19
6.96
4.82
3-01
3.41
6.69
3.28
0.11
0.25
0.14
10.26
2.74
3.41
3.71
3.29
0.16-
0.61
10.50
2.38
2.46
5-25
4.34
1,90
0.08
0.06
0.07
0.09
0.08
3.16
14.35
5.46
7.00
7.42
6.34
0.40
2.94
4.51
5.57
3.36
1.46
0.13
0.94
2.95
4.45
0.61
0.62
5.02
2.41
2.49
5.17
1.19
3-79
2.62
1.60
1.80
3-63
1.87
0.07
0.16
0.08
4.80
1.55
2.00
2.08
• 1.89
0.10
0.32
5.86
•1.12
1.20
2.35
2.13
1.11
0.10
0.06
0.07
0.13
0.09
1.72
7.72
2.87
3.68
4.03
3.57
0.33
1.42
2.36
2.84
1.68
0.74
0.08
0.57
1.70
2.35
0.47
0.37
3.24
1.45
1.46
3.04
0.73
2.33
1.61
0.97
1.07
2.22
1.20
0.06
0.11
0.05
2.54
0.99
1.33
1.32
1.22
0.08
0.19
3.70
0.60
0.66
1.19
1.18
0.73
0.14
0.07
0.09
0.21
0.13
1.06
4.69
1.70
2.19
2.48
2.27
0.31
0.77
1.39
1.63
0.96
0.43
0.05
0.96
0.95
0.94
1.01
0.96
0.97
0.96
0.96
0.96
0.96
0.96
0.96
0.96
0.96
0.96
0.97
1.01
0.99
0.98
0.94
0.97
0.98
0.97
0.98
1.00
0.96
0.97
0.94
0.94
0.93
0.95
0.98
1.14
1.09
1.11
1.17
1.14
0.97
0.96
0.96
0.96
0.96
0.97
1.05
0.94
0.96
0.95
0.95
0.95
0.97
0.89
0.88
0.86
0.93
0.89
0.90
0.89
0.88
0.88
0.89
0.89
0.89
0.89
0.89
0.89
0.90
0.93
0.92
0.90
0.86
0.90
0.90
0.90
0.90
0.92
0.88
0.89
0.87
0.87
0.86
0.87
0.90
1.05
1.01
1.02
1.08
1.05
0.89
0.89
0.88
0.88
0.89
0.90
0.97
0.87
0.88
0.88
0.88
0.88
0.90
0.91
0.90
0.89
0.96
0.91
0.92
0.91
0.90
0.90
0.91
0.91
0.91
0.91
0.91
0.91
0.92
0.95
0.94
0.92
0.89
0.92
0.93
0.92
0.92
0.95
0.90
0.92
0.89
0.89
0.88
0.89
0.93
1.08
1.03
1.05
1.11
1.07
0.91
0.91
0.91
0.91
0.91
0.92
0.99
0.89
0.90
0.90
0.90
0.90
0.92

-------
                            Table B-19 (Continued)

                 ST. LOUIS URBAN AREA  (MISSOURI  SUBAREA)
                    ESTIMATES OF CARBON  MONOXIDE EMISSIONS

                     LINK    DAILY  TONS  EMITTED       5~YEAR GROWTH RATE
CORRIDOR SUBCORRIDOR TYPE  1970  1975   1980   1985    1975  1980  1985

    7
    7
    7
    7
    7
    7
    7
    7
    7
    7
    7
    7
    7
    8
    8
    8
    8
    8
    8
    8
    8
    8
    8
    8
    8
    8
    8
    8
    8
1
2
3
4
5
1
2
3
4
5
1
2
3
1
2
3
4
5
6
2
3
4
6
1
2
3
4
5
6
1
2
3
i|
5
6
1
i
2
-5
1
2
3
1
2
3

§
2
2
2
2
2
3
3
3
3
3
5
5
5
0
0
0
0
0
0
1
1
1
1
2
2
2
2
2
2
3
3
3
3
3
3
4
cf
fi
u
3
3
3
5
5
5
6
g
6
5
5
3
5
3
2
2
5
3
0
0
5
1
10
8
34
1
8
0
0
3
1
3
10
15
6
3
15
1
24
9
14
7
13
9
1
f
_L
3.
3.
4.
0,
0,
0
5
31:
.85
.94
.73
.03
.68
.78
.91
.35
.26
.00
.04
.04
.97
.08
.66
.43
.89
.16
.63
.69
.15
.54
.92
.66
.84
.08
.23
.36
.20
.02
.15
.45
.22
.32
.32
.06
:i?
.13
.0*1
82
29
03
.04
,04
.04
.54
31
5.09
3.77
4.45
2.56
4.85
2.98
2.28
1.83
3.91
2.30
0.07
0.08
4.93
0.89
7.91
6.15
16.87
0.87
6.42
0.55
0.12
2.66
1.45
2.89
8.32
11.44
4.89
2.53
11.38
0.88
18.06
7-09
10.56
5.35
9.70
7.08
$:§E
1. 64
1.^7
2.83
2.39
2.92
0.04
0.05
0.06
4.39
i:$J
2.52
1.59
2.31
1.45
2.77
1.56
1.20
0.95
1.94
1.18
0.10
0.12
2.72
0.49
3.92
3.00
5.^5
0.43
3-19
0.29
0.06
1.33
0.73
1.52
4.26
5.80
2.56
1.27
5-69
0.51
9.02
3.56
5.24
2.61
4.72
3.69
8:98
Q.8J
0 . 78
1.40
1.16
1.42
0.03
0.05
0.07
2.32
i^o7
1
0
1
0
1
0
0
0
1
0
0
0
1
0
2
1
1
0
1
0
0
0
0
0
2
3
1
0
3
0
5
2
2
1
2
2
8
o
0
0.
0.
0.
0,
0,
0
1
8;
.41
.76
.35
.92
.78
.93
.71
.56
.09
.68
.14
.21
.69
.30
.19
.65
.99
.24
.79
.17
.04
.76
.42
.91
.47
.32
• 52
.72
.21
.33
.09
.02
.93
.44
.59
.18
.'3i
• 49
• 47
78
63
77
.02
.05
.09
.39
:§§
0
0
0
0
0
0
0
0
0
0
1
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
J
0
0
0.
0.
0.
1,
1.
1
0
0
0
.95
.92
.96
.97
.97
.96
.96
.96
.95
-95
.15
.18
.97
.97
.95
.94
.87
.95
.95
.96
.96
.95
.95
.96
.95
.95
.96
• 95
.95
.98
• 95
.95
.95
.94
.94
.96

• 35
.96
95
94
94
.01
.07
.11
.96
'M
0.87
0.85
0.88
0.90
0.90
0.88
0.88
0.88
0.87
0.88
1.06
1.09
0.89
0.89
0.87
0.87
0.80
0.87
0.87
0.88
0.89
0.88
0.88
0.88
0.88
0.88
0.88
0.88
0.88
0.90
0.88
0.88
0.87
0.87
0.87
0.88
J.'Sf4
0.88
0.89
0.87
0.87
0.87
0.93
0.99
1.03
0.89
O'M
0.90
0.87
0.90
0.92
0.92
0.91
0.91
0.90
0.90
0.90
1.09
1.12
0.91
0.91
0.90
0.89
0.82
0.90
0.90
0.91
0.91
0.90
0.90
0.91
0.90
0.90
0.91
0.90
0.90
0.92
0.90
0.90
0.90
0.89
0.89
0.90
HI
0.90
O.$l
0.90
0.89
0.89
0.95
1.02
1.05
0.91
0.90
0.90
                                   B-19

-------
                            Table B-19 (Continued)

                 ST. LOUIS URBAN AREA (MISSOURI  SUBAREA)
                    ESTIMATES OF HYDROCARBONS     EMISSIONS

                      LINK    DAILY TONS  EMITTED      5-YEAR GROWTH RATE
CORRIDOR SUBCORRIDOR TYPE  1970  1975  1980  1985    1975  1980  1985

    1          1
    1          2
    1          3
    1          5
    1          6
    1          7
    1          8
    1          1
    1          8
    1          0
    1          1
    1          2
    1          4
    1          5
    l          8
    l          2
    1          3
    1          4
    1          5
    1          6
    1          7
    1          8
    1          1
    1          2
    1          3
    1          4
    1          8
    1          1
    1          2
    1          3
    1          4
    1          5
    1          6
    1          7
    2          1
    2          2
    2          3
    2          4
    2          5
    2          1
    2          2
    2          5
    2          1
    2          2
    2          3
    2          4
    2          5
    2          1
    2          2
    3          1

