A





        TECHNICAL SUPPORT DOCUMENT






                     FOR





           PHOTOCHEMICAL OXIDANTS
               September 1978









              PREPARED BY THE





OFFICE OF AIR QUALITY PLANNING AND STANDARDS





   STRATEGIES AND AIR STANDARDS DIVISION

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    1     UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                    Office of Air Quality Planning and Standards
                    Research Triangle Park, North Carolina 27711
Mr. Harry H. Hovey
Chairman, STAPPA
Director, Air Pollution Control Board
New York State Dept. of Environmental
  Conservation
50 Wolf Road
Albany, NY   12223

Dear Mr. Hovey:

     During recent months, we have received requests from State and
Local Air Pollution Control Agencies, and from our Regional Offices
concerning the need to develop information documents on photochemical
oxidant.  In responding to this need, two projects have been undertaken
after discussions with Tony Cortese of STAPPA.  These documents represent
compromises between what was desired by STAPPA and the time and resources
available to me.  I hope that they will be helpful.

     The first one, accomplished under contract to the Stanford Research
Institute, was the preparation of a short document written in non-
technical language directed to mayors, councilmen, informed laymen, and
others in the local public decision making process.  The main theme of
the document is to advise this target group that ozone is a significant
air pollution problem in nearly all U.S. cities and that SIPs having a
sound technical basis are needed to resolve the problem. A draft of this
public information document has been provided as reference VII1-3.  The
final copy will be distributed soon.

     The output of the second project is included with this letter.  It
is a SIP technical support document intended to assist State and local
agencies in responding to a variety of issues related to oxidants.  It
is also intended to assist agencies in developing SIP revisions.  The
document is a compilation of policy papers, technical studies, procedural
guidelines, and other materials related to photochemical oxidant.

     Pertinent documents have been organized into eight major areas as
follows:

     1.  SIP Requirements               5.  Modeling
     2.  Transportation Controls        6.  Control Technique Guidelines
     3.  Inspection/Maintenance         7.  Costs
     4.  Emission Inventories           8.  Health Effects and Public  Information

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     The document contains three parts.  Part I is a listing of the most
relevant policy statements, technical studies, and other support documents;
Part II is a brief description of the information listed in Part I; and
Part III contains copies of selected references.

     The references cited are generally available from the National
Technical Information Service, Government Printing Office, EPA Regional
Offices or from the Headquarters program offices responsible for trie
specific work cited.  In cases where a reference is not available from
the normal sources, you are invited to contact Joseph Sableski, Control
Programs Development Division, Office of Air Quality Planning and
Standards, FTS 629-5437 or commercial  (919) 541-5437 for assistance.
                                   Sincerely yours.
                                   Walter  C. Barber
                                        Director
                               Office  of Air Quality Planning
                                        and Standards

 Enclosure

 cc:   Directors, Air and Hazardous Materials Division,  Region  I,  III-X
      Director, Environmental  Programs Division,  Region II
      All  State Air Pollution  Control  Agencies
      All  Local Air Pollution  Control  Agencies

 Identical Letter sent to:     Mr. Kenneth MacKenzie
                               Chairman, ALAPCO
                               Houston Dept. of Pollution
                               1115 N. MacGregor
                               Houston, TX   77025

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      PART I
    LISTING OF


POLICY STATEMENTS

TECHNICAL STUDIES

        &

 OTHER SUPPORT
   DOCUMENTS

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Section I - SIP Requirements

  1.  Criteria for Proposing Approval of Revision to Plans for
      Non-Attainment Areas; Federal Register Vol. 43, No.  98,
      May 19, 1978.

  2.  Workshop on Requirements for Non-Attainment Area Plans
       (Revised Edition), April 1978.

  3.  Attainment Designation List Required by the 1977 Clean Air Act
      Amendments, September 28, 1977.

  4.  Questions and Answers on 1979 SIP Revisions.  Memo from
      G. T. Helms to the Regional Air Branch Chiefs, July 28, 1978.

  5.  Final Guidelines for Section 174:  Guidance on Designation of
      Lead Planning Organizations for Non-Attainment Areas and on
      Determination of Agency Responsibilities, Hawkins, December 14,
      1977.

  6.  Questions and Answers in 1979 SIP Revisions from G.T. Helms to the
      Regional Office Air Branch Chiefs, September 8, 1978.

  7.  Continuity of SIP  Regulations.  Memorandum from David Hawkins to
      the Regional Administrator, September 11, 1978

 Section  II -  Transportation Controls

  1.  Transportation Air Quality Planning Guidelines, June 1978.

  2.  Memorandum of Understanding  Between the Department of Transporta-
       tion and the Environmental Protection Agency regarding the  .
       Integrating  of Transportation Air Quality Planning, June 14, 1978.

  3.  Air Quality  Impacts  of Transit  Improvements, Preferential Lane,
       and Carpool/Vanpool  Programs -  Contract Report, EPA 400/2-78-002a,
       March  1978.

  4.   Transit Improvement,  Preferential Lane, and Carpool Programs (An
       annotated Bibliography of  Demonstration and Analytical Experi-
       ence).  - Contract  Report EPA 400/2-78-002b, March 1978.

 Section  III  - Inspection Maintenance

   1.   Inspection/Maintenance Policy  - Memorandum from David  Hawkins
       to the EPA  Regional  Administrators, July  17,  1978.

   2.   Information  Document on  Automobile  Emissions  Inspection  and
       Maintenance  Programs.  GCA Corporation,  EPA 400/2-78-001,
       February 1978.

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Section IV - Emission Inventories

  1.  Procedures for the Preparation of Emission Inventories for
      Volatile Organic Compounds, Volume I, EPA-450/2-77-028,
      December 1977.

  2.  Mobile Source Emission Factors, EPA 400/9-78-005, March 1978.

Section V - Modeling

  1.  Procedures for Quantifying Relationships Between Photochemical
      Oxidants and Precursors:  Supporting Documentation, EPA-450/
      2-77-021b, February 1978.

  2.  Uses, Limitations, and Technical Basis of Procedures for
      Quantifying Relationships Between Photochemical  Oxidants and
      Precursors, EPA-450/2-77-021a, November 1977.

  3.  Question and Answers on Relationship Between Hydrocarbons and
      Photochemical Oxidants, OAQPS, MDAD, September 1978

Section VI - Control Technique Guidelines

  1.  Development of Regulations for HC RACT from CTG's, Memorandum
      from Walter Barber, April 28, 1978.

  2.  Regulatory Guidance for Control of Volatile Organic Compound
      Emissions from 15 Categories of Stationary Sources, 6CA Corpora-
      tion, Contract No. 68-02-2887, April 1978.

  3.  Control Techniques for Volatile Organic Emission from Stationary
      Sources.  EPA Final Report, Radian Contract 68-02-2608, Tasks
      12 and 23, February 1978.

  4.  Stationary Sources of Volatile Organic Compounds and Schedule
      for Applicable Control Technique Guidelines, OAQPS, ESED,
      July 10, 1978.

  5.  Control Techniques Document from Hydrocarbon Sources, see listing
      dated 7-14-78 in Part III.

  6.  Recommended Policy on Control of Volatile Organic Compounds,
      Federal Register, Vol. 42, No. 131, July 8, 1977.

  7.  Seasonal Operation of Natural Gas-Fired Afterburners, Memo from
      Roger Strelow to the Regional Administrators,  July 28, 1976.

  8.  Vapor Recovery Regulations Required to Meet RACT Requirement
      for the 1979 SIP, June 30, 1978.

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Section VI (Con't)
  9.  Hydrocarbon Control Strategies for Gasoline Marketing Operations,
      EPA 450/3-78-017, April 1978.
 10.  Clarification of EPA Policy on Emissions of Methyl  Chloroform.
      Memorandum from Walter Barber to the Regional  Administrator,
      August 17, 1978.
Section VII - Costs
  1.  Cost and Economic Impact Assessment for Alternative Levels  of
      the National Ambient Air Quality Standards  for Ozone, OAQPS,
      June 1978.
Section VIII - Health Effects and Public Information
  1.  The Health Implications of Photochemical  Oxidant  Air Pollution
      to Your Community, EPA-450/2-76-016-1,  August  1976.
  2.  Summary Statements from EPA Advisory Panel  on  Health Effects of
      Photochemical Oxidants.  University of  North Carolina,  June 1978.
  3.  Ozone and Other Photochemical  Oxidants, SRI International,
      Contract Report EPA 68-02-2835, August  1978 (Draft  Final  Report.)
Section IX - Proposed Oxidant Standards
  1.  Photochemical Oxidants-Proposed Revisions to the  National Ambient
      Air Quality Standard, Federal  Register, Vol. 32,  No.  121,
      June 22, 1978.
  2.  Guideline for Interpretating Ozone Air  Quality Standards  (DRAFT),
      OAQPS 1.2-108 Guideline Series (Issued  June 1978).
  3.  Air Quality Criteria for Ozone and Other Photochemical  Oxidants,
      Vols. 1 & 2, EPA 600/8-78-004, April  1978.
  4.  The Use of Judgmental Probability Distribution in Setting NAAQS
      for Ozone—Final Report, SRI International  (Project 6780),
      May 1978.
  5.  Alternative Forms of the Ambient Air Quality Standard for
      Photochemical Oxidants, OAQPS, SASD,  May 1978.
  6.  Assessment of Welfare Effects  and the Secondary Standard  for
      Ozone, OAQPS, SASD, June 1978.
  7.  Environmental Impact Assessment of Control  Measure  Required
      for Attainment of the NAAQS for Ozone,  OAQPS,  SASD, June  1978.

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8.  Energy Impact Assessment for Alternative Levels of the NAAQS
     for Ozone, OAQPS,  SASD, June  1978.

9.  A Method for Assessing the Health  Risks Associated with Alter-
    native Air Quality Standards for Ozone, OAQPS, SASD, July  1978.

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    PART II


BRIEF DESCRIPTION

        OF

POLICY STATEMENTS

TECHNICAL STUDIES

         &

  OTHER SUPPORT
    DOCUMENTS

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SECTION I

I.  SIP REQUIREMENTS

     1.  Criteria for Proposing Approval of Revision to Plans for
          Non-Attainment Areas, Federal Register, Vol 43, No. 98, May 19,
          1978.  (Copy enclosed—Part III, Section X).

          This directive from the EPA Administrator summarizes the elements
          that must be included in State Implementation Plan revisions for
          areas that do not meet national ambient air quality standards.
          It established elements which a State Plan submittal must contain
          in order to be approved by EPA and was published as information
          for the public.

     2.  Workshop on Requirements for Non-Attainment Area Plans (Revised
          and Edited), April 1978.
                                                               ',

          EPA held a series of three two-day workshops to discuss require-
          ments of the Clearv Air Act Amendments of 1977 and specifically
          discuss the provisions of the Act Amendments pertaining to non-
          attainment areas.  The objective of the workshops was to outline
          the criteria for an acceptable 1979 plan.   The workshops focused
          on the major protions of an implementation plan revision and
          provided guidance on specific items that must be part of the plan.
          The workshops were not designed to cover all the details of
          preparation of a SIP revision such as how to estimate future
          emissions and how to model air pollution concentrations.

          The workshop held in Kansas City was videotaped.  Edited tapes
          of this workshop are available through the EPA Regional  Offices
          to further disseminate information concerning the requirements
          for the 1979 SIP revisions.

          The workshop report was designed to accompany the workshops and
          be used as an aid by both the participants and those interested
          in the subject matter.  The compilation contains visual  aids
          and textual material supporting the presentations.   The material
          is restricted to the requirements for the non-attainment area
          SIPs.

          The following subjects are addressed:

              Overview of Clean Air Act Requirements and Organization of
              Workshop

              Control Strategy and General  Plan Requirements

              Transportation-Related Issues

              Emission Inventory

              Emissions - Air Quality Relationships

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         Definition of RACT

         Public Participation  and  Intergovernmental  Consultation

         Reasonable Further Progress

         Procedural Requirements

         New Source Review

         Summary of Clean Air  Act  Amendments  of  1977

         Memorandum, "Criteria for Approval of 1979  SIP  Revisions"

3.   Attainment Designation List Required  by  the 1977  Clean Air Act
     Amendments, September 28, 1977 (Copy  enclosed,  Part III).

     The requirements for designating  areas as attainment,  non-attainment,
     or unclassified is contained  in a memorandum from David Hawkins.

4.   Questions and Answers in  1979 SIP Revisions, Memo from G.T. Helms,
     to the Regional Office Air Branch Chiefs, July  28,  1978 (Copy
     enclosed, Part III).

     A number of questions concerning  specific SIP requirements and
     policy implications on SIP decisions  are covered  in this memo-
     randum.  (Copy enclosed,  Part III).

5.   Final Guidelines for Section  174:  Guidance on  Designation of
     Lead Planning Organizations for Non-Attainment  Areas and on
     Determination of Agency Responsibilities, Hawkins,  December 14,  1977.
     (Copy enclosed, Part III)

6.   Questions and Answers on  1979 SIP Revisions from  G.T.  Helms to
     the Regional Office Branch Chiefs, September 8, 1978.   A number
     of questions	Guidance on  requirement for VOC  RACT  Regulations
     in all Oxidant Non-Attainment Areas is continued  in the memo
     from David Hawkins to the Regional Administrators August 4, 1978,
     (Copy enclosed, Part III)

7.   Continuity of SIP Regulations. Memorandum  from David  Hawkins  to
     the Regional Administrator, September 11, 1978.  Guidance  is
     provided on retaining existing regulations  and  minimize deterioration
     of air quality in non-attainment  areas,   (copy  enclosed, part  III)

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II.  TRANSPORTATION CONTROLS.

    1.  Transportation Air Quality Planninq Guideline, June 1978,
        (Copy enclosed, Part III).

        The guideline developed jointly by EPA and DOT addresses the
        following subject areas:

        The introduction (Chapter I) covers the following aspects of the
        guidelines:  (1)  Purpose, including the basic policy goal;
        (2)  Applicability, including the primary roles of the lead
        agency as well as DOT and EPA Regional Offices; (3) Funding —
        authorized (but not yet appropriated) and available funds; and
        (4)  Background, including the relationship of the guidelines
        to the original transportation control planning process and
        the existing process administered by DOT.

        Chapter II, SIP POLICY, summarizes and elaborates upon the
        transportation portions of a major EPA policy memorandum,
        "Criteria for Approval of 1979 SIP Revisions."  This memoran-
       . dum signed by the EPA Administrator on February 24, 1978, is
        wholly contained in Appendix B.  Chapter II also provides an
        abbreviated checklist of the major transportation-related
        requirements of an acceptable 1979 SIP.

        Chapter III, PROCESS, presents the procedural part of the
        guidelines by describing the elements of the integrated
        transportation-air quality planning process designed to
        accomplish the policy goal and SIP requirements of
        Chapters I and II.  Chapter III defines procedures for:  (1)
        Interagency Coordination, (2) Elected Official Involvement,
        (3)  Public Information and Consultation, and (4) Evaluation
        of Alternative Strategies.

        Chapter IV describes:  (1) modifications to ongoing transporta-
        tion planning activities required by the Clean Air Act and (2)
        documentation of those modifications.  Chapter IV discusses
        the Planning Work Programs, Transportation Plan, Transportation
        Improvement Program, Alternatives Analysis, Consistency Determi-
        nation and the SIP.

        Chapter V concludes the Guidelines with a discussion of the
        purpose, frequency, and content of progress reports.

        The Appendix contains a general summary and description of the
        provisions of the Clean Air Act that primarily concern or most
        directly affect the transporation-air quality planning process.

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                              8
    These  sections  include:
       --  1  108:   AIR  QUALITY  CRITERIA  AND  CONTROL  TECHNIQUES
            (5  108(e):   Planning  Process  Guidelines,  1  108(f):
            Information  Documents)

       --  1  110:   IMPLEMENTATION,  PLANS

       —  I  121:   CONSULTATION

       —  I  172:   NONATTAINMENT PLAN  PROVISIONS

       —  I  174:   PLANNING PROCEDURES

       —  1  175:   EPA  GRANTS

2.  Memorandum of Understanding Between the Department  of Transporta-
     tation  and the Environmental  Protection Agency regarding the
     Integrating of Transportation Air  Quality Planning,  June 1978
     (Copy enclosed, Part III).

     This  Memorandum of Understanding,  developed  pursuant to the
     President's request, is designed (1) to establish  certain
     principles which DOT and EPA agree to  follow in  the  preparation
     of more detailed regulations and administrative  procedures
     required to achieve the objective  of integrating the air quality
     and transportation planning  processes; (2)  to  identify specific
     areas of agreement with regard to  the  joint  administration of
     the air quality aspects of the planning process.

3.  Air Quality Impacts of Transit Improvements,  Preferential Lane,
     and Carpool/Vanpool Programs - Contract Report - EPA 400/2-
     78-002, March 1978.

     This report was prepared in  accordance with  Section  108(f) of
     the Clean Air Act, as amended, August  1977.   It  is intended to
     assist urban areas in developing transportation  measures for
     the State Implementation Plan and integrating  their  transportation
     system management and air quality planning  programs  as required by
     the Federal Highway Administration,  the Urban  Mass Transportation
     Administration and the Environmental Protection  Agency.

     The specific types of short-range transportation programs
     examined this report include:

       —  priority treatment for high occupancy  vehicles  on freeways
          and arterials;

       —  areawide carpool and vanpool  programs;  and

       --  transit fare reductions and service improvements.

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    Other transportation measures such as parking controls, traffic
    operations, and pricing are not covered in this project, but
    will be the subject of future EPA information reports.

    The report is intended to provide information to help urban
    areas covered by EPA's Transportation Planning Guidelines to:

      ~ assess the applicability and potential of the three classes
         of TSM programs described above for improving localised and
         regional air quality;

      -- estimate and evaluate the cost effectiveness of such programs
         and their related travel, energy consumption, cost, and
         economic impacts; and

      -- identify key factors, (e.g., meteorological  conditions,
         vehicle type distributions and vehicle operating speeds)
         likely to affect air quality and air pollution emissions.

4.  Transit Improvements, Preferential Lane, and Carpool  Programs
    (An annotated Bibliography of Demonstrations and  Analytical
    Experience)  Contract Report - EPA 400/2-78/002b, March 1978).

