EPA-450/3-77-001
December 1976
DEVELOPMENT
OF COMPUTERIZED
EMISSION PROJECTION
AND ALLOCATION
SYSTEM-PHASE I:
PRELIMINARY
FEASIBILITY STUDY
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-450/3-77-001
DEVELOPMENT OF COMPUTERIZED
EMISSION PROJECTION
AND ALLOCATION SYSTEM --
PHASE I: PRELIMINARY
FEASIBILITY STUDY
by
Richard R. Cirillo and Michael J. Senew
Energy Research and Development Administration
Argonne National Laboralor\
Energy and Environmental Systems Division
9700 South Cans Avenue
Argonne, Illinois 60439
Interagency Agreement D6-0077
EPA Project Officer: Joseph Sableski
Prepared for
ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
December 1976
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This report is issued by the Environmental Protection Agency to report
technical data of interest to a limited n-umber of readers. Copies are
available free of charge to Federal employees, current contractors and
grantees, and nonprofit organizations - in limited quantities - from the
Library Services Office (MD-35) , Research Triangle Park, North Carolina
27711; or, for a fee, from the National Technical Information Service,
5285 Port Royal Road, Springfield, Virginia 22161.
This report was furnished to the Environmental Protection Agency by
Energy Research and Development Administration, Argonne National
Laboratory, Energy and Environmental Systems Division, 9700 South
Cass Avenue, Argonne, Illinois 60439. in fulfillment of Interagency
Agreement No. D6-0077. The contents of this report are reproduced
herein as received from Energy Research and Development Adminis-
tration, Argonne National Laboratory . 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-450/3-77-001
11
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EPA PROJECT OFFICER'S COMMENT
On pages 63 and 64 of the report, Argonne National Laboratory
reported that several States had problems with some of EPA's automated
data systems. Subsequent to the submission of the report to EPA, EPA
discussed the alleged problems with those States. As a result of those
discussions, the project officer has made several changes to Argonne's
text on pages 63 and 65 to reflect those discussions.
iiA
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iii.
Feasibility Study for the Development
of a Computerized Emission Projection
and Allocation System
Phase I
Preliminary Feasibility Study
1. Executive Summary 1
2. Introduction 3
2.1. Legislation and Policy Requirements 3
2.1.1. Attainment of National Standards 3
2.1.2. Maintenance of National Standards 4
2.1.3. Regulatory Requirements 4
2.2. Study Background 5
2.3. Fundamental Concepts 6
3. Methodology Used 7
3.1. Documents Reviewed 7
3.2. Agency Interviews 7
3.2.1. EPA Regional Offices 7
3.2.2. State Air Pollution Control Agencies 8
3.2.3. Contractors 15
4. System Requirements 16
4.1. Output Requirements 16
4.2. Input Requirements 24
4.2.1. Point Source File 24
4.2.2. Area Source File 26
4.2.3. Planning Data 27
4.3. CEPA System Timing Requirements 28
4.3.1. Federal Register Due Dates for Submittal of Air
Quality Analysis and Plans 29
4.3.2. Potential Uses of CEPA in Non-Attainment Areas ... 34
4.4. Data Processing Requirements 34
4.4.1. EPA Data Processing Policy 34
4.4.2. Other Agency Data Processing Policy 38
4.4.3. Code of Federal Regulations Requirements 40
4.5. Security Requirements 41
5. Potential User Survey 42
5.1. The EPA Regional Office Perspective 42
5.1.1. Current Effort Status ..... 42
5.1.2. Regional Office Analysis Evaluation 47
5.1.3. CEPA System Timing 48
5.1.4. System Design Features 49
5.1.5. General Comments on System Need 50
5.1.6. Summary 51
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iv.
5.2. The State Agency Perspective 52
5.2.1. Current Effort Status 52
5.2.2. Agency Resources Available 53
5.2.3. Agency Experience 60
5.2.4. CEPA System Design 66
5.2.5. Potential for Agency Use 68
5.2.6. Other Agency Priorities 70
5.2.7. State Agency Summary 70
5.3. The Contractor Perspective 72
5.3.1. Character of Contractural Assistance 72
5.3.2. AQMA Planning Evaluation 74
5.3.3.- CEPA System Timing 75
5.3.4. CEPA System Design 76
5.3.5. Potential Contractor Use 77
5.3.6. AQMP Priorities 77
5.3.7. Contractor Summary 77
6. Conclusions and Alternative Plans of Action 79
6.1. Identification of Issues 79
6.1.1. Analysis Requirements 79
6.1.2. Timing of System Development 80
6.1.3. Development of In-house Capability 81
6.1.4. State Capability and Experience 82
6.1.5. Agency Use 82
6.2. Alternative Courses of Action 83
6.2.1. Discontinue Study 83
6.2.2. Proceed with Phase 2 84
6.2.3. Revise Phase 2 84
6.2.4. Summary 85
Appendix A. Sample Questionnaires 87
References 101
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LIST OF FIGURES
Title
4-1. Sample Emission Summary Form 17
4-2. Sample Emission Allocation Summary 22
4-3. Cumulative Frequency of Due Dates for Submittal of Air Quality
Maintenance Analysis 32
4-4. Cumulative Frequency of Due Dates for Submittal of Air Quality
Maintenance Plans 33
LIST OF TABLES
Title
3-1. State Agency Location Characteristics 10
3-2. State Agency AQMAs 11
3-3. State Agency Staffing 12
4-1. Input Data Required for Air Quality Maintenance Planning 25
4-2. Due Dates for Submittal of Air Quality Maintenance Analyses
and Plans 31
4-3. Due Dates for Submittal of SIP Revisions in Non-Attainment Areas . . 35
5-1. Regional Office Summary of AQMA Planning Effort 43
5-2. State Agency Resources Committed to AQMA Analysis 55
5-3. State Agency Use of Contractors 55
5-4. Availability of Computer Personnel 57
5-5. Computer Hardware and Software Availability 58
5-6. Typical Computer Costs 60
5-7. Agency Experience with Computerized Models 61
5-8. Data Base Availability 64
5-9. Potential State Agency Use of a CEPA System 69
5-10. State Agency Priorities 71
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VI.
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1. EXECUTIVE SUMMARY
The Argonne National Laboratory, Energy and Environmental Systems
Division has completed a preliminary feasibility assessment to determine the
need for a computerized emission projection and allocation system (CEPA).
The primary application of a CEPA system is the computerization of otherwise
long and tedious calculations required to properly assess growth and development
when considering the maintenance of National Ambient Air Quality Standards.
The purpose of this feasibility assessment is to determine the actual use such
a system would receive and to assess the positive and negative aspects of an
EPA developed CEPA system.
Data for the CEPA system assessment came from a variety of independent
sources including Federal documents, EPA headquarters, EPA Regional Offices,
state air pollution control agencies, regional planning agencies and private
sector contractors participating in AQMP. All aspects of CEPA application
were investigated including legislative and policy requirements, computer
capabilities, user skill and knowledge requirements, potential application
and system design. A major portion of the assessment came from interviews
with nine potential users of a CEPA system. Seven of the visits were conducted
with specially selected state air pollution control agencies. Two visits
were made with local and regional planning organizations. In addition to
agency interviews, all ten Regional Offices were interviewed by telephone.
While most all those interviewed indicated a CEPA system would
be beneficial if properly designed, the major constraint facing its use
is the schedule for completion of maintenance plans and the earliest date
when a CEPA could be made available. A CEPA developed by January 1977
could be useful in 33% of set 1 pollutant assessments and 52% of the set 2
pollutant assessments. If a CEPA system were not made available for use
until mid-1977 the potential usage drops to 12% of set 1 assessments and
38% of the set 2 assessments. A total of seventeen pollutant assessments
would be the potential use of a CEPA system made available by mid-1977 -
While-direct application of a CEPA system to initial AQMA assessments
is limited by scheduling constraints, greatest benefit and application of a
CEPA system may be in non-AQMP related work. Potential users of CEPA expressed
a need fox computerized aids incorporated in a CEPA for other agency work;
New Source Review, Prevention of Significant Deterioration, data management,
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AQMP rechecks and revisions and long term planning are all examples of
potential CEPA use by state and local air pollution control agencies.
Potential users generally agreed that a CEPA system to be useful
would have to be modular in design, easily used by engineers with basic
FORTRAN programming backgrounds and, above all, the CEPA system must
accept a wide variety of locally formated data.
If a CEPA were made available and did not require additional agency
resources it would be considered for use by all those interviewed. If a
CEPA system were not developed, current state plans would not be adversely
affected. If a CEPA system were in use, however, those plans would
most likely exhibit a greater level of detail and accuracy.
Three courses of action are suggested. The first would be to
discontinue further study at this time since the CEPA system will be of little
use to the current air quality maintenance planning effort. The second would
be to proceed with the previously defined Phase 2 effort in the interest of
having a CEPA system available for the later AQMA analyses. The third would
be to expand the scope of Phase 2 to include potential long range CEPA
applications to other air quality analysis needs. Arguments for and against
pursuing each course of action are given.
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2. INTRODUCTION
2.1. LEGISLATION AND POLICY REQUIREMENTS
Section 110 of the Clean Air Act requires States to develop and
revise whenever necessary, plans to implement the National Ambient Air
Quality Standards. EPA has established NAAQS for six pollutants — particulate
matter, sulfur oxides, carbon monoxide, hydrocarbons, photochemical oxidants,
and nitrogen dioxide. EPA is also developing a standard for lead, which will
tentatively be proposed in August 1977-
States were required to submit their State Implementation Plans
(SIPs) to EPA in January 1972. The plans had to provide for both the
attainment of the national standards by May 31, 1975, and the maintenance
of these standards indefinitely thereafter. States could obtain an extension
of this attainment date of up to two years, but for most areas, the May 1975
date remained applicable. Attainment of the standard in many cases implies
a reduction of emissions that contribute to elevated air pollutant concen-
trations. SIPs contain control strategies that employ emission limitations
for stationary sources. The Federal motor vehicle emission control program
under Title II of the Clean Air Act is reducing most of the emissions from
mobile sources; in densely population areas where the Federal program is
insufficient to attain the standards, however, restrictions on automobile
use are being employed. Maintenance of the standards implies restriction
of emission increases that accompany new sources so that the air pollutant
concentrations remain below the standard.
2.1.1. Attainment of National Standards
Although the attainment date for the primary national ambient
air quality standards for most areas was May 31, 1975, there are many
areas that did not attain the standards. Although in some of these areas
the reasons for non-attainment is the lack of enforcement or the granting
of extensions -to compliance schedules that extend beyond the attainment
date, the reasons for many of the non-attainment problems are inadequate
plans. Where it was determined that a plan is substantially inadequate
to attain a standard, EPA in July 1976 called for a revision to the imple-
mentation plan and established a schedule for its submission. The State
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performing the revision has to analyze the area in question to determine
the magnitude of the inadequacy and then develop a plan to overcome this
inadequacy. In performing the analysis and developing the plan revision,
the State will have to project and allocate emissions and determine the effect
on air quality of control strategies that it wants to apply.
2.1.2. Maintenance of National Standards
As a result of a reassessment of plans required under the 1973 court
ruling in NRDC V. EPA, 475 F. 2d 968 (B.C. Cir), EPA determined that no
State plan contained sufficient measures to ensure long-term maintenance
of the standards. On June 18, 1973, EPA promulgated regulations for
States to identify those areas that have the potential to exceed any national
standard within the subsequent ten year period. These areas are called
air quality maintenance areas (AQMAs). For each AQMA, States must analyze
the air quality impact of growth and development.
Under regulations promulgated by EPA on May 3, 1976, States must
submit their AQMA analyses on schedules established by the appropriate
Regional Administrator. Following receipt of analyses, EPA will then
decide, and in many cases has decided, which AQMAs will need plan revisions
based on the analyses.
*
EPA published the list of AQMAs in three parts. EPA identified
168 areas for at least one pollutant. Of these 159 areas were identified
for particulate matter, 61 for sulfur dioxide, 49 for photochemical
oxidants, 24 for carbon monoxide, and five for nitrogen dioxide. This
results in a total of 298 AQMA-pollutant combinations. Most of the
AQMAs are composed of more than one county. There are more than 400 counties
(or county equivalents) and parts of counties included in the AQMAs out of
a total of 3,141 counties in the United States.
2.1.3. Regulatory Requirements
EPAs Office of Air Quality Planning and Standards (OAQPS) published
the Guidelines for Air Quality Maintenance Planning and Analysis to provide
guidance on techniques for long-term analysis of air quality maintenance
Federal Registers: April 29, 1975 (40 FR 18726); June 2, 1975 (40 ER 23746);
September 9, 1975 (40 FR 41942).
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1-13
plans. The May 3rd, 1976, Federal Register contained EPA regulations
concerning air quality maintenance that require states to use Volume 7,
Projecting County Emissions, and Volume 13, Allocating Projected Emissions
to Sub-County Areas, in developing SIP revisions in AQMAs and other areas
14
identified by the Regional Administrators. (EPA Regional Administrators
may allow states to use alternative techniques, however.) Volume 7 defines
a specific and uniform methodology to upgrade existing emission inventories
and to forecast future emissions of air pollutants within counties. Volume 13
describes a methodology for projecting and allocating emissions to subcounty
areas.
Also, EPA regulations (40 CFR 51.12) require states to collect
information on growth in emissions and to analyze all areas at least every
five years to determine which areas may need plan revisions. Where EPA
calls for plan revisions, the states will have to prepare the revisions
in accordance with part or all of 40 CFR 51. If EPA requires states to
perform the detailed emissions and air quality projections of Subpart D
(which pertain in all cases to AQMAs), states will have to use Volumes
7 and 13 of EPAs guidelines or approved alternative methods. If a state
does not submit an adequate revision when asked to do so by EPA, EPA must
prepare and promulgate a plan in accordance with its own regulations.
2.2. STUDY BACKGROUND
Through informal discussion with agencies and individuals conducting
the analyses required to conform to these regulations, it appeared that the
calculation procedures, although relatively straightforward, were long and
tedious and might be consuming an inordinate amount of resources to perform.
The possibility of providing a computerized version of the analysis techniques
was presented and EPA has decided to embark on a feasibility study to
determine if there is a need for such a system and if existing computerized
packages could be used to satisfy all or part of the analysis requirements.
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The determination of need for a Computerized Emission
and Allocation (CEPA) system is to be carried out in a 3-?hase
study. Phase 1, the results of which are represented in this documer.: .
is designed to determine if there is a need for a CEPA system as per .reived
by the agencies involved in the maintenance planning process; specifically,
the EPA Regional Offices, the state air pollution control agencies. .;r.d zhe
local and regional planning agencies. Upon a positive determinaticr. c-f need
in Phase 1, a review of several alternative existing systems would bo
conducted as part of Phase 2. The objective of this study would be to determine
if existing systems could meet the analysis requirements with some modifications.
Phase 3 would be initiated if it were determined by the Phase 2 effort that
an existing system would need major revision or that an entirely new system
would be needed. The goal of this phase would be to develop a system
specification document that could be used as part of a procurement package.
2.3. FUNDAMENTAL CONCEPTS
There are some fundamental concepts that need clarification Ln the
light of the feasibility study requirements. First, the CEPA system, as
currently perceived, is not intended as a comprehensive data base on growth
and development. Rather, it is intended to operate from such a comprehensive
data base and transform growth and development projections into emission
projections. Although data base management and manipulation will, of necessity,
be an important part of the system, an agency performing an analysis using
CEPA would still have to expend the necessary effort to collect the basic
information.
A second important point that needs to be emphasized is that the
CEPA system is not envisioned as a complete air quality analysis tool . It
will not, for example, include an air pollutant dispersion model although
it will be designed to interface with a variety of models. CEPA's principle
focus will be on emissions and on carrying out the calculations necessary to
project emissions and to allocate these to a better than countywide spatial
resolution.
Third, the CEPA system is not intended to be a developmer.-. '-£
methodologies for growth projections. It will not, for example, prv.:-i%
various regression techniques to determine future trends from hisrvri'.,^
patterns. CEPA is envisioned as picking up the analysis once thes^ projections
are made and transforming them into emissions.
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3. METHODOLOGY USED
The basic procedure used in this Phase 1 of the feasibility
study was to first review several pertinant documents that outlined specific
requirements for a CEPA system and then to conduct a series of interviews
with EPA Regional Offices, state air pollution control agencies, and regional
planning agencies participating in the AQMA analysis.
3.1. DOCUMENTS REVIEWED
The primary documents serving as guidance on CEPA system needs
1-13
were the published guidelines on AQMA analysis , and the regulations
14
outlining specific requirements that must be followed , and the timing
of analysis submissions
Another set of documents that deal with general governmental
requirements on automatic data processing (ADP) systems were also reviewed.
]_7
These included EPA1s automatic data processing manual , Office of Management
and Budget Circular A-109 that outlines procedures for major systems
18
acquisition , General Services Administration Federal Management Circular
19
74-2 that deals with the tracking of ADP in the government , Bureau of
the Budget Circular A-76 that prescribes policies on the acquisition
20
of commercial or industrial products for government use , and the Code
21
of Federal Regulations section that deals with government-wide ADP services
The objective in reviewing these documents was to insure that the current
feasibility study complied with all the necessary requirements of general
government and EPA policy on ADP system evaluation.
3.2. AGENCY INTERVIEWS
Three specific types of agencies involved in air quality analyses
were interviewed to determine their perception of CEPA system need.
These were EPA Regional Offices, state air pollution control agencies,
and regional planning agencies.