                                    B-20
0
0
0
0
0
0
0
1
1
2
2
2
2
2
2
3
3
3
3
3
3
3
4
4
4
4
4
6
6
6
6
6
6
6
0
0
0
0
0
2
2
2
3
3
3
3
3
4
4
0
0.04
0.10
0.01
0.42
0.75
0.4l
0.28
0.06
0.11
0.01
0.01
0.03
0.07
0.11
0.54
0.01
0.27
0.17
1.41
1.17
1.80
0.24
0.01
0.01
0.01
0.01
0.10
0.67
0.72
0.59
0.60
1.49
3.24
1.39
0.27
0.37
0.68
0.50
0.06
0.09
0.72
0.11
0.23
1.38
2.79
0.99
0.13
0.03
0.32
0.71
0.03
0.10
0.01
0.32
0.57
0.30
0.23
0.06
0.08
0.01
0.01
0.02
0.05
0.09
0.39
0.01
0.12
0.12
1.08
0.92
1.28
0.21
0.01
0.01
0.01 '
0.01
0.08
0.57
0.60
0.49
0.17
1.29
2.41
1.07
0.23
0.29
0.51
0.38
0.04
0.07
0.61
0.10
0.19
1.08
2.13
0.79
0.11
0.02
0.25
0.66
0.01
0.06
0.00
0.16
0.28
0.14
0.12
0.04
0.03
0.00
0.00
0.01
0.03
0.05
0.18
0.00
0.03
0.06
0.53
0.46
0.58
0.11
0.01
0.01
0.01
0.01
0.04
0.30
0.32
0.26
0.03
0.71
1.15
0.53
0.12
0.14
0.24
0.19
0.01
0.04
0.33
0.05
0.10
0.54
1.03
0.40
0.06
0.01
0.13
0.40
0.01
0.05
0.00
0.10
0.18
0.08
0.08
0.03
0.02
0.00
0.00
0.01
0.02
0.03
0.11
0.00
0.01
0.03
0.34
0.30
0.35
0.08
0.02
0.02
0.02
0.02
0.03
0.22
0.23
0.18
0.01
0.52
0.72
0.35
0.09
0.10
0.15
0.12
0.01
0.03
0.24
0.04
0.07
0.35
0.66
0.27
0.04
0.01
0.08
0.31
0.96
1.00
0.97
0.95
0.95
0.94
0.96
1.00
0.94
0.97
1.01
0.97
0.95
0.96
0.94
0.98
0.85
0.94
0.95
0.96
0.94
0.97
1.12
1.14
1.15
1.14
0.96
0.97
0.97
0.97
0.78
0.98
0.95
0.96
0.97
0.96
0.95
0.95
0.91
0.97
0.97
0.98
0.97
0.96
0.95
0.96
0.97
0.96
0.96
0.99
0.88
0.92
0.89
0.87
0.87
0.86
0.88
0.92
0.86
0.89
0.93
0.89
0.87
0.88
0.86
0.90
0.78
0.86
0.87
0.88
0.86
0.89
1.03
1.04
1.05
1.04
0.88
0.89
0.89
0.89
0.71
0.89
0.87
0.87
0.89
0.88
0.87
0.87
0.83
0.89
0.89
0.89
0.89
0.88
0.87
0.88
0.89
0.88
0.88
0.91
0.93
0.97
0.94
0.92
0.92
0.91
0.93
0.97
0.90
0.94
0.98
0.94
0.91
0.93
0.91
0.95
0.82
0.91
0.92
0.93
0.91
0.94
1.08
1.10
1.11
1.10
0.93
0.94
0.94
0.94
0.75
0.94
0.92
0.92
0.94
0.93
0.92
0.92
0.88
0.94
0.94
0.94
0.94
0.92
0.92
0.93
0.94
0.93
0.93
0.96

-------
                            Table B-19 (Continued)

                 ST. LOUIS  URBAN AREA  (MISSOURI  SUBAREA)
                    ESTIMATES  OF HYDROCARBONS     EMISSIONS

                     LINK    DAILY  TONS  EMITTED       5-YEAR GROWTH RATE
CORRIDOR SUBCORRIDOR TYPE   1970  1975   1980  1985    1975  1980  1985

    3          2
    3          3
    3          4
    3          5
    3          5
    3          1
    3          2
    3          3
    3          4
    3          5
    3          1
    3          2
    3          3
    3          4
    3          5
    3          3
    3          1
    3          2
    3          3
    3          ^
    3          5
    3          5
    4          1
    4          2
    4          3
    4          4
    4          1
    4          2
    4          1
    4          2
    4          3
    4          4
    4          1
    4          2
    4          3
    4          4
    4          1
    4          2
    4          1
    4          2
    4          3
    4          4
    5          1
    5          2
    5          3
    5          4
    5          1
    5          3
    5          4
    5          1


                                    B-21
0
0
0
0
1
2
2
2
2
2
3
3
3
3
3
4
5
5
5
5
5
6
0
0
0
0
1
1
2
2
2
2
3
3
3
3
4
4
6
6
6
6
0
0
0
0
2
2
2
3
0.54
0.49
0.15
0.13
0.02
0.29
0.41
0.35
0.09
0.18
1.32
1.15
0.64
1.69
0.59
0.57
0.79
1.68
2.45
1.20
0.01
0.19
0.90
0.36
0.73
0.36
0.20
0.01
0.20
0.47
0.44
0.42
1.07
1.46
1.02
0.17
0.01
0.13
2.36
0.15
0.01
0.01
0.60
0.15
1.10
1.04
1.47
0.17
0.25
1.37
0.41
0.37
0.12
0.09
0.02
0.29
0.34
0.27
0.04
0.10
1.02
0.88
0.49
1.26
0.41
0.48
0.72
1.33
1.75
0.89
0.01
0.16
0.76
0.29
0.54
0.26
0.16
0.01
0.20
0.38
0.35
0.30
0.58
1.08
0.71
0.12
0.01
0.11
1.88
0.18
0.01
0.01
0.52
0.12
0.84
0.76
0.84
0.13
0.19
1.04
0.20
0.18
0.06
0.04
0.01
0.18
0.18
0.14
0.01
0.03
0.50
0.43
0.24
0.60
0.18
0.26
0.42
0.67
0.80
0.42
0.01
0.09
0.41
0.15
0.26
0.12
0.09
0.00
0.12
0.20
0.17
0.14
0.20
0.51
0.31
0.05
0.02
0.06
0.96
0.14
0.02
0.02
0.29
0.06
0.41
0.35
0.31
0.07
0.09
0.51
0.12
0.11
0.04
0.03
0.00
0.15
0.13
0.09
0.00
0.02
0.33
0.28
0.16
0.38
0.11
0.18
0.33
0.44
0.48
0.27
0.01
0.06
0.30
0.10
0.16
0.07
0.06
0.00
0.10
0.13
0.12
0.08
0.09
0.32
0.18
0.03
0.03
0.04
0.65
0.14
0.04
0.03
0.21
0.04
0.26
0.22
0.15
0.04
0.06
0.32
0.95
0.95
0.95
0.95
0.94
1.00
0.97
0.96
0.86
0.89
0.95
0.95
0.95
0.95
0.94
0.97
0.99
0.96
0.94
0.95
1.10
0.97
0.97
0.96
0.95
0.94
0.97
0.97
1.00
0.96
0.96
0.94
0.89
0.95
0.93
0.94
1.17
0.97
0.96
1.04
1.18
1.15
0.98
0.96
0.95
0.94
0.90
0.95
0.95
0.95
0.87
0.87
0.87
0.87
0.86
0.91
0.89
0.88
0.79
0.82
0.87
0.87
0.87
0.87
0.86
0.89
0.90
0.88
0.86
0.87
1.00
0.89
0.89
0.88
0.87
0.86
0.88
0.89
0.91
0.88
0.88
0.86
0.81
0.87
0.85
0.86
1.07
0.89
0.88
0.95
1.08
1.05
0.89
0.88
0.87
0.86
0.82
0.87
0.87
0.87
0.92
0.92
0.92
0.91
0.91
0.97
0.94
0.93
0.83
0.86
0.92
0.92
0.92
0.92
0.90
0.94
0.95
0.93
0.91
0.92
1.06
0.94
0.94
0.93
0.91
0.91
0.93
0.94
0.97
0.93
0.93
0.91
0.86
0.92
0.90
0.91
1.13
0.94
0.93
1.00
1.14
1.11
0.94
0.93
0.92
0.91
0.87
0.92
0.92
0.92

-------
                           Table B-l9 (Continued)
                 ST. LOUIS URBAN AREA  (MISSOURI  SUBAREA)
                    ESTIMATES OF HYDROCARBONS     EMISSIONS
                     LINK
CORRIDOR SUBCORRIDOR TYPE
              DAILY TONS EMITTED
            1970  1975  1980  1985
5-YEAR GROWTH RATE
1975  1980  1985
    5
    5
    5
    5
    5
    5
    5
    5