    The Environmental  Protection Agency is evaluating the use and
    cost effectiveness of alternative short-range transit fare and
    service improvement strategies, carpool  and vanpool  strategies,
    and strategies involving the preferential  treatment of high
    occupancy vehicles to improve air quality in urban areas.   The
    evaluation of individual  strategies and  combinations  of the
    above strategies includes their emission and air  quality impacts
    and their related  energy, noise, and economic impacts.   A compre-
    hensive literature review was also conducted, as  part of this
    evaluation, to identify both observed and  projected  travel,
    emission, air quality, energy, noise, and  economic impacts  of
    the short-range, low-cost strategies of  interest.

    This document presents an annotated bibliography  of useful
    reports,  papers, and  other references describing  the  above
    impacts for the  transit,  carpool,  vanpool,  and preferential
    treatment strategies  of interest.   The bibliography should
    be useful  to  elected  officials,  government  administrators
    and  their technical staffs,  and  citizens involved  in  the
    development of Transportation Control  Plans,  Transportation
    System  Management  Elements and related short-range planning
    activities.

    Abstracts  within this  bibliography are organized  under  five
    subject areas.   Each  area  is  described briefly below:

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                      10
- General.   Reports broadly addressing transportation
  system management, short-term transportation planning
  techniques, conference proceedings, and sources which
  treat several  of the strategies addressed in the project,
- Preferential  Treatment of High Occupancy Vehicles
  Descriptive,  simulation,  and case study material on
  reserved lanes,  priority  ramp facilities, and traffic
  signal  preemption for buses, carpools, and vanpools on
  urban freeways and arterial  facilities.

T Carpool and Vanpool  Programs.  Descriptive, case study,
  and simulation analyses on area-wide and employer-based
  carpool and/or vanpool programs.

•* Transit Fare and Service  Strategies. Studies addressing
  the impacts of transit fare reductions or restructuring,
  and of transit service improvements  on transit ridership
  and system performance.

•r Energy, Air Quality, Emissions,  and  Economic Impacts.
  Studies addressing the potential  positive and negative
  impacts of various transportation-related actions on energy
  consumption,  air quality, emissions, and the economy
  of urban areas.

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                                     11
III.  INSPECTION/MAINTENANCE
      1.  Inspection/Maintenance Policy - Memorandum from Dave Hawkins
          to the EPA Regional Administrator, July 17, 1978.

          This memorandum establishes what EPA will consider a minimally
          acceptable program whenever I/M is required.  It is designed
          to aid states in developing adequate I/M submissions for the
          SIP revisions due in January 1979, (copy enclosed).

      2.  Information Document on Automobile Emission Inspection and
          Maintenance Programs.  GCA Corporation, EPA 400/2-78^001
          February 1978.

          This document presents information on inspection/maintenance
          programs, a means of reducing vehicular emissions  which has
          been successfully adopted by several  states.  The  increased
          interest in this strategy has led to a need for an inspection/
          maintenance primer.  It is this need to which this report is
          addressed.

          The objectives or purposes of tnis compendium are  twofold.  First,
          it is to provide basic information on a number of  both the
          technical and nontechnical aspects of I/M and, second,  to do
          so in a manner which is virtually free of esoteric terms.  Such
          information was developed to be of use to both policy makers
          and interested citizens.

          The report is organized in to seven sections: Section 1 is
          an introduction to this report; SectiOn..2 discusses the purpose
          of inspection/maintenance programs and Section 3 presents the
          benefits which result from their implementation.  The various
          approaches to I/M programs are discussed in Section 4.   The
          implementation of I/M programs is presented in Section 5.
          Section 7 provides fact sheets on existing I/M programs.  A
          bibliography glossary are included as appendices to the report.

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                                    12
IV.   EMISSION INVENTORIES

     1.   Procedures  for  the  Preparation of Emission Inventories for
         Volatile  Organic  Compounds, Volume I, EPA-450/2-77-028,
         December  1977.

         This guide  is intended for general use by the air pollution
         community in planning and compiling inventories for use in oxidant
         control strategy  development.  Emphasis is placed on compiling
         organic emission  inventories; however, to some extent, planning
         considerations  and  procedures described are applicable to
         inventories in  general.

         This guide  is published in two volumes.  Volume I provides
         technical guidance  on compiling organic emission inventories
         on  an annual or seasonal basis at the county (or county
         equivalent) level.  Such inventories are considered adequate
         for use in  less data-intensive source/receptor relationships
         that are  based  on rollback or chemical kinetics considerations.
         Volume II provides  technical guidance on compiling organic
         emission  inventories at a more detailed level of temporal  and
         spatial resolution  than results from the techniques prescribed
         in  Volume I.  Methodologies are discussed for compiling daily
         and hourly  inventories, with emissions being allocated to
         suhcounty grids.   Volume  II  should be available  in  early  1979.

     2.   Mobile Source Emission Factors, EPA 400/9-78-005, March 1978.

         This  document revises previous mobile source emission factors
         contained in supplement No. 5 to AP-42, Compilation of Air
         Pollutant Emission  Factors (December 1975).  This document does
         not revise all  information in Supplement No.  5.  Updated factors
         are not included  for light-duty diesel automobiles, light-duty
         diesel tracks,  off-road source, or aircraft.   No information is
         included in participates.  The major areas addressed include:

         Part  I - For all Regions except California and High Altitude

             1.  Light-duty, Gasoline-powered vehicles (LDV)(Automobiles)

             2.  Gasoline-powered, light-duty trucks (LOT)

             3.  Heavy-duty, gasoline-powered vehicles (HDG)

             4.  Heavy-duty, Diesel-powered vehicles (HDD)

             5.  Motorcycles (MC)

         Part  II - Mobile Source Emission Factors for California

         Part  III - High-Altitude Regions

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                                   13


V.  MODELING

    1.  Procedures for Quantifying Relationships Between Photochemical
        Oxidants and Precursors:  Supporting Documentation, EPA-450/
        2-77-021b, February 1978.

        The purpose of this report is to amplify the information in
        Uses, Uimitations and Technical Basis of Procedures for
        Quantifying Relationships Between Photochemical Oxidants and
        Precursors,  EPA 450/2-77-021 a.  Several of the assertions
        are applicable only to the Empirical Kinetic Modeling Approach
        (EKMA) described at length in that document.  Others, such as
        the prevailing background concentration of ozone and the greater
        importance of transported ozone as opposed to transported
        precursors, have general significance in a number of different
        procedures for quantifying ozone-precursor relationships.
        Specifically, eight issues are addressed:

              1.  What levels of ambient ozone and precursors are
                 attributable to natural sources?

              2.  How significant are natural sources of ozone and
                 precursors likely to be in contributing to maximum
                 ozone concentrations observed within and downwind
                 or urban areas?

              3.  What are typical ratios of non-methane hydrocarbon
                  (NMHC) to oxices of nitrogen (NO ) in urban and
                 suburban areas?

              4.  How do ambient precursor concentrations vary, both
                 spatially and diurnally, in and near urban areas?

              5.   Is there any apparent difference in precursor levels
                 and NMHC/NO  ratios on days experiencing high ozone
                 concentrations as opposed to other days?

              6.  Can existing ambient data be used to draw inferences
                 about ozone gradients upwind and downwind of major cities?

              7.  What is the relative importance of transported ozone,
                 NMHC, NO  , N0?/N0   ratio and aldehydes in contributing
                 to a maximum ozone  concentrations observed in the vicinity
                 of urban areas?

              8.  How is the impact of transported ozone likely to be
                 affected by such factors as changes in locally generated
                 precursor levels, prevailing NMHC/NO  ratios, varying
                 diurnal emission patterns,  level of transported ozone
                 aloft, prevailing atmospheric  dilution rates, and
                  sunlight intensity?

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                               14
2.  Uses, Limitations and Technical  Basis of Procedures for
    Quantifying Relationships Between Photochemical  Oxidants and
    Precursors, EPA-450/2-77-021a, November 1977.

    This document describes the technical basis,  uses and limitations
    of several  approaches for relating photochemical  oxidant
    (expressed as ozone) to organic  compounds and  oxides of nitrogen.
    It is not intended as a statement of EPA policy  concerning which
    method to use in relating ozone  to precursors.   By reporting the
    nature and present status of various analytical  techniques,
    it is intended that the document will prove useful  to (1) estimate
    the amount of precursor controls needed to attain the National
    Ambient Air Quality Standard (NAAQS) for photochemical  oxidants
    (160yg/m3 hourly average concentration not to  be exceeded more
    than once per year), and (2) estimate the reduction in  ozone
    concentrations accompanying specified reductions in precursors.
    Some of the methods described also provide additional measures  of
    improvement in ambient air quality which may  accompany  precursor
    controls.  These additional capabilities are  identified where
    applicable.  (Note April  12, 1978 errata sheet).

3.  Questions and Answers in Relationships between Hydrocarbons and
    Photochemical Oxidants, OAQPS, MDAD, September 1978
    (Copy enclosed - Part III, Section IX)

    This series of questions and answers supports  the position that
    reducing hydrocarbon emissions reduces ambient ozone levels.
    This position is based on experimental and theoretical  studies
    that establishes a physical cause/effects relationship  between
    organic pollutants and ozone in  the precursors of oxides of
    nitrogen.  The questions and answers focus on  the control
    strategies of contracting organic emissions to reduce ambient
    levels of ozone.

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                                   15
VI.  CONTROL TECHNIQUE GUIDELINE

     1.   Development of Regulations for HC RACT from CTGs.  Memorandum
          from Walter Barber, April 28, 1978 (copy enclosed).  This
          memorandum stresses the need for flexibility and case-by-case
          determination in developing RACT regulations.

     2.   Regulatory Guidance for Control of Volatile Organic Compound
          Emissions from 15 Categories of Stationary Sources - GCA
          Corporation, Contract No. 68-02-2887, April 1978.  (DRAFT)

          This report provides guidance for regulation development in
          the form of sample regulations based heavily on guidelines for
          15 categories of stationary sources as well as existing Federal
          and State laws.  In addition, the report contains a compendium
          of existing regulations and test procedures.  The sample regu-
          lations set forth in regulatory format definitions, emission
          limitations, equipment standards, exemptions, compliance
          schedules and testing methods and procedures.  Ncte:  States
          are advised to consider economic impact in determining RACT
          requirements.

          The 15 stationary volatile organic compound source categories
          for which guidelines were available in January 1978 include:

               o  Surface Coating of Automobiles and Light-Duty Trucks
               o  Surface Coating of Cans
               o  Surface Coating of Metal Coils
               o  Surface Coating of Paper
               o  Surface Coating of Fabric Products
               o  Surface Coating of Metal Furniture
               o  Surface Coating of Large Appliances
               o  Surface Coating for Insulation of Magnet Wire
               o  Petroleum Liquids in Fixed-Roof Tanks
               o  Bulk Gasoline Plants
               o  Gasoline Loading Terminals
               o  Service Stations Stage I.
               o  Miscellaneous Refinery Sources
               o  Solvent Metal Cleaning
               o  Cutback Asphalt

     3.   Control Techniques for Volatile Organic Emissions from Stationary
          Sources.  EPA-Final Report, Radian Contract 68-02-2608,
          Task 12 & 23.

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                              16
     This is a revised and updated version of a March, 1970, EPA
     publication entitled, Control Techniques for Hydrocarbon and
     Organic Solvent Emissions from Stationary Sources (AP-68).
     It is intended primarily as a general reference for State and
     local air pollution control engineers.  It provides:

          1.  Basic information on sources of photochemical oxidant
               precursors and control of these sources,
          2.  Estimates of control costs,
          3.  Estimates of control technique energy requirements,
               and
          4.  Estimates of emission reductions achievable through
               control application,

     The cost curves presented in the text are the result of
     averaging costs for differing industrial applications.  The
     costs derived from these curves are rough estimates.  Actual
     costs for a particular installation may vary.

     The control techniques described in this document present a
     spectrum of information from many technical fields.   The
     devices, methods, and prinicples have been developed and used
     over many years and are constantly being revised and improved.
     They are recommended as the techniques generally available, control
     hydrocarbon and organic solvent emissions.  Because of the
     general nature of the document, it is not intended to be used
     as the basis for developing or enforcing regulations.

4.   Stationary Sources of Volatile Organic Compounds and Schedule
     for Applicable Control Technique Guidelines, OAOPS, ESED,
     July 10, 1978.  (Copy enclosed.)

     A schedule of the issuance of the control technique guidelines
     for volatile organic compounds has been established by OAQPS.

5.   RACT Documents - A number of control technique documents have
     been published and are listed in the reference section.(Part  III)

6.   Recommended Policy on Control of Volatile Organic Compounds,
     Federal  Register. Vol. 42, No. 131, July 8, 1977.  (copy enclosed).

     The purpose of this notice is to recommend a policy for States
     to follow on the control  of volatile organic compounds (VOC),
     which are a constituent in the formation of photochemical
     oxidants (smog).   This notice does not place any requirements
     on States; State Implementation Plan (SIP) provisions which
     offer reasonable alternatives to this policy will be approvable.
     However, this policy will be followed by EPA whenever it is
     required to draft State Implementation Plans for the control
     of photochemical  oxidants.

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                               17
 7.    Seasonal  Operations of Natural  Gas Fired Afterburners,  Memo
      from Roger Strelow to the Regional Administrators,  July 28, 1976.
      (copy enclosed)

 8.    Vapor Recovery Regulations Required to meet RACT Requirement
      for the 1979 SIP, June 30, 1978 (copy enclosed).  This  memorandum
      provided guidance on how much regulations can  vary  from RACT
      requirements and still be acceptable to EPA.

 9.    Hydrocarbon Control Strategies  for Gasoline Marketing Operations,
      EPA 450/3-78-017, April 1978.

      This document provides basic and current descriptions of
      gasoline marketing operations and methods that are  available
      to control hydrocarbon emissions from these operations.   The three
      types of facilities that are described are terminals, bulk  plants,
      and service stations.  Operational and business trends  are  also
      discussed.  Emissions from typical facilities, including transport
      trucks, are estimated.

           The operations which lead  to emissions from these  facilities
      include (1) gasoline storage, (2) gasoline loading  at terminal
      and bulk plants, (3) gasoline delivery to bulk plants and ser-
      vice stations, and (4) the refueling of vehicles at service
      stations.

           Available and possible methods for controlling emissions are
      described with their estimated  control efficiencies and costs.
      The costs for control of a unit weight of hydrocarbon are
      calculated from these estimates.

10.    Clarification of EPA Policy on  Emissions of Methyl  Chloroform.
      Memorandum from Walter Barber to the Regional  Administrator,
      August 17, 1978.  Guidance is provided on the  preparation of
      SIP regulatory packages regarding the exemption of  methyl
      chloroform for control and wide scale substitution.

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                                    18


VII.  COST

          Cost and Economic Impact Assessment for Alternative Levels
          of the National Ambient Air Quality Standards for Ozone -
          OAQPS, June 1978.

          This report includes an analysis of 90 Air Quality Control
          Regions CAO^CRs) which currently exhibit ambient ozone
          concentrations in excess of the current photochemical  oxidant
          standard (-08 ppm hourly average not to be exceeded more than
          once per year).  For each AQCR this analysis estimates potential
          emissions in 1987 and potential  emission reductions achievable
          with the Federal Motor Vehicle Control  Program (FMVCP), new
          and modified source control, application of reasonably available
          control technology (RACT) on existing stationary sources and
          further motor vehicle controls through transportation control
          plans.  Based on the projected emission reductions, control
          costs are estimated for applying technology in an attempt to
          attain alternative standard levels.   While the analysis considers
          each AQCR separately, the results are presented in aggregate
          form for all 90 AQCRs instead of each individual  AQCR.

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                                     19
VIII.  HEALTH EFFECTS

       1.  The Health Implications of Photochemical Oxidant Air Pollution
           to Your Community  - EPA-450/2-76-016-1, August 1976.

           This document explains in laymans1 language the basic health
           effect of photochemical oxidants.  Its purpose is to convey
           this information to local public decision makers and to
           others with non-technical backgrounds.

       2.  Summary Statements from the EPA Advisory Panel on Health
           Effects of Photochemical Oxidants. University of North
           Carolina, June 1978.

           The Advisory Panel on Health Effects of Photochemical Oxidants
           N.C. on June 7th and 8th, 1977.

           The purpose of the panel discussions was to interpret the
           current state of knowledge on health effects of ozone and
           other photochemical substances, with the objective of develop-
           ing a guideline to the Environmental Protection Agency (EPA)
           for the protection of public health.  These discussions were
           prompted by EPA's current program for review and re-assessment
           of the existing air quality standard for photochemical oxidants.

           The panel reviewed studies relating to the following categories
           of health effects:

                A.  Human studies

                    1.  Mechanical function of the lung (controlled human
                        exposures)
                    2.  Asthma and lung function in children
                    3.  Athletic performance
                    4.  Other effects:  mortality, occupational hazards

                B.  Toxicological studies

                    1.  Experimental infection of animals
                 -  2.  Morphological abnormalities of the respiratory system
                    3.  Biochemical effects
                    4.  Mutagenic and teratogenic  potential
                    5.  Performance and behavioral effects

           In its discussions, the Panel considered several issues bearing
           on the overall interpretation of  reported studies.   Among  the
           major issues were:  relative weights to be given to  published
           and unpublished reports, concept  of threshold concentrations
           for effects, human health significance  of toxicological data,
           chemical specificity of the air quality standard  ("ozone,"
           'bxidants," "photo-chemical substances") margins of  safety, and
           the health significance of exceeding a  stated concentration one

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                             20
    or more times.  Conclusions and recommended guidelines for
    the protecting public health are contained in this report.

3.  Ozone and other Photochemical  Oxidants,  SRI Contract Report,
    EPA 68-02-2835, (Draft) August 1978,  (copy enclosed).

    This report is addressed to the local  decision makers  and other
    interested persons with an understanding for informal  decisions
    real ted to oxidant pollution and its  control.  The report covers
    the following aspects of oxidants;

         1.  Definition,  Effects,  and Standards
         2.  The Ozone Problem
         3.  Ozone and the Law
         4.  Approaches to Control

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                                   21
IX.   PROPOSED OZONE STANDARD

     1.   Photochemical Oxidants - Proposed revisions to the National
         Ambient Air Quality Standard - Federal Register, Vol.  32, No.  121,
         June 22, 1978.