3.2.1. EPA Regional Offices
All ten EPA Regional Offices were contacted regarding the CEPA
system feasibility study. In each region a telephone discussion was held
with the EPA Regional Office representative responsible for issues concerning
maintenance of air quality standards. Each representative was asked to
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-8-
give his opinion on specific issues pertaining to CEPA feasibility and
development. General opinions were solicited and then each representative
was asked to suggest states to visit who would provide a state agency's
perspective regarding CEPA feasibility. Three of the Regional Office
desiring additional discussion about cEPA were visited. Regional meetings
were attended by technical AQMP staff and computer systems staff. Regional
opinions were again discussed within a larger group. State agency questionnaires
were also reviewed and regional comments were incorporated in a revised
state questionnaire-
3.2.2. State Air Pollution Control Agencies
Air pollution control agencies selected for the CEPA review were
chosen according to the following criteria:
1) Regional office recommendations
2) Geographic distribution
3) Agency size
4) EPA staff recommendations.
Regional office recommendations were solicited from each of the
ten regional air quality maintenance representatives. Specifically, regional
representatives were asked to suggest agencies which could best provide a
sample of the tasks and problems being encountered in AQMA plan development.
EPA staff was solicited for additional candidates who could
provide insight regarding AQMP analysis. A list of fifteen potential agencies
was reviewed and reduced to nine site visits. Major considerations in the
final agency selection insured that 1) the survey would adequately cover
the nation geographically, 2) the survey would include large well funded
agencies as well as small agencies with limited funding, and 3) the survey
would include agencies with diverse pollutant problems and AQMA designations.
Final agency selections were approved by EPA staff and regional
air quality maintenance representatives. Constrained by OMB regulations,
Argonne could perform only nine interviews. In an attempt to include several
regional planning organizations, the list of state air pollution control
agencies visited was reduced to seven.
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Characteristics of Selected Air Pollution Control Agencies
Tables 3-1 to 3-3 illustrate the characteristics of surveyed
agencies. Personnel staffing illustrates the diversity of funded state
air pollution control agencies. Agencies with as few as two and as many
as 72 were interviewed. Interestingly, the agency funded for only 18
positions has more pollutant-AQMA designations than the agency funded for
324 positions. Positions most directly involved in AQMP analysis are
engineers, meterologists and data processing specialists. The diversity
of funding is even greater when these groups are totaled with only 3 positions
funded in the least comprehensive agency and 88 positions funded in the most
comprehensive agency.
In terms of agency budgeting, EPA's grant for the most comprehensive
agency totaled 1.7 million dollars. The total agency budget including federal
and non-federal funding exceeded 7.5 million dollars. Five and one-half
million dollars went to personnel and fringe benefits.
The following is a brief description of each agency.
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Table 3-1. State Agency Location Characteristics
1
South-
Location East
Population of
State (thou-
sands) 4,590
Land Area
(Thousands of
square miles) 58.9
EPA Region IV
Agency Demographic/Geographic Characteristics
2345
East North- Mid- North-
East West West
3,922 5,689 3,805 694
10.6 8.2 84.1 147.1
III I V VIII
6 7
South- West
West
11, 197 1, 059
267.3 84.9
VI VIII
o
Source: 1970 Census figures.
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Table 3-2. State Agency AQMAs.
Number of Designated Air
Pollutant
Particulates
S00
2
CO
Oxidents
TOTAL
1 2
4 3
1
2
4 6
3
4
1
2
7
Quality Maintenance Areas in State
4 5
2 5
1 4
2
3 11
6
5
1
6
12
7
7
6
13
Source: Guidelines for Air Quality Maintenance Planning, Volume 14: Designated Air Quality Maintenance Areas.
Report No. EPA-450/4-75-002. December 1975.
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Table 3-3. State Agency Staffing
Agency Staffing
Position
Management
Engineers
Meterologists
Data Processing
Specialists
Other Technial
Staff
Inspectors
Office and Other
Non-Technical Staff
TOTAL
1
1
19
1
3
7
35
7
73
2
2
31
1
4
18
14
15
85
3
4
37
1
5
12
33
10
102
4
2
12
-
2
12
-
4
32
5
1
3.
3
1
9
-
2
19
6
7
72
3
13
65
89
75
324
7
2
2
1
—
7
2
4
18
Source: 1976-77 Directory of Government Air Pollution Agencies. Published by the Air Pollution
Control Association.
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Agency #1
Located in the south eastern United States, this agency addresses
environmental problems typical of agricultural sunbelt states. Particulate
and area emissions is the prime concern although one urban area in the state
has a CO-oxidant problem. The agency is sufficiently staffed to handle
technical issues requiring advanced analytical techniques.
Agency #2
Located in the eastern United States, this agency encounters
environmental emissions similar to those in mid-atlantic states. Air
quality attainment and maintenance depends heavily on control of areawide
urban emissions and control of selected large point sources throughout
the state. Agency #2 is adequately funded, has a reputation as a well-
managed agency and appears to display depth in experience and technical
ability. Regional planning agencies are well developed in urban areas;
as a result,local planning agencies are developing AQMP's for the two
urbanized AQMA's. The state agency is coordinating local plans and con-
ducting the analysis in rural areas designated for particulates. Con-
tractors and consultants have been employed for specific AQMA related
projects such as conducting an AQMA run of a metropolitan area.
Agency #3
Located in the northeast, agency #3 must control urban emissions
as well as widespread industrial point sources. Rural sections of the
state do not appear to present difficult environmental control problems,
so that most of the agencies resources are focused on the industrialized
sections of the state. While the agency appears adequately staffed,
outside contractors have been used extensively in all aspects of AQMP
analysis. Growth projections for both area and point sources as well
as emissions allocations were conducted via contractor. Plan development
is on schedule with no significant problems.
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Agency #4
Agency #4 is located in the upper mid-west. Pollutant problems
are primarily fugitive dust and point source SO . While the agency is
small, the staff appears to be well trained and experienced to conduct any
technical analysis required by AQMP. Contractors and consultants have
been used for specific projects but most of the AQMP work will be completed
in-house.
Agency #5
Located in the northwestern coal belt, most environmental problems
are with large primary resource oriented industries. Coal, copper and
fertilizer plants create 6 AQMA's with a total of 11 pollutant-AQMA plans.
Particulate and S09 emissions from large point sources are the chief
contributors to poor air quality. Large fugitive emissions also make
air quality maintenance difficult. Because of its rapid development and
large size, this state has difficulty obtaining adequate air quality data.
Projecting future emissions is especially difficult because of rapid energy
development. OBERS projections used by a contractor for AQMP have been supple-
mented with local university growth projection and national estimates. Growth
and projected future emissions appears to be the weakest aspect of the analysis.
Despite a large number of AQMA's and low staffing this agency is taking
an agressive approach to developing a technical capability.
Agency #6
Agency #6 is located in the southwestern United States. The
agency is among the largest in the country with a budget exceeding 7.5
million dollars. The primary issue in this agency is the measurement
and control of fugitive dust. Fugitive dust from dirt roads and vacant
land is typical in the southwest and remains the single most important issue
to control agencies. Since attainment has been of most concern to the
state agency, maintenance planning work is still in the planning stage.
It has not been determined if the agency will employ contractual help.
With 4 computer operators, 4 systems analysts, 8 programmers, and 3
meterologists, the agency displays technical depth adequate to develop
the plans internally.
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Agency #7
Located in a sparsely populated western state, this agency is one
of the smallest in the country. Fugitive dust from unpaved roads, desert
and energy development areas is of prime concern. Despite a small staff,
agency #7 has sufficient technical capability to conduct AQMP analysis.
All seven particulate plans have been completed with work on six SO plans
proceeding. Like other western states^ 208 agencies are coordinating and
providing data to the air pollution control agency.
3.2.3. Contractors
In addition to the state air pollution control agencies, two
regional planning agencies serving as contractors in the AQMA analyses
were interviewed. This was designed to broaden the perspective to include
groups conducting AQMA analyses outside of the framework of state
government. These agencies can be characterized as follows.
Cont ractor A
Contractor A is a planning organization located in a large eastern
urban community. This agency has taken the prime role in AQMP analysis
for the city. The state air pollution control agency has provided data and
limited technical support to the agency.
Contractor B
Contractor B is a regional planning agency located in the east.
Contractor B differs from A in that its scope includes a large region
composed of several urban communities and additional rural areas. The
entire AQMP was developed by the regional planning agency. Within this
agency are many other planning functions including 208 planning. Many
of the calculations in the analysis were made by computerized routines
developed in-house.
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4. SYSTEM REQUIREMENTS
The structure of the air quality maintenance planning regulations
sets specific requirements on the type of information that must be included
in both the AQMA Analysis and the AQMA Plan. These requirements prescribe
the data that must be retreivable from a CEPA system and the type of calcu-
lation procedures that must be used in generating that data. In turn, these
requirements imply that certain input information must be processed by the
system. EPA's calls for SIP revision also defines time schedules on which the
Analyses Plans are due. This fixes one of the constraints that is imposed on
system availability. Finally, the OMB, GSA, and EPA circulars dealing with
procurement of computer hardware and software prescribe the general adminis-
trative requirements that must be next. Each of these requirements will
be discussed in turn.
4.1. OUTPUT REQUIREMENTS
The AQMA analysis regulations require the use of the techniques
described in Volume 7 of the guideline series to project emissions on
a county level. The format in which this information is to be summarized
is given on Fig. 4-1 (Table 7-1 from Ref. 7). The data are to be presented
for at least the baseline year, one intermediate year, and the tenth year
of the planning horizon. The information covers six basic emission source
categories: fuel combustion - external and internal, industrial process,
solid waste disposal, transportation, and miscellaneous. There are 125
subcategories that must be considered (although some analysis areas will
not have any sources in these categories) for the designated pollutants.
The regulations also require the use of the techniques in Volume 13
13
of the guideline series to allocate the emissions to subcounty areas. The
format of the data summary is shown on Fig. 4-2 (Table 4-2 from Ref. 13).
Emissions of only the pollutants for which the area has been designated
are required. The number of master grid squares depends on the gridding
procedure. The test case in Ref. 13 used 123, one state used 4000 grids
to cover the entire state, and another state used 394 grids to cover 3
counties.
-------
COUNTY.
YEAH
SOURCE
FUEL
COMBUSTION.
EXTERNAL
RESIDENTIAL
FUEL
(AREA)
ELECTRIC
GENERATION
(POINT)
INDUSTRIAL
FUEL
ANTHRACITE COAL
BITUMINOUS COAL
DISTILLATE OIL
RESIDUAL OIL
NATURAL GAS
WOOD
TOTAL
ANTHRACITE COAL
BITUMINOUS COAL
LIGNITE
RESIDUAL OIL
DISTILLATE OIL
NATURAL GAS
PROCESS GAS
COKE
SOLID WASTE/COAL
TOTAL
ANTHRACITE COAL
BITUMINOUS COAL
LIGNITE
RESIDUAL OIL
DISTILLATE OIL
NATURAL GAS
PROCESS GAS
COKL
WOOD
LIOUIl) I'LIHOL GAS
UAGASSt
OTHER
TOTAI
AREA
POINT
AREA
POINT
r-OINT
AREA
POINT
AREA
POINT
AREA
POINT
AREA
POINT
POINI
AREA
POIN]
POINT
POINT
POINT
AHLA
POINT
EMISSIONS, TONS PER YEAR
PART
SOX
NOX
HC
CO
H-
OQ
I
I— '
(D
H-
Cfi
CO
H-
O
CO
O
t-i
3
-------
(TO
-IN
O
O
0
ft
oT
SOURCE
FUEL
COMBUSTION:
EXTERNAL
(CONTINUED)
FUEL
COMBUSTION:
INTERNAL
COMMERCIAL-
INSTITUTIONAL
FUEL
OTHER
ANTHRACITE COAL
BITUMINOUS COAL
LIGNITE
RESIDUAL OIL
DISTILLATE OIL
NATURAL GAS
WOOD
LIQUID PETROL GAS
OTHER
TOTAL
TOTAL EXTERNAL COMBUSTION
ELECTRIC
GENERATION
INDUSTRIAL
FUEL
COMMERCIAL-
INSTITUTIONAL FUE
AREA
POINT
AREA
POINT
POINT
AREA
POINT
AREA
POINT
AREA
POINT
AREA
POINT
POINT
POINT
AREA
POINT
POINT
AREA
POINT
DISTILLATE OIL
NATURAL GAS
DIESEL
OTHER
TOTAL
DISTILLATE OIL
NATURAL GAS
GASOLINE
DIESEL
OTHER
TOTAL
DIESEL
L TOTAL
ENGINE TESTING AIRCRAFT
TOTAL INTERNAL COMBUSTION
TOTAL FUEL COMBUSTION
AREA
POINT
PART
SOX
NOX
HC
CO
00
I
-------
H-
OP
o
o
rt
(^
SOURCE
INDUSTRIAL
PROCESS
(POINT)
SOLID
WASTE
DISPOSAL
CHEMICAL MANUFACTURING
FOOD/AGRICULTURE
PRIMARY METAL
SECONDARY METALS
MINERAL PRODUCTS
PETROLEUM INDUSTRY
WOOD PRODUCTS
PROCESS EVAPORATION
METAL FABRICATION
LEATHER PRODUCTS
TEXTILE MANUFACTURING
INPROCESS FUEL
OTHER/NOT CLASSIFIED
TOTAL
GOVERNMENT
(POINT)
RESIDENTIAL
(AREA)
COMMERCIAL-
INSTITUTIONAL
INDUSTRIAL
MUNIC. INCIN.
OPEN BURNING
OTHER
TOTAL
ON-SITE INCIN.
OPEN BURNING
TOTAL
ON-SITE INCIN-
ERATION
OPEN BURNING
APARTMENT
OTHER
TOTAL
ON-SI1E INCIN
ERATION
OPEN BURNING
AUTO BODY INCIN.
OTHER
TOTAL
TOTAL SOLID WASTE
DISPOSAL
AREA
POINT
AREA
POINT
POINT
AREA
POINT
AREA
POINT
AREA
POINT
AREA
POINT
POINT
POINT
AREA
POINT
AREA
POINT
PART
SOX
NOX
HC
CO
-------
TO
-P^
n
o
rr
CL
SOURCE
TRANSPORTATION
(AREA)
LAND
VEHICLES
AIRCRAFT
VESSELS
GASOLINE
DIESEL
LIGHT DUTY
HEAVY DUTY
OFF HIGHWAY
TOTAL
HEAVY DUTY
OFF HIGHWAY
RAIL
TOTAL
MILITARY
CIVIL
COMMERCIAL
TOTAL
BITUMINOUS COAL
DIESEL FUEL
RESIDUAL OIL
GASOLINE
TOTAL
GAS HANDLING EVAPORATION LOSS
TOTAL TRANSPORTATION
PART
SOX
NOX
HC
CO
I
N)
O
-------
H-
OQ
n
o
3
rr
d.
SOURCE
MISCELLANEOUS
(AREA)
GRAND TOTAL
SOLVENT
EVAPORATION
FIRES
DUST CAUSED
BY HUMAN AGI-
TATION OF THE AIR
AIRBORNE DUST
CAUSED BY
NATURAL WINDS
INDUSTRIAL SOURCES (AREA)
DRY CLEANING
STRUCTURAL
FROST CONTROL
SLASH BURNING
WILD FOREST
AGRICULTURAL
UNPAVED ROADS
UNPAVED AIRSTRIPS
PAVED ROADS
MINERAL PROCESSING
TILLING ACTIVITIES
LOADING CRUSHED ROCK, SAND, GRAVEL
CONSTRUCTION
STORAGE PILES
TILLED LAND
UNTILLEDLAND
AREA
POINT
PART
SOX
NOX
HC
CO
N)
H
-------
-22-
A. County
B. Year
(1)
Master Grid
Designation
Emissions
(tons/yr)
(2)
Part.
(3)
SO
(4)
CO
(5)
HC
(6)
.NO
Fig. 4.2. Sample Emission Allocation Summary
-------
-23-
7 13
The techniques for projection and allocation ' are not in
themselves exceptionally difficult. Projection techniques rely on either
direct information about planned growth in emission sources (e.g., capacity
addition plans of a power plant) or an indirect information about surrogate
variables (e.g., employment projections). In the first instance, an
emission factor is applied to the new capacity addition and this represents
the forcasted emissions. In the second case, a growth factor is generated
by taking the ratio of projected employment to baseline employment,
applying this to the source activity level, and again applying an emission
factor. The procedure is complicated somewhat by the consideration of
things like plant retirements, increased utilization of maximum plant
capacity (in which case the growth is subject to SIP regulations and not
New Source Performance Standards), and growth that cannot be identified
with specific source categories.
Likewise, the allocation procedure is not a conceptually difficult
task since the technique is to develop an allocation parameter based on
area, population, or other variable and to apportion the countywide
emissions to the subcounty area on the basis of this parameter.
What is a more significant consideration than the complexity of
the calculation is the volume of the calculations. The number of source
categories (125), the number of pollutants (1-5), the number of projection
years (at least 3), and the number of grid cells multiplicatively combine
to generate a large number of pieces of information that must be handled.
On top of this must be added the evaluation of alternative control strategies
in which the process of projection and allocation must be repeated for at
least part of the source inventory.
There is a trade-off that can be made to satisfy the requirements
of the regulations and, at the same time, remain within budegtary and time
constraints. The regulations allow for varying levels of sophistication
to be used in the analyses to reduce the demands placed on state and local
agency resources. In practice this means that the complexity of the cal-
culations can be reduced by using aggregated data sources, ignoring the
details of certain calculations, and relying on the most readily available
sources of information. The volume of the calculations can also be reduced
through using larger grid squares and fewer allocation variables.