    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    6
    5
    6
    7
    7
    7
    7
    7
    7
2
3
4
1
2
1
2
3
4
1
2
3
4
5
6
7
1
5
1
2
3
4
5
6
7
1
2
3
4
5
6
7
2
3
4
5
6
1
2
3
4
5
6
7
1
2
3
4
5
2
3
3
3
4
4
6
6
6
6
0
0
0
0
0
0
0
1
1
2
2
2
2
2
2
2
3
3
3
3
3
3
3
4
4
4
4
4
6
6
6
6
6
6
6
0
0
0
0
0
1
0.35
1.20
2.11
0.14
0.23
1.60
0.90
0.98
2.07
0.38
1.19
0.83
0.53
0.60
1.15
0.54
0.02
0.04
0.02
2.29
0.51
0.60
0.69
0.60
0.02
0.12
1.99
0.53
0.53
1.24
0.94
0.34
0.01
0.01
0.01
0.01
0.01
0.61
2.81
1.09
1.40
1.44
1.19
0.05
0.57
0.81
1.02
0.62
0.27
0.02
0.28
0.90
1.46
0.14
0.18
1.35
0.71
0.75
1.59
0.30
0.96
0.66
0.41
0.47
0.92
0.45
0.02
0.04
0.02
1.58
0.42
0.52
0.57
0.51
0.02
0.10 '
1.64
0.37
0.38
0.82
0.68
0.30
0.01
0.01
0.01
0.01
0.01
0.49
2.23
0.85
1.09
1.15
0.98
0.06
0.41
0.62
0.77
0.46
0.20
0.02
0.14
0.44
0.65
0.09
0.09
0.73
0.35
0.37
0.78
0.15
0.49
0.34
0.21
0.23
0.47
0.24
0.01
0.02
0.01
0.70
0.23
0.29
0.30
0.27
0.01
0.05
0.86
0.17
0.18
0.35
0.31
0.16
0.01
0.01
0.01
0.02
0.01
0.25
1.13
0.42
0.54
0.59
0.52
0.05
0.18
0.31
0.37
0.22
0.10
0.01
0.09
0.28
0.38
0.08
0.06
0.52
0.23
0.24
0.51
0.10
0.33
0.23
0.14
0.15
0.32
0.17
0.01
0.02
0.01
0.41
0.16
0.21
0.21
0.2Q
0.01
0.03
0.60
0.10
0.11
0.19
0.19
0.12
0.02
0.01
0.01
0.04
0.02
0.17
0.76
0.28
0.35
0.40
0.37
0.05
0.11
0.20
0.23
0.14
0.06
0.01
0.96
0.95
0.93
1.01
0.96
0.97
0.96
0.95
0.95
0.96
0.96
0.96
0.96
0.96
0.96
0.97
1.00
0.99
0.97
0.93
0.97
0.98
0.97
0.97
1.00
0.95
0.97
0.94
0.94
0.93
0.94
0.98
1.13
1.09
1.10
1.17
1.13
0.96
0.96
0.96
0.96
0.96
0.97
1.05
0.94
0.95
0.95
0.95
0.95
0.97
0.88
0.87
0.85
0.92
0.88
0.89
0.88
0.87
0.87
0.88
0.88
0.88
0.88
0.88
0.88
0.89
0.92
0.91
0.89
0.85
0.89
0.89
0.89
0.89
0.91
0.87
0.88
0.86
0.86
0.85
0.86
0.89
1.04
1.00
1.Q1
1.07
1.04
0.88
0.88
0.87
0.87
0.88
0.89
0.96
0.86
0.87
0.87
0.87
0.87
0.89
0.93
0.92
0.90
0.97
0.93
0.94
0.93
0.92
0.92
0.93
0.93
0.93
0.93
0.92
0.93
0.94
0.97
0.96
0.94
0.90
0.9^
0.91*
0.94
0.94
0.97
0.92
0.93
0.90
0.91
0.89
0.91
0.94
1.10
1.05
1.07
1.13
1.09
0.93
0.93
0.92
0.92
0.93
0.94
1.01
0.91
0.92
0.92
0.92
Q.92
0.94
                                    B-22

-------
                            Table B-19 (Continued)

                  ST. LOUIS  URBAN AREA (MISSOURI SUBAREA)
                     ESTIMATES  OF HYDROCARBONS    EMISSIONS

                      LINK     DA-ILY TONS EMITTED      5-YEAR  GROWTH RATE
CORRIDOR SUBCORRIDOR  TYPE   1970  1975  1980  1985    1975  1980   1985

    7          1
    7          2
    7          3
    7          4
    7          5
    7.          1
    7          2
    7          3
    7          4
    7          5
    7          1
    7          2
    7          3
    8          1
    8          2
    8          3
    8          4
    8          5
    8          6
    8          2
    8          3
    8          4
    8          6
    8          1
    8          2
    8          3
    8          4
    8          5
    8          6"
    8          1
    8          2
    8          3
    8          4
    8          5
    8          6'
    8          1
    8          2
    9          1
    9          2
    9          3
    9          1
    9          2
    9          3
    9          1
    9-          2
    9          3
    9          1
    9          2
    9          3
                                    B-23
2
2
2
2
2
3
3
3
3
3
5
5
5
0
0
0
0
0
0
1
1
1
1
2
2
2
2
2
2
3
3
3
3
3
3
4
4
0
0
0
3
3
3
5
5
5
6
5
6
1.07
0.93
0.89
0.47
0.89
0.60
0.46
0.37
0.83
0.48
0.01
0.01
0.94
0.15
1.41
1.11
4.61
0.15
1.14
0.10
0.02
0.49
0.27
0.57
1.63
2.26
0.94
0.51
2.28
0.16
3.77
1.47
2.22
1.14
2.08
1.45
0.01
0.28
0.28
0.24
0.60
0.51
0.63
0.01
0.01
0.01
0.90
0.28
0.61
0.78
0.58
0.68
0.39
0.75
0.47
0.36
0.29
0.61
0.36
0.01
0.01
0.77
0.12
1.03
0.80
2.20
0.11
0.84
0.08
0.02
0.37
0.20
0.44
1.23
1.69
0.72
0.37
1.68
0.14
2.78
1.09
1.62
0.82
1.49
1.12
O.Q1
0.21
0.21
0.19
0.44
0.37
0.45
0.01
0.01
0.01
0.70
0.21
0.46
0.37
0.23
0.33
0.21
0.40
0.23
0.18
0.14
0.29
0.17
0.01
0.02
0.40
0.06
0.48
0.37
0.67
0.05
0.39
0.04
0.01
0.17
0.10
0.22
0.60
0.81
0.36
0.18
0.79
0.07
1.31
0.52
0.76
0.38
0.68
0.55
0.01
0.10
0.10
0.10
0.20
0.17
0.21
O.QO
O.Q1
0.01
0.35
0.10
0.23
0.23
0.12
0.22
0.15
0.29
0.15
0.12
0.09
0.18
0.11
0.02
0.03
0.27
0.04
0.30
0.22
0.27
0.03
0.24
0.02
0.01
0.11
0.06
0.15
0.38
0.51
0.23
0.11
0.49
0.05
0.81
0.32
0.47
0.23
0.41
0.36
0.02
0.06
0.07
0.06
0.13
0.10
0.12
0.00
0.01
0.01
0.23
0.06
0.15
0.94
0.92
0.95
0.97
0.97
0.96
0.95
0.95
0.94
0.95
1.15
1.18
0.96
0.96
0.94
0.94
0.87
0.94
0.94
0.96
0.96
0.95
0.95
0.96
0.95
0.95
0.95
0.95
0.95
0.97
0.95
0.95
0.94
0.94
0.94
0.95
1.13
0.94
0.95
0.96
0.94
0.94
0.94
1.00
1.07
1.11
0.96
0.95
0.95
0.86
0.84
0.87
0.89
0.89
0.87
0.87
0.87
0.86
0.87
1.05
1.08
0.88
0.88
0.86
0.86
0.79
0.86'
0.86
0.87
0.88
0.87
0.87
0.87
0.87
0.87
0.87
0.87
0.87
0.89
0.87
0.87
0.86
0.86
0.86
0.87
1.03
0.86
0.87
0.88
0.86
0.86
0.86
0.92
0.98
1.02
0.88
0.87
0.87
0.91
0.88
0.92
0.94
0.94
0.92
0.92
0.92
0.91
0.92
1.11
1.14
0.93
0.93
0.91
0.91
0.84
0.91
0.91
0.92
0.93
0.92
0.92
0.92
0.92
0.92
0.92
0.91
0.91
0.94
0.91
0.91
0.91
0.91
0.91
0.92
1.09
0.91
0.92
0.93
0.91
0.91
0.91
0.97
1.03
1.07
0.92
0.92
0.92

-------
                            Table B-19 (Continued)

                 ST. LOUIS  URBAN AREA  (ILLINOIS SUBAREA)
                    ESTIMATES OF CARBON  MONOXIDE EMISSIONS

                     LINK    DAILY  TONS  EMITTED      5-YEAR GROWTH RATE
CORRIDOR SUBCORRIDOR TYPE   1970  1975   1980  1985    1975  1980  1985