         In accordance with the provisions of Sections 108 and 109 of the
         Clean Air Act as amended, EPA conducted a review of the criteria
         upon which the existing primary and secondary photochemical
         oxidant standards was based.  The revised criteria was published
         simultaneously with the issuance of this proposed rulemaking.
         The existing primary and secondary standards for photochemical
         oxidants is currently set at 0.08 ppm, 1-hour average not to be
         exceeded more than once per year.  As a result of the review and
         revision of health and welfare criteria, EPA proposes to raise
         the primary standard level to 0,10 ppm, 1-hour average,   EPA
         also proposes that the secondary welfare^based standard remain
         at 0.08 ppm, 1-hour average.  Other changes proposed in the  rule-
         making included:  (1) changing the chemical designation of the
         standard from photochemical oxidants to ozone, and (2) changing
         to a standard with a statistical rather than deterministic form,
         i.e., allowable exceedances will be stated as an expected value,
         not an explicit value,

     2.   Guideline for Interpretating Ozone Air Quality Standards (DRAFT),
         OAQPS 1.2-108 Guidelines Series.

         The purpose of this document is to amplify discussions dealing
         with compliance assessment and to indicate the data analysis
         procedures necessary to determine appropriate design values  for
         use in developing control strategies.  Where possible, the
         approaches discussed are conceptually similar to the procedures
         presented in the earlier "Guideline for Interpreting Air Quality
         Data with Respect to the Standards" (OAQPS l.a-008, revised
         February 1977).  However, the form of the proposed standards
         necessitates certain modifications in two general  areas:
         (1) accounting for less than complete sampling and (2) incor-
         porating data from more than one year.

         The following subjects are addressed:

             ASSESSING COMPLIANCE

             Interpretation of "Expected Number"
             Estimating Exceedances for a Year
             Extension to Multiple Years
             Examples Calculation

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                             22
3.  Air Quality Criteria for Ozone and Other Photochemical  Oxidants,
    Vols. 1 & 2, EPA 600/8-78-004, April  1978.

    This two-volume report summarizes current data on effects on man,
    vegetation, and ecosystems of oxidant/ozone in the ambient air.
    The effects that have been observed will  form the scientific
    basis for supporting the present National  Ambient Air Quality
    Standard of 160 yg/m3 (0.08 ppm) or a revised standard.

                         VOLUME I

    Nature and Atmospheric Concentration  of Photochemical Oxidants
    Sources and Sinks of Oxidants
    Oxidant Precursors
    Relationships between Ambient Oxidant and Precursor Emissions
    Measurement Methods for Oxidant and Oxidant Precursors
    Health Effects of Ozone and Other Photochemical  Oxidants
    Effects of Photochemical Oxidants on  Vegetation and Certain
      Microorganisms
    Effects of Photochemical Oxidants on  Ecosystems
    Effects of Photochemical Oxidants on  Materials

                         Volume II

    Clinical Appraisal of the Effects of  Oxidants

      • Occupational and Accidental Exposure to Ozone
      • Controlled Studies of Human Health Effects

    Epidemiological Appraisal of Photochemical  Oxidants
    Effects of Photochemical Oxidants on  Vegetation and Certain'
      Microorganisms
    Ecosystems
    Effects of Ozone on Materials

4.  The Use of Judgmental Probability Distribution in Setting NAAQS
    for Ozone—Final Report, SRI International  (Project 6780),
    May 1978.

    This report presents a discussion of  the concept of judgmental
    probability, its past use (especially by government agencies),
    its proper role in decision-making, and a brief description of
    an accepted method of encoding a probability distribution.
    This paper is being prepared in support of the document A Method
    for Assessing the Health Risks Associated with Alternative
    Air Quality Standards for Photochemical Oxidants. EPA (1978).
    The assessment of probabilities from  health experts is one part
    of the method.

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                              23
    The report is divided into three sections.   The first section
    defines judgmental probability and shows how it has been used
    in both the public and private sectors.   The relationship of
    probability encoding to the other aspects of the discipline of
    decision analysis is also covered.

    The second section describes a procedure that has been developed
    for the assessment of probability, and shows how this procedure
    counteracts the effects of possible biases  that may influence
    the result of some assessment techniques.

    The third section discusses the question of validation of
    assessments.

5.  Alternative Forms of the Ambient Air Quality Standard for
    Photochemical Oxidants, OAQPS, SASD, May 1978.

    The current standard can lead to inconsistent treatment from
    one AQCR to the next in deciding both compliance and degree of
    emission control required.  While health and welfare effects
    are the primary considerations in choosing  the  most appropriate
    form of the standard it is also important that  the form provide
    an adequate and clear basis for defining the overall  quality
    of ambient air it is desired to achieve.

    In the report it is suggested that the form should be designed
    to;  (1) adequately define  what must be measured to determine
    compliance and measurements which can be made with the needed
    accuracy; (2) provide clear, unambiguous criteria for determining
    whether an area is or is not in compliance; and (3) provide a
    clear, unambiguous definition of the air quality it is desired
    to achieve to serve as a target for the development and verifi-
    cation of control strategies.

    In this report the form of the standard is  examined from this
    point of view and provides a basis for examining the impact of
    health and welfare effects on the form.

6.  Assessment of Welfare Effects and the Secondary Standard for
    Ozone, OAQPS, SASD, June 1978.

    The Clean Air Act mandates the setting of a national  secondary
    ambient air quality standard to protect the public welfare from
    any known or anticipated adverse effects associated with the
    presence of an air pollutant in the ambient air.  Ozone and
    other photochemical oxidants constitute a form  of air pollution
    that affects vegetation and materials.  The resultant economic
    loss has been estimated to be in the range of several hundred
    million dollars per year nationwide.  Non-quantifiable losses
    to the natural environment occur as well,  Major areas covered
    by the report include:

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                              24


    Effects of Ozone and Other Photochemical  Oxidants

      Vegetation Damage

       Monitoring Methods and Data Reliability
       Foliar Injury
       Growth and Yield Effects
       Pollutant Interactions and Ambient Exposures
       Economic Assessment
       Effects on the Natural Environment

      Materials Damage

    Air Quality Issues

      Sources and Concentrations  of Oxidants  in Ambient Air

       Sources
       Urban Oxidant/Ozone Levels
       Rural Ozone Levels
       Natural Background Levels
       Levels of Non~0zone Oxidants

7.  Environmental Impact Assessment of Control  Measure Required
    for Attainment of the NAAQS for Ozone,  OAQPS,  SASD, June 1978.

    A review of the National  Ambient Air Quality Standard (NAAQS)
    for photochemical oxidants has recently been concluded and the
    Air Quality Criteria for Ozone and Other  Photochemical Oxidants
    and ControVTechnqiues for Hydrocarbons and Volatile Organic
    Compounds have been reissued.The criteria document has been
    revised to incorporate new information about the health and
    welfare effects on oxidants.   The control  techniques documents
    presents available control technology based on experience and
    new developments since the previous publications.

    The purpose of this assessment is to review the information
    presented in the control  techniques document and to present an
    analysis tff the environmental impact of control measures required
    for attainment of the air quality standard for ozone.

8,  Energy Impact Assessment for  Alternative  Levels of the NAAQS
    for Ozone, OAQPS, SASD, June  1978.

    Energy requirements for the selected control strategy depend
    upon the rate of emissions, the concentration of the effluent
    stream, and the specific arrangement of equipment and process.
    For some industries, substitution of water-based materials
    for photochemically reactive  materials or process changes that
    reduce or eliminate vapor emissions prove to be the least
    cost strategy.  Process changes may also  include measures such
    as good housekeeping practices and electrostatic sprays to

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                             25
    reduce or eliminate solvent emissions.   Recently completed studies
    on energy impacts associated with asphalt paving, gasoline
    markering, automobile and light duty truck body painting
    operations, and petroleum refining formed the principal  data
    base on energy impacts used in this study.

9,   A Method for Assessing the Health Risks Associated with  Alter-
    native Air Quality Standards for Ozone, OAQPS, SASD,  July 1978.

    The National Academy of Sciences recommended that EPA make use
    of some of the principles and techniques developed in the
    discipline of decision analysis which are helpful to  rational
    decision-making under uncertainty.  The method discussed in
    this report incorporates some of these principles and techniques.
    For example, the technique of "probability encoding", which enables
    optimal use of the quantitative judgments of health experts,
    plays an important role.  The decision analysis principle of
    reducing complex judgments to smaller,  more manageable sub-
    judgments whose logical implications can be determined
    mathematically is employed.  Subjects addressed in this  report
    include the following:

    Underlying Principles of the Metohd

      Risk and Margins of Safety

       Legislative Guidance
       Health Effect Threshold
       Idealized Risk Surfaces
       "Risk" Nomenclature
       Basic Model

    Undertainty Concerning Health Effect Threshold Concentrations

       Subjective Probability
       Independence of Health Effects
       Responses of Concern
       Sensitive Population
       Seriousness of Effect
       Uncertainty about Causality
       Defining the Encoding Variable

    Uncertainty in Peak Air Quality Levels
    Secondary Uncertainties and Public Probability

    General Description of the Method

       Mathematical Description of the Method
       Obtaining the Pr(C) Distributions
                      L.

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                         26
Application of the Risk Assessment to Ozone

  The Judgments of Health Experts
  Determination of Pc Functions for Ozone
  Risk Tables and Risk Ribbons

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     PART III
     COPIES OF



SELECTED REFERENCES

-------
                                                      REF  1-1
[6560-01]

  Title 40—Protection of Environment

    CHAPTER I—ENVIRONMENTAL
       PROTECTION AGENCY

             CFRL 897-1]

  PART 51—STATE IMPLEMENTATION
    PLANS UNDER CLEAN AIR ACT

Criterio for  Proposing Approval of
  Revision to  Plans  for Nonattain-
  ment Areas

AGENCY:  Evironmental  Protection
Agency.

ACTION:  Notice  of policy memoran-
dum.
SUMMARY:  Reproduced below  is a
copy of a  Memorandum in which the
EPA Administrator summarized the
elements that  must  be included in
State Implementation  Plan  Revisions
for areas that  do not meet national
ambient air quality standards  under
the Clean Air Act. The Memorandum
establishes  elements  which  a State
Plan submittal  must contain in order
to be approved by EPA. EPA is pub-
lishing this Memorandum for the in-
formation of the public.

EFFECTIVE  DATE:  February   24,
1978.
FOR  FURTHER  INFORMATION
CONTACT:
  Darryl D. Tyler, U.S. Environmental
  Protection  Agency,   Office  of  Air
  Quality  Planning and  Standards
  (MD-15).  Research  Triangle  Park.
  N.C. 27711, 919-541-5425.
     RULES AND REGULATIONS

SUMMARY  INFORMATION:  New
provisions  of the  Clean Air Act en-
acted in 1977 require stairs to revise
their State Implementation Plans for
all  areas that do not attain National
Ambient Air Quality Standards. States
must submit the necessary Plan revi-
sions to EPA by January 1,1979.'
  The    Memorandum    reproduced
below,  which the EPA Administrator
issued to the ten Regional Administra-
tors on  February 24, 1978, summarizes
the  elements which a Plan submittal
must contain in order to be approved
by  EPA as meeting the requirements
of Part D  of the Act. Copies of this
Memorandum have already been sup-,
plied to the state air pollution control
agencies, to provide guidance in their
preparation of  Plan  revisions. It is
being published  now for the informa-
tion of the  public.
  EPA considers this Memorandum to
state "nationally applicable"  Agency
policy,  but not  "regulations promul-
gated, or final action taken, by the Ad-
ministrator" that is ripe for  judicial
review under the first sentence of sec-
tion 307(b)(l) of the Act  (42VU.S.C.
7607(b)(D). Only after  EPA  has re-
ceived actual Plan submlttals, and has
invited  and considered  public com-
ment on whether the submittals satis-
fy  the  requirements  for approval
under the  Act, will the Administrator
take final  actions with respect to the
individual submittals. The opportunity
for  judicial  review of  those final
Agency actions under the second and
third sentences of section 307(b)(l) of
the  Act, will provide an opportunity
for judicial consideration of the policy
issues addressed  in this Memorandum,
  Dated: May 9,1978.
            DAVID G. HAWKINS,
        Assistant Administrator for
         Air and Waste Management.
  On February 24, 1978, the Adminis-
trator  of the  Environmental  Protec-
tion Agency  issued  the   following
Memorandum:
SUBJECT:  Criteria for  Approval  of
1979 SIP Revisions.
FROM: The Administrator (A-100).
TO: Regional Administrators, I-X.

                FEBRUARY 24,1978.
  The attachment to this memo sum-
  'The new requirements for nonattainment
areas are contained in Part D to Title I of
the Act (42 U.S.C. 7501-7508). The general
requirements for Plans are set forth in sec-
tion 110 of the Act (42 U.S.C. 7410). Several
consequences that may result if a state fails
to adopt and carry out the necessary Plan
provisions for a nonattainment area  are
found in sections  110(a)(2)(I), 173(4). and
176(a)-(b)  of  the   Act.  (42   U.S.C.
7410(aX2XI), 7503(4), and  7506(a)-(b)>. The
January 1,1979, deadline is stated in section
129(c) of the Clean Air Act Amendments of
1977, Pub. L.  95-95 (note under 40 U.S.C.
7502).
                              21673

 marizes the  elements  which  a  1979
 State Implementation Plan (SIP) revi-
 sion  for a non-attainment area must
 contain in  order to be approved  by
 EPA as meeting the requirements of
 Part D of the Clean Air Act.
   In  summary,  the Act requires  the
 demonstration of  attainment  of  the
 air quality standards (primary and sec-
 ondary) as  cxpcdlllouHly as practica-
 ble, but in the case of national prima-
 ry standards not later than December
 31, 1982. However, for carbon monox-
 ide  (CO) and oxldants (Ox),  if  the
 State can demonstrate attainment is
 not possible by 1982 despite the imple-
 mentation of all reasonable stationary
 source   and  transportation   control
 measures, the Act provides for up to a
 five-year extension. In those cases the
 plan  revisions must  demonstrate at-
 tainment as  expeditiously as practica-
 ble but no later  than  December 31,
 1987. The extension is not automatic;
 a demonstration of need must be made
 and the State must fulfill the other
 statutory requirements.
  It is the intent of the Agency to es-
 tablish   reasonable and  achievable
 goals for SIP submissions and to take,
 a firm  posture on the  Imposition of
 sanctions where the reasonable goals
 are not achieved. Accordingly, while
 the policy requires a commitment to
 many specific strategies in the 1979
 submissions (e.g., RACT on stationary
 sources, inspection/maintenance pro-
 grams where attainment for carbon
 monoxide or oxidants extends beyond
 1982,  other reasonable transportation
 control measures, etc.) the  memo also
 requires (for carbon monoxide and ox-
 idants)  a commitment to a  continuing
 process.  This process must be  one
 which extensively involves  the  public
 as well  as State and local elected offi-
 cials and which ambitiously pursues a
 wide range of alternatives.   <,

  Since reliance on  stationary controls
 and Federal  new car standards alone
 will not enable  most areas with oxi-
 dant  and carbon monoxide problems
 to attain these standards by 1982, each
 Regional Office  will need to put par-
 ticular  emphasis  on additional meas-
 ures to reduce transportation system
 emissions. The process  committed to
 in the 1979 plan submission must lead
 to the expeditious selection and imple-
 mentation of comprehensive transpor-
 tation control measures. In Judging
 the adequacy of the 1979 plan submis-
 sion  for  the transportation  sector,
 each  Regional Administrator should
ensure that ambitious alternatives (as
 described in the draft "Tranportation
 Planning guidelines" which have been'
 circulated) will be analyzed.
  The Department of Transportation
 (DOT). Housing  and Urban Develop-
 ment (HUD) and EPA are seeking to
 integrate the transportation/air qual-
                               FEDERAL REGISTER, VOL. 43, NO. 98—FRIDAY, MAY 19, 1978

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 21674

 ity planning  and implementation re-
 quired by the Clean Air Act into exist-
 ing  planning and programing  proce-
 dures.  The  air  planning  activities
 should be  included  in  the Unified
 Work Program required by DOT and
 the  adopted  transportation  measures
 should be included in the  Transporta-
 tion  Improvement  Program  required
 by DOT. In complying with the Clean
 Air  Act  requirements, the  Regions
 should also keep  in mind  the require-
 ments  of  the  HUD-EPA Agreement
 which provides for coordination of air
 quality planning and planning assisted
 under the HUD Comprehensive Plan-
 ning Assistance (701)  Program. Inte-
 gration of air and transportation plan-
 ning  with  comprehensive  planning
 which  incorporates  growtTr~-manage-
 ment concerns should improve the ef-
 fectiveness  of air  quality planning; and
 could reduce the need for enforcement
 measures in the future.
   States will be provided some discre-
 tion  regarding the amount  of  emis-
 sions  growth  to be  accommodated
•within the SIP. EPA generally will not
 question the  growth rates desired by
 the State so long as reasonable further
 progress is  demonstrated and there is
 a demonstration of attainment by the
 statutory  deadline  (1982 or  1987).
 However, the growth rate identified in
 the   SIP  must  be  consistent  with
 growth rates  used  (or  implied  by)
 other planning programs  in the area
 {e.g., FWPCA §§208, 201,  HUD §701,
 FHWA § 134).
   You  should  note that  there  are
 other SIP revisions which are not dis-
 cussed in the attachment but  which
 are required by the 1977 Amendments.
 These include:
   1.  Section  128 (relating  to  State
 boards).
   2. Section 126 (relating to interstate
 pollution).
   3. Section 127 (relating to public no-
 tification).
  4. Part C (relating to prevention of
 significant deterioration).
  5. Section 110(a)(2)(K)  (relating to
 permit fees).
  6.  Section  123  (relating  to  stack
 heights for existing source  in  other
 than non-attainment areas).
  7. Section 121 (relating  to consulta-
 tion).
  Although  incorporation of these pro-
 visions is required by the  law, failure
 to achieve final approval  by July 1,
 1979 does not trigger the  new source
prohibition of Section 110(a)(2)(I).
  It is Important to emphasize to the
States that all current SIP  require-
ments remain in effect despite the de-
velopment of  the  1979  revisions. Any
suspension or discontinuance of an ex-
isting SIP provision must be submitted
 for EPA approval. This should be done
as part of the  revision submitted in
 January 1979. Exceptions to this pro-
 cedure may. be  found in  certain new
              REF  1-1

     RULES AND  REGULATIONS

provisions of §110 relating to reduc-
tion of on-street parking, bridge  tolls,
and other measures.
  The  development  of  the January
-1979  SIPs to meet the minimum  re-
quirements  of  the  Clean  Air  Act
Amendments of 1977 is a complex and
demanding program.  It  will require
the commitment   of significant  re-
sources on the part of the air pro-
grams staff of the Regional Office to
ensure that the  States develop  and
submit -A comprehensive  and npprov-
able plan. We are working with  your
staff  to develop the necessary guid-
ance  and  follow-up  programs which
will assist your office and the State to
carry out this very difficult but impor-
tant part of the overall air program.
Attachment
cc: Alr~7fc~Hiizardaus Division Direc-
tors, Air Branch Chiefs.