-------
-24-
The use of a computerized emission projection and allocation
scheme must be viewed in the light of the regulatory framework. The
output requirements can be met, in many ways, through the use of simplified
calculation procedures and with minimal spatial resolution and requiring
only small, if any, computer capability. The availability of a CEPA system
can be viewed, in this instance, as a means of upgrading the'*' .jphistication,
and presumably the accuracy, of the analysis. An alternative perspective
is to view the CEPA system as a tool to permit the analysis of those
complex situations where manual computations are totally inadequate (e.g.,
large metropolitan.areas with a great deal of data). A third perspective
is to consider the reduction in resource requirements that a CEPA system
might result in if, for example, a significant amount of agency staff time
could be spared from the performance of the calculations.
These three considerations are among the fundamental questions
that were addressed in determining CEPA system need through the agency
interviews. Summarily stated they are:
1. Will the CEPA system result in an increase in the
sophistication of the analyses submitted under the
regulatory requirements?
2. Will the CEPA system permit the analysis of complex
problems that could not be otherwise handled in
accordance with regulatory requirements?
3. Will the CEPA system reduce the resource requirements
of state and local agencies?
4.2. INPUT REQUIREMENTS
The generation of the data in Figs. 4-1 and 4-2 requires the
processing of a considerable amount of input information. This information
can be grouped into two basic sets: emission inventory and planning data
as shown on Table 4-1.
4.2.1. Point Source File
The point source information is generally obtained by means of a
survey questionnaire to all major sources. This represents a considerable
amount of effort to review the forms and evaluate the data. Some of the
-------
-25-
Table 4—1. Input Data Required for Air Quality Maintenance Planning
Data Set Information Contained
Emission Inventory Point Source File
Source identification and location
Stack data - height, diameter, exhaust temper-
ature, exhaust flow rate
Control equipment - type, efficiency
Operating parameters - throughput, fuel para-
meters
Emission rate - estimated, stack tests, allow-
able
Compliance schedule
Area Source File
Fuel Consumption
Solid waste generation
Vehicle miles travelled
Aircraft LTO cycles
Solvent use
Gasoline marketed
Fugitive dust generation
Planning Data Population
Employment
Land Use
Earnings
Energy Consumption
Transportation System Plans
-------
-26-
seven states interviewed conduct a survey of all sources every one or two years
while for others, the AQMA effort represents the first major update of the point
source inventory since the original SIP development. All states have available
to them the National Emissions Data System (NEDS) computer codes, which
can be used to process this large volume of information. These codes
are available for use on the EPA's computer facility in North Carolina.
In addition, many states have developed their own computerized emission
inventory routines that either follow the NEDS format or use individualized
formats. These routines have been developed to give the states more control
in analyzing the data and to overcome the time lags in processing data
through EPA's North Carolina facility. Some states have developed routines
to translate their own emission inventory format into NEDS format for
submission to EPA.
In terms of CEPA system requirements, it is immediately apparent
that an interface with point source emission inventory data files and
programs is a critical issue. From the standpoint of universal acceptance,
compatability with the NEDS system is mandatory. At the same time, the
possibility for interfacing with other emission inventory formats must
also be left open.
4.2.2. Area Source File
The area source emission inventory presents a much more complex
picture because of the diversity of sources and the wide range of information
needed to estimate emissions. Although the volume of information is not
nearly as great as for the point sources, the complexity of the source
characterizations generates an almost equivalent problem in terms of
resource requirements to make credible emission estimates. In most of the
interviewed states the point source emission inventory can be and is being
done at the highest level of detail (i.e., Level 3 in Ref. 7) while the area
source inventory requires lower levels of detail because of data collection
and verification problems.
The NEDS system has the capability to handle area source emissions
on a countywide basis. There are also a number of peripheral routines that
enable the data to be summarized in a variety of ways. However, the NEDS
area source system does not provide an adequate method for handling the
-------
-27-
information needed to make the calculations required in Refs. 7 and 13.
The principle difficulty is the lack of spatial resolution finer than
the county level. Only the simplest of allocation methods would have to
be used to obtain a more spatially detailed inventory. Another problem
is the lack of resolution in the source categories themselves. Sources
are grouped into rather broad categories that do not lend themselves
well to the needs of AQMA planning. For example, a control strategy
aimed at converting residential apartment buildings from burning residual
oil to burning distillate oil could not be tested using only NEDS area
source data, since all residential fuel oil use is aggregated. In essence,
the NEDS area source routines serve as a useful summary of emission informa-
tion but do not provide the necessary detail.
In terms of a CEPA system requirement, the incentive to interface
with NEDS area source data is not as strong as with the point source
data. The CEPA system must be able to process the more detailed and exten-
sive data that is needed to make area source emission estimates and growth
projections. It might be noted parenthetically here that one state agency
visited suggested that the CEPA system be used to maintain a file of data
Ce.g., fuel use, population, dwelling units, etc.) that the states could
access to update their own inventories. This concept more closely describes
a modification of NEDS that might be considered.
4.2.3. Planning Data
The Air Quality Maintenance Planning effort represents the first
time that air quality management has been integrated with local and regional
planning efforts. The original SIPs were not required to delve into the
details of projected growth and development; there is, therefore, no
systematic set of planning data that is available for AQMA analyses.
There is also no systematic set of computer routines that can be applied
to handle this information in a fashion analagous to the NEDS routines.
The development of a good AQMA analysis requires the use of
planning data from a variety of agencies and planning programs, such as
3-C transportation planning, 208 wastewater planning, HUD 701 planning,
and others. Some of the information is available in standard format in many
-------
-28-
areas (e.g., census data on population, housing, employment). In most
cases, however, the planning data are handled in a fashion that is unique
to the local area. For example, one planning agency will project growth
on the basis of employment, another will use earnings by industrial category,
and yet another will use land use. In some instances the data are available
in a computer-readable format, while in others only hard copy data are
available.
Despite the rather amorphous nature of the planning information,
the agencies doing AQMA'analyses are required to incorporate, wherever
possible, the inputs of local planning efforts. The regulations specifically
call for coordination among various planning agencies and for the use
of common data bases as one means of achieving this coordination. Two
CEPA system requirements result from these considerations that are not
necessarily compatible. On one hand, the CEPA system can be viewed as
a mechanism to enhance the integration of planning data into the air
quality management process. As one state representative observed, the
availability of computerized emission projection and allocation procedures
opens the door to whole new sets of planning data that could not be
handled manually. On the other hand, the diverse nature of the planning
data formats presents serious problems in designing a system that is
powerful enough to manipulate the data effectively but is general enough
to adapt to different data sets. This is a non-trivial problem that would
have to be solved in system design.
4.3. CEPA SYSTEM TIMING REQUIREMENTS
Data pertaining to the timing of CEPA system development came
from a variety of independent sources. Federal Registers were reviewed
first, Regional Offices were surveyed, state air pollution control agencies
were interviewed, and two regional planning organizations were surveyed.
All of the sources provided the same general conclusion. CEPA development
should have been completed in early 1975 to be widely used. If it could
have been developed by the end of 1976, a CEPA system would have been of
limited use during the initial state AQMA analysis. Potential use does
increase slightly, however, if the CEPA system is considered as a means
-------
-29-
to recheck already completed plans. Perhaps the greatest potential for
CEPA application, considering submission schedules, is the use of CEPA
subroutines to aid in non-attainment plan revision. Over 120 AQCR portions
could use a CEPA subroutine for land use analysis if it were made available
by early 1978.
4.3.1. Federal Register Due Dates For Submittal of Air Quality Analysis
and Plans
The Federal Register provides the most detailed look at AQMP
analysis and plan scheduling on a national basis. AQMP work for scheduling
purposes can be subdivided into 8 separate milestones. Due dates, some
of which coincide, include:
Due date for analysis in air quality maintenance areas,
set 1 pollutants.
Due date for analysis in air quality maintenance areas,
set 2 pollutants.
Due date for plan revisions in air quality maintenance
areas?set 1 pollutants.
Due date for plan revisions in air quality maintenance
areas,set 2 pollutants.
Due date for plan revisions in non-attainment areas,
set 1 pollutants.
Due date for plan revisions in non-attainment areas,
set 2 pollutants.
Due dates for plan revisions in non-attainment areas
requiring land use and/or transportation controls,
set 1 pollutants.
Due dates for plan revisions in non-attainment areas
requiring land use and/or transportation controls,
set 2 pollutants.
-------
-30-
Of the eight milestones published in the Federal Register, the
most important for CEPA development is the analysis due date in air quality
maintenance areas, set 1 and set 2 pollutants. State interviews indicate
that analysis and planning actually begins six to eight months prior to
submittal dates. An analysis submission date of first quarter 1977 demands
a program plan which begins in mid-1976. Use of a CEPA system would require
development and distribution of the programs prior to initiation of the
analysis. A possibility exists that the CEPA could be used to recheck the
analysis,giving the system limited utility at least until the plan revision
due date. After plans are submitted,the only use a CEPA might see for
AQMA analysis might be Regional Office checking of completed plans;
however, this is not a likelihood since none of the Regional Offices
indicated that their plan review would include analyses requiring a CEPA.
Table 4-2 presents a regional summary of maintenance analysis and plan
submittal dates for set 1 and set 2 pollutants. This data has been illustrated
by a cumulative distribution curve in Fig. 4-3. Assuming a six month
preparation period for AQMA analyses, Fig. 4-3 illustrates that 77% of the
states will be unable to use a CEPA for set 1 pollutants if it was made available
by January 1977. This number increases to 88% if the CEPA is not available
until mid-1977. This would represent about 9 AQMA's where CEPA had direct
use for AQMA analysis.
For set 2 pollutants only 48% of the AQMA's would have completed
plans if the CEPA system were ready by January 1977. By mid-1977, 62%
of the AQMA's would have used an alternative approach. Eight AQMA's could
use the CEPA system for set 2 pollutants if it were available by mid-1977.
Looking at the latest date which a CEPA system must be distributed for
state use, all of the agenices will have committed themselves during the
first quarter of 1978. If a CEPA system were available by mid-1977, 17
AQMA's could use a CEPA system for set 1 or set 2 pollutant analysis.
These figures support state interviews concerning the potential usefulness
of a CEPA system for use in the first round of AQMA analysis efforts.
Although development of a CEPA system by mid-1977 may be useful
to only a few states for the initial analysis, it could have slightly greater
use for rechecking plans. Table 4-2 and Figure 4-4 indicate that a CEPA
system available by the end of 1977 or early 1978 could be useful in checking
-------
Table 4-2. Due Dates for Submittal uC Air Quality Maintenance1 Analyses and Plans
EPA
Region/
Pollutant
Set3
Number of AQMAs
Analysis Due Date
Plan Due Date
1976
1977
1978
1976
1977
1978
3rd 4th 1st 2nd 3rd 4th 1st 2nd 3rd 4th
Qtr Qtr Qtr Qtr Qtr Qtr Qtr Qtr Qtr Qtr
Sub- 3rd 4th 1st 2nd 3rd 4th 1st 2nd 3rd 4th Not
mitted Qtr Qtr Qtr Qtr Qtr Qtr Qtr Qtr Qtr Qtr Established
II
III
IV
VI
VII
Total
Set 1
Set 2
Set 1
Set 2
Set 1
Set 2
Set
Set
Set
Set
Set 1
Set 2
Set 1
Set 2
VIII Set 1
Set 2
IX Set 1
Set 2
X Set 1
Set 2
Set 1
Set 2
5
0
16
12
10
5C
15
13b
5C
5
24.c
I
U>
9
1
14
2
6
i
32
16
70
36
12
8"
2
24
13
10
6
18
16
aSet 1 pollutants are TSP, SCL; Set 2 pollutants are CO, HC, NO , 0 .
Includes statewide revisions for oxidant control.
CIncludes 2 counties not designated AQMAs.
Includes 1 county not designated an AQMA.
elncludes 2 cities and the remainder of a state excluding AQMAs.
Includes 1 AQCR not designated an AQMA.
Source: Re£. 15
-------
-32-
CEPA
DEVELOPED
JAN,
1977
CEPA
DEVELOPED
MID-1977
100
oo
<£.
O
UJ
Q
CQ
-------
-33-
CEPA
DEVELOPED
JAN. 1, 1977
100
80
SET 1 POLLUTANTS
Q
UJ
3=
1/1
i—i
_)
CD
-------
-34-
24 set 1 plans and 13 set 2 plans before submittal. State interviews
indicated that available time between analysis and submittal would be spent
rechecking and revising the analysis. Several states indicated they would
consider using a CEPA system for this activity.
4.3.2. Potential Uses of CEPA in Non-Attainment Areas
While CEPA is primarily for use in Air Quality Maintenance
Analysis, portions of a properly designed CEPA could have application in
non-attainment areas. Table 4-3 presents a regional distribution of SIP
revision due dates for AQCRs and AQCR portions requiring and not requiring
land use controls. In the case of non-attainment areas, CEPA subroutines
could be useful in 96% of the set 1 AQCRTs and 95% of the set 2 AQCR's if
the computational tools were available by January 1977. Any routines
developed after that would have virtually no application in non-attainment
areas not requiring land use controls.
Any CEPA subroutines developed by January 1978 could be used by
all the AQCR portions requiring land use or transportation controls.
The application of CEPA subroutines in AQCR portions with land use controls
has the greatest potential use totaling 122 AQCR portions for set 1 and
set 2 pollutants.
4.4. DATA PROCESSING REQUIREMENTS
In addition to the technical output and input requirements and
the timing restrictions that are imposed on CEPA system utilization, there
are a number of administrative conditions that must be met in system
definition, design, performance, and acquisition.
4.4.1. EPA Data Processing Policy
Reference 17 is the principal source of guidance on EPA policy
regarding automatic data processing (ADP). The fundamental policies are to
a. Supply the Agency with sufficient yet the most advanced
ADP and systems technology feasible.
b. Assure management that the allocations of ADP resources
for each system will consider cost/benefit analysis.
c. Work towards the integration and coordination of informa-
tion systems across media, functional, and program lines.
-------
Table 4-3. Due Dates for Submittal of SIP Revisions in Non-Attainment Areas
EPA
Region/
Pollutant Sub-
Set mitted
I
II
III
IV
V
VI
VII
VIII
IX
X
Total
Sec 1
Set 2
Set 1
Set 2
Set 1
Set 2
Set 1
Set 2
Set 1
Set 2
Set 1
Set 2
Set 1
Set 2
Set 1
Set 2
Set 1
Set 2
Set 1
Set 1
Set 2
No Land Use or Transportation Plan Required
1976 1977 l')78
3rd 4th 1st 2nd 3rd 4th 1st 2nd 3rd 4th
Qtr Qtr Qtr Qtr Qtr Qtr Qtr Qtr Qtr Qtr
1 9
6C
11
12
11
llc
3
5
•5-
2 17 1
2 5
9
2
14
2
7 1
1 8
7
1
2 101 1 1
2 1 61
Land Use and/or Transportation Required
1976 1977 1978
3rd 4th 1st 2nd 3rd 4th 1st 2nd 3rd 4th
Qtr Qtr Qtr Qtr Qtr Qtr Qtr Qtr Qtr Qtr
11
12
11
11C
3
5
13
9C
17
5
9
0
14
2
78
44
Not
Established
1
1
Includes AQCRs and parts of AQCRs.
bSet 1 pollutants are TSP, S02. Set 2 pollutants are CO, HC, N0x> 0^
""Includes statewide revisions for oxidant control.
Source: Ref. 15.
I
W
Ul
-------
-36-
d. Make optimum us-^ of centrally provided ADP resources.
e. Assure compliance with. Federal directives which have a
bearing upon the management of ADP and systems resources.
f. Provide adequate security for proprietary/privileged
information maintained in automated systems.
In carrying out these policies a five-step process of acquiring
ADP systems is defined. These steps are:
1) Feasibility study
2) System design specification
3) System development and implementation
4) System operation and maintenance
5) Periodic review and audit.
Phases 1 and 2 of this contract work are aimed at satisfying the first
step requirements.. Phase 3, if conducted, will address the second step.
Several of the requirements of the feasibility study have special bearing
on the CEPA system. The feasibility study must determine that a proposed
ADP system has special features among which are:
1) "The performance of new work, or the rendering of better
and more timely service or products to both the Government
and the public, which is necessary but was not feasible to
accomplish within the limitations of the previous system.
(Example: scientific and engineering applications which involve
a depth of calculation or analysis not practical by any other
method.)"
2) "The integration of basic data, common to many functions,
into a single master information system. (Example: the
integration of data common to the payroll, personnel, and
accounting functions.)"
3) "The integration of data processing systems, as permitted
by security considerations, between agencies, or between
private industry and the Government. (Example: the provision
of air quality data on magnetic tape by State Governments
to EPA.) Government efforts to achieve appropriate
standardization of ADP equipment and techniques, including
substantial support of the American Standards Association
program in this field, give promise of alleviating some
of the incompatibility problems which have impeded the ex-
ploitation of the potential benefits of data interchange in
machine-sensible form."
-------
-37-
The first item essentially refers to the same considerations as the comments
on the output requirements of the CEPA system in Section 4.1. Thus, a
satisfactory answer to the questions of whether CEPA will increase the
sophistication of the analyses and/or will enable otherwise untreatable
problems to be addressed becomes not only an interesting consideration,
but a requirement to meet EPA policy objectives. The second item closely
described the discussion in Section 4.2.3. on the integration of planning
data into the air quality analysis. The question of whether a CEPA system
would encourage this type of integration again becomes one of meeting EPA
policy objectives.