    0          0
    0          0
    0          0
    0          0
    0          0
    1          1
    1          2
    1          3
    1          4
    1          5
    1          6
    1          7
    1          1
    1          2
    1          3
    1          4
    1          5
    1          6
    1          7
    1          1
    1          2
    1          3
    1          4
    1          5
    1          6
    I          1
    1          2
    1          3
    l          4
    1          5
    1          6
    1          7
    1          1
    1          2
    1          3
    1          6
    1          1
    1          2
    1          3
    1          6
    1          7
    1          4
    1          5
    1          6
    2          1
    2          2
    2          3
    2          4
    2          1
    2          2
                                    B-24
0
1
2
3
6
0
0
0
0
0
0
0
1
1
1
1
1
1
1
2
2
2
2
2
2
3
3
3
3
3
3
3
4
4
4
4
5
5
5
5
5
6
6
6
0
0
0
0
1
1
6.38
2.18
8.17
4.66
0.04
6.46
17.69
10.85
1.65
3.30
5.77
1.62
1.59
3.87
0.11
1.08
0.08
0.05
0.11
3-45
1.49
3.98
0.06
0.12
0.80
4.75
23.26
16.94
5-31
5.89
10.62
3-37
0.33
0.04
0.04
0.04
0.04
0.04
0.04
0.04
0.04
0.04
0.04
0.04
1.85
5-92
2.92
0.54
0.05
1.06
4.78
1.85
6.35
3.18
0.07
4.96
14.26
8.64
1.36
2.44
4.64
1.80
0.87
3.26
0.11
0.79
0.06
0.09
0.17
2.69
1.34
3.63
0.10
0.14
0.39
3.19
14.96
10.15
3-62
4.25
6.04
1.05
0.35
0.10
0.10
0.06
0.05
0.09
0.08
0.09
0.09
0.08
0.08
0.09
1.51
5.24
2.35
0.42
0.04
0.90
2.39
1.05
3.29
1.45
0.10
2.54
7.67
4.60
0.75
1.21
2.50
1.34
0.32
1.83
0.07
0.39
0.03
0.10
0.18
1.40
0.81
2.22
0.12
0.11
0.13
1.43
6.42
4.06
1.65
2.05
2.30
0.22
0.24
0.16
0.15
0.06
0.04
0.16
0.13
0.14
0.16
0.12
0.10
0.16
0.82
3.10
1.26
0.22
0.02
0.51
1.35
0.67
1.93
0.75
0.15
1.47
4.67
2.76
0.47
0.68
1.52
1.13
0.13
1.16
0.06
0.21
0.02
0.13
0.22
0.83
0.55
1.53
0.15
0.10
0.05
0.72
3.12
1.84
0.85
1.12
0.99
0.05
0.19
0.29
0.26
0.07
0.04
0.31
0.23
0.26
0.31
0.21
0.16
0.30
0.50
2.07
0.76
0.13
0.01
0.33
0.95
0.97
0.96
0.93
1.15
0.95
0.96
0.96
0.97
0.95
0.96
1.03
0.89
0.97
1.01
0.94
0.94
1.12
1.11
0.96
0.98
0.99
1.11
1.04
0.87
0.93
0.92
0.91
0.93
0.94
0.90
0.80
1.01
1.20
1.19
1.09
1.06
1.21
1.19
1.20
1.21
1.18
1.15
1.21
0.97
0.98
0.96
0.96
0.94
0.97
0.88
0.90
0,88
0.86
1.07
0.88
0.89
0.89
0.89
0.87
0.89
0.95
0.82
0.90
0.93
0.87
0.87
1.03
1.02
0.88
0.91
0.91
1.03
0.96
0.80
0.86
0.85
0.84
0.86
0.87
0.83
0.74
0.93
1.10
1.10
1.00
0.98
1.12
1.10
1.11
1.12
1.08
1.07
1.12
0.89
0.91
0.89
0.88
0.87
0.90
0.90
0.92
0.90
0.88
1.09
0.90
0.91
0.91
0.91
0.90
0.91
0.97
0.84
0.92
0.95
0.89
0.89
1.06
1.04
0.90
0.93
0.93
1.05
0.98
0.82
0.88
0.87
0.86
0.88
0.89
0.85
0.75
0.96
1.13
1.12
1.03
1.00
1.15
1.12
1.13
1.15
l.ll
1.09
1.15
0.91
0.93
0.91
0.91
0.89
0.92

-------
                            Table B-19 (Continued)

                 ST. LOUIS URBAN AREA  (ILLINOIS  SUBAREA)
                    ESTIMATES OF CARBON MONOXIDE EMISSIONS

                     LINK    DAILY TONS EMITTED       5-YEAR GROWTH RATE
CORRIDOR SUBCORRIDOR TYPE  1970  1975  1980   1985    1975  1980  1985

     2
    2
    2
    2
    2
    2
    2
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    4
    4
    4
    4
    4
    4
    4
    4
    4
    4
    4
    4
    4
    4
    4
    5
    5
    5
    5
    5
    5
    5
                                    B-25
4
1
2
1
2
3
4
1
2
3
4
3
l
2
3
4
2
3
4
4
1
2
3
4
1
2
3
4
1
2
3
4
1
2
3
4
2
3
4
1
2
3
4
1
2
3
1
2
3
1
1
2
2
3
3
3
3
0
0
0
0
1
2
2
2
2
3
3
3
5
6
6
6
6
0
0
0
0
1
1
1
1
2
2
2
2
3
3
3
6
6
6
6
0
0
0
1
1
1
2
1.54
1.96
0.05
2.91
7.89
4.80
1.20
0.12
4.69
3.00
0.58
0.31
0.65
1.75
0.62
2.24
0.92
2.07
2.28
0.04
3.31
8.03
3.88
3.73
1.00
1.00
2.69
1.46
0.74
0.37
0.48
0.53
1.71
0.05
1.59
1.86
2.03
0.05
0.28
0.86
2.86
2.82
6.18
3-36
4.15
0.68
3.56
0.53
0.69
5.22
1.26
1.42
0.06
2.22
6.33
3.80
0.92
0.10
3-58
2.28
0.47
0.29
0.51
1.50
0.49
1.66
0.75
1.52
1.74
0.06
2.73
6.72
2.92
2.90
0.79
0.88
2.44
1.11
0.62
0.30
0.44
0.40
1.35
0.08
1.11
1.35
1.50
0.06
0.24
0.70
2.28
1.80
5.47
2.68
3.89
0.51
2.74
0.25
0.59
2.30
0.69
0.68
0.05
1.14
3.39
2.01
0.47
0.05
1.83
1.16
0.26
0.18
0.27
0.86
0.26
0.82
0.41
0.74
0.89
0.06
1.50
3-76
1.46
1.51
0.41
0.51
1.48
0.57
0.34
0.16
0.27
0.20
0.71
0.07
0.51
0.65
0.74
0.05
0.14
0.38
1.21
0.77
3.23
1.43
2.44
0.26
1.41
0.08
0.33
0.68
0.42
0.37
0.05
0.66
2.05
1.20
0.27
0.03
1.05
0.66
0.16
0.12
0.16
0.56
0.15
0.46
0.25
0.41
0.51
0.06
0.94
2.37
0.83
0.89
0.25
0.34
1.01
0.33
0.21
0.10
0.19
0.11
0.42
0.08
0.27
0.36
0.41
0.05
0.10
0.23
0.73
0.37
2.16
0.86
1.72
0.15
0.82
0.03
0.21
0.23
0.97
0.94
1.05
0.95
0.96
0.96
0.95
0.96
0.95
0.95
0.96
0.99
0.96
0.98
0.96
0.95
0.96
0.94
0.95
1.09
0.97
0.97
0.95
0.96
0.96
0.98
0.99
0.95
0.97
0.96
0.99
0.95
0.96
1.08
0.93
0.94
0.95
1.06
0.98
0.96
0.96
0.92
0.98
0.96
0.99
0.95
0.95
0.86
0.97
0.85
0.89
0.87
0.97
0.88
0.89
0.89
0.88
0.89
0.88
0.88
0.89
0.91
0.88
0.90
0.88
0.87
0.89
0.87
0.88
1.00
0.89
0.90
0.88
0.88
0.88
0.90
0.91
0.88
0.89
0.89
0.91
0.88
0.89
0.99
0.86
0.87
0.87
0.98
0.90
0.89
0.89
0.85
0.91
0.89
0.92
0.88
0.88
0.80
0.90
0.79
0.91
0.89
0.99
0.90
0.91
0.91
0.90
0.91
0.90
0.90
0.91
0.94
0.91
0.92
0.91
0.90
0.91
0.89
0.90
1.03
0.91
0.92
0.90
0.90
0.91
0.93
0.93
0.90
0.92
0.91
0.94
0.90
0.91
1.02
0.88
0.89
0.89
1.00
0.93
0.91
0.91
0.87
0.93
0.91
0.94
0.90
0.90
0.82
0.92
0.81

-------
                           Table B-19 (Continued)