CRITERIA  FOR APPROVAL OF 1979 STATE
  IMPLEMENTATION PLAN REVISIONS FOR
  NON-ATTAINMENT AREAS

              PURPOSE

  The purpose of  this document  is to
define the criteria by which State Im-
plementation Plan (SIP) revisions for
non-attainment areas required  by the
Clean  Air Act Amendments of  1977
(the Act) will be approved. These revi-
sions  are  to  be submitted to EPA by
January 1,1979.

     CATEGORIES OF SIP REVISIONS

  SIP  revisions submitted by January
1, 1979 can be divided into two catego-
ries:
  1. Those which  provide for  attain-
ment   of  the Primary Ambient  Air
Quality  Standards  (primary  stand-
ards)  for  all criteria pollutants on or
before December 31, 1982.
  2. Those which  provide for  attain-
ment   of  the primary  standards for
sulfur  dioxide, nitrogen  oxides,  and
particulate matter on or  before  De-
cember 31, 1982 but show that despite
the implementation of  all reasonable
transportation  and stationary  source .
emission control measures attainment
of the primary  standards  for  carbon
monoxide and/or  oxidants cannot be
achieved until after this date. In these
cases, the revisions must demonstrate
attainment as expeditiously as practi-
cable  but no later than December 31,
1987.
  In order for an  adequate SIP  revi-
sion to fall into the second category.
the State has an affirmative responsi-
bility  to demonstrate to the satisfac-
tion of EPA that attainment  of the
primary carbon monoxide and/or oxi-
dants  standards is  not  possible in  an
area prior to December 31, 1982.
  It should be noted that SIP revisions
of either category  should also provide
for attainment of  Secondary Ambient
Air  Quality  Standards  (secondary
standards) as expeditiously as practi-
cable although there  is  no specific
deadline contained In the'Act.

 GENERAL REQUIREMENTS OF ALL 1979 SIP
              REVISIONS

  Each 1979 SIP revision must contain
the following:
  1.  A  definition  of the geographic
areas for which control strategies have
been  or  will  be developed. Considera-
tion should be given to the practical
benefits  of defining an-os which corre-
spond whenever possible to those sub-
state  districts established pursuant to
Part IV,  Attachment A of OMB Circu-
lar No. A-95.
:  2. An accurate, comprehensive, and
current (1977 calendar year) inventory
of existing emissions.
  3. A determination of the level of
control  tiooded to domonstratp attain-
ment by 1982 (including growth). This
demonstration should be made by the
application of modeling  techniques as
set forth in  EPA's Guideline on Air
Quality Models. For oxidants, any le-
gitimate  modeling   technique  (e.g.,
those referenced in "Use, Limitation
and Technical Basis of Procedures for
Quantifying  Relationships  Between
Photochemical Oxidants and Precur-
sors." EPA 450/2-77-021a. November
1977) can  be used.  Consideration  of
background and transport for oxidants
should generally be in accordance with
the procedures documented in "Proce-
dures for  Quantifying  Relationships
Between Photochemical  Oxidants and
Precursors."   In   developing  photo-
chem- ical oxidant control strategies
for  a particular  area,  states  may
assume  at  a minimum that the stand-
ard will be attained in adjacent stales.
  If a state can demonstrate that the
level  of  control necessary for attain-
ment of the primary  standards  for
carbon  monoxide  and/or oxidant is
not possible by 1982 despite the appli-
cation of all  reasonable measures, an
extension past 1082 (but not beyond
1987) is authorized.
  4. Adoption  in  legally enforceable
form2 of all measures  necessary  to
  'Written evidence that the State, the gen-
eral purpose local  government or govern-
ments, or a regional agency  designated by
general purpose local governments for such
purpose, have adopted by statute, regula-
tion, ordinance or other legally enforceable
document, the necessary requirements and
schedules and timetables  for  compliance.
and are committed to implement and  en-
force the appropriate elements of the plan.
The relevant organizations shall provide evi-
dence  that the legally enforceable attain-
ment measures and the "criteria, standards
and Implementing procedures necessary  for
effectively guiding  and controlling major
dorlslonn OB to where growth shall and shall
not take place." prepared by State and local
government* In compliance with Section  101
of the Housing Act of 1964, as amended,  arc
fully coordinated In the attainment and
maintenance of the NAAQS,
                                FEDERAL REGISTER, VOL 43, NO. 98—FRIDAY, MAY 19, 1978

-------
                                                    REF 1-1
provide for attainment  by  the pre-
scribed date or, where adoption of all
such measures by 1979 is not possible,
(e.g.,  certain  transportation control
measures,  and  certain  measures  to
control  the oxides  of nitrogen and
total suspended particulate) a sched-
ule for expeditious development, adop-
tion, submittal, and implementation of
these  measures. The  situations  in
which  adoption of measures may  be
scheduled after 1979 are discussed in
the pollutant specific sections of this
document. Each schedule must pro-
vide for implementation  of all reason-
ably available control measures as ex-
peditiously as practicable. During the
period  prior  to  attainment,  these
measures must be implemented rapid-
ly enough to provide at a minimum for
reasonable further progress (see dis-
cussion below). "Each schedule will be
considered part of  the applicable im-
plementation plan and thus will repre-
sent a commitment on the part of the
State to meet the key mile- stones set
forth in the submitted schedule.
  5. Emission reduction  estimates for
each adopted  or  scheduled control
measure or for related groups of con-
trol measures where estimates for  in-
dividual measures are impractical. It is
recognized  that reduction  estimates
may  change as measures  are more
fully analyzed and implemented.  As
such estimates change, appropriate re-
sponses will be required to insure that
the plan remains adequate to provide
for attainment and for reasonable fur-
ther progress.
  6. Provision for reasonable further
progress toward attainment of the pri-
mary and secondary  standards in  the
period prior to  the prescribed date for
attainment. Reasonable  further pro-
gress is defined as annual incremental
reductions in total  emissions  (emis-
sions from new as  well as  existing
sources)  to provide for attainment  by
the prescribed date. The plan shall
provide for substantial reductions  in
the early  years  with regular reduc-
tions thereafter.
  Reasonable further progress will  be
determined for each  area by dividing
the total emission reductions required
to attain the applicable  standard by
the number of years between 1979 and
the date projected for attainment (not
later than 1987). This is represented
graphically by  a straight line drawn
from the emissions inventory submit-
ted in  1979 to the allowable emissions
on the attainment date. However, EPA
recognizes that some measures cannot
result  in immediate emission reduc-
tion. Therefore, if  a State can show
that some lag in emissions reduction is
necessary,  a SIP will be acceptable
even though reductions  sufficient  to
produce decreases at the "straight-line
rate" are not achieved for  a year  or
two after 1979. This lag in achieving
the "straight-line rate" for emissions
     RULES AND REGULATIONS

reduction is to be accepted only to ac-
commodate the time reouired for com-
pliance  with the first set of regula-
tions adopted on or before January 1,
1979, if immediate  compliance is not
possible. It does not authorize delays
in adoption of control requirements.
  The   requirement to  demonstrate
reasonable further  progress  will,  in
most areas designated non-attainment
for oxidant or carbon monoxide, ne-
cessitate "a continuous, phased imple-
mentation of transportation  control
measures. In areas  where attainment
of all primary ambient standards by
1982  is  not possible  EPA will  not
accept mere  reliance on the  Federal
Motor Vehicle  Control  Program  by
itself as a demonstration of reasonable
further progress.
  In determining "reasonable  further
progress", those emission  reductions
obtained  from  compliance  between
August  7. 1977, and  December  31,
1979, with (1) SIP revisions that have
been submitted  after August  7, 1977,
and (2) regulations which were ap-
proved by the Agency prior to the en-
actment of the 1977 Clean Air Amend-
ments, can be treated as having been
achieved during  1979. There should be
an assurance, however, that these are
real emission reductions  and not just
"paper" ones.
  7.  An identification and  quantifica-
tion of an emissions growth increment
which will be allowed  to result from
the  construction  and  operation  of
major   new  or  modified  stationary
sources  within the area for which the
plan has  been developed. Alternative-
ly, an emissions offset regulation can
be adopted to provide  for major new
source growth.
  The  growth  rates established  by
states  for mobile  sources  and new
minor stationary sources should also
be specified, and in combination with
the growth associated with major new
or modified stationary sources will be
accepted so long as they do not jeopar-
dize the  reasonable further  progress
test and attainment by the prescribed
date. However, the growth rate identi-
fied in  the SIP must be consistent
with the growth  rates used (or implied
by) the  other planning  programs in
the  area  (e.g.f  PWPCA  Section  208
[201], HUD Section 701. FHWA Sec-
tion 134). A system for monitoring the
emission growth rates from major and
minor  new stationary  sources and
from transportation sources and assur-
ing that they do not exceed the speci-
fied amounts must also be provided for
in the revision.
  8. Provision for annual reporting on
the  progress  toward  meeting  the
schedules summarized in (4) above as
well as  growth  of mobile  sources,
minor new stationary sources, major
new or  modified stationary sources,
and reduction in emissions from exist-
ing sources to provide for reasonable
                              21675

further progress as in (6) above. This
should include an updated emission in-
ventory.
  9.  A  requirement that permits be
issued for the construction  and oper-
ation  of  new  or  modified  major
sources in accordance with Section 173
and 110(a)(2)(D).
  10. An identification  of and commit-
ment to the financial  and manpower
resources necessary  to carry out the
plan.   The  commitment  should be
made at the highest  executive  level
having  responsiblity for SIP or that
portion of it and having authority to
hire new employees. This commitment
should  include  written evidence  that
the State, the  general purpose  local
government or governments, and all
state, local or regional agencies  have
included appropriate provision In their
respective budgets and intend to con-
tinue to do so in future  years for
which budgets have not yet been final-
ized, to the extent necessary.
  11. Evidence of public, local govern-
ment,  and  state  legislative involve-
ment and consultation. It shall also in-
clude an identification and brief analy-
sis of the air quality, health, welfare,
economic, energy, and social effects of
the plan revisions  and of the alterna-
tives  considered by the State,  and a
summary of the public comment on
such analysis.
  12. Evidence that the SIP was adopt-
ed by the state after reasonable notice
and public hearing.

ADDITIONAL REQUIREMENTS FOR CARBON
  MONXIDE AND OXIDANT SIP REVISIONS
  WHICH PROVIDE  FOR  ATTAINMENT OF
  TFIE PRIMARY STANDARDS LATER  THAN
  1982

  For those  SIP revisions which dem-
onstrate that attainment of the prima-
ry  standards  for  carbon  monoxide
and/or oxidants is not possible in an
area prior to December 31, 1982 de-
spite the implementation of all reason-
able emission control measures tho fol-
lowing Items must be Included In the
January 1, 1979 submission in addition
to all the general requirements listed
above:
  1. A program which requires prior to
issuance of  any permit for construc-
tion or  modification of a major emit-
ting facility an  analysis of alternative
sites,  sizes, production processes, and
environmental control  techniques for
such  proposed  source  which  demon-
strates that benefits of the proposed
source significantly outweigh the envi-
ronmental and social cost imposed as a
result of its location, construction, or
modification.
  2. An  inspection/maintenance pro-
gram  or a schedule endorsed by and
committed to by the Governor for the
development, adoption, and implemen-
tation of such  a program as expedi-
tiously as practicable.  Where the nec-
essary legal  authority does not CUT-
                                FEDERAL REGISTER, VOt 43, NO. 98—FRIDAY, MAY 19,  1978

-------
                                                     REF  1-1
 21676

 rently exist, it must be obtained by
 June  30, 1979. Limited exceptions to
 the requirement  to obtain legal  au-
 thority by June 30, 1979 may be possi-
 ble if the state can demonstrate that
 (a) there was insufficient opportunity
 to conduct necessary  technical analy-
 ses and/or (b) the legislature has had
 no opportunity to consider any neces-
 sary enabling legislation for inspec-
 tion/maintenance  between  enactment
 of the 1977 Amendments to the Act
 and June 30, 1979. In addition, where
 a legislature has adequate opportunity
 to  adopt  enabling legislation  before
 January 1, 1979, the Regional Admin-
 istrator should require submission of
 such  legal  authority  by January 1,
 1979. In no case can the schedule sub-
 mitted provide for obtaining legal-au-
 thority later than July 1,1980.
   Actual  implementation of the  in-
 spection/maintenance  program  must
 proceed as expeditiously as practica-
 ble. EPA considers two and one half
 years   from the   time of  legislative
 adoption to be the maximum time re-
 quired to implement a centralized in-
 spection/maintenance  program  and
 one and one half years to implement a
 decentralized program. In no case may
 implementation of the program, i.e.,
 mandatory inspection and mandatory
 repair  of  failed vehicles be delayed
 beyond 1982 in the case  of a central-
 ized program  (either  state lanes  or
 contractor  lanes)   or beyond 1981 in
 the case of a  decentralized (private
 garage) system.
   3. A commitment by the responsible
 government official or officials to  es-
 tablish, expand,  or  improve public
 transportation measures to meet basic
 transportation needs as expeditiously
 as is practicable.
   4. A  commitment to use insofar as Is
 necessary Federal grants, state or local
 funds,  or  any  combination of such
 grants and funds as may be  consistent
 with the terms of  the legislation pro-
 viding such grants and funds, for the
 purpose of establishing, expanding or
 improving public transportation meas-
 ures  to meet  basic   transportation
 needs.
  Note  that HUD  has prepared guide-
 lines for local development  codes and
 ordinances to provide  special require-
ments  for areas which for significant
periods of time may exceed the prima-
ry standards. These guidelines specify
criteria for new construction operation
of buildings which  minimize pollutant
concentrations  to  ensure  a  health
indoor  and  outdoor  environment.
States  are  encouraged  to adopt such
measures as part of the SIP.

   POLLUTANT SPECIFIC REQUIREMENTS

           Sulfur Dioxide
  Specifically, with regard to item (4)
of the General Requirements, the Jan-
uary 1979 plan revisions dealing with
sulfur  dioxide  must contain all the
      RULES  AND REGULATIONS

 necessary emission limitations and le-
 gally  enforceable procedures  to pro-
 vide for attainment by no later than
 December 31, 1982 (i.e., schedules for
 the development, adoption, and sub-
 mittal of regulations  will' not be ac-
 ceptable).

           Nitrogen Oxides

  For  NO,,  the January  1979  plan
 must  contain all the  necessary emis-
 sion limitations  and  the  legally en-
 forceable procedures,  or  as  a mini-
 mum,  the  appropriate  schedules  to
 adopt  and submit the  emission limita-
 tions  and legally enforceable proce-
 dures  which provide  for implementa-
 tion so that standards will  be attained
 by no later  than December" 31, 1982.
 EPA is currently evaluating the need
 for a short term NOi standard and ex-
 pects  to promulgate such  a standard
 during 1978.  If such a  standard for air
 quality is promulgated, a new and sep-
 arate SIP revision will be required for
 this pollutant.

          Particulate Matter

  The January  1979  plan  revisions
 dealing with particulate matter must
 contain  all  the  necessary  emission
 limitations  and  legally   enforceable
 procedures   for  traditional  sources.
 These emission  limitations and  en-
 forceable procedures must  provide for
 the  control  of   fugitive   emissions.
 where necessary, as well as stack emis-'
 sions  from  these stationary  sources.
 Where  control   of   non-traditional
 sources (e.g., urban fugitive dust, resu-
 spension, construction, etc.) is neces-
 sary for  attainment,  the  plan shall
 contain an assessment of the impact of
 these  sources and a commitment on
 the part of the state to adopt appro-
 priate  control measures, this commit-
 ment shall take the form of a schedule
 to develop, submit, and implement the
 legally enforceable  procedures,  and
 programs for  controlling   non-tradi-
 tional   particulate  matter  sources.
 These  schedules  must include miles-
 tones for evaluating progress and pro-
 vide for attainment of  the primary
 standards by no later  than December
 31, 1982,  and attainment  of the sec-
 ondary standards as expeditiously  as
 practicable. States should initiate the
necessary studies  and demonstration
projects for controlling the non-tradi-
tional sources as soon as possible.