Another requirement of EPA directives on ADP system acquisition
is the demonstration that the potential users of the system are prepared
to commit the resources to maintain and operate the system and are willing
to make the adjustments necessary to insure its success. For the CEPA
system this implies a demonstration that state and local air quality
planning agencies will use CEPA and are willing to change their existing
practices to accomodate it in air quality maintenance planning and/or other
analysis procedures.
The remaining directives contained In Ref.17 apply to system
design specification, system procurement, and standardization requirements.
These will be addressed in Phase 2 and 3 of this study, if the decision
to proceed is made.
In addition to the requirements of Ref. 17, several other system
requirements have been reviewed. EPA has directed that, in accordance
with GSA restrictions: 1) all new software packages must be programmed in
3. high level Federal Standard Language using only standard features, and
-) general purpose software packages (e.g., data base management) should
be procured from independent firms with highest priority given to those
7-ickages that have demonstrated ease of adaptability to a variety of equip-
ment configurations. It has been further recognized that EPA does not
r..ive a coordinated policy on the use of EPA data systems by outside agencies.
Tvc approaches have been employed: the limiting of access to computer
facilities to EPA offices, and the opening of access to most state government
^ancles with the costs being covered by either the FPA ADP budget or by
c,i.:ec::i^g some agency grant money into the £DP fund for this purpose.
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Since CEPA is the type of system that would be expected to find widespread
use by a number of agencies, its design must keep these two possible
procedures in view. This may mean system design to minimize the potential
demands on EPA computer facilities by outside users (e.g., design of a
package that could be sent to an agency for its own installation).
4.4.2. Other Agency Data Processing Policy
The Office of Management and Budget (OMB) and General Services
Administration also impose requirements on ADP systems.
18
OMB Circular A-109 outlines requirements for the acquisition
of major systems designed to fulfill responsibility, or "mission need",
of an agency. One of the principle policy objectives is to insure that
a major system (in this case, CEPA) does in fact fulfill a clearly articulated
mission need. The required output of an air quality maintenance analysis
has already been described in Section 4.1; the need for a CEPA system to
fulfill this requirement is determined by the Regional Office and agency
interviews to be presented in Section 5. Thus the structure of the
feasibility study complies with this requirement. The circular also requires
that the appropriate scheduling of system acquisition be evaluated. This
has been discussed in Section 4.3.
Most of the rest of the circular's requirements are not relevant
to the current feasibility study or are more closely identified with what
will be done in Phase 2 and 3 if they are implemented. Among these latter
requirements, the most significant is the stipulation that mission needs
must be identified independently of any existing system or technological
solution and that ample opportunity be given to weighing the value of several
alternatives. The Phase 2 work plan addresses this by first identifying
the specific requirements of the emission projection and allocation scheme
and then comparing several alternatives to meeting those requirements. In
this sense, the Phase 2 effort complies with the circular's directives.
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20
Bureau of the Budget Circular A-76 prescribes policies on the
acquisition of commercial or industrial products and services for government
use. The objective of the circular is to provide policy guidance on whether
the Federal government should seek private industry to provide products
and services or should provide these itself. The application to a CEPA
system is indirect in that the CEPA system is not intended for Federal
government use but rather for state and local agency use. The question
is reduced to a decision if the Federal government should develop and supply
a CEPA system to the states or if reliance should be placed on the states
and/or their contractors to develop their own. Several criteria are given
in the circular for determining that government activity is warranted.
The three that are relevant to a CEPA system include: 1) a satisfactory
commercial source is not available and cannot be developed in time to
provide a product or service when it is needed, 2) the product or service
is available from another Federal agency, and 3) procurement of the product
or service from a commercial source will result in higher cost to the
government. An evaluation of whether the first criteria is met is included
in the discussion of the current state responses to the AQMA regulations.
The quality of the analysis efforts without a CEPA system will be highlighted.
The time schedule considerations have already been discussed. The second
criteria will be addressed in Phase 2 when existing systems are evaluated.
The third criteria will be discussed primarily in Phase 2 when a cost assessment
of a CEPA system is made. A related discussion regarding the current method
of conducting the analysis and its cost implications is presented later.
General Services Administration Federal Management Circular (FMC)
74-2 discusses a policy for the development of a management information
system to track ADP use in government. The circular relates to CEPA system
evaluation only to the extent that a CEPA system might increase EPA computer
utilization and this would have to be reported as part of a regular financial
statement of ADP use. The primary emphasis of the circular is on hardware
inventorying.
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4.4.3. Code of Federal Regulations Requirements
Title 41, Part 101-32 of the Code of Federal Regulations deals
with Government-wide Automated Data Management Services. Subpart 32.203
outlines the criteria for a government agency acquiring ADP capability.
The regulation requires that it must first be demonstrated that existing
Federal ADP resources are not adequate to satisfy the need; then procurement
procedures are outlined. For the GEPA system this demonstration will be
handled primarily in Phajse 2 when several existing systems are evaluated.
Subpart 32.4 requires the specification of system performance independent
of existing equipment. That this will be treated in Phase 2 has already
been discussed. The section does, however, distinguish "desirable features"
from "mandatory requirements" and requires that these be identified separately
in any procurement document.
Subpart 32.13 specifies the use of Federal Information Processing
Standards Publications tFIPS PUBS) as the standard reference for ADP
hardware and software. These documents outline specific guidance on items
such as character code used, magnetic and paper tape standards, flowchart
standards, program documentation requirements, and others. All of these
requirements can be built into a CEPA system specification. Standard
terminology for use in procurement documents is given. One of the requirements
that might have direct significance for a CEPA system is Subpart 32.1305-1,
which specifies the use of COBOL in all "business-oriented computer applications;
(i.e., those applications or programs that emphasize the manipulation of
characters, files, and input/output as contrasted with those concerned
primarily with computation of numeric values)..." Although the CEPA
system is not business-oriented in this sense, parts of it would require
significant data set manipulation and input/output processing that might
be difficult to handle with a scientific language such as FORTRAN. Although
this subpart may not necessarily mandate the use of COBOL in'this case,
it does create an incentive to use it for the sake of general familiarity
with the language on the part of Federal ADP users. This will be discussed
again in the light of state and local agency requirements.
Subpart 32.16 describes the Federal Software Exchange Program,
which is designed to serve as a cataloguing center of computer programs.
The regulations require that agencies planning to acquire software first
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screen the existing programs on file in the Federal Software Exchange
Catalog. This has not been incorporated into the current feasibility
study and may provide some useful insight into computer programs available
from other agencies that would be beneficial in CEPA system considerations.
4.5. SECURITY REQUIREMENTS
The Code of Federal Regulations C41 CFR Part 101-32.17) discusses
security requirements for ADP systems. Although the focus of these regulations
is on the protection of an individual's privacy, there are some implications
for a CEPA system. The primary security problems result from the handling
of industrial process information that could be confidential proprietary
information and from the handling of industrial expansion planning data that
might be confidential. Since this information involves point sources only,
the security practices built into existing emission inventory procedures
apply directly and should be adequate to safeguard proprietary data.
Although expansion planning data has not traditionally been included in an
emission inventory, the protection of confidential plans should be readily
handled by existing procedures. It is also quite conceivable that expansion
plans involving extreme security requirements will simply not be reported
by industry until such time as permit requests are made.
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5. POTENTIAL USER SURVEY
One of the principle objectives of this phase of the feasibility
study was to identify the potential users of the system and to determine if
a CEPA system would, in fact, be a useful tool for them. Because of
the different perspectives of the various user groups, the comments of each
will be discussed separately. The ten EPA Regional Offices, seven state
air pollution control agencies, and two regional planning agencies were
interviewed.
5.1. THE EPA REGIONAL OFFICE PERSPECTIVE
In recent years, the EPA Regional Offices have been assuming more
responsibility in the development of air quality management programs for the
states. The air quality maintenance planning program delegates a good deal
of authority to the Regional Administrators to determine the needs and re-
quirements of the maintenance plans within the framework of the basic
regulations. For this reason, the viewpoints of the Regional Offices play
a significant role in determining the need for a CEPA system to carry out
the analysis.
All ten EPA Regional Offices were contacted by phone to insure that
the opinions and viewpoints of all of the regions would be represented. In
addition, three Regional Offices were visited to obtain more detailed
information. Appendix A includes the telephone survey questionnaire used.
5.1.1. Current Effort Status
Table 5-1 presents a summary of the AQMA planning effort as compiled
from the phone survey. It is immediately evident that most of the states
involved in air quality maintenance planning have either completed or are
well under way with the initial analysis. Nine states have either not begun
or are substantially behind schedule according to the Regional Office evaluation.
This further reinforces the conclusions of Section 4.3. in that the development
of a CEPA system to assist in the AQMA analysis is substantially late.
Use of Contractors Another point is immediately apparent from
the table. The vast majority of the states are using contractual assistance,
either a regional planning agency or a private consultant, to handle the bulk
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Table 5-1. Regional Office Summary of AQMA
Planning Effort
Status
of b
Analysis
Analysis Completed
Analysis Underway
Analysis Not Yet
Started0 TOTAT
Number of
Agency
State
Agency
1
6
2
a
States Involved in AQMA Analysis
Performing Principle Efforta
Regional
Planning Agency
1
2
4
7
Private
Consultant
10
14
3
27
TOTAL
12
22
9
43
Q
Indicates agency doing the bulk of the work although some involvement
by others is included.
Refers to initial analysis of attainment and maintenance problems.
clncludes states that were identified as being for behind schedule.
of the analysis. Only 9 states are planning to or have already done the
majority of the work in-house. This is especially signficant in light of
the fact that there have been some dissatisfactions expressed on the part
of the Regional Office staffs and the state agency staffs with the quality
of the contractual work being done. Two Regional Offices expressed the
feeling that some contractor performance had been less than adequate and a
third indicated that there is a strong preference to have the states do most
of the work in-house rather than having contractors carry the majority of
the effort. One Regional Office said it had been forced to be more detailed
and specific on its contracts to insure adequate quality control. Two
Regional Offices indicated that the regional planning agencies generally did
a superior job to the private consultants.
At the same time, the only assistance that the Regional Offices
have been providing to the AQMA analysis effort has been in the form of
contracts to consultants to do some of the work. Five of the Regional Offices
indicated that this was the major form of help they had given the states,
four indicated that they had not provided very much assistance at all, and
one indicated that the states had taken a very active role in conducting
the analysis and little assistance or direction from the Regional Office was
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needed. In addition, five of the Regional Offices anticipate that they will
have to do some of the AQMA analysis because of possible inadequacies in
state submissions. Three of the Regional Offices indicated that they would
use contractors to do the analysis rather than doing it in-house. The other
two did not indicate how they would approach the problem. Only one Regional
Office indicated that it would like to develop its own analysis capability;
another indicated its ability to handle a part of the allocation procedures
with existing in-house procedures.
It is evident that the bulk of the AQMA. analysis has been carried
by contractors rather than state agencies. Clearly, the time schedules
and funding restrictions, both on the federal and state levels, have made
this the only possible way to proceed. Many Regional Offices and states
have expressed satisfaction with their contractors' efforts, but the incidence
of inadequate performance is high enough to warrant some review of the regulatory
procedures that make this mode of operation effectively mandatory rather than
elective. There have been instances of a state being virtually unaware of
the data and techniques used by a contractor; there are reports of a contractor
not adding anything substantive to what a state agency supplies, yet charging
for a full analysis; there have been instances of a contractor using an
analysis technique without consideration of the reality of the results. It
must be emphasized again that this is not intended to imply that the majority
of contract work is inadequate. In fact, the opposite is probably true.
Rather, it indicates that the situation needs to be studied to determine
how the incidence of inadequate performance can be reduced.
The availability of a CEPA system can be viewed as a means of en-
couraging the development, in state and local air pollution control agencies,
of in-house capability to do air quality analyses. The Regional Office
survey indicated that this would be true in a number of states, but not across-
the-board. Specifically, 29 states were identified as currently having the
in-house expertise to handle a CEPA system, while 15 were identified as being
unable to handle it; no evaluation was available on 11 states. Of the 15
currently unable to make use of the system, at least 5 would probably not be
interested in developing the capability. It is evident from this information
that the potential for the use of a CEPA system to decrease reliance on
contractors exists in at least half of the states. The question of whether,
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in fact, the availability of such a system would encourage this trend cannot
be answered by this information alone. Clearly some of the states, although
the capability exists, would still prefer to Use contractors. Only 6 of the
29 states were identified by the Regional Offices as being definite candidates
interested in expanding their own in-house capability; 1 other was a clear
candidate not to use CEPA because it had already developed its own system.
No evaluation was made on the remaining states. One Regional Office indicated
that other incentives to develop in-house capability would be stronger than
CEPA availability. The availability of emission inventory and air quality
data processing capability were cited as examples.
Problem Tasks The Regional Offices were asked to identify which
tasks in the AQMA analysis were creating the most difficulty for the states.
One of the most recurring problems was that of the quality of the emission
inventory data. Several Regional Offices reported that the emission inventories
were in very poor shape and a significant amount of effort was being spent
on improving them. Although the point source data represented a significant
problem by the nature of its volume, the area source information appears
to be creating a bigger difficulty. A large number of data sources must be
contacted and very often the information is contradictory or inconsistent.
Quality control of the data handling was another problem area. One Regional
Office reported problems with data management where individual pieces of
2 3
information were expressed in terms of powers of 10 (e.g., 10 , 10 , etc.).
This format led to many errors on the part of data processing staff.
A CEPA system will not be able to directly improve the quality of
the inventory data. It can be viewed as providing a standardized format
for data collection and allowing the user to more easily cross check
information but will not alleviate the need for substantial emission inventory
efforts. One Regional Office indicated the need to determine the level of
accuracy of the analysis. A CEPA system could help by providing the ability
to do a sensitivity analysis of the various parameters assumed.
Another problem that was mentioned in two Regional Offices is that
of gridding and mapping various areas on to a grid system. The states are
apparently using many different areal representations (e.g., census tracts,
regional planning districts, municipal jurisdictions, etc.) and are still
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having some difficulties with mapping this information onto a grid system
for modeling purposes. One Regional Office indicated that the Engineering
22 a
Science model seems to handle this. The use of the CAASE program to
assist in this task, however, has not met with uniform success. Three Regional
Offices reported the use of CAASE. One region indicated that the CAASE
program was difficult to use and the 5-step process made it cumbersome.
They also indicated that if a CEPA system was designed to be as complex as
CAASE that the states would probably avoid it and rely on contractors
instead. Two of the regions indicated that there were substantial problems
with the use of the allocation parameters in CAASE. One stated that they
had begun to require that any activity allocated to a grid cell by CAASE
must be accompanied by a prior knowledge that the activity does, in fact,
occur in that cell (i.e., reliance on the allocation parameter alone was in-
adequate) . The other stated that there were some significant problems with
using the subjective allocation parameter option in CAASE. One Regional
Office indicated that they did not advocate the use of CAASE in their region
(likewise, they did not advocate the LANTRAN routine in AQUIP) and that
they were "stuck with it" in one area. Another region indicated that they
had decided against the use of CAASE since they had been advised that it
was too difficult and expensive to operate. They also indicated problems
with accepting the allocation parameters mechanically. These considerations
lay some significant foundations for the consideration of a CEPA system.
A complex approach that is not easily implemented will be avoided by the
states.
Another problem area that was mentioned in four Regional Offices
was that of dispersion modeling. Particular difficulties were in short
term modeling, complex terrain, and fugitive dust. A CEPA system would
not help this situation except that it would allow the user to try a
variety of models without having to expend a great deal of effort on ad-
justing the input data to the variety of model formats.
Additional problem areas referenced included the need for socio-
economic evaluation techniques and the need for good meteorological data.
State-developed Systems The Regional Offices were asked if any
of ihe states had computerized portions of the analysis procedures. Four
ir.ciraced that this had not been done and that the emission projections and
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allocations were being done manually. Three indicated that some parts of
it had been computerized by contractors to suit specific needs and another
indicated that a highway department package was being used. Two others
stated that one state in their respective regions had developed relatively
extensive computer-based growth projection programs that pre-dated the
AQMA requirements and are using these in their analyses. In one case
it was reported that the availability of the large data handling capability
had been crucial to the incorporation of input from a wide variety of
decision making groups. The computer requirements in this instance were,
however, extremely large. Two states were reported as using metropolitan
planning organization and/or land use models to project growth.
5.1.2. Regional Office Analysis Evaluation
The Regional Offices were asked if the availability of a CEPA
system would make review of the AQMA analyses and plans easier. Seven
regions indicated that it would (with varying levels of usefulness), one
indicated it would not, and two had no opinion. One point that did surface
in this part of discussion is that there are virtually no formal arrangements
that have been finalized on how exactly the plan review process will take
place. Two regions indicated that they will treat the review on a case-
by-case basis; one region stated that they do not plan to go through the
analysis in detail; three regions reported that they are attempting to work
closely with the states to avoid inadequate analyses.
It has already been mentioned that five of the Regional Offices
anticipated having to do some or all of the analysis in certain areas.
This, combined with the fact that a plan review process has not yet been
determined, may indicate that a CEPA system could prove useful in the Regional
Offices as well as in the states. It has already been stated, however,
that only one Regional Office expressed a desire to develop its own
capability in this area.
The Regional Offices were also asked if they had imposed any special
requirements or permitted any relaxations of the analysis techniques outlined
in Refs. 7 and 13. Two regions had modified the dispersion modeling require-
ments somewhat, one had pressed for a higher level of detail, and another had
required a short term particulate and SO- analysis. None of these would have
a major impact on a CEPA system.