                 ST. LOUIS URBAN AREA  (ILLINOIS  SUBAREA)
                    ESTIMATES OF CARBON  MONOXIDE EMISSIONS

                     LINK    DAILY TONS  EMITTED       5-YEAR GROWTH RATE
CORRIDOR SUBCORRIDOR TYPE  1970  1975   1980  1985    1975  1980  1985

    5          2
    5          3
    5          1
    5          2
    5          3
    5          1
    5          2
    5          3
    6          1
    6          2
    6          1
    6          2
    6          1
    6          2
    6          1
    6          2
    6          1
    6          2
2
2
3
3
3
5
6
6
0
0
1
1
2
2
3
3
4
5
0.
1.
1.
10.
4.
0.
0.
0.
9.
1.
1.
0.
10.
11.
7.
3.
0.
0.
05
12
95
48
88
03
04
04
54
84
96
08
62
53
9^
72
04
04
0.10
0.86
1.81
6.35
3.10
0.05
0.07
0.10
7.58
1.46
1.62
0.06
8.04
7-85
4.23
2.51
0.09
0.07
0.13
0.44
1.12
2.57
1.32
0.06
0.10
0.18
4.02
0.77
0.89
0.03
4.07
3.57
1.51
1.14
0.13
0.10
0
0
0
1
0
0
0
0
2
0
0
0
2
1
0
0
0
0
.19
.25
.78
.18
.63
.07
.15
.37
.41
.46
.55
.02
.33
.83
.61
.58
.21
.14
1
0
0
0
0
1
1
1
0
0
0
0
0
0
0
0
1
1
.14
.95
.99
.91
.92
.10
.16
.22
.96
.96
.97
.94
.95
.93
.89
• 93
.17
.15
1
0
0
0
0
1
1
1
0
0
0
0
0
0
0
0
1
1
.06
.88
.91
.84
.85
.01
.07
.13
.89
.89
.89
.87
.88
.86
.82
.86
.08
.06
1.08
0.90
0.94
0.86
0.87
1.04
1.09
1.16
0.91
0.91
0.91
0.89
0.90
0.88
0.84
0.88
1.11
1.08
                                  B-26

-------
                            Table B-19  (Continued)

                 ST. LOUIS  URBAN  AREA (ILLINOIS SUBAREA)
                    ESTIMATES  OF  HYDROCARBONS    EMISSIONS

                     LINK    DAILY  TONS EMITTED      5-YEAR GROWTH  RATE
CORRIDOR SUBCORRIDOR TYPE   1970   1975  1980  1985    1975  1980   1985

    0          0
    0          0
    0          0
    0          0
    0          0
    1          1
    1          2
    1          3
    1          4
    1          5
    1          6
    1          7
    1          1
    1          2
    1          3
    1          4
    1          5
    1          6
    1          7
    1          1
    1          2
    1          3
    1          4
    1          5
    1          6
    1          1
    1          2
    1          3
    1          4
    1          5
    1          6
    1          7
    1          1
    1          2
    1          3
    1          6
    1          1
    1          2
    1          3
    1          6
    1          7
    1          4
    1          5
    1          6
    2          1
    2          2
    2          3
    2          4
    2          1
    2          2
                                    B-27
0
1
2
3
6
0
0
0
0
0
0
0
1
1
1
1
1
1
1
2
2
2
2
2
2
3
3
3
3
3
3
3
4
4
4
4
5
5
5
5
5
6
6
6
0
0
0
0
1
1
0.89
0.33
1.28
0.7^
0.01
0.90
2.47
1.52
0.22
0.44
0.81
0.23
0.25
0.60
0.02
0.15
0.01
0.01
0.02
0.54
0.23
0.62
0.01
0.02
0.12
0.75
3.69
2.68
0.83
0.92
1.68
0.53
0.05
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.26
0.83
0.41
0.08
0.01
0.17
0.66
0.27
0.98
0.50
0.01
0.68
1.96
1.19
0.18
0.32
0.64
0.25
0.13
0.50
0.02
0.11
0.01
0.01
0.03
0.41
0.21
0.56
0.02
0.02
0.06
0.50
2.34
1.58
0.56
0.65
0.94
0.16
0.05
0.02
0.02
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.21
0.72
0.32
0.06
0.01
0.14
0.31
0.15
0.48
0.21
0.01
0.33
1.00
0.60
0.09
0.15
0.32
0.17
0.05
0.27
0.01
0.05
0.00
0.02
0.03
0.20
0.12
0.32
0.02
0.02
0.02
0.21
0.95
0.60
0.24
0.30
0.34
0.03
0.04
0.02
0.02
0.01
0.01
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.11
0.40
0.16
0.03
0.00
0.07
0.19
0.10
0.31
0.12
0.02
0.21
0.67
0.40
0.06
0.09
0.22
0.16
0.02
0.19
0.01
0.03
0.00
0.02
0.04
0.13
0.09
0.24
0.02
0.02
0.01
0.12
0.51
0.30
0.14
0.18
0.16
0.01
0.03
0.05
0.04
0.01
0.01
0.05
0.04
0.04
0.05
0.03
0.03
0.05
0.07
0.30
0.11
0.02
0.00
0.05
0.95
0.97
0.95
0.93
1.15
0.95
0.96
0.96
0.96
0.94
0.96
1.02
0.89
0.97
1.00
0.94
0.94
1.12
1.10
0.95
0.98
0.98
1.11
1.03
0.87
0.93
0.92
0.90
0.93
0.94
0.90
0.79
1.01
1.19
1.18
1.08
1.06
1.21
1.18
1.19
1.21
1.17
1.15
1.21
0.96
0.98
0.96
0.96
0.94
0.97
0.87
0.89
0.87
0.85
1.05
0.87
0.88
0.88
0.88
0.86
0.88
0.94
0.81
0.89
0.92
0.86
0.86
1.02
1.01
0.87
0.90
0.90
1.02
0.94
0.80
0.85
0.84
0.83
0.85
0.86
0.82
0.73
0.92
1.09
1.08
0.99
0.97
1.11
1.08
1.09
1.11
1.07
1.05
1.11
0.88
0.89
0.88
0.87
0.86
0.89
0.91
0.94
0.92
0.90
1.11
0.92
0.93
0.93
0.93
0.91
0.93
0.99
0.86
0.94
0.97
0.91
0.91
1.08
1.07
0.92
0.95
0.95
1.07
1.00
0.84
0.89
0.89
0.87
0.90
0.91
0.87
0.77
0.98
1.15
1.14
1.05
1.02
1.17
1.15
1.15
1.17
1.13
1.11
1.17
0.93
0.95
0.93
0.92
0.91
0.94

-------
                           Table B-19 (Continued)

                 ST. LOUIS URBAN AREA  (ILLINOIS  SUBAREA)
                    ESTIMATES OF HYDROCARBONS     EMISSIONS

                     LINK    DAILY  TONS  EMITTED       5-YEAR GROWTH RATE
CORRIDOR SUBCORRIDOR TYPE  1970 1975   1980  1985    1975  1980  1985