    Carbon Monoxide and Oxidant

  An adequate SIP for oxidant is one
which  provides for sufficient control
of volatile organic compounds (VOC)
from stationary and mobile sources to
provide for attainment of the oxidant
standard. Accordingly, the 1979 plan
revision must set forth the necessary
emission limitations and schedules  to
obtain sufficient control of VOC emis-
sions  in  all non-attainment  areas.
 They must be directed toward reduc-
 ing the peak concentrations within the
 major urbanized areas to demonstrate
 attainment as expeditiously as practi-
 cable but in no case later than Decem-
 ber 31, 1987. This should also solve the
 rural oxidant  problem by minimizing
 VOC emissions and more Importantly
 oxidants  that  may  be  transported
 from urban to rural areas.  The 1979
 submission  must represent a compre-
 hensive strategy  or plan for each non-
 attainment   area;  plan  submissions
 that address only selected portions of
 non-attainment are not adequate.
  For the purpose of oxidant plan de-
 velopment,  major  urban  areas  are
 those with an urbanized population of
 200,000 or  greater (U.S.  Bureau of
 Census,  1970).  A  certain  degree of
 flexibility will be allowed in defining
 the specific boundaries of the urban
 area. However, the areas must be large
 enough to cover the entire urbanized9
 area and  adjacent fringe  areas of de-
 velopment.  For non-attainment urban
 areas, the highest pollutant concentra-
 tion for the entire area must be used
 in determining the necessary level of
 control. Additionally, uniform model-
 ing techniques must be used through-
 out  the nonattainment urban area.
 These requirements  apply  to inter-
 state as well as intrastate areas.
  Adequate  plans must provide for the
 adoption of reasonably available con-
 trol   measures   for  stationary and
 mobile sources.
  For stationary sources, the 1979 oxi-
 dant plan submissions for major urban
 areas must  include, as a minimum, le-
 gally enforceable regulations to reflect
 the application of reasonably available
 control  technology (RACT)4 to those
 stationary sources for which EPA has
 published   a  Control   Techniques
 Guideline (CTG)  by January 1978, and
 provide for the adoption and submittal
 of   additional   legally   enforceable
 RACT regulations on an annual ba.ilfi
 beginning In January  1980, for those
CTG's that have been published by
January of the preceeding year.
  For rural  non-attainment areas,  the
 Ox plan must provde the necessary le-
 gally  enforceable procedures for  the
control  of  large  HC  sources  (more
 than 100 ton/year potential emissions)
for which EPA has  issued a CTG by
January 1978, and to adopt and submit
additional legally enforceable  proce-
dures on an annual basis beginning in
January 1980, after publication of sub--
sequent CTGs as set forth above.
  For mobile sources in urbanized area
(population  200,000) SIPs must pro-
  'As defined by the U.S. Bureau of Census,
urbanized area generally include core cities
plus any closely settled suburban areas.  '
  'While It Is recognized that RACT will be
determined on a cose-by-casc basks, the cri-
teria for SIP approval rely heavily upon the
Information contained in the CTQ.  Devi-,
atlons from the use of the-CTG must be ;
adequately documented.        "
                                FEDERAL REGISTER, VOL. 43, NO. 98—FRIDAY, MAY 19, 1978

-------
vide for expeditious implementation of
reasonably available control measures.
Each of the measures for which EPA
will  publish  information  documents
during 1978 is  a reasonably available
control measure. These measures  are
listed on the following page:
  1. To be published by February 1978:
  a. Inspection/maintenance;
  b. Vapor recovery;
  c. Improved public transit;
  d. Exclusive bus and carpool lanes;
  e. Area wide carpool programs.
  2. To be published by August 1978:
  a. Private car restrictions;
  b. Long range transit improvements;
  c. On street parking controls;
  d. Park and ride and fringe parking
lots;,
  e. 'Pedestrian malls;
  f. Employer programs to  encourage
car and van pooling, mass transit, bicy-
cling and walking;
  g.  Bicycle lanes and storage facili-
ties;
  h. Staggered work hours;
  i. Road pricing to discourage single
occupancy auto trips;
  j.  Controls  on  extended  vehicle
idling;
  k. Traffic flow Improvements;
  1. Alternative fuels or engines and
other fleet vehicle controls;
  m. Other than light duty  vehicle re-
trofit;
  n. Extreme  cold  start emission re-
duction programs.
  The  above measures (either individ-
ually  or  combined into packages  of
measures) should be analyzed prompt-
ly and thoroughly  and scheduled for
expeditious implementation. EPA rec-
ognizes that not all analyses of every
measure  can be completed by January
1979 and, where necessary, schedules
may provide for  the  completion  of
analyses  after January 1, 1979 as dis-
cussed below. (If analysis after Janu-
ary  1979 demonstrates  that  certain
measures would be  unnecessary or in-
effective,  a decision not to implement
such   measures may  be  justifiable.
However, decisions  not to implement
measures will have  to be carefully re-
viewed to avoid broad rejections  of
measures based oh conclusory asser-
tions of infeasibility.)
  As described  previously,  annual in-
cremental reductions  in  total emis-
sions  must occur in order to achieve
reasonable further progress during the
period prior to attainment of  the
standards. Therefore, not all transpor-
tation  measure implementation activi-
ties should wait until the comprehen-
sive analyses of control measures are
completed. Demonstration studies are
important and  should accompany or
precede full scale implementation of
the  comprehensive strategy.  It  is
EPA's  policy that each area  will be re-
quired  to schedule a representative se-
lection of reasonable  transportation
measures  (as listed above) for  imple-
                REF  1-1

     RULES AND REGULATIONS

mentation at least on a pilot or dem-
onstration basis prior to the end  of
1980.
  Every effort must be made to inte-
grate the air quality related transpor-
tation plan  and implementation  re-
quired by the Clean Air Act into plan-
ning and prograrriming procedures ad-
ministered by DOT. EPA will publish
"Transportation Planning Guidelines"
which will, if followed carefully, insure
that an adequate transportation plan-
ning process exists.
  EPA recognizes  that the planning
and implementation of very extensive
air  quality   related  transportation
measures can be a complicated and
lengthy  process, and  in areas with
severe carbon  monoxide or oxidant
problems, completion of some of the
adopted measures may extend beyond
1982. Implementation of even  these
very  extensive  transportation meas-
ures, however, must be initiated before
December 31,1982.
  In the  case of plan revisions that
make the requisite  showing to justify
an extension of the date for attain-
ment,  the portion  of the 1979 plan
submittal for transportation measures
must:
  1. Contain procedures and  criteria
adopted into the SIP by which it can
be determined whether the outputs of
the  DOT  Transportation  planning
process conform to the SIP.
  2. Provide for the expeditious imple-
mentation of currently  planned rea-
sonable transportation control meas-
ures. This includes reasonable but un-
implemented transportation measures
in  existing SIPs and transportation
controls with demonstrable air quality
benefits  developed  as  part  of the
transportation   process   funded,  by
DOT.
  3. Present a program for evaluating
a  range of  alternative  packages  of
transportation options that includes,
as a minimum, those measures listed
above for which EPA will develop im-
formation  documents. The  analyses
must identify a package of transporta-
tion control  measures to  attain the
emission reduction  target ascribed  to
it in the SIP.
  4. Provide for the evaluation of long
range  (post-1982) transportation and
growth policies.  Alternative  growth
policies and/or development patterns
must be examined  to determine the
potential  for modifying  total  travel
demand. One of the growth alterna-
tives  evaluated  should  be  that pre-
pared in response to Section 701 of the
Housing Act of 1954, as amended.
  5.  Include  a schedule  for analysis
and adoption of transportation control
measures as expeditiously as practica-
ble. The comprehensive analysis  of al-
ternatives (item 2 above) must be com-
pleted by July 1980 unless the desig-
nated  planning  agency  can demon-
strate that analysis of individual com-
                              21677

ponents  (e.g., long range transit im-
provements)  may require additional
time. Adopted  measures must  be im-
plemented as expeditiously  as  practi-
cable and on a  continuous  schedule
that demonstrates reasonable further
progress from 1979 to the attainment
date. Determinations of the reason-
ableness of a schedule will be based on
the nntue of the existing or planned
transportation  system and  the com-
plexity of implementation of an  indi-
vidual measure.

  ADDITIONAL CARBON MONOXIDE AND
 OXIDANT MONITORING REQUIREMENTS

  It is EPA's policy to require that all
SIPs which provide for  Attainment of
the oxidant standard after December
31,1982, must contain commitments to
implement a complete oxidant moni-
toring program  in major urbanized
areas in order to adequately character-
ize the nature and extent of the prob-
lem and to measure the effectiveness
of the control  strategy for oxidants.
The  1979 plan submittal must provide
for a schedule to conduct  such  CO
monitoring as necessary  to correct any
deficiencies  as  identified by the Re-
gional Office.

     SIPs FOR UNCLASSIFIED AREAS
   REDESIGNATED NON-ATTAINMENT

  With  respect to  unclassified areas
which are later found  to be non-at-
tainmont areas the state will  be re-
quired to submit a plan within  nine
months of the  non-attainment  deter-
mination. During plan  development.
the state will  be required to  imple-
ment the offset policy for that area.
However, it should be noted that in
many cases, because of  previous plan
revisions or adoption of previous  con-
trol regulations, the baseline for off-
sets will  be more restrictive and thus
offsets  may be  more  difficult to
obtain. For oxidants,  state-wide regu-
latory development (for at  least all
sources  greater than 100 tons/year).
however,  would permit the  state to
utilize the regulations  developed for
the entire state as the applicable  plan
for the newly  designated non-attain-
ment area. This would  normally  con-
stitute an approvable  SIP  per  the
above criteria and could essentially ac-
commodate   the  proposed   growth
within the previously submitted state1
plan and not require  offsets once the
area is designated as non-attainment.
 [PR Doc. 78-13634 Piled 5-18-78; 8:45 am]
                               FEDERAL REGISTER, VOL. 43, NO. 98—FRIDAY, MAY 19, 1978

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                             REF  1-3
         UNITED STATES ENVIRONMENTAL PROTECTION  AGENCY

                           WASHINGTON. D.C.  20460
                              SEP 2 8 1977
AIR AND WASTE MANAGEMENT
SUBJECT:  Attainment Designation List Required              OCf 12 1977
          by the 1977 Clean Air Act Amendments

FROM:     David G. Hawkins, Assistant Administrator
            for Air and Waste Management

MEMO TO:  Regional Administrators, Regions I-X

     With the  passage of  the  1977 Clean Air Act Amendments, many new
tasks  have  been placed  upon  this Agency.  One of the most pressing,
of  these  is the requirement  by Section 107(d) of the revised Act to
publish a list by  February 3, 1978, of air quality control regions
(AQCRs)'or  portions  thereof  reflecting their attainment/nonattain-
ment status for all  criteria pollutants.

      You  are requested  to notify your States of  this requirement and
convey the  importance  of these designations for  future air quality
control strategy  planning.  I have  enclosed a model  letter to use  as
a  guide in  preparing a  letter from  your  office to  the head of each
State's air pollution  control agency  detailing the requirements of
the Act in  regards to  this task  and giving  the necessary  guidance
for developing these attainment  designation lists.

      The  State submittals should be reviewed  by  the  Regional Offices
for consistency in applying  the  criteria set  forth for determining
attainment status. The validation  of  the air  quality monitoring data
used by the State in making  such determinations  is most  important.
 I?i light of the tight schedule,  copies of the  State  submittals
 should be  forwarded to the Office of  Air Quality Planning and  Standards
 (OAQPS) for concurrent review as they are received by  the Regional
 Offices.    Where modifications are made by the Regional  Office  to  the
 status of  any designated  area,  these  revisions should  be submitted
 to OAQPS no later than January 19,  1978.  States will  be given
 notification by the Regional Offices  when modifications  are  made  and
 allowed to rebut any such changes.   OAQPS will  then  prepare  a
 Federal Register notice compiling the attainment designations  for
 all areas  and publish  the notice by February 3,  1978.

      Given the time schedule and the resulting impact of such
 designations on future air quality planning,  your immediate atten-
 tion  is requested.

 Enclosure

 cc:   Air & Hazardous Materials  Division  Directors,  Regions  I, III-X
       Environmental  Programs  Division Director,  Region II
       Air Branch Chiefs,  Regions I-X

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                    REF 1-3

     UNITED STATES ENVIRON! -uNVAU PnOTECTlON AGENCY'

                    WASHINGTON. D.C-
                      DDT   71977
                                                 OFFICE OP
                                           AtFT AND WASTE MANAGEMENT
SUBJECT:  Model Letter Regarding State Designation
          of Attainment Status     '•'•.

MEMO, TO;  Regional'Administrators, Region I-X

FROM    :  David G. Hawkins, Assistant Administrator
            for Air and Waste Management
     On October 6, 1977, members of your staff were notified,
via telephone, of the pending revision to. the model letter
prepared as guidance for notification to the State agencies
concerning designation of attainment/non-attainment status
as' required by the 1977 Clean Air Act Amendments.  The
language of the September 28, 1977, model letter to you has
been revised  regarding designation for photochemical oxidants,
The attached  model letter requests States to presume that
all urban areas greater than 200,000 population are non-
attainment areas for photochemical oxidants and encourages
States to consider oxidant.non-attainment designation on a
State-wide basis in States east  of the Mississippi River.

     Please consider this model  letter as representing Agency
policy and proceed to notify each. State.                 -   •

Attachment
 cc:
Air 0 Hazardous Materials Division Directors,. Regions 1,
   III-X
Environmental Programs Division Director, Region II '
Air Branch Chiefs, Regions I-X

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               Hadul Letter Froin ltegiornI  Administrators      Revised on
 '  ' REF 1-3              .  to State Agencies      '.-           10/7/77


     On August 7, 1977,  President Cart-r signed the Clean Air Act
Amendments of 1977.  As  a result, several  new tasks are being required
of the States find of the Environmental Protection Agency (EPA),      • •

     One  of the most pressing tasks prescribed by the Clean A1r Act
Amendments Is the submission by each State, by December 5 of a list  •
of air quality control regions (AQCRs) or portions thereof which
denotes the attalnment/nonattalnment status of the areas In regards
to the National Pjrjblent  Air Quality Standards (NAAQS)'for'all criteria
pollutants. -Section 107 of the amended Act requires, attainment
designations as js shown by tha attached fomat which we request you
.follow when compiling State designations.    '    •             "
 •         .        -  »       "-".*
  •"  Generally, the area designations should  be on a basis not'
larger than an AQCR.  However, the Act does allow that,, when adequate
Information Is available* States may divide AQCRs.into various non--
attainment, attainment or unclassiffable portions.  The designated
area should be es precise as feasible, i.e.,  county,, sub-county or
other  geographic area  that can be clearly defined in v/r1tten terms.
A  different geographical area can be used in  designating each pollutant.
The  attached listing format is designed to accommodate such sub-AQCR •  •
designations.without modification to the form.   •     •  '•-.  .. .

     OAQPS Guideline Ho. 1.2-015, Guidelines  for  the Evaluation of
Air Quality Data published in February, 1974, should be used to  r~
evaluate air quality data in making the required  determinations.
That is,  each monitoring site within the designated area must meet
the  standards or the area 1s considered nonattainment for the specific.
pollutant. The ciost recent consecutive four  quarters of data available  "
-are  to be used.  If the most recent four quarters  of data show  attainment*
the  previous four quarters of data should also be examined.- This
minimizes the chances  of relying on a single year's data which might
reflect abnormally favorable meteorological  conditions.  In using
older  data, States may wish to account for control that has. taken   '  .
place  since those data were recorded.  Modeling data can be  used to
supplement or be used  in lieu of ambient data. Future growth  should
not'be considered 1n determining attainment status for purposes  of
Section 107.         '   .                         •  •
                    •                     *                         ™

     You  should  bs nware of the implications of designating an area
as attainment, nonattainment* or unclassifiable.   Tor any  pollutant,
the  designation  of "nonattaimnent area" uill  require that  a SIP be
developed for that area  by January 1, I97g.   During  this interim
period, offsets will be  required in the nonattainmant areas.   However,.
the  baseline  for determining offset'credit will ba the applicable  ••_"<
SIP  regulations  at the tiros a permit "is considered.                 ' •'*

     In designating the  attainment status for ths criteria pollutants,
the  following guidelines apply:                      -.  •

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                     REF  1-3


Total Suspended Particulatcs

     The area should be designated attainment when  a  TSP  violation can
be clearly attributed to rural fugitive dust (as  defined-ln the  EPA
fugitive dust policy paper).                 I

Total Suspended Particulates and Sulfur Dioxide            • '     .

     In cases where an area 1s unciasslfiable or  1s designated as
attainment, major new or modified sources must be reviewed to  ensure
consistency with PSD requirements.

Carbon Honoxide                              ' '

     Specific areas covered by monitors showing violations should  be
designated as non-attainment.  However, SIP revisions covering larger
geographic areas may be  necessary to solve  the non-attainment problem,

Photochemical Oxldants
      It is  well  established that the high concentrations of oxldant
 precursors  and the ratio  of hydrocarbons to nitrogen oxides typically
 found 1n major urban areas 1s  conducive to formation of photochemical
 oxidants.  For example, measured data  from cities with urbanized area
 populations exceeding 200,000  show violations of the oxidant standard for •
 all  areas where data are  available.  Data are available for almost all'
 urbanized areas that exceed 200,000 population.-Accordingly, non-attainment
 can, and should be presumed for all such urbanized areas, even for those
 few urbanized areas that  do not have measured data.  Since oxfdent
 levels well In excess of  the oxidant standard have been shown to persist
 for many miles downwind of urban areas, the area designated as non-
 attainment  around urban areas  should reflect this phenomenon.

      Because urban areas  are  relatively numerous east of  the Mississippi;
 River, there are few, 1f any,  areas that are not affected by an urban
 oxidant plume.  Available rural monitoring  data support this conclusion.
 Rather than designating areas  as  unclassffiable, States east of the
 Mississippi River are encouraged  to designate  their  State non-attainment
 (which probably reflects  the  actual case).   The  fact that ozone Is
 transported from urban areas  will  be  explicitly recognized in the
 development of policies related to SIP content and approval.  Additional
 monitoring will be required for areas  designated as  unclassifiable   '  .'
 pursuant to Section 107  (d)(l)(E).  If data showing  non-attainment
 become available, the appropriate change to the  attainment status must  .
 be made.

      The Act  requires that States submit designations to  EPA by December  5,
 1977.  EPA must then promulgate the lists  In the Federal  Register by
 February 3, 1970, with any modifications as necessary.   When any mod-
 ification  to  the  list is proposed by  the Administrator, the affected
 State will be notified and provided an opportunity to demonstrate why
 the  proposed  modification 1s  inappropriate.  EPA will compile all State
 lists with all modification?;  as may HP nproccat-v/ ar.H pnhi-ich  as required  —
 by  the Act.

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                                        REF  1-3
     Given the time required to desinn.ilo  attainment status and resolve
any differences which may arise, we niuld  appreciate 1t if you would give
this your immediate attention.  If you have  any questions, please
contact (designated Regional Office contact).