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5.1.3. CEPA System Timing
The Regional Offices were asked to comment on the timing of CEPA
system development. Four regions indicated that the system might find some
use even if it were available late in the analysis period (e.g., mid 1977)
but that it would be only in limited circumstances. For example, one state
had requested a delay in the analysis submission date and several other
states were evaluated by the Regional Office as being in an "idling" mode
pending the outcome of the elections. Two other Regional Offices suggested
that the system would be of value only if it were available immediately,
and two others indicated that it would only be of value in the 5-year
update analysis.
These comments, combined with the previous discussions in Sections
4.3. and 5.1.1. emphasize the critical flaw with CEPA system development.
It is too late to be of much help in this portion of the AQMA analysis
sequence. As the following discussions will show, the potential for
successfully developing and introducing the system for widespread use would
have been much higher if it had been prepared at the beginning of the planning
process.
Two significant suggestions were made by Regional Offices. One was
that parts of the system be introduced early to make them of some value to
the current efforts. This would be difficult to accomplish since this
feasibility study (Phases 2 and 3) are not scheduled for completion before
mid 1977. A decision to proceed with all or part of the CEPA system would
be needed before the completion of the work effort.
The second significant suggestion was that a strategy to implement
a CEPA system be developed prior to its actual introduction. Such a strategy
might be its introduction in a part of a state first, with further expansion
later. This would help ease the transition process and would keep the
states from deciding a priori that it was too big and complex to handle.
One potential problem area was noted. Several Regional Offices
indicated that the introduction of a CEPA system at this point in time
might give some states an excuse to seek delays in submission of AQMA analyses
and plans. A suggestion was made that if a CEPA system is built that it
not be made available until after the initial round of analyses had been
completed.
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5.1.4. System Design Features
Several Regional Offices offered some suggestions on the type of
system and the design features that would be most useable. Three Regional
Offices emphasized the need to relate the CEPA system to regional planning
data by providing the appropriate data handling interfaces. One suggested
the development of standardized format for the data; another suggested that
the development of pre-processing modules that could be modified by the user
to handle varying data formats would be the most useful. This pre-processing
could be handled by a data base management system (e.g., MARK IV or System
2000) with some editing and sort routines available to the user. In either
case, there were clear indications that the ability of a CEPA system to
process other sets of information is a critical design parameter.
The types of data sets that need to be considered in addition to
regional planning data include information from the Census Bureau, Department
of Housing and Urban Development, Department of Transportation, Urban Mass
Transit Admisistration, and others. One Regional Office suggested that this
interface would enable an air quality evaluation of other planning programs
to be made above and beyond the specific requirements of the AQMA effort.
Another indicated that the CEPA system could be used to force the issue of
the use of compatable data bases by the various planning groups. The
specific requirements of interagency cooperation in the AQMA analysis
regulations reemphasizes these points.
In terms of CEPA system structure, there was a division of opinion
on the part of the Regional Offices. Some suggested that a set of modular
packages be developed that would enable the user to select the piece(s)
of most interest and ignore the rest. This was further emphasized by the
need to retain system flexibility to adapt to varying situations. Another
suggested that, based on the experience of the cumbersome 5-step process
involved, in using CAASE, the use of several steps is prone to error and
that an integrated package would be most helpful. It was acknowledged,
however, that a large and complex system does offer the user the possibility
of not critically evaluating the data and appropriateness of the techniques
and ending up with a meaningless set of numbers that are given credance
si.nply because they were generated by a sophisticated computer program.
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A computerized set of standard emission factors was suggested as
a useful tool for users. These could be used as default values in the
absence of actual emission data. The availability of default values for
other parameters was also suggested as a beneficial feature. Suggestions
were also made that the system allow for varying levels of analysis, provide
varying outputs for different dispersion models, allow for cross-check
and trade-off evaluations, provide a strategy evaluation package, and permit
separation of the data by political jurisdiction.
Computer system hardware and software constraints on a CEPA system
were expressed by several Regional Offices. One region alone indicated that
the states had CDC, IBM, POP, and UNIVAC equipment thus indicating the need
for a program that was readily adaptable to a wide variety of hardware.
Many state air pollution control agencies were sharing their equipment
with other state agencies and had some problems getting run time priority.
This would seem to indicate that a large, time-consuming system might create
some turnaround problems for states using it. It was suggested that the
CEPA system be available on a large centralized computer facility (e.g.,
EPA's) for use by states with computer access problems but that it also
be available for installation on other systems. Disk and tape drive constraints
were mentioned as a possible problem. For programming languages, FORTRAN
was a universal recommendation for use with the calculational parts of the
system. For the data management aspects, COBOL was recommended most often
although some agencies might have only limited experience with it. (The
Federal requirement of COBOL use for business and management programs has
already been mentioned in Section 4.4.3.). Doubts were expressed as to the
usefulness of PL1 programs.
Some miscellaneous suggestions were also included such as the
segregation of Set I and Set II pollutants in the system and the combination
of point source allocations into CAASE.
5.1.5. General Comments on System Need
The Regional Offices were asked to provide general comments on the
need for a CEPA system and were then asked if they would encourage its use
in their region. One Regional Office indicated that there was potential for
system use in the region and that they would encourage its use. Three regions
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indicated that the primary utility would be in the five year update and that
the system would not be of much use in the current round of analyses . Two
of the three indicated that they would encourage its use but not across the
board. States that were behind schedule, had ill-defined problems, or that
had weak analyses would be prime candidates. States that had already developed
an analytical approach would not be asked to change direction. Likewise,
the system would not be encouraged in states where it would be likely to
create requests for delay and postponement of analysis submittal dates.
One Regional Office indicated they would recommend it for use if
some of the bugs in the Ref . 7 and 13 procedures were ironed out, another
said they would recommend it as a means of reducing the tedious work load,
and another said they would recommend it primarily as a tool for emission
inventory update.
One Regional Office indicated that they were neutral to the idea.
CEPA would be another general analytical tool and would probably be used if
it were available. One Regional Office felt it was unnecessary since most
of the tasks could be done manually but the system could be viewed as a
supplementary aid and might have some future utility.
The need for adequate training to assist the states in using the
system was also mentioned.
5.1.6.
To sum up the Begional Office perspective on the need for a CEPA
system, the comment of one representative appears especially appropriate:
"The package would be good, but I'm not sure exactly how it would be used.
There would be times when we could really use such a program." Only one
representative indicated that the CEPA system was not necessary. The general
feeling of the others was that it would have been beneficial 1-2 years ago
and that its utility at this point in time must be viewed from long-range
considerations. The 'principle advantages of the system would be the ability
to interface with other planning data, the encouragement of in-house analysis
capability, and the upgrading of the quality of the analysis. The principle
disadvantages would be the poor timing of system introduction, the tendency
co rely on computer-generated data, and the possible transformation of a
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relatively straight-forward manual task into an exceedingly complex
automated task. One of the principle considerations that appeared in many
places was the quality of the data used by a CEPA system. More difficulty
was encountered with the data than with the actual projection and allocation
techniques. A CEPA system that could ease some of the data collection
and evaluation burden and would promote the development of better emission
information would be a significant bonus.
5.2. THE STATE AGENCY PERSPECTIVE
Representatives of seven state air pollution control agencies were
interviewed to determine their perception of the need for a CEPA system.
Since the questions were more detailed than those used for the Regional
Office discussions, a separate questionnaire was developed; this is included
in Appendix A. Since the agencies interviewed represented a wide range of
capabilities, experience, and resources it can reasonably be expected that
the comments will give a relatively accurate picture of the need for a CEPA
system from the state agency viewpoint.
5.2.1. Current Effort Status
The seven states interviewed among them had 33 AQMAs designated.
All but 2 were designated for particulates, 14 were designated for SO ,
2 for CO, and 10 for oxidants. In 21 of the AQMAs the analysis for
maintenance had been completed and work was beginning on the development
of the AQMA plan. Two of the AQMAs had the analysis well underway and 10
had the analysis either in very early stages or not yet begun.
The extent of the analyses varied as did the type and special
problems of the AQMAs. Most of the analyses had been done following the
guidance of Refs. 1-13. There were, however, some variations that have some
implications for a CEPA system. One state, in reviewing the guidance of
Refs. 7 and 13 decided not to go into the details of emission projection
and allocation because of the complexity of the analysis. Review of the
problem indicated that a New Source Review (NSR) procedure might be adequate
to resolve the maintenance problem. Two states indicated that several of
their AQMA problems were dominated by one or a few large sources and NSPS
coupled with a NSR procedure would be adequate to maintain the standards.
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In these cases the analysis was relatively simple and required only minimal
calculational effort. At the other extreme two states reported extensive
calculations, one having analyzed the entire state and the other using a basic
data set on a 1/4 square mile resolution. This indicates that any type of
CEPA system must be able to deal with the easy problems as well as the more
complex or it will be useful only in the large metropolitan areas with large
data requirements.
Two states indicated that growth projections were especially tenuous
because decisions, outside of their control, could make a dramatic impact
on the type and extent of growth they could expect. These decisions included
government policy directives on the development of western energy resources
and the world market for copper. One state indicated that one of the principal
benefits that could be derived from the availability of a CEPA system would
be the ability to analyze a variety of development scenarios instead of
having to choose just one as was the current practice.
Four of the states reported problems with fugitive dust and the
development of adequate techniques to evaluate the causes and determine
appropriate controls. One state indicated that the nature of the fugitive
sources made projections extremely difficult. They also indicated that they
have very few ideas on how to develop and implement a control strategy.
Modeling of complex terrain was another problem area often raised.
All of the states had been interacting with regional and local
planning groups. The level of involvement varied primarily with the
experience and activity of the planning agency. One state indicated that
planning was a relatively new concept in the state as a whole while another
was able to assemble a good deal of the information it needed in the
appropriate format from the planning agency. One state reported that the use
of the CAASE program for AQMA analysis had prompted the state highway depart-
ment to shift to a machine-readable, UTM-coordinate system for the sake
of compatability.
5.2.2. Agency Resources Available
The states were asked about the in-house, contractor, computer
personnel, and computer hardware resources they had available.
-------
-54-
In-house staff Table 5-2 indicates the level of manpower that each
state had committed to the AQMA analysis. There appears to be almost a uni-
form level of 2 man-years for each state. The state with 4 man-years committed
is not the largest in terms of number of AQMAs and extent of problems; the
state with 1 man-year is the smallest of the seven in terms of maintenance
problems.
These figures do not represent agency activities such as emission
inventory, monitoring support, and clerical and management support. A typical
profile of the agency AQMP personnel would be two senior engineers (a senior
engineer and a junior engineer in smaller agencies) organizationally located
in a strategy/regulation development position.
It is evident from this information that the level of resource
commitment is relatively low. Legislative restrictions on agency size and
budget, competing tasks placing demands on agency staff time, and the ready
availability of outside contract assistance with Federal EPA funding are among
the reasons for this phenomenon. In terms of CEPA system requirements there are
indications that if it were designed to support the AQMA analysis only, there
would be substantial restrictions on the resources available to maintain
and operate the system. Several criteria for system utility would be that:
1) it must enable this typical 2-person staff to function more efficiently
in conducting the AQMA analysis, 2) it must be simple enough to enable it
to be used without increasing agency resources, and 3) it must have utility
for other agency functions if it requires more resources to be committed to it.
Contractor Utilization Table 5-3 shows the extent of contractor
utilization among the states. All had used contractors to some extent although
in 2 states the use had been minimal. Four states were interested in either
building or maintaining their in-house capability with one state specifically
rejecting contractor funding. In general, the perspective that was prevelant
at the Regional Offices was upheld from the states' viewpoint: i.e., the
states would like to have more in-house capability, the use of contractors
was almost mandatory to meet the analysis requirements and time schedules
dictated by the regulations, and there was a higher than would be desired
incidence of dissatisfaction with contractor performance.
-------
-55-
Table 5.2. State Agency Resources Committed to AQMA Analysis
Resources Committed
State
1
2
3
4
5
6
7
State
1
FY 76
(man-years) (1000$)
2.50 50
2 NA
4 NA
1 NA
1.91 40
NA NA
2 62
Table 5-3. State Agency Use
Contractor-Performed
Tasks
Area source information
FY 77
(man-years )
Decreasing
NA
NA
Increasing
Decreasing
NA
2.3
of Contractors
State Policy on
(1000$)
NA
NA
NA
NA
NA
NA
75
Contractor Use
Prefer to do as much in-house
4
5
Most of the analysis
Growth projections,
point and area source
allocations
Allocations using CAASE
Projections and allocations
in all but easiest AQMA
Very little
Very little
as possible.
Have used regional planning
agencies.
Parts of analysis were
redone in-house.
Are building more in-house
capability.
Undecided regarding extent
of contractual assistance.
Have turned down contractual
assistance funding in order
to maintain in-house capa-
bility.
-------
-56-
The implications of this pattern for a CEPA system are not
entirely obvious. From one perspective, the development of a CEPA system
can be viewed as providing a tool to the state agencies that will enable them
to perform more of the analysis in-house and reduce their reliance on external
sources. From another viewpoint, the CEPA system could become so complex
and difficult to operate that the states would be forced into even heavier
reliance on contractual assistance to maintain it and extract the maximum
potential from it. From yet a third viewpoint, it may not be desireable to
minimize the use of contractors since many states are satisfied with their
performance and the procedure does have the advantage of providing the states
with skilled personnel that need not become permanent staff. One thing is
evident from this situation: that a policy decision on the extent to which
in-house capability will be emphasized over contractual assistance will
play an important role in determining the need for and the design of a
CEPA system.
Computer Personnel Available Table 5-4 gives the states' availability
of computer personnel. The groups are separated into computer programmers,
whose principle function is to develop and operate computer codes, and know-
ledgeable staff who are primarily technically trained (e.g., engineers) but
who know how to program.
Many of the states have access to large state computer facilities
and programming staffs although only in the larger agencies are programmers
specifically assigned to the air pollution control agency. Computer programming
is most frequently handled by the technical staff (engineers, meteorologists,
etc.) who have the immediate need. In the air quality maintenance analysis
effort, the programming, including the use of some of the available routines
such as CAASE, were almost always handled by a member of the technical staff
familiar with the AQMA procedure rather than a trained programmer. The
complexity of the computer routines was limited by the extent of the
familiarity of the staff with FORTRAN and/or COBOL. Two states did have
technical staff who were especially competent in computer use but other
demands on their time kept them from functioning purely in a computer support
role.
From the viewpoint of CEPA system development it must be recognized
that the eventual user will not be a highly specialized computer programmer
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-57-
Table 5-4. Availability of Computer Personnel
State
1
2
3
4
5
6
7
Number
„ a
Programmers
1
4
12
2
of People
Knowledgeable Staff
2
NA
6
3
2
7
3
Agency
Feels Staff
is Adequate
Yes
Yes
Yes
Yes
Yes
Yes
Yes
a
'Includes programmers available to the air pollution control agency from
state computer personnel pool.
but rather an engineer or meteorologist who knows some programming. This
is significant in that programming techniques that involve intricate
manipulations of data or involve subtle program steps are likely to be
confusing to the average user unless very clearly documented. In the
worst circumstances, the CEPA system could become completely unuseable because
it is too sophisticated. To counteract this possibility, it may be necessary
to sacrifice some machine efficiency to develop a code that is more readily
understandable and changeable by the average user. Documentation requirements
also become more important in the light of this user profile.
The states were also asked to assess their own capability to
operate and maintain a sophisticated computer package like a CEPA system
might be. Without exception they replied in the affirmative although some
indicated that they might need some assistance in getting the codes mounted
on their equipment. In general, an agency experienced in the use of the
various computerized dispersion models (AQDM, CDM, etc.) would probably
not have an exceptional amount of difficulty operating a well-designed
CEPA system.
Computer Hardware and Software Availability Table 5-5 indicates
the extent of computer hardware and software capability available to the
states. There is a wide variation in the machine type with four states
-------
Table 5-5. Computer Hardware and Software Availability
State
1
2
3
4
5
6
7
Machine
UNIVAC 1110
UNIVAC 1108
SYBER 72
POP 11
CDC 3300
IBM 370
DEC
2-UNIVAC 1106
UNIVAC 1108
IBM 360
Data General
Core Size
(1000 words)
600+
650
98
32
131
NA
64
262 each
NA
NA
NA
Availability
State facility,
shared
State facility,
shared
State facility, shared
In-house
University
State facility,
shared
In-house
State facility, shared
University
State facility, shared
In-house
Input
Capability
Interactive and
Batch
Interactive and
Batch
Interactive and
Batch
Primarily Batch
Batch
Interactive and
Batch
Primarily Batch
Languages Available
FORTRAN COBOL
Yes Some
Yes No
Yes Yes
Yes Yes
Yes Some
Yes Yes
Yes Yes
Other
Some BASIC
Some Assembly
Language
BASIC
Some BASIC
Some BASIC
PL1
Assembly
Language
Some PL1
Some APL
00
-------
-59-
having UNIVAC equipment, two having IBM, one each having CDC, PDF, SYBER,
DEC, and Data General. Three of the states have more than one type of
equipment. Machine core size varies but the information presented only
partially reflects actual machine capacity. Word size is another signifi-
cant parameter but this information was not available. In general the availa-
bility of the large machines, at least on a shared basis, presents no constraints
on CEPA system utilization.
All of the states are sharing at least a part of their computer
facilities with other state agencies or are contracting for the use of a
university computer. Only three of the states have access to small, in-house
equipment that is used primarily to handle smaller programs and routine data
processing. These facilities may be generally too small for a CEPA system.
Four of the states used both interactive and batch processing of
jobs on their equipment. Two others used primarily batch although some inter-
active processing was done. One state used only batch. This indicates that
the CEPA system should probably not rely too heavily on interactive processing.