    2
    2
    2
    2
    2
    2
    2
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    3
    4
    4
    4
    4
    4
    4
    4
    4
    4
    4
    4
    4
    4
    4
    4
    4
    4
    4
    4
    5
    5
    5
    5
    5
    5
    5
                                   B-28
4
1
2
1
2
3
4
1
2
3
4
3
1
2
3
4
2
3
4
4
1
2
3
4
1
2
3
4
1
2
3
4
1
2
3
4
2
3
4
1
2
3
4
1
2
3
1
2
3
1
1
2
2
3
3
3
3
0
0
0
0
1
2
2
2
2
3
3
3
5
6
6
6
6
0
0
0
0
1
1
1
l
2
2
2
2
3
3
3
6
6
6
6
0
0
0
1
1
1
2
0.24
0.31
0.01
0.46
1.25
0.76
0.19
0.02
0.66
0.40
0.08
0.04
0.10
0.27
0.09
0.34
0.15
0.32
0.36
0.01
0.52
1.27
0.63
0.61
0.15
0.14
0.38
0.20
0.12
0.06
0.07
0.08
0.27
0.01
0.25
0.29
0.32
0.01
0.04
0.13
0.45
0.44
0.97
0.51
0.58
0.09
0.56
0.08
0.10
0.83
0.19
0.22
0.01
0.35
0.99
0.59
0.14
0.01
0.49
0.30
0.06
0.04
0.08
0.23
0.07
0.25
0.12
0.23
0.27
0.01
0.42
1.04
0.47
0.46
0.12
0.12
0.34
0.15
0.09
0.05
0.07
0.06
0.21
0.01
0.17
0.21
0.23
0.01
0.04
0.11
0.35
0.28
0.85
0.40
0.54
0.07
0.42
0.04
0.08
0.36
0.10
0.10
0.01
0.17
0.50
0.30
0.07
0.01
0.24
0.14
0.03
0.02
0.04
0.13
0.04
0.11
0.06
0.11
0.13
0.01
0.22
0.55
0.22
0.23
0.06
0.07
0.19
0.07
0.05
0.02
0.04
0.03
0.11
0.01
0.07
0.09
0.11
0.01
0.02
0.05
0.18
0.11
0.47
0.20
0.32
0.03
0.20
0.01
0.04
0.10
0.07
0.06
0.01
0.11
0.33
0.19
0.04
0.00
0.15
0.09
0.02
0.02
0.03
0.09
0.02
0.07
0.04
0.07
0.08
0.01
0.15
0.38
0.14
0.15
0.04
0.05
0.14
0.05
0.03
0.02
0.03
0.02
0.07
0.01
0.04
0.06
0.07
0.01
0.02
0.04
0.12
0.06
0.35
0.13
0.25
0.02
0.13
0.00
0.03
0.04
0.96
0.94
1.04
0.95
0.96
0.96
0.95
0.96
0.95
0.95
0.96
0.99
0.96
0.97
0.95
0.9^
0.96
0.94
0.95
1.08
0.96
0.97
0.95
0.95
0.96
0.98
0.98
0.95
0.97
0.96
0.99
0.95
0.96
1.07
0.93
0.94
0.94
1.06
0.98
0.96
0.96
0.92
0.98
0.96
0.99
0.95
0.95
0.86
0.97
0.85
0.88
0.86
0.95
0.87
0.88
0.88
0.87
0.88
0.87
0.87
0.88
0.90
0.87
0.89
0.87
0.86
0.88
0.86
0.87
0.99
0.88
0.89
0.87
0.87
0.87
0.89
0.90
0.87
0.88
0.88
0.90
0.87
0.87
. 0.98
0.85
0.86
0.86
0.97
0.89
0.88
0.88
0.84
0.89
0.88
0.91
0.87
0.87
0.79
0.89
0.78
0.93
0.91
1.01
0.92
0.93
0.92
0.92
0.93
0.92
0.92
0.93
0.95
0.92
0.94
0.92
0.91
0.93
0.91
0.92
1.05
0.93
0.93
0.91
0.92
0.92
0.94
0.95
0.92
0.93
0.93
0.95
0.91
0.92
1.04
0.90
0.91
0.91
1.02
0.94
0.93
0.93
0.89
0.95
0.93
0.96
0.92
0.92
0.83
0.94
0.82

-------
                            Table B-19 (Continued)

                 ST.  LOUIS  URBAN AREA  (ILLINOIS SUBAREA)
                    ESTIMATES  OF HYDROCARBONS    EMISSIONS

                      LINK    DAILY  TONS EMITTED      5-YEAR GROWTH RATE
CORRIDOR SUBCORRIDOR  TYPE   1970   1975   1980  1985    1975  1980  1985

    5          2
    5          3
    5          1
    5          2
    5          3
    5          1
    5          2
    5          3
    6          1
    6          2
    6          1
    6          2
    6          1
    6          2
    6          1
    6          2
    6          1
    6          2
2
2
3
3
3
5
6
6
0
0
1
1
2
2
3
3
4
5
0.
0.
0.
1.
0.
0.
0.
0.
1.
0.
0.
0.
1.
1.
1.
0.
0.
0.
01
17
31
66
76
01
01
01
33
24
31
01
66
73
26
58
01
01
0.02
0.13
0.29
0.99
0.48
0.01
0.01
0.02
1.04
0.19
0.25
0.01
1.24
1.16
0.66
0.39
0.01
0.01
0.02
0.06
0.17
0.38
0.19
0.01
0.01
0.03
0.52
0.09
0.13
0.00
0.59
0.50
0.22
0.16
0.02
0.01
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
.03
.04
.13
.19
.10
.01
.02
.06
.35
.06
.09
.00
.37
.28
.10
.09
.04
.02
1
0
0
0
0
1
1
1
0
0
0
0
0
0
0
0
1
1
.14
.95
• 99
.91
.92
.10
.15
.22
.96
• 96
.96
• 94
• 95
• 93
.88
.93
.17
.14
1
0
0
0
0
1
1
1
0
0
0
0
0
0
0
0
1
1
.04
.87
.90
.83
.84
.00
.06
.11
.88
.88
.88
.86
.87
.85
.81
.85
.07
.04
1.10
0.92
0.95
0.88
0.89
1.06
1.12
1.18
0.93
0.92
0.93
0.91
0.92
0.90
0.85
0.90
1.13
1.10
                                    B-29

-------
              APPENDIX C
 ST. LOUIS AQMA EMISSION PROJECTIONS


FOR SO  AND TSP FROM HIGHWAY SOURCES
      x

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-------
              APPENDIX D
GROWTH PATTERNS IN THE ST. LOUIS AQMSA

-------
                              APPENDIX D
                GROWTH PATTERNS IN THE ST. LOUIS AQMSA

     Of particular significance to air quality maintenance planning is
the regional development potential to accommodate predicted growth
patterns for industrial land use and population.  A growth and distribu-
tion projection for population in the region generated for the 1995 Regional
Land Use Plan for Metropolitan St. Louis is presented in Table D-l.
                               Table D-l
               Population for Counties in St. Louis Area
                             (1970, 1995)
Area
Madison County
Monroe County
St. Clair County
St. Louis City
Franklin County
Jefferson County
St. Charles County
St. Louis County
TOTAL
1970
250,911
18,831
285,199
622,236
55,127
105,248
92,954
951,671
2,382,177
1995
407,000
45,000
423,200
622,000
91,500
210,200
217,100
1,520,000
3,536,000
The majority of the population was projected to be located in St. Louis
County and City.  With substantial increases in St.  Charles,  Jefferson,
St. Clair and Madison Counties.
                                  D-l

-------
     A land development potential analysis was also conducted as a back-
ground study to the 1995 Regional Land Use Plan for Metropolitan St.  Louis.  The
factors used to evaluate land development potential were:
     •    Highway accessibility
     •    Availability of water and sewer service
     •    Proximity of existing urbanization
     •    Certain physical  constraints to development
The results of that study suggested the directions of growth in the
metropolitan area would most likely assume the given available land
development potential.  The analysis indicated corridors of high develop-
ment potential similar to the directions of growth shown in Figure D-l.
     The development potential for specifically industrial  land use is
critical to air quality maintenance planning as well.  In generating  the
1995 projection for this land use category, certain factors were consid-
ered.  It was known the density of manufacturing activities had been
decreasing in the region primarily due to the trend in construction of
horizontal rather than vertical industrial facilities.  Therefore, in
projecting industrial land use to 1995, a density of workers of 15-20
per acre was used rather than the current density of 20-25 workers per
acre.  Consequently, while allocating land for industrial  use in 1995,
utilizing development potential and population projections for given
areas, an additional 15,000-20,000 industrial acres and 300,000 manufac-
turing employees were projected to be required in the region.  This indus-
trial acreage expansion roughly paralleled the river basins and the 1-70
corridor.  In addition, if the proposed new international  airport was
located in Illinois on the St. Clair-Monroe County lines,  an additional
southeasterly industrial expansion could be experienced.  Figure D-2
illustrates the projected 1995 industrial land use pattern relative to
1974 major point and area air pollutant emission sources.   Table D-2 lists
growth factors associated with projected pollutant emission sources in
1975, 1980, and 1985.

                                  D-2

-------
                                                       
-------
D-4

-------
                                           GROWTH FACTORS USED IN AQMA ANALYSIS
       Source Categuiy
      Growth Factors
  1975 to J.9BO  I960 to 1985
                                                                                                          Comments
Point Sources:
   Fuel Combustion
      Industrial
      Commercial/Industrial
   Industrial Process
      Some Primary Sources
      Other Sources
         Food Products
         Chemicals
         Petroleum
         Mineral
         Primary Metals
         Metal Fabrication
         Misc. Manufacturing

   Solid Haste Disposal
      Municipal Incinerator
                                    1.19
                                    1.30
                                                 1.18
                                                 1.23
Individual growth rates were
obtained from some primary
point sourcea3
     1.11
     1.24
     1.08
     1.19
     1.13
     1.21
     1.15
1.07
1.22
1.07
1.15
1.12
1.19
1.14
For St. Louis City, growth
factor of 0    because  trash
will be burned by power
plants as fuel after  1978
       Industrial Incinerator
For other areas:
      1.07
                                    1.19
                                                 1.07
                                                  1.18
                              BEA  St. Louis SMSA manufac-
                              turing earnings growth pro-
                              jections
                              BEA St. Louis SMSA
                              government earnings growth
                              projections
            Local survey
                              BEA or PEDCo  St. Louis SMSA
                              earnings growth projections
                              by industrial categories
           BEA
           BEA
           PEDCo
           BEA
           PEDCo
           BEA
           BEA

Local information
            BEA St. Louis SMSA popula-
            tion growth projections
                                                             BEA St. Louis SMSA manufac-
                                         Manufacturing  earnings were the BEA
                                         statistic most closely related to  in-
                                         dustry;  growth projections by county
                                         not available  in usable  format for
                                         every  county

                                         Employment and wholesale growth
                                         to commerce and industry; civilian
                                         government gives a more  conservative
                                         emissions estimate
                             Obtain  growth rates  for  all  companies
                             which are  primary  point  sources.