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                               List of Noncon ,'Mncj  Regions
                     Section 103 of the 1977  (.loan Air Act Amendments

FORMAT A for Designating TSP and SO,
Designated
Area
Area designated
can he an AQCR,
county or other
defined geo-
graphic area
Primary Standard
Exceeded
Section (d)(l)(B)

Secondary Standard
Exceeded
Section (d)(l)(C)

Unclassifiable
Section (d)(l)(D)

Attainment

.FORMAT B for Designating CO/0 /NO,
                             A   L.
Designated
Area
Primary Standard
    Exceeded

Section (d)(l)(A)
Unclassifiable
                                             Section (d)(l)(E)
Attainment
                    Section (d)(l)(E)
 Area  designated  can
 be  an AQCR,  county or
 other defined  geographic
 area
 INSTRUCTIONS:
 Format A is  to be used  for designating  the  attainment  status  for  TSP  and  S0
 required by  Section 103 (d)(l)(B);  Section  103  (d)(l)(C)  and  Section  103
 Format B is to be used for designating  the attainment  status  for  CO,  oxidants
 and N02 required by Section 103 (d)(l)(A)  and  Section  103  (d)(l)(E).
 A separate table is to be used for designating the status  of  each pollutant.
 An "x" is to be used to indicate the appropriate status  of each pollutant using
 at least the most recent four consecutive quarters of  air  quality data or
 modeling data where applicable.

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                                       REF 1-4

                     UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

  DATE:   23 JUL 1978

SUBJECT:  Questions  and Answers on 1979 SIP Revisions
  FROM:  G.  T.  Helms, Chief
         Control  Programs Operations Branch

    TO.-  See Addressees Below
              This is a compilation of the five monthly questions and answers

         memos.   Also included are questions and answers (dated January 12)

         from the January Air Branch Chiefs1 meeting in Denver.  The questions

         and answers are grouped by subject in the hopes it will enhance the use

         of the memos in clarifying the 1979 SIP revision requirements.  The

         date of the original memo follows each question.

         Enclosure

         Addressees:

         Thomas Devine, Region I
         William Baker, Region II
         Howard Heim, Region III
         Greg Glahn, Region IV
         Wayne Pearson, Region V
         Jack Divita, Region VI
         Art Sprat! in, Region VII
         Robert DeSpain, Region VIII
         Wayne Blackard, Region U
         Clark Gaul ding, Region X
 EPA Form 1320 6 (Ret. 3-76>

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                        SECTION 107 DESIGNATIONS


Q:  What are the general criteria for EPA promulgation where a State
defaults and a violating monitoring site is present?  And for EPA
acceptance of State designations for Section 107? (1/12)       	

A:  Given below on a pollutant-by-pollutant basis are the two cases—first,
where EPA must promulgate the area to be generally designated as  non-
attainment is given; and second, the criteria to be  used by  the Regional
Offices in evaluating State submitted designations.

TSP

EPA promulgation — political boundaries such as county, city.
State designation — if monitoring sites are unrepresentative according
to SAMWG — call area unclassified.

Oxidants
EPA promulgation — county as a minimum.
State designation — accept all reasonable designations.
EPA promulgation — county as a minimum.
State designation — accept all reasonable designations.

Cp_

EPA promulgation — urban core area.
State designation — accept reasonable designations.  Regional  Office
would redesignate as "unclassified" if State submitted attainment designa-
tion for large urban area > 200,000 population with no monitoring or
modeling data.

   Designation of all areas as nonattainment, attainment, .or unclassified
relative to air quality standards must be made by EPA in  e'arly February,  1978,
based on State recommendations due December 5, 1977.
                                                       '• t' —
Q:  Which should be given preference "in designating areas,  monitored data
or modeling results? (1/1 2)

A:  In urban areas monitoring results should be used.  For areas around
isolated point sources, especially for S02, it is difficult for a few
monitors to catch the hotspot.  If there is a conflict between adequate
monitoring data and modeling results, monitored values should be used.
However, if the monitoring data are inadequate, then available modeling
results should be used.  It is not necessary to model specifically for
the §107 designations.

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Q:  Is there any flexibility allowed in determining nonattainment areas? (1/12)

A:  Areas clearly showing attainment or nonattainment must be classified -
as such.  Areas with only sketchy data may be defined as unclassifiable.

   We recognize the subtle complexity of this issue and the inherent
difficulties created by the above guidance.  However, two factors must
be recognized:  (1) sites with clearly defined nonattainment problems
cannot be arbitrarily reclassified except as provided in the fugitive
dtisf policy paper; and (2) a SIP cannot be totally approved by EPA
uriTess it 6*em'drtstrates attainment of the NAAQS in all areas.

Q:  Are all sampling sites to be included in determining nonattainment
areas?  (1/12)

A:  Yes, unless it can be clearly shown that such data points do not
represent the true ambient air quality occurring at the site in question.

Q:   If the last four quarters of sampling were shown to be abnormal  in
terms of frequency and magnitude of violations, would previous data  be
accepted as the basis for not declaring nonattainment status at this
time?  (1/12)

A:   Both the long term trend and specific data point given by the four
quarter analysis should be examined.  If there is a discrepancy between
the  two, the State should make a judgment as to which is the most valid
indicator.  Rationale utilized in making this judgment should be provided
to EPA.  As a practical guide, data significantly impacted by rare
meteorological conditions (for example, the recent Northwest drought)
may  be considered abnormal and thus be discounted for these determinations.

Q:   Will EPA accept a designation of attainment for>an area with a monitor
showing recent violations due to a temporary situation such" as construction? (1/1

A:   Yes, if a history of attainment can be shown and if the temporary
activity is demonstrated to be responsible for the violation.

Q:   Is it necessary to designate an area~as nonattainment if the source
of the violation is known and regulatory measures are underway? (1/12).
 A:  Yes, if the data are available and valid.   The area'of nonattainment
 can be made small in these situations.

 Q:  Is the boundary of a..nonattainment area best  determined by the
 "contour"~around areas experiencing ambient violations  or by the
 location of sources that contribute to these violations?  (1/12)

 A:  Nonattainment areas are in .general defined by ambient violations.
 It appears that sufficient flexibility exists  to  allow  States to  include
 an additional area around the actual nonattainment area to make new
 sources located immediately adjacent to the problem areas subject to
 offset requirements.

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Q:  What are EPA's intentions on Ox designations?  (1/12)

A:  It  is our  intention to designate all urbanized areas with populations.
greater than 200,000  (1970 census) as nonattainment for Ox even in the
absence of  air quality data.  Valid rural data on Ox cannot be ignored
and at  a minimum the county in which the sampler is located must be
declared nonattainment if a violation has been recorded.

Q:  Does EPA intend to hold public hearings on the State designations
of attainment  status? (1/12)

A:  EPA does not intend to conduct public hearings on the State designa-
tions.  Instead, EPA  will publish anlist of attainment, nonattainment
and unknown designations qn_February 3, 1978, followed by a 30-day	
comment period^ Any  changes_to the designation status will be promulgated  I
'at least 30™days later/ ^	/

Q:  Should  illegal stack heights be considered in Section 107 designations? 0/T2

A:  Yes, to the extent that they are known.

Q:  Can attainment/nonattainment status be changed? (1/12)

A:  Yes.  An area designated nonattainment on the basis of this year's
data  could  be  redesignated whenever the data show that the area has
achieved attainment.                 .-.               ...

Q:  What form  will the February 3, 1978, Federal Register notice take
which will  give the State designations for attainment/nonattainment areas
as required by Section 107 of the Clean Air Act?  (1/12)

A:  The designations  will appear in the notice section of the Federal!
Register with  a general national perspective preamble accompanying the
actual  list of designations as approved by EPA.  Where necessary, a
portion of  the preamble will be devoted to a discussion for any signifi-
cant  actions taken by the Regional Offices.

     Q.   Is it true that if a  monitor is properly  sited, i.e., influenced
 by a significant stationary source,  then  the area of the nonattainment
 designation should be as  small  as  possible, so as to reflect only the-
 impact of a nearby source? (6/2)

     A.   Yes.   The nonattainment area may  be as small as possible as long
 as it covers  the whole area of the source's impact.

..„ ..  Q.   Should monitors that are improperly sited, according to EPA
 criteria, and hence could be unduly influenced by resuspended street
 dust, be ignored in establishing the attainment status of  an area?  (6/2)

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    A.  No.  It is not current Agency policy that only those monitoring
sites which meet SAMWG guidelines be used for both SIP development and  -
Section 107 designation purposes.  EPA's proposed guidance states that
there are situations in which data from existing monitors located in the
"unacceptable" zone may still be useful.  For sites not located within.
the proposed guidelines, an evaluation is needed to determine the roadway
influence.  This evaluation is then used to decide if the roadway influence
is significant enough to warrant relocation of the monitor.  If relocation
is necessary, the monitor must be within the immediate vicinity of the
original location such that the new site meets the proposed guidelines.
The area is presumed to be nonattainment until such time as data from
the relocated station indicate otherwise.
    Q.  Are States required to monitor air quality in areas desig-
nated as unclassified in order to establish a base for determining the
attainment/nonattainment status?  (7/11)

    A.  No specific monitoring requirements apply.  However, the require-
ment for sources subject to PSD regulations to obtain one year of air
quality data prior to construction does apply and that data could be
used for purposes of designating the area.

   •s,  Q.  What is the future of the Section 107 designation  process?  Will
  designations be modified, changed, and updated  on any kind of annual
  basis? (7/28)

      A.  There is no specific schedule for revising  the Section 107 desig-
  nations.  The designations are dynamic and designation changes are to be
  made whenever new and relevant information is brought to  the attention
  of the State (or EPA if the State does not act.)  The designation changes
  are to be accomplished by-the Regional  Office as an informal rulemaking
  action revising Part 81.

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                      EMISSION INVENTORIES
  . Q.  Must the emission inventory forms recommended in the workshops
on requirements for nonattainment area plans be used for submitting
Inventories with the 1979 SIP submissions? (6/2)

    A.  No.  The formats in the nonattainment workshop summaries are
merely suggestions.  Due to the vast number of computerized systems
using varied storage formats, it is nearly impossible for all submissions
to fit the particular suggested formats,  Whatever particular summary
format a State chooses, must be approved by their Regional Office and
should reflect that the emission inventory is accurate, current, and
comprehensive.

  ..',• Q.  Must chemical species information be included in the emission
inventory?  (6/2)

    A.  Total nonexempt volatile organic compound emissions are  the only
emissions that need to be identified in the emission inventory submitted
in the January, 1979, plan.  Chemical species information may be useful
in the determination of the most appropriate method of control for a
particular industry, but this information need not be submitted  in the
emission inventory.

    Q-  Emission inventories are to 6e on an annual basis, yet some
problems and standard violations occur on a short-term, basis (daily
or seasonal).  Is there a way these sources can be reported so their
emission inventories will reflect this? (3/31)

    A.  If the nonattairment area has short-term problems, the State can
attempt to develop a selective short-term emission inventory for those
sources which have an impact on the air quality problem.

  '  Q.  Are sources located outside a nonattainment area  which significantly
impact on that area required to be inventoried? (3/31)

    A.  Sources outside the nonattainment area which, due' to meteorological
conditions, impact on the nonattainment area are required to be  included
in the emissions inventory.   It is unlikely that standards will  be
attained if these outside sources are not part of the inventory  and con-
trol strategy.                                                -

  .   Q.   What date is acceptable as a "current" emission  inventory? (5/H)

     A.   A "current" emission inventory is generally considered  to be
 1977.  However, the emission inventory should be comparable with the
 air-quality data used to develop the control  strategy and if pre-1977
 air quality data were used, a "current" emission inventory can  be
 anywhere from  1975-1977.

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  ,; Q.  What information is available to do a mobile source emission
inventory?  (6/2)

    A.  Mobile Source Emission Factors (EPA 400/9-78-005) is now available.
The computer program Mobile 1 tape along with a short user's guide, is
available from Len Fleckenstein in OTLUP (755-0603).

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                           FUGITIVE DUST
   As previously stated in the Hawkingsto the Regional
nemo-dried October 7, 1977, for rural  areas,  the ™
dust to monitored air quality levels can be neglected before dete
the attainment/nonattainment status for Section 107 designations.

Q:  For purposes of defining nonattainment areas for TSP, what is rural
fugitive dust? 0/12}

A-  The State may subtract both the impact of industrial sources  located
within an area and the normal ambient background level.  The remainder
may be considered "rural fugitive dust" in non-urban areas.

Q:  Windblown particulate need not be counted against nonattainment in
rural areas but all particulate must be counted in urban areas.  What
is a rural area? 0/12}

A:  Significant flexibility is allowed in this determination.   Generally,
Regional Offices have b&en using 25,000 population as the cut  point between
an urban setting and a rural situation.  However,  for the purposes.of
implementing the fugitive dust policy, rural  areas are determined by
the following criteria:  (1) the lack of major industrial development
or absence of significant industrial particulate emissions; and (2) low
urbanized populations.               %.

  .   Q.  If an area influenced by fugitive dust is designated  as  a non-
 attainment area due to point source emissions, does the control  strategy
 analysis have to include fugitive dust controls?   (5/4)

     A.  Yes, fugitive dust may only be discounted in accordance  with
 the fugitive dust policy paper.  An area which cannot be classified as
 attainment through the discounting of fugitive dust cannot subsequently
 discount fugitive dustr sources in developing control strategies, assuming,
 of course, that point source control alone will not be sufficient to
 attain the ambient standards.

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                               OFFSETS
Q:  If a source locates or expands  in an attainment area and is therefore
not subject to offset, can it  be  allowed to significantly contributes
to violations of standards in  an  adjacent nonattainment area? (1/12)

A:  No, the requirement that each NAAQS shall act as an overriding ceiling
to any otherwise allowable increment assures that a source constructed
in an attainment area will not significantly contribute to violations of
standards  in an adjacent  area.

Q:  Can sources be allowed to  construct under the State emission offset
ruling after July  1979?   (1/12)

A:  Yes, in the following situations:

     (1) The requirements  of  Part  D  are otherwise met, but the allowance
for growth has been used  up  (or none was provided initially).

     (2)  If an area is  determined  to be nonattainment subsequent to the
Initial  February  1978  designations, a State will have 9 months in which
to develop an acceptable SIP,  and EPA will have six months to approve
during which time new sources  may be  permitted  in accordance with the
offset  ruling.                       .-_.

   •-  Q.  How is a  nonattainment area treated before promulgation  in the
  Federal Register, specifically with respect to offsets?; (6/2") '

     A.  Section  1G7 designations in no way affect offset requirements.
  Once data show an area to be  nonattainment, the area is required to  get
  offsets imnediatelyv  irrespective  of the Federal promulgation date.  This
  works both ways.  .If  data show an  area to be attaining the standards and
  that a new source will not cause or contribute to a violation, offsets
  are not required.

       Q.   Are hydrocarbon (HC) offsets required of major new sources
   locating in rural Ov nonattainment  areas? (5/4)
                      ^^
       A   Yes,  offsets are required in rural  0   nonattainment areas until
   the Stste develops a SIP which  demonstrates Attainment in the urban non-
   attainment areas and requires RACT on  all  existing  100 ton HC sources
   located in rural nonattainment areas:   The required  offsets, however, do
   not have to be  obtained in  the vicinity of the proposed new source.
     Q.  Does a source wishing to construct in a nonattainment area need
  to obtain offsets if the new  source permit is approved after  the SIP is
  submitted? (7/11)

     A.  Offsets are required  up  until the time a SIP is approved by  EPA
  even if the SIP submittal has a  margin for growth provision rather than
  an offset requirement.   However, rather than go through the offset ruling,
  the State could process  a new source application under the new source
  review procedure  in the  revised  SIP.  As soon as EPA approves the SIP,
  the State can issue the  nermit.

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                                   PSD

Q:  Do the PSD Increments become applicable when an area moves  from
nonattainment to attainment? (1/12)

A:  No.  Since the baseline for determining air quality deterioration
for PSD purposes is air quality as of January 6, 1975 (which  exceeded
the NAAQS), the NAAQS would always be more restrictive than any PSD
increment.

Q:  Can Indian reservations unilaterally redesignate to Class I? H/12)

A:  Yes, Indian reservations can reelassify their lands from  Class  II
to Class I by following the proper procedures outlined in the Clean Air
Act Amendments and PSD Federal Register.

Q:  Can a new source be allowed in a rural attainment area that is  just
barely achieving the NAAQS if the source's emissions, even though within
the allowable PSD increment, would cause violations of the NAAQS?  (1/12)

A:  No.  If the source would cause violations of NAAQS,:it would not be
allowed to build.  PSD increments are not allowed to cause an area  to
exceed the NAAQS.  Yes, if offsets are practiced.

Q:  If a source is constructed in a nonattainment area and meets the
required offset, would it be allowed to violate PSD increments  in an
adjacent Class I area even though it is not subject to the PSD  regulations?(1/12)

A:  PSD reviews are required in all areas.  The source would  not be
allowed to violate PSD increments in any area.

Q:  Will sulfur dioxide from ships be included in the PSD requirements
if the potential cumulative emissions exceed 250 tons per year? (1/12)

A:  Yes, it is recommended that the S0£ emissions from ships  be included
in the PSO analysis for the duration of time that they are docked or
attached to the facility.

Q:  Do hydrocarbons and oxidants have to be included in PSD reviews at
this time?  If not, when do you anticipate that they will-be  included?_
If these pollutants are to be included at some future daie\ will
facilities previously planned or under construction be exempt?  (1/12)

A:  If a source can get a final permit by March 1, 1978, the  PSD
applications will only need to assess the impacts for 562 and partic-
ulates.  After March 1, 1978, the new definitions and regulations under
Section 165 will go into effect.  (Even a source which could  obtain a
final permit by March 1, 1978, must be reviewed in accordance with  the
new rules to be issued in March if it will commence construction on or
after December 1, 1978.)  BACT would be required for all sources which
require PSD review.  Increments for hydrocarbons and oxidants may go
into effect within the next few years.

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    Q.  Will EPA require PSD permit applicants to monitor for hydro-
carbons in addition to oxidant?  (7/11)

    A.  Since the  .24 ppm hydrocarbon standard is only a guide for
developing SIPs to attain the oxidant standard, no monitoring for hydro-
carbons will be required.