This was further reinforced by later discussions where the states indicated
that interactive connection time was too expensive for general use.
All of the states had FORTRAN available. All but one had COBOL
available although two indicated that it was not used very much. The other
languages, BASIC, PLI, APL, and Assembly were only occasionally available.
This is a strong incentive for CEPA to be confined to FORTRAN or COBOL. Even
at that, some states recommended that FORTRAN-COBOL programs be avoided
because of difficulties in using a combined language program.
Table 5-6 presents typical dispersion model run costs. The basic
computer charges are difficult to compare because of the varying accounting
systems msed at different computer installations. Costs for a dispersion
model run are nominally in the hundred dollar range although there have been
some reports as high as $1000 per run. It is evident that this rate can
cause computer charges to mount very rapidly. A CEPA system cannot be
designed in such a way as to create large increases in computer time
requirements. Two states reported computer budgets for AQMA analyses of
$10,000. Considering the costs of the dispersion model run itself, there
is not a great deal of room for creating large space- and time-consuming
-------
-60-
Table 5-6. Typical Computer Costs
State
1
2
3
Basic
Computer
Charge
$8 per
NA
$50 per
core block hour
cpu hour on
Dispersion Model Parameters
Sources Receptors
90 225
470 80
2000 60
Cost
$90
$300
$1000
Turnaround
NA
NA
Daily
state machine
$550 per cpu hour on
contractor machine
4
5
6
7
$1.50 per minute
NA
NA
NA
1700
NA
500
120
125
NA
2500
250
$100
NA
NA
$100-day
$50-night
Overnight
NA
4 hours
Overnight
programs. A CEPA system might conceivably be used to minimize computer
requirements by allowing the analyst to review the impact of a large number
of strategies on emissions (with a detailed spatial and/or temporal resolution)
prior to the testing of the strategy on the dispersion model. To be used in
this manner, the CEPA system would have to have significantly lower resource
requirements than the dispersion model.
5.2.3. Agency Experience
The states were asked to relate some of their experience in AQMA
analysis.
Computerized Models The states were questioned on their experience
with computerized dispersion models and computerized emission projection
techniques. It has already been implied that a CEPA system, as envisioned
here, would be analogous to a dispersion model in terms of complexity and
ease of use. An agency's experience with the dispersion models would be
indicative of how successful a CEPA system would be. Table 5-7 indicates
agency experience with both dispersion models and with the CAASE program.
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-61-
Table 5-7- Agency Experience with Computerized Models
State
1
2
3
4
5
6
7
AQDM/CDMa
X
X
X
X
X
X
X
Dispersion Models Used
HIWAY PTMAX PTMTP
X X
X
X X
X
X
X X
Emission Projection and
Allocation Models Used
Other None
X
X
APRAC X
X
Valley,
C9M3D,
PTDP
CAASE
X
X
X
Includes use of the TDM and TCM models.
All of the agencies have experience with the multi-source urban
diffusion models such as AQDM and CDM. Some have fairly extensive experience
with point source, line source, and complex terrain models in addition.
The problems with the models that were reported were application oriented;
that is, the biggest issue was the validity of the model when applied to
the local situation. The most frequently occurring problem was the
difficulty in modeling in complex terrain. One state did indicate some
computer problems in using a model from EPA*s UNAMAP file. About two
months of effort were expended on getting a UNAMAP model operational on the
agency's computer. The compatability of the FORTRAN level used in the
model with the system's compiler was the primary problem. Another state
had some difficulties with the HIWAY model and indicated, "It never has
worked properly." The restrictive assumptions required in HIWAY was
another reason cited for the state's abandoning it. Most of the evidence
indicates, however, that from an operational standpoint, the use of com-
puterized dispersion models does not appear to be presenting significant
problems for the states.
-------
-62-
The states' experience with the CAASE program was not as positive
however. One state started to use CAASE but were advised by their EPA-
supplied contractor that it would not work properly and so did not proceed
further. They also reported asking EPA for information about the AQUIP
program but never received a response. Another state reported that they
had their contractor use CAASE but that the type of information that was
required was not available and was prohibitively expensive to obtain. The
resolution of the growth data was the biggest problem and there was an indi-
cation that some operational difficulties between the contractor and the
agency led to some confusion about the delegation of responsibility of data
collection. The inaccuracy of the CAASE techniques of allocation by population
was another problem. They were, however, considering getting CAASE operational
on their computer. A third state indicated that some of the local planning
agencies had looked at the possibility of using CAASE but they were not aware
of the results of the experience.
It is evident from these discussions that the CAASE program is
presenting more problems in its implementation than are the dispersion models.
In one respect this should be expected since CAASE is much more complex
from an operational standpoint; it involves the processing of tapes generated
external to the air pollution control agency, it requires some manual
interaction in developing grid squares, and it is a 5-step program rather
than a single "black box". It is evident that a CEPA system will, of
necessity, have to be easier to implement than CAASE if it is to be widely
used.
Manual Analysis Techniques Since much of the emission projection
and allocation was done by hand, the states were asked to identify the areas
that presented the biggest problems.
One state indicated that they had almost entirely avoided the projections
and allocations as outlined in Refs. 7 and 13. They felt that the resources
were not available to follow these procedures and that the procedures themselves
were unrealistic. They spent most of their effort on collecting area source
data and are planning to rely on a New Source Review procedure to control
growth. Four states indicated that the collection of good data was the
biggest problem in the entire analysis. Problems with completeness of the
emission inventory (especially area source information), compatibility of
-------
-63-
data (e.g., same year of information), consistency of data (e.g., one source
contradicting another), validity of growth projections, and the use of federal
and statewide guidelines and information that do not apply to local situations,
were cited as problem areas. One state indicated that the manual methods were
inadequate to treat their problems while another indicated that computerized
methods would be unnecessary in all but one of their study areas.
One point was consistent through most of the interviews: the collection of
good emission inventory and growth data is presenting a significant problem to
the air quality analyses. If a CEPA system could provide a mechanism for
alleviating some of these problems it would undoubtedly be widely implemented.
It has already been discussed from the Regional Office perspective that the
system could not eliminate the need for significant data collection efforts,
but the ways in which it could play a role would be to allow the states to handle
more information, which could then be more easily cross-checked for validity,
to provide a standarized format for assembling the information; to, as one Regional
Office suggested, "force the issue" of using compatable data bases onto the
participating agencies; and to permit the analysts to evaluate alternative scenarios
and to identify the sensitivity of the analysis results to key pieces of informa-
tion. If the decision is made to proceed with CEPA system development, these
considerations should be evaluated as potential design objectives.
Data Bases Available. The data bases of principle concern to the air
quality analysis are the emission inventory and the planning data from regional,
state, and local agencies. Table 5-8 indicates the type of emission inventory
systems being used. Three of the states rely on the NEDS as the primary inventory
tool although two are in the process of developing their own in-house computer-
ized systems. The NEDS point source format appears to be widely accepted
although some states have indicated they would like some additional information
incorporated (e.g., other than annual emissions, employment, facility land area,
etc.). One state, however, commented that the NEDS area source data are based on
counties and that gridding and apportioning are necessary before use in air
quality models. This is true but it should be noted that the CAASE gridding pro-
gram and Volume 13 of the AQM Guidelines are provided by EPA specifically for
such purposes.
During the interviews, three states reported delays of six months to two
years in acquiring NEDS data printouts. Investigation by EPA subsequent to the
Argonne interview revealed that such delays existed two to three years ago but
have since been substantially reduced due to system and computer improvements. For
-------
Table 5-8. Data Base Availability
State
Emission Inventory
NEDS
In-house System
Other Data Bases
Data
Source Computerized
Submit updates only
Submit updates only
Submit updates only
Submit updates only
Used as basic inventory
Used as basic inventory
Used as basic inventory
Computerized,
NEDS format
Computerized
Computerized
Computerized,
NEDS format,
EIS/P&R
Computerized system
under development
with NEDS format,
EIS/P&R
Computerized system
under development
with NEDS format,
EIS/P&R
Manual
Census tract data
VMT
Population, employ-
ment, VMT
Land use maps, popu-
lation, employment
Population, SIC
employment, housing
starts by political
jurisdiction. VMT
Energy studies
VMT by link
NA
Census Bureau
Highway Dept
Planning Agency
Planning Agency
Planning Agency
Contractors
FHWA
NA
Population, some 208 Agency
employment by county,
voting district
Yes
Yes
NA
Yes
No
No
Yes
NA
No
I
ON
-------
-65-
example, in early 1976 one state experienced a seven-month delay in acquiring
NEDS data whereas more recently, processing time had been reduced to two months.
Four states indicated that they had made use of some of the NEDS peripheral
routines to process emission inventory data. Three of the four either had in-
stalled or are in the process of installing the Emission Inventory/Permits and
Registration Subsystem (EIS/P&R) for use with their own inventories. This
raises a significant observation that reflects on the possible use of a CEPA
system. Most of the states are, in general, satisfied with the NEDS system
structure and with the various routines available to manipulate the data.
This satisfaction is indicated by the widespread use of these routines on
in-house systems. The dissatisfaction arises whenever data must be in the
centralized NEDS system before the States can access the data. This situation
is being corrected by EPA via the installation of the EIS/P&R system in numerous
state and local agencies. In this manner, the states can utilized their own
data immediately upon collection and easily fulfill their reporting require-
ments to EPA. Also, one state complained that EPA had not provided adequate
assistance on the use of the system; the state was not fully aware of all
its capabilities and of how to resolve problems with the system. The respon-
sible Regional Office has subsequently been advised of this problem and
will send the appropriate references. There is a clear indication that a
complete computerized package (like NEDS and like CEPA) can be designed to
be of significant value to the states, but the need for adequate instruction
and training in the use of the system is imperative.
As an aside to this discussion, it is also evident that a CEPA system
design should strive for consistency with existing emission inventory data
processing routines. This is especially true for the EIS/P&R system which
is being installed in a number of states. One state felt the system would
provide all the necessary point source data needed for AQMA planning and
they are redesigning their inventory forms for use with the system.
Table 5-8 also indicates other data bases used by the states. This is
not a comprehensive list for each state but does indicate the most prevalant
forms of information,available. One state indicated that it had access to
a great deal of information but did not use it because the agency lacked the
data handling facilities. Another reported that they had interacted with
the regional planning agency and were using their data management routines
to process the information. Manual methods were interspersed with compu-
terized methods to generate emission estimates. Two
-------
-66-
states indicated that the information they had received from the planning
agency was not in machine-readable form; one handled part of it by
computer, the other felt that the amount of information was small enough
that there was not need to computerize it. These perspectives reinforce
earlier conclusions that the data input to AQMA analyses vary considerably
and a CEPA system must be flexible enough to interface with a wide variety
of formats, spatial and temporal resolutions, and levels of detail.
5.2.4. CEPA System Design
The states were asked to comment on any specific design features
of a CEPA system that would be most useful. Three specific examples were
cited in the question: a strategy package to apply various control strategies
to the emission inventory, a computerized compilation of emission factors
for use with the inventory, and a cross-checking feature that would tabulate
data from different sources and check for consistency. Five states felt
that the strategy package would be useful; one felt that this type of
feature could be handled with the EIS/P&R system and one had no comment on
it. In addition, two states indicated that the strategy package would be
useful if it could be used to determine the consequences of a wide range
of strategies and that flexibility was a key issue. Another state felt
that the primary utility would be in area source strategies since there
were not a great many point source problems that could not be handled
manually. Three states indicated that the computerized emission factor
file, with possible override capability was a good feature. Two states
already had computerized emission factor files and the remaining two had
no comment. Two states felt the cross-checking feature was useful, one
felt it wasn't necessary, and the remainder had no comment.
In addition to these suggested features, some of the states offered
their own comments. Three states indicated that a growth package would
be especially helpful. Two forms of this were suggested. One would accept
growth information from local sources and apply growth factors to the emission
inventory to project emissions. Another would actually generate the growth
factors from input historical data. The second version is much more involved
and actually represents a growth algorithim. It was also suggested that the
Federal government assume the responsibility for generating the growth
-------
-67-
scenarios. For both, cases, the ability to handle several growth scenarios
was suggested as a useful option.
The ability to interface with a variety of local data sources was
identified as an important feature by three states. One state suggested
that a graphics module, a statistical analysis package, a report writer, and
an output feature that would provide information in a format directly
compatable to dispersion models. Another state suggested that the system
allow for varying levels of detail in the analysis.
With regard to the preference for an integrated CEPA system or a
set of modular units, five states indicated that the modular approach would
be the most desirable because of the flexibility it gives. One state
prefered an integrated package but also emphasized the need for flexibility.
One state had no opinion.
The question of a system that could be mounted on in-house computers
vs. a centrally located system drew some differing responses. Four states
indicated a preference for an in-house system primarily because of past
problems with access to EPA computer facilities. Two of these states felt
very strongly about this issue. Two states preferred the centrally located
system and preferred to have EPA maintain and operate it. One felt there
would be no use in keeping the system in-house if it were to be used only
infrequently. One state suggested that the system be designed for in-house
use but also be available on EPA facilities for those states needing it.
The computer language preferred was FORTRAN with four states indicating
that COBOL was also a useful language. PL1 was suggested in two states and
one indicated that APL had been successfully used. One state specifically
emphasized the use of the programming principles in the EIS/P&R routines.
Six of the states suggested that batch processing would be
preferable; one had no comment. Three states indicated that a combination
of batch and interactive processing might be helpful. One state observed
that the instantaneous turnaround associated with some interactive packages
was not necessary and not worth the higher cost. Another state indicated
that it has experienced difficulties in gaining access to an interactive
terminal.
-------
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5.2.5. Potential for Agency Use
The states were asked for their general comments on the need
for a CEPA system, its timing, and its potential application to other
air quality problems. Table 5-9 summarizes these comments. Only one
state felt that the CEPA system concept was not a very useful one; all
others believed that it did have merit. Without exception, however,
all felt that the system is too late to be of major usefulness to the
current round of air quality analysis. The states that suggested an
availability date quoted a time in early or mid 1977, which is much too
soon to have a CEPA system operational. The utility of a later-developed
system to the 1978 analyses for areas needing land use and/or transportation
controls was also indicated as marginal because of the inertia of current
programs that have adapted to other manual and partially computerized
techniques. There was some indication from several states that if pieces
of the CEPA system were available at an early date then they would be
used to assist some of the on-going analyses.
With regard to the commitment of resources to use the CEPA system,
five of the states declared that they would probably not use it if
additional resources (manpower and/or money) were needed to maintain and
operate it. Two states felt that the resource issue was not a major
problem for them and that they would not be deterred from using it by
resource constraints. All of the states indicated that they would at
least consider using the system if it did not require an increase in
resource requirements. Most indicated that the system would need to
demonstrate its utility before the commitment would be made. One indicated
specifically that a large and complex system paralleling the 13 volume
1-13
guideline series would probably be ignored.
All of the states felt that if the system were to be implemented
it would be used in-house rather than by a contractor. This answers one
of the primary concerns of whether the system would promote the development
of in-house capability.
There were a wide variety of possible other applications of the
CEPA system described by the states. The use of the system in the 5-year
update of the maintenance plans was one of the most obvious areas. One
state did indicate that it would prefer to have EPA support the system if it
-------
Table 5-9. Potential State Agency Use of a CEPA System
State
Issue
Is the CEPA concept useful? Yes
When must it be available? 1/77
Would the agency commit
additional resources to use a
CEPA system? No
Would the agency use the
system is no additonal
resources were required? Yes
Would the CEPA system be
used in-house or contracted
out? In-house
What are other possible uses
for a CEPA system in the
agency? 5-yr. update
PSD
General Comments System to
keep track
of area
source data
helpful.
Not very
Too late
No
Possibly
In-house
PSD,
track
area
sources
Yes
6/77-12/77
No
Yes
In-house
5-yr. update,
PSD, NSR, SIP
revisions,
208 analysis
Good system
will get
later use.
Yes
Too late
No
Yes
In-house
5-yr. update,
208 analysis,
CZM analysis
Would not
support ie
if states had
to collect
data and sub-
mit it to EPA.
Must be inte-
grated into
current emis-
sion inventory
process.
Yes
Too late
No
Possibly
In-house
PSD,
energy
scenario
evalua-
tion
A large
complex
system
analagous
to the 13
volume
guideline
would be
ignored .
Yes
1/77
Possibly
Possibly
In-house
PSD, NSR
Must be
better
than
existing
methods .
Yes
7/77
Possibly
Possibly
In-house
5-yr. update,
PSD, Alterna-
tive scenario
evaluation
Would have
to be easy
to use.
I
cr>
vo
aPSD-preyention of significant deterioration, NSR-new source review, CZM-coastal zone management.
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-70-
were only to be used every 5 years. Another state indicated that the
5-year update would probably not be as complex as the current round of
analysis but that the system might still prove useful.
Use of the system in prevention of significant deterioration analyses
was mentioned by all but one of the states. Although the details of the PSD
analyses have not yet been outlined, it is evident that some of the same
analysis techniques as are being used in the maintanance planning process
are applicable. This is a clear indication that the CEPA system needs
to address other than the AQMA analysis if it is to be useful.
CEPA could also be used in New Source Review programs, for
interfacing with other planning programs (e.g., 208, CZM), to evaluate
alternative growth and development scenarios, and to track area source data.
5.2.6. Other Agency Priorities
Table 5-10 lists the priority issues identified by the states.
The most frequently occurring issue was the development of better dispersion
models, particularly for complex terrain, short averaging times, and
photochemical oxidants. Four states indicated that better growth projections
were important. This was more from the standpoint of how to forecast what
will happen rather than how to convert these forecasts into emissions.