                              For those  primary  sources for which in-
                              dividual growth rates were unobtainable
                              and for non-primary  sources, the ir.cst
                              appropriate BEA or Pedco industrial
                              projection was used.
BEA statistics were confidential

BEA statistics were confidential
      Commercial/Industrial
         Incinerator
      1.30
                   1.23
            turing earnings growth
            projections

            BEA St. Louis SMSA
            government projections
                              Population projections were more
                              closely related to municipal incineri-
                              tion than to any other

                              Manufacturing earnings were the BEA

                              statistic most closely related to
                              industry

                              Employment growth was con-
                              sidered a conservative prediction of
                              commercial/institutional growth
Power Plants
                               Individual plan information:
                               compliance information, pro-
                               jected growth or phasing out
                               of existing plants, openings
                               of new plants
                               Information provided by Union
                               Electric Co., Illinois Power
                               Co., Missouri Air Conserva-
                               tion Commission, and Illi-
                               nois Environmental Protec-
                               tion Agency
                                          Best source-by-source information
                                          available
Arcia Sources
   Fuel Combustion
      Residential
         Bituminous Coal
         Other Fuels:
           Residual oil
           Distillate oil
           natural gas

      Industrial
      Commercial/Industrial
                                    1.07
                               Decrease to
                               1/2 of 1975
                                                 1.07
                Decrease to
                2/5 of 1980
Increase with population
growth and with conversion
from coal to other fuels
in proportion
                                    1.19
                                    1.30
                                                 1.18
                                                 1.23
                                                             BEA St. Louis SMSA popula-
                                                             tion growth projections
            Local estimate


            Fuel balance  methodology
                              BEA St. Louis SMSA manufac-
                              turing earnings growth pro-
                              jections

                              BEA St. Louis SMSA
                              government earnings growth
                              projections
                              Residential  coal  burning
                              furnaces  are being phased out

                              BTO's  not generated by burning coal
                              were ascribed proportionately to  other
                              fuels  in  absence  of information to  the
                              contrary

                              Manufacturing earnings were  the BEA
                              statistic most closely related to
                              industry

                              Employment growth was  con-
                              sidered a conservative prediction of
                              commercial/industrial  growth
                                                               D-5

-------
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-------
                APPENDIX E








       TOTAL SUSPENDED PARTICULATES



EMISSION DENSITY VS.  ANNUAL CONCENTRATIONS

-------
                      TOTAL SUSPENDED PARTICULATES

              EMISSION DENSITY VS. ANNUAL CONCENTRATIONS*
      200
          111111111111111111111111 ITT 111111111111111 ITTTTIT:
       50
3"=
      100
a-- z
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ULJ C-3
       so
        o
.Ti IJ.I I I..1. i I I I I I I I I  I I I I I I I I I I I  I I I I I I I II I l.i-1 U 1 I i U.L
0         250         500         750       1,000       '.250


         PARTICUUTE  EMISSION  DENSITY, tons'nu2  yt
 U.S.  Department H.E.W.,  Interstate Air Pollution  Study Pollution
 Phase II Project Report,  December 1966.
                                    E-l

-------
                APPENDIX F









SUPPORTING CALCULATIONS FOR SULFUR DIOXIDE




     CONCENTRATIONS BY SOURCE CATEGORY

-------




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-------
                      APPENDIX G









   PERCENT EMISSION CHANGE FOR CARBON MONOXIDE




IN SUBCORRIDORS INFLUENCING NINE RECEPTORS IN THE AQMA

-------
   PERCENT EMISSION REDUCTION FOR CARBON MONOXIDE
IN SUBCORRIDORS INFLUENCING NINE RECEPTORS IN THE AQMA
                             Carbon Monoxide Emissions  (Daily Tons)
Receptor Subcorridors 1975
1 3-5 5.22
9-2 5.40
9-3 7,35
Totals 17.97
Percent Reduction:1975-1980 - 49.6%
1980-1985 - 42.1%
2 6-2 6.42
6-3 2.31
1-4 2.27
1-5 18.13
Totals 29.13
Percent Reduction:1975-1980 - 48.0%
1980-1985 - 36.8%
3 1-7 17.30
1-6 23.54
8-2 34.91
8-3 24.78
Totals 100.53
Percent Reduction J.975-1980 - 48.6%
1980-1985 - 43.0%
4 4-2 13.38
5-2 8.33
6-6 20.74
Totals 42.48
Percent Reduction:1975-1980 - 45.7%
1980-1985 - 38.0%
1980
2.57
2.72
3.77
9.06

3.19
1.17
.85
9.97
15.18


8.64
13.08
17.58
12.42
51.72


7.32
4.42
11.31
23.05


1985
1.48
1.56
2.27
5.25

2.02
.78
.48
6.22
9.60


4.90
7.58
10.04
7.03
29.55


4.62
2.66
7.02
14.30


                               G-l

-------
                    Carbon Monoxide Emissions (Daily Tons)
Receptor Subcorridors
5 3-2
3-3
7-3
Totals
Percent Reduction :

6 1-5
6-3
7-2
Totals
1975
19.31
21.92
16.78
58.01
1975-1980 - 48.0%
1980-1985 - 41.0
18.13
15.46
10.77
44.36
1980
10.23
11.14
8.82
30.19


9.97
8.22
5.35
23.54
1985
6.14
6.42
5.23
17.79


6.22
4.97
3.12
14.31
Percent Reduction:1975-1980 - 47.0%

7 3-1
3-2
6-5
Totals
Percent Reduction

8 1-5
7-2
7-1
\
Totals
Percent Reduction

9 3-4
8-4
8-5
1980-1985 - 39.2%
17.37
19.31
20.13
56.81
:1975-1980 - 46.0%
1980-1985 - 38.0
18.13
10.77
11.08

39.98
d.975-1980 - 48.0%
1980-1985 - 40.0%
14.93
39.87
8.75

10.27
10.23
10.45
30.95


9.97
5.35
5.60

20.92


7.49
14.58
4.31

6.91
6.14
6.38
19.43


6.22
3.12
3.25

12.59


4.25
7.20
2.40
Totals               63.55          26.38
PercentReduction:1975-1980 - 39.0%
                 1980-1985 - 47.5%
13.85
                     G-2

-------
            APPENDIX H
APPENDIX J FEDERAL REGISTER 40CFR51

-------
RELATIONSHIP  BETWEEN  PERCENT  REDUCTION  IN HC EMISSIONS  AND PHOTOCHEMICAL

OXIDANT  CONCENTRATION
             »
                     0.10
                                         APPENDIX J


                           MAXIMUM MEASURED 1- hour PHOTOCHEMICAL OXIDANT CONCENTRATION. N*


                                   0 IS             0.20            07$
                                                                               0.30
         3
             40



         II
         S2 ID

         S
                                    I
                                    T
                                                     NOTE: NO HYDROCARBON OR PHOTOCHEMICAL

                                                          OXIDANT BACKGROUND ASSUMED
                      I
               I
I
I
I
I
I
         P
         u
         g
150     2W      2M     MO      J50      400      450      500      550


            MAXIMUM MEASURED 1 • tall PHOTOCHEMICAL OXIDANT CONCENTRATION, ft/ml
                                                                                 (00
                                                H-l

-------
              APPENDIX I







MISSOURI REGULATIONS DIRECTLY RELATED



      TO AIR QUALITY MAINTENANCE

-------
 EXISTING


     The existing enabling legislation and regulations included in the
State Implementation Plans for the Missouri and Illinois portions of the
St. Louis AQCR provide a basis for the attainment and maintenance of air
quality.  These regulations have particular application to air quality
maintenance and are described below:
REGULATION XVIII  APPROVAL OF PLANNED INSTALLATIONS, LAND USE PLANS,
                  AND ZONING REGULATIONS REQUIRED

A.   Review of Plans and Approval

A._   DEFINITIONS:
     1.   Conmenoed - an owner or operator has undertaken a continuous
          program of construction or modification or that an owner or
          operator has entered into a binding agreement or contractual
          obligation to undertake and complete, within a reasonable time,
          a continuous program of construction or modification.
     2j_   Construction - fabrication, erection or installation.
     3.   Modification - any physical change in, or change in method of
          operation of, an air contaminant source which increases the
          the amount of any air pollutant emitted by such source or which
          results in the emission of any air pollutant not previously emitted.
     4.   Startup - the setting in operation of a source for any purpose.
     5.   Owner or operator - any person who owns, leases, operates,
          controls or supervises an air contaminant source.