    Q.  What is the effect of reducing baseline emissions? (7/11}

    A.  Reductions in baseline emissions (such as the application of
RACT as a result Of 1979 SIP revisions) will serve to expand the avail-
able increment for an area.  .

 T'-  Q.  Does a SIP relaxation count against a PSD increment? (7/11)

    A.  SIP relaxations that were pending as of August 7, 1977, are  part
of the baseline.   The contribution to the baseline from existing sources
affected by the relaxation that was pending as of August 7 would be
based on the allowable emissions under the SIP as revised.

        SI? relaxations received by EPA after August 7, 1977, but before
promulgation of the PSD regulations do consume increment.  However,
these revisions require special consideration due to the uncertainty of
how the new Act would apply to such SIP relaxations.  These SIP relaxa-
tions need not be  individually assessed to determine the.precise amount'
of consumed increment before such relaxations may be approved.  The
periodic assessment requirement to verify that the applicable increments
have not been exceeded is thought to be sufficient protection.  This
assessment would result in revisions to the SIP if an increment were
found to have been violated.  All SIP relaxations received after the
date  of promulgation of the PSD regulations will be individually reviewed
against the available PSD increments.  If deterioration beyond that
allowed under the.available increments would occur under a SIP relaxa-
tion, then such a  SIP revision would be disapproved to the extent that
it would cause significant deterioration.  Whether a plan relaxation
would consume the  available increment would be typically determined
through nicdeling the difference between the allowable emissions resulting
from  the new relaxed SIP limit and the emissions of the applicable
source(s) which were included in the baseline.

    Q.  Can EPA delegate PSD as an interim measure? (7/11)

    A.  The PSD program can be delegated to the States as has been done
in the past.  States should, however, be encouraged to develop their own
PSD program.

    Q.  Does an applicant located in a nonattainment area have to obtain
one year of air quality data if the control agency has sufficient data
reflecting the predicted ambient impact of the new source?  (7/11)

    A.  No.  If the Regional Office feels that existing air quality data
are representative, then no additional monitoring would be required.

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    Q.  SIP relaxations which would exceed the air quality increments
established under Part C of the Clean Air Act to Prevent significant
deterioration will be disapproved.   Will  this be retroactive for previously
approved SIP relaxations?  (7/11)

    A.  There is no need to immediately disapprove previously approved
SIP relaxations which would have caused the increment to be violated.
However, the State should be notified of  the need to assess the possible
violation of the increment.  If the review indicates a violation of an
increment, then the plan should be revised within 60 days or such  time
as determined by the Administrator.  The  SIP revision should be designed
to obtain such reduction in emissions so  that the increment is no  longer
exceeded.

    Q.   Is it appropriate  to disapprove implementation plan relaxations
if such  relaxations would  exceed the  air quality increment established
under Part C of the Clean  Air Act  (CM) to prevent significant deteriora-
tion  (PSD) of air quality? (3/31)

    A.   Yes, Section 110(a)(2)(j)  of  the CAA requires, prior to         j
approval, that each plan contains measures to prohibit a stationary
source from emitting pollutants which^would interfere with any PSD
increment.  Any SIP relaxations which exceed the increment would  be in
violation of this provision.  It should be noted that this policy
applies  in all instances,  even if the^relaxation would not jeopardize
attainment or maintenance  of jthe ainbiint standards.

    Q.   If a State is  conducting some of the PSD review, but not issuing
permits, should it obtain  a formal  delegation of authority from EPA to
conduct that review?  (7/28)

    A.   Yes.  In order to  clarify  the relationship between EPA and the
State, the Governor (or his designated agent) should request a partial
delegation.                          ,•-.

'*•  Q.   Will post-construction monitoring play any role in determining
whether a source has used  up the increment? (7/28)

    A.   Section 52.2!(n)(l) of the  PSD regulations provides that the
owner or operator shall conduct such  post-construction monitoring as  the
Administrator determines may be necessary to establish the effect which
emissions of a criteria pollutant from a source are having or would have
on air quality,  in the preamble to the regulations, EPA indicates it
would, in any event, only  require monitoring data for the purpose of
determining whether a NAAQS has been  or would be violated.  At the
present  time, however, EPA is generally not requiring post-construction
monitoring for this purpose.

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 •-.  Q.  What is EPA's role in approval/disapproval of PSD classification
redesignations?  (7/28)

    A.  EPA can disapprove a redesignation only if the procedural  require-
ments of Section 164 of the Clean Air Act and Sections 52.21(g)  are
not met (which includes, e.g., failure to give public notice or  failure
to hold public hearings) or if the redesignation is inconsistent with
Section 162(a) or Section 164(a)(l)(2).  If the above requirements are
satisfied, EPA cannot overturn a redesignation and will approve  the
redesignation.

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                CO AND Ox  ATTAINMENT DATE EXTENSIONS
     Q.  What is the effective date of Section 172(b)(ll)? (5/4)

     A.  Section 172(b)(ll) states that when a plan due on or before
 January T, 1979, demonstrates that attainment is not possible for either
 0  or CO (or both) before December 31, 1982, that plan must establish a
 plrmit system, a schedule for implementation of inspection/maintenance
 (I/M), and identify other measures necessary to provide attainment by
 December 31, 1987.

  ^- Q.  Can an extension to 1987 be requested after 1979 if the original
 1982 attainment for CO or 0  (or both) does not materialize? (5/4)

     A.  Yes.  If a State has their SIP approved in 1979 which provides
 for attainment of CO or 0  (or both) by 1982, but that plan later proves
 inadequate for achieving attainment by 1982 and the State demonstrates
 that it cannot attain the standards by 1982 despite the implementation
 of all reasonably available control measures, a plan revision may be
 submitted providing attainment by 1987.

    Q.  If a State concludes it is impossible to demonstrate attainment
 of  the CO or 0  standards or both by 1987 using all reasonable measures,
 will there be § no growth sanction as of July, 1979? (7/11)

    A.  A State should not draw that conclusion.  The Clean Air Act requires
 commitment to the implementation of all RACT in the January, 1979, SIP.
 If  these reasonable measures are not adequate to show attainment, the
 State must identify the-additional control measures which could theoretically
 produce the additional required emission reductions and commit to further
 investigation of the measures.  However, the Clean Air Act does not require
 that a State commit in 1979 to implement these specific additional measures.
 Such a comnritjnent is not required until 1982.
                                     • *^.
    Q.  For CO nonattafnroent areas which cannot attain by 1982» is
 inspection/maintenance required? (6/2)

    A.  Yes.  Section 17Z(a)(2) of the Clean Air Act says that in the
 case of the nationa-1 primary ambient air quality standard for photochemical
 oxidants or CO (or both) "if the State  demonstrates...that such attainment
 is  not possible in an area with respect to either or both of such pollu-
 tants within the period prior to December 31, 1982,...such provisions
shall provide for the attainment of the national primary standard for
the pollutant (or pollutants) with respect to which such demonstration
 is made,  as expeditiously as possible but not later than December 31, 1987."
Section 172(b)(ll) says that in the case of plans which make a demonstra-
tion pursuant to Section 172(a)(2), the plan provisions shall establish
a specific schedule for implementation  of a vehicle emission control
inspection and maintenance program.  However, as a matter of policy, EPA
is not requiring I/M in cities with populations of less than 200,000.

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                         GENERAL REQUIREMENTS


Q:  What are the criteria that must be met for  EPA to approve a State
submitted SIP revision due in January, 1979?  (1/12)

A.  The criteria for approval are contained in  the Hawkins1 memo of
February 24, 1978, entitled "The Criteria  for Approval of 1979 SIP
Revisions."

    Q.  If attainment is reached before the projected date (1982 or 1987),
do control strategy measures not yet  effective have to be implemented? (3/31)

    A.  Yes, unless the State wants to reevaluate the control strategy
and demonstrate that some of the controls  are no longer needed in view
of changed conditions.  Unless there  is some reason to doubt the control
strategy, it should be assumed that all the measures must be implemented
to assure attainment at all  times, not just during years with good
dispersion conditions.

    Q.  Do the 1979 SIPs have to demonstrate maintenance and if so, for
how long? (3/31)

    A.  The 1979 SIPs must demonstrate both attainment and maintenance.
For most areas the maintenance requirements are satisfied by first
demonstrating attainment and then having, adequate new source review
(NSR) procedures.  For air quality maintenance areas (AQMAs) for which
the Region has determined the need for an  AQMA plan, such a plan is
still required and maintenance for a  period established by the Region
must still be demonstrated.  Otherwise, unless a nonattainment area is
within an AQMA or there is a severe problem with minor source growth, a
NSR program is adequate-for  satisfyinq the maintenance requirement.

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                          SECONDARY STANDARDS
    Q.  Can an 18-month extension be granted for submission of a secondary
standard control strategy? (6/2)

    A.  Yes.  A state may request from the Administrator an extension
under-40 CFR 51.31.  Such a request shall show that attainment of the
secondary standard will require emission reductions exceeding those
achieved through application of RACT.  A request for an extension must
be submitted early enough to permit development of a plan prior to the
deadline in the event that such request is denied.

  V Q.  What criteria must a State meet prior to changing the date
specified for attainment of a secondary standard?  (5/4)

    A.  Section 172(a)(l) of the CAA requires that secondary standards
be attained as expeditiously as practicable, while Section 110(a)(2)(A)
requires that secondary standards be attained by a reasonable time.
Reasonable time for attainment of TSP and sulfur dioxide (S02) secondary
standards is 1982 if only reasonable available control technology (RACT)
is needed to attain and maintain the secondary standard.  Section 51.13
of Title 40 of the Code of Federal Regulations states that in any
Region where application of RACT will not be sufficient for attainment
and maintenance of the secondary standard,  or where the State  shows that
good cause exists for postponing the application  of such control  technology,
reasonable time shall  depend on the degree  of emission reduction  needed
for attainment of such secondary standard and on  the social, economic,
and technological problems involved in carrying out a control  strategy
adequate for attainment and maintenance of  such secondary standard.   A
date specified for attainment of a secondary standard which satisfies
these requirements will also satisfy the provision of Section  172 which
requires that the secondary standard be attained  as expeditiously as
practicable.

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                      NONATTAINMENT AREA PLANS
    Q.   Does  the January 1,  1979,  submission date hold for areas redesig-
 nated nonattainment for minor boundary adjustments as a result of the
 sixty-day comment period on  the March  3,  1978, Section 107 designations? (6/2)

    A.   Yes.   Any nonattainment area revised for minor boundary adjustments
 as  a  result of the 60-day comment  period  on the original designations promul-
 gated March 3, 1978, is required to submit a SIP before January 1, 1979.

 ; ' • Q.   When  are SIPs due for nonattainment designations made after the
 revised March 3, 1978, final promulgations? C6/2)

    A.   SIPs  are due nine months from  the date of any new promulgations.

 Q:  Will  all  nonattainment areas of primary and secondary standards
 require SIP revi sions? (1/12)

 A:  Nominally, yes, but the  exact  nature  of the SIP revision could vary
 considerably.  For instance, a number  of  TSP nonattainment areas will be
 washed  out in advance by current EPA policy that authorizes a designation
 of  "attainment" where present nonattainment is demonstrated to be cause
 by,rural  fugitive dust sources. It also  appears possible in a number of
 cases that attainment might  be possible by December 31, 1982, without
 adding  any significant new regulatory  requirements to the SIP; in such
 cases,  the SIP "revision" might consist of an official notification that
 the time extensions for the  primary and the secondary-NAAQS contained
 in  the  Clean  Air Act Amendments (accompanied by the underlying analysis).

 Q:  Is  there  any difference  between violations of primary and secondary
 standards in  terms of actions that must occur, especially with regards
 to  offset? (1/12)

 A:  SIP revisions are required for both violations of primary and
 secondary standards.  Offsets apply in both cases until July 1979 unless
 the State subnets a revised  attainment date for the secondary standard
 for either TSP or sulfur dioxide.

Q:  Where a nonattainment plan  is  required by Section 178, should EPA-
require the States  to  implement the provisions of Section-124 (i.e.,  -
consider whether low polluting  fuels that are presently being used will
continue  to be available)  in  their January 1979 SIP submissions?  (1/12)

A:  Yes.  It makes  little sense for a  State to revise their SIP without
dealing with  these  issues, and  then have EPA call for a SIP revision
several  months  later.   Where  a  SIP is  not required to be revised as
a result of a  nonattainment designation, the analysis and submission
of a revised SIP  (if necessary)  may be done on the more extended
schedule outlined in Section  124.

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                   RURAL Oy WONATTAINMENT AREAS
    Q.  Are control strategies needed (and if so, what should they look
like) for States whose only 0  nonattainment areas  have a population of
less than 200,000 persons? (7711)

    A.  Control strategies are needed for all  areas designated nonattain-
ment, but their form and substance will  vary depending on the nature
and complexity of the problem.  To have  an approvable  1979 SIP, areas
less than 200,000 persons need only to adopt VOC RACT  regulations  for
100 tons/yr point sources.  As a minimum, these regulations should be
accompanied with an emissions inventory  quantifying emissions  from the
affected sources.  For the 1982 0  SIP,  the State should  adopt a more
detailed plan which can rely upon any mix of measures  it  desires—
Federal Motor Vehicle ControlJProqram, additional stationary source
controls, I/M, and any other measures.  A control strategy demonstra-
tion showing attainment must also be contained ijrijthe  1982,SIP.

....  Q.  Must the attainment plan for areas designated  nonattainment for
photochemical oxidant with a population  less than 200,000 contain  an
organic compound inventory? (7/11)

    A.  If an area has been designated nonattainment in accordance  with
Section 107 of the Clean Air Act, then the attainment  plan must contain
an inventory of organic compound emissions regardless  of  population.
However, where a plan specifies Statewide RACT control..for major sources,
detailed emission inventories are required only for those areas specif-
ically designated as nonattainmenr.

  '\  Q.  If an 0  nonattainment area with a population less than 200,000
 (i.e., rural arias) develops a control  strategy, can  Federal  monies be
 used?  (5/4)

     A.  The classification of areas by  population  is  primarily for the
 purpose of rural end non-rural consideration as well  as  for  setting of
 priority for resources.  In some areas  it may be necessary to develop
 strategies in these rural areas.  If available, Federal  monies can be
 used in these areas and the use and amounts of monies should be nego-
 tiated with the State and/or local agencies involved  with the strategies.
    Q.  Are  rural araas  nonattainment for photochemical  oxidants  required
to implement reasonably  available control  technology  (RACT)?  C3/3V}

    A.  RACT must be applied  to rural major stationary sources with the
potential for emitting more than 100 tons  per year, but  a demonstration
of attainment does  not have to be made  for such areas.

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 •   Q.  Even though it is not required for rural areas to demonstrate
attainment for oxidants, how are areas with urbanized populations of
40,000 - 200,000 classified? C3/31)

    A.  There may be some adjustment later, but for now areas with
populations greater than 200,000 are considered urban areas  and any
areas less than 200,000 are considered as being rural areas  for purposes
of demonstrating attainment.

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                           RACT REGULATIONS
Q:  RACT on selected source categories is a requirement for SIP
for Ox SIPs.  RACT is defined by the CTG documents.  Many States have
existing regulations for VOC that are already being implemented   Can
RACT determinations be softened to account for existing regulations and
control control efforts? (1/12)

A:  While it is recognized that RACT will be determined on a "^-by-case
basis, the criteria for SIP approval should rely heavily upon the informa-
tion contained in the CTGs.  Any deviations from the use of the crbs
shouTd ba- adequately documented to be approvable.                   -----   >

    X. Q,  Is it possible to approve hydrocarbon control regulations which
  are less stringent than the emission limitations provided in the CTGs?(5/4)

      A.  Yes, in son* cases if adequate justification is provided.  Where
  economics or other circumstances justify regulatory requirements less
  stringent than those contained within CTGs, such justification is to be
  clearly documented .in the SIP submittal.           ..,_..
  **>  Q.  What will be accepted as adequate justification  to explain
  deviations from the CTGs for hydrocarbon regulations?  (7/28)

     A.  Where deviations from the CTG results in a more  stringent control
  requirement, no justification is necessary.   However,  a  deviation resulting
  in a less stringent control requirement is acceptable  only if one of two
  conditions is met.  One condition is that the 1979 SIP: submittal  contains
  adequate justification that economics or other circumstances  warrant
  requirements less stringent than those contained within  the CTG.   The
  other condition is that the impact on emissions differs  imperceptively
  (less than 5 percent in cases where it is possible.to  quantify the
  difference) from that of the CTG and there is no significant  threat of
 undermining EPA activities elsewhere in the nation.  This  concept is
 only applicable on a source category basis.   In other  words,  it would
  be unacceptable to approve a source category specific  regulation  requiring
 significantly less control  than the corresponding CTG  on .the  basis that
 other source categories are regulated to a degree significantly more
 stringent than the comparable CTGs.
                                                       > ' "*             ~"
     Q.   Can States apply VOC RACT regulations .to sources in attainment
 areas surrounding a nonattainment area? (7/28)

     A.   Yes,  States can obviously apply RACT regulations wherever they
 wish.   The application  of RACT regulations to expanded areas, perhaps
 even Statewides  is probably a wise action since it will  greatly simplify
 the SIP revision process for future 0  nonattainment "discoveries" made
 through the PSD program.   However, EPH presently does  not  require VOC
 RACT regulations for attainment areas.

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                             MISCELLANEOUS
Q:  Section 126 "Interstate Pollution Abatement" allows any State or
political subdivision to petition EPA for finding that a source in a
neighboring State "prevents attainment or maintenance...of any...national
primary or secondary ambient air quality standard."  The Administrator
must make a decision within 60 days of the receipt of a petition and
follow up with appropriate new abatement actions.  What will be the
basis for EPA decision on whether a source prevents attainment? (1/12)

A:  EPA generally will make a positive finding only if the source is
causing the violation of the standard and control of the out-of-state
source will result in attainment.  That^js, the petitioning State
must have its own house in order and must fail to attain only because    /'
of the interstate source before"EPA will invoke the special powers'
of Section 126.  Where the interstate source or sources are only contri-
buting to violations that would exist anyway, the situation should be
regulated through a comprehensive SIP revision for the area.