Several states felt that additional federal assistance in the form of money
for additonal positions and for contractual help was important.
5.2.7 State Agency Summary
In most regards, the perspective of the state agencies on the
utility of a CEPA system parallels the Regional Office perspective. The
concept is basically a good one but is too late to be of much value in
the current analyses. The potential for future use of the system will
depend on how well it can adapt to other agency needs such as prevention
of significant deterioration regulations, new source review, and others.
The agencies are willing to assign resources to the use of a CEPA system
as long as it does not increase overall resource requirements; the states
would plan on using it in-house. A CEPA system that helps with the maintenance
of emission inventory information, particularly area sources, would be most
helpful. A system that is excessively large and complicated to use would
be ignored.
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Table 5-10. State Agency Priorities
State Priority Issues
1 Additional short term dispersion models, highway model
between HIWAY and APRAC.
Assistance on growth projections and allocations.
Better definition of worst case conditions.
Photochemical oxidant models.
Federal assistance to do growth projections.
Emission inventory.
Additional positions.
Particulate transport, reintrainment, fugitive dust.
Additional positions and time for analysis.
Guidance on developing politically and socially acceptable
control strategies.
Additional training on air quality analysis procedures.
Dispersion models for complex terrain.
Development of better growth and allocation procedures.
Additional positions.
Better dispersion models.
Energy development projections.
Dispersion models for short term, rough terrain, oxidants.
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5.3. THE CONTRACTOR PERSPECTIVE
Non-agency technical personnel are being widely used in all
phases of Air Quality Maintenance Planning. Results of the Regional
Office telephone survey indicate that 27 states have initiated work or plan
to initiate work with private consultants and 7 states will rely on regional
planning agencies for AQMP analysis. With almost 80% of the states using
some form of outside assistance it is important to look at CEPA from the
contractors perspective.
5.3.1. Character of Contractual Assistance
Contractors act as an extension of the air pollution control agency
staff. Contractors (or consultants) may be hired using agency operating
funds, with special state funding or with special federal funds. Contractual
services are easier to aquire than additional budgeted positions and have
thus become a preferred mechanism for non-routine agency activities.
Contractors in the CEPA review have been divided into three categories: 1)
the individual consultant, 2) the private sector consulting organization,
and 3) the governmental planning agency.
Almost all of the agencies reviewed -have employed individual
consultants from time to tijme. Individual consultants are mostly university
personnel who have specialized in modeling, economics or law. Three of
the agencies surveyed use local university computers for dispersion modeling.
University staff have been hired for programming assistance. While most
agencies are using local consultants directly or indirectly in AQMP, individuals
are only being used in specialized areas. No individual consultants were
observed being used for a major portion of the plan development.
Consulting organizations, on the other hand, have been employed
both for specific segments of plan development and for the development of
entire plans. Consulting organizations can be subdivided into private sector
consulting firms and governmental planning agencies. While the operation
and character of these two types of organizations are quite different, the
service they perform is essentially the same. Of the 43 states commented
on by the Regional Offices, 27 states had plans to employ private sector
consulting organizations to develop a significant portion of the plan.
Two prime reasons given for contracting AQMP work are:
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1) insufficient number of budgeted positions
for AQMA plan analysis and development, and
2) lack of knowledgeable personnel in
specialized technical areas.
While the most common response for contracting AQMA work has
been, "We don't have enough people to do it in-house", one must question
internal priority and institutional forces which promote use of outside
contractors. It has been observed that states with 100-200 budgeted
positions have opted for contractual assistance. One institutional
arrangement which facilitates contracting are EPA's BOA agreements. The
basic ordering agreement allows states to use EPA funds to obtain technical
assistance from outside contractors, thus freeing agency staff for other
more routine activities.
The BOA contractor can be funded by a state to conduct
an entire AQMA analysis. Tasks involved in the contract include emission
inventory update as well as growth projections, emissions allocation,
modeling and strategy development. The same company may complete various
portions of plans in several states. While it is not uncommon for a
private sector consultant to develop the entire plan, indications are that
in most cases, the state air pollution control agency provides some guidance
during the analysis and often will intervene in contractural work to test
specific strategy options. If the contractor is hired using BOA funds, the
Regional Office frequently becomes a major influence in determining the
scope of the effort. It has been observed that five or six private sector
contractors are performing most of the AQMP work. The scope of the contracts
and level of detail vary from state to state. Analysis techniques range
from crude growth and allocation routines to the most specific level of
detail. The general opinion of private sector consultants has not been
favorable. While contractors appear to have the technical capability and
can meet time deadlines, the quality of the work has been questioned. Contractors,
on the other hand, have complained about the lack of cooperation and poor data
supplied by agencies for the analysis.
Another instance where work is being conducted outside the APC agency
is where regional planning agencies have been given AQMP responsibility.
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Councils of Government (COGS), Regional Planning Agencies and City Development
Organizations are state chartered organizations charged with a variety of
tasks related to growth and urban planning. A planning organization may
encompass a single urban area or may include many cities, townships and
counties. Population growth, transportation, water and waste treatment,
as well as economic and environmental effects of growth are issues addressed
by planning agencies. Funding for these agencies come from local governments,
State governments and federal grants. A variety of federal agencies including
HUD, DOT and EPA provide grants to local planning agencies. Development
of these organizations varies greatly from state to state. Some states are
well organized with budgets for AQMP work, other states have small agencies
with little or no air pollution capability. Seven of the AQMP states have
planning organizations with funding and manpower sufficient to perform a
major portion of the AQMA plan.
In each of the four governmental planning organizations participating
in AQMP development, all four were operating with only minimal guidance
from the state air pollution control agency. All four agencies had completed
the analysis ahead of schedule and in every case the Agency appeared satisfied
with the analysis. In general, local and regional planning agencies appear
to be adequately staffed and technically capable of performing AQMP work.
They are integrating air planning with 208 water planning and tend to display
a better grasp of AQMP than either the private sector contractors or the
air pollution control agencies surveyed.
As part of the CEPA study, two governmental planning agencies
were surveyed. Both agencies had completed the entire plan and each worked
independently of the state air pollution control agency. In each case only
minimal technical assistance and data came from.the state APC Agency.
One of the surveyed planning agencies was regional and the other was a city
planning agency. Both received state and federal funding including 208 money.
Two other planning agencies were studied as part of another project.
Comments and opinions of those agencies have also been used.
5.3.2. AQMA Planning Evaluation
Because of the limited number of interviews conducted as part of
this study, only two contractor-type organizations provided opinions regarding
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the development of a CEPA system. Although the contractors visited make-up
of a good cross-section of non-agency AQMP staff, it is not certain that their
opinions are representative of all outside contractors.
A strong case was made by one of the planning agencies, that AQMP's
should not be developed by the state air pollution control agency. Development
of such plans represent a conflict of interest according to the planning
agency. When state agencies develop plans, they use their own data and
perspective to develop plans which will directly impact the funding and the
influence over local regulations given to that agency. Evaluation of
the adequacy of existing regulations should be made by a knowledgeable
"disinterested" independent organization. An example of agency perspective
influencing Air Quality Maintenance Plans is the case of an agency explaining
why particulate readings are exceeding standards as part of the AQMP instead
of revising enforcement policy for the pavement of dirt roads. Other reasons
for not developing maintenance plans within state air pollution control
agencies include the right of local communities to establish their own
plans and the inability of state agencies to properly coordinate with
highway, water and other city planners. Thus the point was made that
1) state agencies should not be encouraged to develop their own plans
and 2) if EPA wishes to develop CEPA, it should be for regional and
local planners, not state air pollution control agencies.
5.3.3. CEPA System Timing
All of the contractors interviewed indicated that a CEPA system,
even if available today, would only be of limited value. The two planning
agencies interviewed have completed their plans and indicated that a CEPA
system might be used for future review of the plan. If the CEPA system
had been available in the early part of 1976, it would have been extremely
useful to the agencies interviewed. The most probable application of a
CEPA developed in,1977 was for 1978 plans involving transportation and/or
land use controls. Another potential application was in non-attainment
states. A CEPA system developed in 1977 could possibly be used to
reevaluate plans and cross-check work done in non-attainment areas.
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5.3.4. CEPA System Design
Both of the two contractors interviewed expressed strong reservations
regarding a CEPA system's ability to accept the diverse character of local
planning data. One agency for example used gas meter data from a local
utility, basing the entire plan on the utility's gridding procedure. The other
private sector consultant, who was exposed to AQMP in several states elaborated
on the poor quality of state planning analysis. If a CEPA were developed,
it would have to be modularized, system assumptions would have to be clearly
defined and easily adaptable to local conditions. A series of small computerized
routines would best suit the needs of AQMP analysis. One planning organization
developed internally over 20 separate computerized routines to aid in the
analysis as defined in Volumes 7 and 13. The other contractor interviewed
had also developed internal computational routines.
In every case, the routines were written in FORTRAN. Similar to
air pollution control agencies, personnel in contracting organizations
working on AQMP were primarily engineers with programming backgrounds in
FORTRAN and limited working knowledge of COBOL. As a result,all those
interviewed preferred a CEPA system written in FORTRAN and easily used by
personnel other than computer programmers. The contractors were in agree-
ment in their desire for batch processing. A feeling was expressed that
interactive programs were too expensive and bulky. The CEPA routines
should be able to accept a variety of input data including:
1) census tract data,
2) utility data,
3) FHWA data formats,
4) local growth estimates,
5) local emission estimates, and
6) Bureau of Mines data.
The CEPA programs should include a variety of transformations
to manipulate data for preprocessing and to process output suitable for model
use. Most importantly the programs should be well documented and simple to use.
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5.3.5. Potential Contractor Use
Each of the contractors expressed an opinion that CEPA routines
would have been useful if they had been available earlier in the AQMP pro-
cess. Unfortunately. CEPA timing and AQMP due dates make potential contractor
use of CEPA limited. If a CEPA were developed by early 1977, it would probably
receive limited use by private sector consultants. The system would be
used in states who are now just planning their AQMP effort. Portions of
the CEPA system could be used for other projects related to modeling and
emission inventories. It is not likely that a CEPA system would be used by
private sector contractors to recheck their AQMA analysis. Planning agencies
are not likely to reopen their analysis unless they receive specific funding
for such a task. Potential contractor use of CEPA routines is limited to
plans due in 1978 and not yet contracted and emission/air quality projects
which could be simplified using special routines which would be incorporated
as part of the CEPA..
5.3.6. AQMP Priorities
One of the contractors interviewed was unable to indicate any special
priority in the AQMP process. The other, however, had definite feelings
regarding the weakest aspect of AQMP. Emissions inventory data is by far
the weakest aspect of AQMP. It was necessary for the planning agency to totally
reestimate emissions in its AQMA. A private sector consultant was given
extremely poor, emissions data with which to work in one state and had to
survey all point sources to obtain adequate emissions data in another state.
Without good emissions data the entire plan is of little value. Simulation
runs of various strategies will not be representative of actual controlled
emissions and the final strategies will be unrealistic. Virtually every agency
has had to reevaluate baseline emissions before AQMP could proceed. Any effort
in AQMP by the Federal Government should be placed in improving emission
estimates. This feeling is the strongest expressed by planning agencies
and private sector consultants regarding AQMP.
5.3.7- Contractor Summary
From the perspective of private sector contractors, and governmental
planning agencies, any CEPA system at this point in time would be of limited
value. CEPA would be too late for AQMP's due in 1977. CEPA components may
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be of value for 1978 plans and would be of value for future projects.
Potential uses of CEPA components would be for data translation for modeling,
PSD, checking future emission estimates for new source review and for
general agency improvement of existing emission estimates. Contractors
would support Federal funds being used to improve emission inventories but
would not favor a "big black box" which would only act to compound the
problems of state air pollution control agencies.
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6. CONCLUSIONS AND ALTERNATIVE PLANS OF ACTION
The conclusions to be drawn from the information accumulated in
the course of this preliminary feasibility study are not clear cut. There
are indications that a CEPA system would have some definite advantages in
performing air quality analyses. At the same time, there is little indication
that CEPA development is a matter of utmost priority. Given this situation,
the decision to proceed with the feasibility study of CEPA must be made on the
basis of evaluating several issues that are important to the entire air quality
management process. The purpose of this section is to provide the decision-
makers with an identification of these issues and" an assessment of how CEPA
system development is impacted by each. A set of alternative courses of
action is also outlined.
6.1. IDENTIFICATION OF ISSUES
The key issues that will influence the decision on CEPA system
development are the following.
6.1.1 Analysis Requirements
The analysis requirements generated by the AQMA regulations specify
that emissions be projected for at least the baseline year, one intermediate
year, and the tenth year of the planning horizon and that these emissions
be allocated to a finer than countywide spatial resolution. The CEPA system
will have direct impacts on how these requirements are met.
Arguments For CEPA Development Arguments Against CEPA Development
1. Even the minimum output require- 1. Despite the data handling problems,
ments call for the handling of a most states have managed to do the
substantial number of pieces of analysis either manually or with in-
information. When the possibility house-developed computer systems.
of evaluating several control A number of the analyses are relatively
strategies and/or growth scenarios simple involving only a few sources
is included, the data handling and would not require computer
problems multiply rapidly. assistance.
2. There is evidence to indicate that 2. Where necessary, it is possible to
the sophistication of air quality use contractual assistance to increase
analyses has been reduced where no the level of sophistication of the
computerized system was available analysis. Also, Regional Offices can
and has been enhanced where the permit less sophisticated analysis
state developed its own system. techniques.
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Tor CEPA (cont'd)
3. The CEPA system has potential use
in Regional Office review of AQMA
plans and in the several situations
where the Regional Office may have
to promulgate a plan. The CEPA
system will also encourage a degree
of uniformity in plan submission
making review easier.
4. The CEPA system will permit the
processing of local planning data
and will assist in achieving the
required interagency cooperation.
This has been demonstrated in the
experience with state-developed
systems.
5. The availability of a CEPA system
will improve the quality of the
analyses by allowing the states to
process more information, cross-
check the data, conduct sensitivity
analyses, and evaluate alternative
growth and development scenarios.
6. A CEPA system will assist in the
emission inventory process by pro-
viding a structure for data collec-
tion and by forcing the issue of
compatable data base use on the
part of air pollution control and
other planning agencies.
Against CEPA (cont'd)
3. The Regional Offices can use contractual
assistance to develop the necessary plans.
4. The diverse nature of local planning
data makes it difficult to design a
CEPA system that will have nation
wide usefulness.
5. The availability of a CEPA system
will promote heavier reliance on
computer-generated calculations, which
can lead to a decrease in agency
evaluation of the reality of the cal-
culations . The CAASE program has led
to problems in this respect.
6. The CEPA system itself will not
alleviate the need for extensive
effort to compile emission inventory
data.
6.1.2. Timing of System Development
The timing of CEPA system development and introduction is a significant
issue in the decision to proceed with further study at this time.
Arguments for CEPA Development
If parts of a CEPA system were made
available in a relatively short
period of time they could be very
useful. The system could also be
useful for the plans that require
transportation and land use controls
that are not due until 1978.
Arguments Against CEPA Development
L. The CEPA system is too late to be
of major value to the AQMA analysis
process. Even where it may be useful
for later plans, inertia will inhibit
the agencies from changing direction
to utilize CEPA instead of their
current procedures.
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For CEPA (cont'd)
2. There is general agreement that the
CEPA system will be useful for the
5 year update required of AQMA plans.
System development begun now will
avoid a timing problem later.
Against CEPA (cont'd)
2. Development of a CEPA system now
could cause some states to request
delays in their plan submittals
pending the availability of CEPA.
6.1.3. Development of In-house Capability
The issue of in-house capability vs. contractual assistance is a
prime consideration in the consideration of CEPA system need.
Arguments For CEPA Development
1. Many states wish to Improve their
in-house capability to do air
quality analyses.
Arguments Against CEPA Development
1. Some agencies have state-imposed
restrictions on obtaining additional
positions and resources. Also the
Federal government policy of not getting
involved in providing services available
from commercial sources except under
certain circumstances, may be state
policy also.
2. An experienced contractor can do a
job more quickly than an inexperienced
agency and can result in lower overall
costs. Contractor assistance can be
used to shave the peaks from manpower
requirements without the agency having
to commit itself to long term employees.
3. From the Regional Office perspective,3. Some states would still prefer to use
2. Contractor manpower are typically
higher than agency costs ($5000 per
man-month vs. $3000 per man month).
most of the states could handle a
CEPA system in-house. All of the
states interviewed indicated that
they would use it in-house.
4. Contractor performance has not
always been acceptable. There are
instances where an agency was
totally unaware of a contractor's
assumptions and analysis procedures.
a contractor for the purpose of obtain-
ing additional resources through EPA
grants and/or BOA assistance. This
procedure frees their own staff for
other work.
4. A large and complex CEPA system could
promote even heavier reliance on con-
tractors if the states could not handle
it easily.
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For CEPA (cont'd)
Against CEPA (cont'd)
Some questions have been raised as
to the desirability of having an air
pollution control agency perform
extensive growth and development
analyses. Concern has been expressed
that these functions belong to a
planning agency and not in a
regulatory agency.
6.1.4. State Capability and Experience
The decision to develop a CEPA system relies, in part, on whether
the state agencies have the experience to maintain and operate such a system.
Arguments For CEPA Development
The AQMA analysis staff of an agency
is typically two engineers. A CEPA
system would reduce their computa-
tional work load and allow them to
pursue more analytical tasks.
2. All of the agencies surveyed have
experience with, computerized
dispersion models. A CEPA system
would be of approximately equal
complexity.