IL_  [A.]  General
     1.   No owner or operator shall commence construction or modification
          of any air contaminant source after the effective date of this
          regulation without first obtaining a permit from the Executive
          Secretary.
                                   1-1

-------
2.   Each application for a construction permit shall be accompanied
     by site information, plans,  descriptions,  specifications,  and
     drawings showing the design of the source,  the nature and
     amount of emissions, and the manner in which it will be operated
     and controlled.
3.   Any additional information,  plans, specifications,  evidence or
     documentation that the Executive Secretary may require shall
     be furnished upon request.
4.  [The Executive Secretary shall determine if the ambient air
     quality standards in the vicinity of the source are being
     exceeded, and shall determine the impact on the ambient air
     quality standards from the source prior to granting a permit
     to construct or modify.}  No permit to construct or modify
     shall be issued if it is determined that the proposed source
     will [interfere or] prevent the attainment or maintenance of
     [national} ambient air quality standards,  or_ violate any of
     the regulations pursuant to Chapter 20S, RSMo.
5.   Upon receipt of an application, the Executive Secretary shall
     act promptly, [but in no case later than sixty (60) days,]
     and shall notify the applicant in writing of his approval,
     conditional approval, or denial of the application.  The
     Executive Secretary will set forth his reasons for any denial.
6.   The Executive Secretary may impose any reasonable conditions,
     upon a permit, including conditions requiring the source to be
     provided with:

     a.   Sampling ports of a suitable size, number and location,
     b.   Safe access to each port,
     c.   Instrumentation to monitor and record emission data,  and
     d.   Other sampling and testing facilities.

7.   Apermit may be cancelled if construction or modification work
     is not begun within two (2) years from the date of issuance,
     or if work is suspended for one (1) year.
8.   Any owner or operator subject to the provisions of this regulation
     shall furnish the Executive Secretary written notification as
     follows:

     a.   A notification of the anticipated date of initial startup
          of source not more than 60 days or less than 30 days
          prior to such date.
     b.   A notification of the actual date of initial startup of a
          source within 15 days after such date.
                              1-2

-------
     9.   Within 60 days after achieving the maximum production rate at
          which the source will be operated, but [by] not later than 180
          days after initial startup of such source, the owner or operator
          of such source shall conduct performance test(s) in accordance
          with methods and under operating conditions approved by the
          Executive Secretary and furnish the Executive Secretary a
          written report of the results of such performance test.

          a.   Such tests shall be at the expense of the owner or operator.
          b.   The Executive Secretary may monitor such tests and may
               also conduct performance tests.
          c.   The owner or operator of a source shall provide the
               Executive Secretary 15 days prior notice of the performance
               test to afford the Executive Secretary the opportunity to
               have an observer present.

     10.  Approval to construct shall not relieve any owner or operator
          of the responsibility to comply with other [all} local, state,
          and Federal regulations^ [which are part of the applicable
          plan.]

[B.  Other requirements:
     1.   A twenty-five dollar ($25.00) filing fee payable to the State
          of Missouri shall accompany each application, and the appli-
          cation shall not be considered, evaluated, or the permit
          approved until the filing fee is paid.
     2.   No manufacturing or processing plant or operating location
          shall be required to pay more than one filing fee.}

C.    Exceptions:
     1.   Fuel burning equipment which use gas or oil or grade #3 or
          lighter for space heating,  air conditioning,  or heating water;
          is used in a private dwelling;  or has a heat input as specified
          by the manufacturer or designer of less than 250,000 BTU's per
          hour.
     2.   Mobile internal combustion engines.
     3.   The construction of a private residence.
     4.   Portable equipment including, but not limited to rock crushers,
          asphalt plants, and concrete batching plants shall be exempted
          from the requirements of this regulation after an initial permit
          has been obtained,  provided that:
                                    1-3

-------
          a._   Each new location is reported to the Executive Secretary
               as early as possible, but in no case later than fourteen
               (14) days prior to ground breaking or initial equipment
               erection, and
          b_._   The equipment that was originally approved, shall be
               operated and maintained in a manner identical to that
               as specified in the initial construction perm-it.

     5^_   Planned periodic modification of air contaminant souroes shall
          be exempted from the requirements of this regulation, provided
          that:

          o._   A. prior permit 'has been obtained for all planned air
               contaminant sources, and*
          b._   Eadh modification be reported to the Executive Secretary
               as soon as possible, and*
          £._   The prior permit contains provisions for controlling
               emissions from all probable air contaminant sources that
               may be expected to come into existence as a result of
               the periodic modifications.

     6^_  [4.]  Other sources of minor significance specified by the
               Executive Secretary,

B.   Planning Agency Land Use Plans — Preparation and Approval

1.   Planning agencies will, in preparing land-use plans, obtain and use
information supplied by the Air Conservation Commission concerning:

     a.   air quality
     b.   air pollutant emissions
     c.   air pollution meteorology
     d.   air quality standards
     e.   air pollution effects

2.   The Executive Secretary will review all land-use plans prior to
formal adoption and prepare recommendations.  No such plan may be adopted
without the approval of the Executive Secretary.
                                    1-4

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C.   Zoning Agency Regulations — Preparation and Approval

1.   Zoning control agencies will, in preparing regulations, obtain and
use information supplied by the Air Conservation Commission concerning:

     a.   air quality
     b.   air pollutant emissions
     c.   air pollution meteorology
     d.   air quality standards
     e.   air pollution effects

2.   The Executive Secretary will review all zoning regulations and
proposed changes in zoning classifications prior to formal adoption and
prepare recommendations.  No such regulation or change in classification
may be adopted without the approval of the Executive Secretary.
REGULATION XXIII    ADDITIONAL AIR QUALITY CONTROL MEASURES MAY BE
                    REQUIRED WHEN SOURCES ARE CLUSTERED IN A SMALL
                    LAND AREA

A.   Areas to Which This Regulation Applies
     1.   This regulation shall apply to areas in which there are one or
          more existing sources and/or proposed new sources of particulate
          matter in any circular area with a diameter of two miles
          (including sources outside metropolitan area) from which the
          sum of particulate emissions allowed from such sources by
          regulations of general application are or would be greater
          than 2,000 tons per year or 500 pounds per hour.
     2.   This regulation shall apply in areas in which there are one or
          more existing sources and/or proposed new sources of sulfur
          dioxide in any circular area with a diameter of two miles from
          which the sum of sulfur dioxide emissions from such sources
          allowed by regulations of general application are or would be
          greater than 1,000 tons for any consecutive three months or
          1,000 pounds per hour.

B.   Air Conservation Commission May Prescribe More Restrictive Air
     Quality Control Measures
     1.   In areas where this regulation applies, as specified in Section A
          herein,  the Air Conservation Commission may prescribe air
          quality control requirements that are more restrictive and
          more extensive than provided in regulations of general appli-
          cation.
                                   1-5

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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
 1. REPORT NO.
 EPA-450/3-74-052
                                                           3. RECIPIENT'S ACCESSION-NO.
4. TITLE AND SUBTITLE
 DEVELOPMENT OF A TRIAL AIR QUALITY MAINTENANCE
 PLAN  FOR  THE ST. LOUIS AQMSA
             5. REPORT DATE

              December 1Q74
             6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)

  Planning  Environment International  Division of AMV
                                                           8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS

 Alan  M.  Voorhees & Associates,  Inc.
 Westgate Research Park
 McLean,  Virginia  22101
                                                           10. PROGRAM ELEMENT NO.
             11. CONTRACT/GRANT NO.

               68-02-1388, Task no.  5
 12. SPONSORING AGENCY NAME AND ADDRESS
                                                           13. TYPE OF REPORT AND PERIOD COVERED
  Environmental  Protection Agency
  Office  of Air  and Waste Management
  Office  of Air  Quality Planning and Standards
  Research  Triangle Park. North Carolina  27711
                   Final
             14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
 This report  documents the development  of a Trail  Air Quality Maintenance Plan
 for the  St.  Louis Air Quality Maintenance Study Area.  This is  one  of four such
 trial plans  prepared as part of the  development and testing of  EPA  Guidelines for
 air quality  maintenance planning.  The four areas include St. Louis,  San Diego,
 Denver,  and  Baltimore.   The study area in this report includes  the  City of St.
 Louis and  the  seven counties in Missouri  and Illinois which comprise  the St.  Louis
 SMSA.  The preparation  of this trial plan included the review of existing State
 Implementation Plans, emission inventory analysis and projection, air quality
 analysis and projection, and the formulation of attainment/maintenance strategies
 for control  of particulates, sulfur  dioxide, carbon monoxide, and photochemical
 oxidants.  Both  direct  emission control  measures  and administrative or planning
 measures were  examined  for applicability to the air quality maintenance problems.
 Finally, the institutional arrangements  and intergovernmental cooperation required
 to prepare and implement the Trial Plan  were explored.
 7.
                               KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS  C. COSATI Field/Group
 Air Polution
 Land Use
 Regional Planning
Air Quality Maintenance
uand Use Controls
St. Louis
National Ambient Air
  Quality Standards
18. DISTRIBUTION STATEMENT


 Unlimited
19. SECURITY CLASS (ThisReport)
UNCLASSIFIED
                                                                        21. NO. OF PAGES
197
20. SECURITY CLASS (This page)
UNCLASSIFIED
                           22. PRICE
EPA Form 2220-1 (9-73)

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