3. All of the agencies surveyed have ac-
cess to large computer facilities and
programming staff which can be used
to operate a CEPA system.
4. All of the agencies surveyed felt
that they would be capable of
handling a CEPA system in-house.
Arguments Against CEPA Development
1. Agencies do not typically have a
computer analyst or programmer
directly assigned to AQMA work and
who can handle very complex computer
system and data base manipulation
routines.
2. The agencies using CAASE, which is
a computerized allocation routine,
are experiencing some difficulties
in getting it operational.
6.1.5. Agency Use
Perhaps one of the most critical issues in the entire decision on
CEPA development is whether the air quality analysis agencies would use it
if it were available.
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Arguments For CEPA Development
1. Eight of the Regional Offices
surveyed indicated that they
would encourage the use of a
CEPA system although not for
all states and agencies.
2. All of the states surveyed
indicated that they would give
consideration to using a CEPA
system in their air quality
analyses provided that it did
not require an increase in re-
sources.
3. The states indicated that there
were definite possibilities that
the system could be useful in
analyses other than AQMA (e.g.,
prevention of significant
deterioration, new source review)
Arguments Against CEPA Development
1. One Regional Office felt the system
was unnecessary and another indicated
it was neutral toward its utility.
2. It was generally agreed that a large
and complex system would probably
not be used. Five states surveyed
would not commit additional resources
to use a CEPA system.
6.2.
ALTERNATIVE COURSES OF ACTION
There are basically three alternative courses of action that can be
followed at this point. These are:
1) Discontinue further study.
2) Proceed with Phase 2 as planned.
3) Modify the scope and objectives of Phase 2.
There are ample justifications for proceeding along each of the three paths.
6.2.1. Discontinue Study
It may be reasonably argued that the information gathered in the
preliminary study indicates that the development of a CEPA system is too late
to be of any use in the AQMA analysis and that the Regional Offices and
state agencies are taking a cautious, rather than enthusiastic, view of its
utility at this point in time. Other needs, such as better dispersion
models for complex terrain and better data for emission inventories, have
arisen in the course of this survey and limited resources might better be
utilized to solve other higher priority requirements.
It may also be reasonably argued in favor of continuing that previous
delays in the consideration of a CEPA system have resulted in the present circum-
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stances. There is evidence to indicate that a CEPA system, properly designed
and introduced, would have found extensive use in the AQMA analysis. Delay
of further consideration of the system now would only postpone the problem
to some future date when it will surface again. The same poor timing
that inhibits CEPA system utility now would again inhibit its utility later.
6.2.2. Proceed with Phase 2
Phase 2, as planned, will provide insight into the utility of
four computerized air quality analysis systems and although these will not
be of direct value to the current AQMA analyses, they will provide a reference
point as to what kinds of techniques are the most useful. The Phase 2 effort
also focuses on the well-defined analysis requirements of air quality maintenance
planning and has the advantage of clearly defined objectives. There is also
evidence that a CEPA system based on this review would have some use in
later AQMA analyses and in the 5 year update. These considerations, along
with those against discontinuing further study, argue for continuance of
the Phase 2 effort as planned.
There are reasons for not proceeding with Phase 2 as planned that
go beyond the arguments for ceasing all further study. The primary objections
can be based on the fact that Phase 2 is too narrow in scope to fit the
actual requirements as indicated by the survey. It focuses too closely on
AQMA analysis requirements when there are clear indications that a CEPA
system could be of use to other air quality management programs. Also,
Phase 2 considers only four systems as candidates for all or part of a
CEPA system. A number of other possible candidates may exist in other
Federal and state agencies, which may be of significant value in meeting
overall air quality analysis goals.
6.2.3. Revise Phase 2
There are some strong reasons for considering a re-vision of the
Phase 2 effort and a change in direction to suit the broader requirements
that have surfaced in this preliminary study. It is clear that an identi-
fication of the analysis requirements of other air quality management programs
and the integration of these requirements into the overall design of a CEPA
system is needed to insure maximum utility of the computerized routines.
One portion of the Phase 2 effort specifically addresses the specification
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of CEPA system performance requirements independent of existing routines
and this could easily be expanded to include programs other than AQMA analysis.
Phase 2 could also be modified to include a review of more than
the four systems currently planned for consideration. As has been done in
the past, it may prove useful for EPA to issue a notice in either the Federal
Register and/or the Commerce Business Daily indicating an interest in collecting
information on available computerized routines that might be applied to
emission projection and allocation. A program underway by the EPA Office
of Transportation and Land Use Policy will have as one of its outputs a review
of growth projection techniques; these should be considered for CEPA system
use. The previously referenced Federal information service on computer
routines should be reviewed for potential candidate programs. It is possible
that this expanded scope of the Phase 2 effort can be met within the constraints
of the current resource commitments by decreasing the level of detail in
which the present four systems will be reviewed.
An even broader scope of Phase 2 can be considered. This would
involve a review of all of the air quality analysis requirements and available
tools with a view toward developing a systematic plan for the upgrading of
the methodologies. The publication of a guidebook outlining both current
computer programs and routines under development would be of substantial
help to agencies conducting air quality analyses. This would, of necessity,
involve a joint effort among a number of EPA organizational units with
differing areas of responsibility -
From an opposition standpoint, it may be argued that there are too
many unknowns regarding air quality analysis requirements of new air quality
management programs (e.g., prevention of significant deterioration). A
review of these would be speculative at this time and Phase 2 effort operating
in this fashion would not have as clearly defined bounds as one that focused
on AQMA planning only.
6.2.4. Summary
It may be said, in summary, that there are valid reasons for pursuing
each of the three courses of action discussed above. The decision-maker
must make a determination in the light of other policy and program considerations
which were beyond the scope of this preliminary feasibility study. Had the
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results of the surveys been clearcut in one direction or another the choice
would have been obvious. In the light of the lack of such definitive
results, it is only possible to present the alternatives along with the
reasons for pursuing one or the other in the interest of generating an
informed decision.
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APPENDIX A
Sample Questionnaires
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Argonne National Laboratory
Energy and Environmental Systems Division
Computerized Emission Projection and Allocation System
Feasibility Study
Preliminary EPA Regional Office Survey
Region States
AQMA Representative
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Discussion Agenda
1. Introduction
(a) Purpose of the Survey
Argonne National Laboratory and OAQPS are reviewing the feasibility
of computerizing techniques for projecting and allocating emissions
as required by 40 CFR 51 subpart D in air quality maintenance areas.
(b) Information Desired From this Call
A general evaluation from the R.O. perspective on the need for a
CEPA system. R.O.'s evaluation of the state and local agency need
for CEPA system. General ideas and comments on the type of system
that would be most useful. Possibilities for further discussion with
R. 0. and/or state and local agencies.
2. R. 0. Perspective
(a) Have the states requested assistance on emission projection and all-
ocation? How will the R. 0. assist: general guidance, conduct
growth and allocation analyses, run dispersion models, recommend
procedures and models, other?
(b) What tasks will be the most difficult? Would computerization aid in
these tasks?
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(c) Does the R.O. expect to be in the position of doing an AQM analysis
or verifying a state's analysis? Would a CEPA system be of help?
(d) Would a standardized CEPA system simplify the plan review process?
(e) Is the R.O. requiring special types of analyses in addition to the
FR notice? Has any decision been made with regard to the required
level of analysis detail (i.e. Level 1, 2, 3 in Vol. 7, Order 1, 2,
3 in Vol. 13)?
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3. State Needs
(a) What directions are the states pursuing with regard to the AQMA
analysis (including task schedule):
ot t Emission Subcounty Air Quality General Opinion
Projections Allocations Analysis of Capability
A - Has asked for federal assistance
B - Plans to do analysis in-house
C - Has initiated in-house analysis
D - Has completed in-house analysis
E - Plans to contract activity
F - Has initiated contract
G - Has conpleted contract
H Agency has sufficient depth to conduct analysis
I Agency will require assistance and/or positions
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(b) What states could benefit from a CEPA system if it is available
March 1977, September 1977, December 1977. What states would have
no use for such a system?
(c) Have any states developed all or part of such a system?
4. General Comments
(a) General Comments on the need for a CEPA system.
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(b) Graranents on the type of system that would be most useful,
(c) Would you encourage the use of a CEPA system?
5. Further Discussion
(a) Is a more detailed discussion and visit worthwhile?
(b) Agencies that would be good to talk to. Can a meeting be arranged?
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Argonne National Laboratory
Energy and Environmental Systems Division
Argonne, Illinois 60439
COMPUTERIZED EMISSION PROJECTION AND ALLOCATION SYSTEM
FEASIBILITY STUDY
conducted for
Control Programs Development Division
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
Agency
Representative
Position
1. Introduction
EPA is considering the development of computerized aids to perform the
emission projection and allocation calculations necessary for AOMA Analysis.
Argonne National Laboratory is assisting by conducting a feasibility study of
the computerized approach and its potential benefits, if any, to state and local
air pollution control and planning agencies. Your response to our feasibility
survey would be appreciated to help determine if development of computerized aids
should be undertaken. Please answer the questions to the best of your know-
ledge. It is recognized that in most cases your response will be a "best guess"
since many states have not formalized their AQMA approach.
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2. Extent of Attainment/Maintenance Problem
These questions are designed to determine when various tasks associated
with the analysis will be performed and how they will be done.
Projections Allocations Modeling
AQMA Poll Sched Proced Sched Proced. Sched Proced Special Problems
Sched: Time schedule for initiating and completing task, e.g., 8/76 4/77
Proced: Procedure by which the task will be carried out, e.g., manual, CAASE etc.
I - will do task in-house
C - will have contractor do task
F - asked for federal assistance
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3. Resources
These questions are designed to identify computer resources available.
(a) What type of computer capability is available? is this shared with
T , „ , . other agencies?
In-house Machine
, Batch Processing
Tune-sharing Core Size
Interactive
Contractor
(b) What types of computer languages are used regularly?
FORTRAN APL SPEAKEASY
PL1 COBOL BASIC
ALGOL Assembly Lang. Other
(c) How many computer personnel are on your staff? Available to your staff?
Operators Programmers
Computer Systems Analysts Modeling Staff
Other Knowledgable Staff
(d) What resources have been allocated to the AQMA analysis? Last year, this
year.
Manpower Money
Computer Time
(e) Do you feel your computer staff is adequate to operate a large computerized
system and/or dispersion model?
(f) What are typical AQDM/CIM run parameters?
Turnaround Sources Receptors
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4. Experience
The following questions are designed to determine previous experience.
(a) What type of dispersion models do you have experience with? What applications?
Previously AQMP
Rollback
IPP
AQDM/CDM
HIWAY
PTMAX
Box Model
Other
(b) Have any computerized emission projection and allocation analysis routines
been used (been planned for use) in the current AQMP process?
CAASE REPS Other
AQUIP FAQM
What is your evaluation of the systems you have used?
(c) Has (will) the emission projection and allocation analysis been done
manually? What areas presented (may present) the most difficulty?
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(d) Is the emission inventory in NEDS-compatable format? Do you plan to use
NEDS and SAROAD as prime data sources? If not, what are the alternatives?
5. CEPA System Design
(a) Based on your experience, do you feel there is a need for the computeriza-
tion of all or part of the emission projections and allocations? What
parts, if any? What levels of detail?
(b) Should the system be an integrated package or a set of modular units?
(c) Should the system be designed for principle use on a centralized computer
or should it be designed for widespread distribution?
(d) What language should be used?
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(e) Should the system be interactive, batch, or a combination?
(f) What data sets would the system have to interface with in your state?
What form are they in?
(g) What special features would you like to see the system have (e.g., strategy-
package t emission factors from AP-42, cross checking, etc.}?
6. Agency Use
(a) If a CEPA system were available would your agency commit the resources to
operate it? require your contractor to use it? At what level would you
commit resources to it? Contract it out?
(b) Would your agency use it if it were available in January 1977, March 1977,
June 1977, September 1977, January 1978? Would you anticipate using it
in the 5-year update?
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(c) Could you envision any utility of the system for non-AQMA. related work?
7. Priorities
Please order activities you feel would best aid your agency in long
tern air quality analysis (place number next to task, i.e., 1 = most needed).
Development of a standardized growth model to estimate projected
emissions.
Development of an allocation model using projected estimates..
Additional aids for air quality analysis (e.g., dispersion models)
Additional training seminars on air quality analysis.
Additional positions for air quality analysis.
Federal assistance in doing state growth, allocation and air quality
analysis.
Special problems (specify).
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REFERENCES
"Guidelines for Air Quality Maintenance Planning and Analysis, Volume 1:
Designation of Air Quality Maintenance Areas." Report No. EPA-450/4-74-001.
U.S. Environmental Protection Agency, Research Triangle Park, N. C. 27711.
" , Volume 2: Plan Preparation." Report No. EPA-450/4-74-002.
USEPA, RTP, N.C. 27711. July 1974.
" , Volume 3: Control Strategies." Report No. EPA-450/4-74-003.
USEPA, RTP, N.C. 27711. July 1974.
' , Volume 4: Land Use and Transportation Considerations."
Report No. EPA-450/4-74-004. USEPA, RTP, N.C. 27711. August 1974.
1 , Volume 5: Case Studies in Plan Development." Report No.
EPA-450/4-74-006. USEPA, RTP, N.C. 27711. December 1974.
' , Volume 6: Overview of Air Quality Maintenance Area Analysis,
Report No. EPA-450/4-74-007. USEPA, RTP, N.C. 27711. September 1974.
, Volume 7: Projecting County Emissions, Second Edition."
Report No. EPA-450/4-74-008. USEPA, RTP, N.C. 27711. January 1975.
1 , Volume 8: Computer-Assisted Area Source Emissions Gridding
Procedure." Report No. EPA-450/4-74-009. USEPA, RTP, N.C. 27711.
September, 1974.
' , Volume 9: Evaluating Indirect Sources." Report No. EPA-450/
4-75-010. USEPA, RTP, N.C. 27711. January 1975.
10. " , Volume 10: Reviewing New Stationary Sources." Report No.
EPA-450/4-74-011. USEPA, RTP, N.C. 27711. September 1974.
11. " , Volume 11: Air Quality Monitoring and Data Analysis."
Report No. EPA-450/4-74-012. USEPA, RTP, N.C. 27711. September 1974.
12. " , Volume 12: Applying Atmospheric Simulation Models to Air
Quality Maintenance Areas." Report No. EPA-450/4-74-013. USEPA, RTP,
N.C. 27711. September 1974.
13. " , Volume 13: Allocating Projected Emissions to Subcounty
Areas" (with Appendices A and B). Report No. EPA-450/4-74-014.
USEPA, RTP, N.C. 27711. November 1974.
l->. "Maintenance of National Ambient Air Quality Standards." Title 40,
Code of Federal Regulation, Part 51. 41FR18382, May 3, 1976.
15. "Maintenance of National Ambient Air Quality Standards", Federal
Register. 41 FR 27864 July 7; 41 FR 27999 July 8; 41 FR 28600 July 12;
-1 FR 29478 July 16; and 41 FR 32302 August 2, 1976.
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16. "Code of Federal Regulations", 40CFR, Part 51.7.
17. "Automatic Data Processing Manual", U.S. Environmental Protection
Agency, Washington, D.C. March 31, 1975.
18. "Major Systems Acquisition". Office of Management and Budget.
Circular A-109. April 5, 1976.
19. "ADP Management Information System". General Services Administration,
Office of Federal Management Policy. Federal Management Circular
FMC 74-2. February 25, 1974.
20. "Policies for Acquiring Commercial or Industrial Products and Services
for Government Use". Bureau of the Budget. Circular A-76. August 30, 1967
21. "Code of Federal Regulations", 41CFR Part 101-32.
22. "A Program for the Phased Development of a Computer Model to Evaluate the
Effect of Land Use Planning on the Air Quality in Fairfax County, Virginia".
Engineering Science Inc. To be published.
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing}
1. REPORT NO.
EPA 450/3-77-001
2.
3. RECIPIENT'S ACCESSIOI^NO.
4. TITLE AND SUBTITLE
Development of Computerized Emission Projection
and Allocation System—Phase I: Preliminary
Feasibility Study
5. REPORT DATE
December 1976
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
Richard R. Cirillo and Michael J. Senew
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Energy Research and Development Administration
Argonne National Laboratory
Energy and Environmental Systems Division
9700 South Cass Ave., Argonne, IL 60439
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
Interagency Agreement No.
D6-0077
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning & Standards
Research Triangle Park, NC 27711
13. TYPE OF REPORT AND PERIOD COVERED
F1naT
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
Another report may follow if decision is made to continue study on the CEPA system.
Phase 2 would cover a comparison of alternative systems.
16. ABSTRACT
This report describes a preliminary feasibility assessment to determine the
need for a computerized emission projection and allocation (CEPA) system. The pri*
mary application of a CEPA system would be the computerization of otherwise long and
tedious calculations required to properly assess growth and development when con-
sidering the maintenance of the national ambient air quality standards. A major
portion of the assessment came from interviews with nine potential users of a^CEPA
system—seven air pollution control agencies and two local and regional planning
organizations. The study concludes that although a CEPA system would be beneficial
if properly designed, the major constraint facing its use is the fact that the
schedule for completion of air quality maintenance plans would not permit many
States to wait until the development of a CEPA system. The report, however, iden-
tifies uses of the system other than the current effort of air quality maintenance
plan development.
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Air Pollution
Atmosphere Contamination Control
Regional Planning
National Ambient Air
Quality Standards
Air Quality Maintenance
Analysis
Air Quality Maintenance
Plan
13-B
8. DISTRIBUTION STATEMENT
Release unlimited
19. SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
102
20. SECURITY CLASS (This page)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
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