     Q.  What is the legal status of a source which is not meeting an
  approved SIP limit and to which the State has granted a variance but EPA
  has net yet approved the variance as part of the SIP?  (3/31)

     A.  The source will be out of compliance and subject to Section 113
  enforcement and nonconip] la nee penalties under Section 120.

     Q.  What effect will non-ferrous smelter orders have on mandatory
  S02 attainment by 1982?  (3/31)                        ::-

     A.  The issuance of a nonferrous smelter order (NSO) will  not inter-
  fere with the attainment of the ambient sulfur dioxide standards since
  any smelter subject to a NSO will be required to employ dispersion
  techniques  to ensure attainment of the ambient standards until expiration
  of the NSO.  Upon expiration, the smelter will be required to attain
  the ambient standards through constant control technology alone.

   ;  Q.   Can monitors be relocated  as  part of a SIP revision? (6/2)

     A.   Yes.
                                                        • '* •*,
   1  Q.   Are BACT and LAER nationwide or Statewide determinations? (3/31)

     A.   Neither, BACT and LAER are case-by-case determinations.

     Q.   Are Federal facilities subject to SIP  limits  and procedures? (3/31)

     A.   Yes, Federal facilities should be treated as  any other source.

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  ~.  Q.  Does the existence of Federal  regulations alleviate sanctions? (6/2)

      A.  Only in limited circumstances.   For example, to the extent
  resources permit, EPA will  promulgate RACT for stationary sources.  If
  this fills the only deficiency in  the SIP, approval will then be possible
  and any sanctions will  be  lifted.  However, in this case sanctions would
  UhL£ ll I   ft??6/ai'!ed  to  implement the Federally promulgated regulations.
  wnere states fail  to adopt  emission control regulations needed to provide
  Tor attainment and maintenance of  the national air quality standards,
  tPA may not have sufficient resources to correct all deficiencies and  it
  will  be necessary to impose sanctions.

    $.  Q.   Are Federal  facilities required to pay permit fees to the State
   in which they are located? (5/4)

       A.  Yes, the Federal  government is  not exempt  from thesejfees^.	

 ^;Q;   Can Section'175 funds a~pply to TSP related project! or grants? :(6/2)

     A   Yes, Section 175 applies to TSP related.projects or grants to
  solveVeentrained dust  and  other TSP problems.

  <*.  Q.  What model  should States use to determine percent reduction
 seeded to attain the  Ox  standards?  (6/2)

     A.  The Regional  Office  need not djctate model consistency but can
 leave it to the option of the  States.
   r   Q.   Is a delayed compliance order (DCO) a SIP revision?  (5/4)

      A.   A DCO is not a  SIP  revision under Section 110(a)(3) of the CAA.
  A BCG is, however, an addition to  the SIP and modifies the terms of an
  approved SIP under Saction  110(i)  and Section 113(d)(ll).  Consequently,
  a source subject to a DCO  is  potentially subject to non-compliance
  penalties.  DCO's will  be  published in 40 CFR 65.

      Q.   Who is required to submit  a DCO to the Administrator? (5/4)

      A.   A State issued  DCO is required to be submitted by. the State to
  the Regional Office which  in  turn  submits it to headquarters for review.
  A DCO is not required to be submitted by the State  Governor but can be
  submitted by a local  agency.
              f
    Q.  When and to whom will  the Section 108 transportation control
measures  (TCM)  guideline documents  be distributed? (6/2)

    A.   Inspection/maintenance and  bus/carpool guidelines are now being
distributed  to  the  Regional  Offices.  The vapor recovery guideline is
expected  from the contractor on June 1.  Limited copies of this will be
distributed  in  early June with more copies available in early July
Other  guidelines are due at  the end of this year.  Transportation planning
guidelines have been completed  in-house and are awaiting DOT consensus
This review  should  be  completed in  early June and the guidelines avail-
able then.

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 -   Q.  When will the "Microinventory Technique for TSP Assessment" be
available?  (7/11)  '

    A.  This technique, which has recently been applied to several
areas, emphasizes a more definitive area source inventory in the
immediate vicinity of hi vols.  It will be discussed, along with other
analysis techniques, at the Workshop on Particulate Analysis and
Assessment Methods, July 19 and 20, in Raleigh, North Carolina.  A paper
describing the technique in more detail will be available at that time
and afterwards by requesting a copy from Tom Pace, MD-14, Research
Triangle Park, North Carolina 27711, or at 629-5486 (FTS).

     Q.  How is an "urbanized area" of greater than 200,000 people defined? (7/2;

     A.  As defined in the U.S. Department of Commerce publication,
 1970 Census Users'  Guide Part 1, p. 82, urbanized area includes  a core
 city plus any closely settled suburban area.  For the purpose  of oxidant
 plan development, major urbanized areas are urbanized areas with a popula-
 tion of 200,000 or greater.  (See attachments to this enclosure  for the
 Bureau of Census1 definition and a list of urbanized areas.)

 'T.  Q.  Is the reference (in the February 24, 1978, memo on criteria for
 approval of 1979 SIP revisions) to use of the highest pollutant  concentra-
 tion for determining the necessary level of control for photochemical
 oxidants in nonattainnient urban areas an attempt to modify current
 Agency policy regarding the use of the second highest value? (7/28)

     A.  No, the use of the highest pollutant concentration is  intended
 by definition to mean the second highest value since the ambient standard
 dictates: that the cxidantr standard can be exceeded once per year.

 5   Q.  If an area contains several CO monitors all showing nonattainment,
 must the control strategy demonstrate attainment for all monitors or
 only the one with the highest reading?(7/28)

     A.  The control strateay must demonstrate attainment at all  locations.
 Site specific controls alone are sufficient if they take care  of the
 problem and do not serve simply to relocate it.  However, measures that
 provide comprehensive control (such as I/M) and area-wide VMT  reduction
 (such as mass transit, car pooling, etc.) may provide the best solution
 to the problem.

-------
82
                        Definition  of "Urbanized Are,a,
                    1970 Census Users'  Guide"  Part  1
 17.  Urbanized areas (UA)— An  urbanized area
 contains a ciry (or twin cities) of 50,000or more
 population  (central  city)  plus the  surrounding
 closely settled incorporated and  unincorporated
 areas which meet certain criteria of population
 size ordensity. Beginning with the 1950 Censuses
 of Population  and Housing, statistics have been
 presented  for urbanized" areas,  which were
 established primarily to distinguish the urban
 from the rural population in the vicinity of large
 cities.   They  differed from SMSA's chiefly in
 excluding the  rural  portions  of counties com-
 posing the SMSA's  and excluding those places
 which were separated by rural  territory from
 densely populated fringe around the central-city.
 Also,  urbanized  areas are defined on the basis
 of the  population distribution at the time of the
census, and  therefore  the boundaries are not
permanent.                              .    -w
Contiguous urbanized areas with central cities in
the same SMSA are combined.  Urbanized areas
with central  cities in different SMSA's are not
combined,  except  that a single urbanized area
was established  in  each of  the  two Standard
Consolidated Areas.

Essentially  the same  definition  criteria  are
being, followed in  1970  as  in 1960 with two
exceptions:

   A.  The decision  not to recognize selected
   towns  in New  England  and  townships in
   Pennsylvania and New Jersey as urban places
   under special rules  will affect the definition
   of some areas in these States.  Included in
   urbanized areas  will be only the portions of
   towns and townships  in these States that meet
   the rules followed in defining urbanized areas
   elsewhere in the United States.   This also
   affects Arlington  County, Virginia, which will
   be considered an  urban unincorporated place
   rather than an urban by special  rule county.

   B.  A change has been introduced with regard
  :^.to the treatment of extended cities (previously
   called "overbounded") that contain large areas
   of very low density settlement. The decision
    to distinguish between urban and rural parts
    of extended  cities in urbanized areas  and to
    exclude the rural parts from  the urbanized
    areas  will help to present a more accurate
    representation of the population that is truly
    urban.    Approximately sixty incorporated
    places  are involved of which about twenty
    are central cities.  An alphabetic code "A"
    appearing on the census summary tapes will
    identify these particular areas.

  Pre-census  planning  indicated  approximately
  fifty potential  new urbanized areas. Those which
  prove to  have  a  qualified .central  city or twin
  central cities in 1970 will appear in the published
  reports.              •'• .

  Maps in the Metropolitan MapSeriesessentially
  cover the urbanized areas of SMSA's and contain
  all  recognized census boundaries down to the
  block level.

  Two sets of four digit numeric codes for urban-
  ized areas are  contained  in the 1970 census
  tabulations.  The potential urbanized area code
  will  identify each  record (collection of related
  data items) in each  urban  fringe zone.  This
  zone includes all   of the area  which  has the
  potential of being part of  an  urbanized  area
  after  the 1970 census.  The actual  urbanized
  area code uniquely identifies all  records irieach
  urbanized area.  The final extent  of the urbanized

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                                                                                            83

area and, therefore, each of the specific records    or their parts, will qualify as part of the urban-
that will contain this code is not determined until    i/cd area or.ly if they meet rule C above.
after the 1970 census.

The components  of  UA's and  their opecific
.definitional criteria are as follows:

   17.1  Central city of an urbanized area—An
   urbanized area contains at least one city which
   had 50,000 inhabitants in the census as well as
   the  surrounding closely settled incorporated
   and  unincorporated  areas  that  meet  the
   criteria for  urban fringe areas.  (There are a
   few urbanized areas where there are "twin
   central  cities" that have combined population
   of at least 50,000.)  All persons residing in an
   urbanized area   are included in the urban
   population.

    17.2 Urban fringe--In addition to its central
    city or  cities, an urbanized area also contains
    the following types of contiguous areas, which
    together constitute its urban fringe:

      A. Incorporated places with  2,500 inhabi-
      tants or  more.

      B.  Incorporated  places  with less  than
      2,500  inhabitants, provided  each  has a
      closely settled  area of 100 dwelling units
      or more.

      C.  Enumeration  districts  in  unincor-
      porated areas with a population density of
       1.000 inhabitants or more per square mile.
      (The area  of large  nonresidentia! tracts
      devoted  to such urban land uses as rail-
      road yards,  factories,  and cemeteries is
      excluded  in  computing  the  population
      density.)

      D  Other enumeration districts in unin-
       v.orporatcd   territory  with  lower popu-
       lation density provided that  it serves one
       of the following purposes:

         1.  Fo eliminate enclaves.

         2.  To ciose indentations  in the urban-
         ized  area  of one mile or less across
         the open end.

         3.  To  link outlying enumeration dis-
         tricts of qualifying density that were no
         more than  1-1/2 miles from the main
         body  of the urbanized area.

 A  change  in the definition since  1960 involves
 dropping the use of towns in ,thc  New England
 States, townships  in  New  Jersey  and Pennsyl-
 vania, and counties elsewhere which were classi-
 fied as  "urban by  special rule."'  These areas

-------
awe 21.  Rank of Urbanized Areas in the United States by Population:   1970
                                      f_F« meaning of symbols, see lexfj
ank      Urbanized Areas
1  »«• York, H.Y.-Kortheestera He»
    Jaraey	
2  Loe Angeles-Long Beach, Calif....
3  Chicago, Ul.-Korthweatera
    Indiana.. .......................
4  Philadelphia, Pa.-H.J	]	
S  Detroit, llich	
   San Franclaco-Oakland, Calif	
   Boston, Mass	
   Washington, D.C.-Md.-V»	
   Cleveland, Chlo.	
   St. Loula, Mo.-Ill	
 6
 7
 a
 9
10
tl  Pittsburgh, Pa	
12  Uinneapolle-St. Paul, Mian	
13  Houston, Tex	
H  Baltlaor*, Md	
15  Dallaa, Tax	
16  Hllwauke*, Wia	
17  See,ttle-Kv«rett, Wash	
18  Ut*m\, n»	
19  Su Diego, Calif	
20  Atlanta, Cm	
21  Cincinnati, Chlo-Ky	
22  Kanaaa City, lio.-Kan*	
23  Buffalo, H.t	
24  Denver, Colo...'.	
25  Saa JOM, Call*	
26  Mev Orleana, La...	
27  Phoealx, Aria.....	
28  Portland, dreg .-Wash	.*...
29  Indianapolis, Ind	
30  Provld«ne*-Pawtucket-*arvicx,
     B.X.-Hsaa	
31
32
33
34
35
36
37
38
39
4O

41
    Coltabu*, Cblo	
    Sao AatoBio, Tex...............
    loulsvilla, Ky.-Ind	
    Dayton, Qilo...................
    Fort Worth, Tex................
    Korfolk-Portaawuth, Va.........
    MeicphlB, Tena.-Mlaa	
    Sacriuaento, Calif	
    Fort Laudardale-Hollyvood, Fla.
    Rochester, M.»....	
     Saa Bernardino-Rlvarald*, Calif..
 *.2  OSlaaoMa C±t7,  Cila..-.	
 43  Blnll*haa,  Ala		
 44  Akron,  Olio			
 45  Jacksonville, Fla	
 4S  Sprins;fl»14'«iicop»e-}{olTok*>
      Haae.-Cooa	
 47  St. Petersburg, Ma	
 48  Ouha,  Mebr.-Iowa	
 49  Toledo, Cblo-Wich		..
 SO  Albaay-6eb«nectaily-?roir, H.Y.,.
     Salt Lake City,  Utah	
     Hartfont, Conn	
     Baabvilla—Davlsiaao, T»nn.,.~	
     Honolulu, Hawaii	
     glciurond, Va	,	
     Bridgeport,  Cor.n.................
     Youngatown-VaiTei*, Chlo	
     Syracuae, H.Y	
     Tulsa,  Cisla	
     Vlbiing-ton,  Rsl.-H.J	
     T*»pa,  Fla	
51
52
53
54
£5
56
57
S3
59
£9

SI
$2
     Pa.-H.J	"....
63  Grand Rapid*, Mich	
64  New Haven,  Conn	
65  £1 Paso, Tex	
66  Tacona, ,Wasa..................
67  Flint, Mich.	
68  Orlando^ Fla	
69  Wichita, Kana	.'	
70  Albuquerque, H. Mex	

71  Tucson, Ariz	
72  South Bend, Ijid.-Mlch	
73  West Pala Deach, F1"	•
74  Charlotte,  H.C	
75  Trenton, H.J.-Pa	
76  Kevport Newa-Hupton, V»	
77  Davenport~R~:k Islsnd-Hollne,
     Iowa-Ill	
78  Austin, Tex	
79  Fre-.no, Calif.'	
30  Mobile. Ala	
                                         Population
                                       16,206,841
                                        8,351,266
6,714,578
4,021,066
3,970,584
2,987,850
2,652^575
2,481,489
 ,959,880
 ,882,944

 ,846,042
 ,704,423
 ,677,863
 ,579,781
 ,338,684
 ,252,457
 ,238,107
 ,219,861
 ,198,323
 ,172,778

1,110,514
1,101,787
1,086,594
1,047,311
1,025,273
  961,728
  863,357
  824,926
  820,259

  793,311

  790,019
  772,513
  739,363
  695,942
  676,944
  668,239
  663,976
  633,732
  613,797
  601,361

  533,537
  579,788
  558,099
  542,775
  529,585

  514,308
  495,159
  491,776
  487,789
  486,525

  479,342
  4S5.001
  4^?"(4J4
  442,397
  416,563
  413,265
  295,540
  376^169
  371,439
  371,23
                                          353,517
                                          352,703
                                          3-:S,341
                                          337,471
                                          332,521
                                          330,123
                                          305,479
                                          302,334
                                          297,451

                                          294,181
                                          288,572
                                          287,561
                                          279,530
                                          274,148
                                          268,263

                                          266,119
                                          264,499
                                          262,908
                                          257,816
            ank
          Urbanized Areas
 81
 82
 83
 84
 85

 86
 87
 88
 89
 90

 91
 92
 93
 94
 95
 96
 97
 99
10O
                                                        Dea Koines, Iowa	
                                                        Baton Rouge, La.....	
                                                        Worcester, llass	
                                                        Peoria, 111	
                                                        Oxnnrd-Ventura-Tliousanci Oaks,
                                                         Calif	
                                                        Canton, Ohio...................
                                                        Columbia, S.C	
                                                        Karrisburg, Pa.................
                                                        Las Vegas, Kev	
                                                        Shrevcport, la.................
                                                        Aurora-Elgin, 111	
                                                        Spokane, Wash ..................
                                                        Lansing, Mich..;	
                                                        Charleston, S.C.............*..
                                                        Fort Vayne, Ind	
                                                        Chattanooga, Tenn.-Ga	
                                                        Vllkes-Barre, Pa	
                                                        Little Roek-Horth Little Rock,
                                                          Art	
                                                        Corpua Oirlstl, Tex	
                                                        ColiAbua. Ca.~Ala..............
101  Boekford, 111	
102  Madison, Wls...;	
103  Colorado Springs, Colo..	
1O4  Scranton, Pa...............*-.
105  Lawmce-Havexhlll, Hass.-N.H.
106  Lorala-Elyrla,  Chlo	
107  Knoxvlile, Tenn.	
109  Jackson, Mlsi...>	
109  Stanford, Conn	
110  Lowell, Miss	
Ill
115
113
114
115
116

117
118
119
120

121
122
i ft-i
124
125
126
127
123
123
130

131
132
133
134
135
133
137
133
139
140

141
142
143
114
145
14 S
147
143
149
1.50

151
152
153
154
155
156
157
158
159
160
 161
 162
 163
 164
                                                         Ittlca-Rone,  H.Y	
                                                         Ann Arbor, Blch	-.	
                                                         Sakersflald, Calif	
                                                         Sri», Pa	
                                                         jteading. Pa	
                                                         Runtington-Ashland, V. Va.-Ky.
                                                          Ch lo	...;...
                                                         2iash»aton,  H.Y	J.ii.;"'...
                                                         Pensacola, Fla................
                                                         Savannah, Ga..................
                                                         Fzyettevllle, H.C	:	
                                                         Stockton, Calif	
                                                         Lexington. Kjr.................
                                                         Charleston,  5?. Va	
                                                         Greenville,  S.C	
                                                         Vatfiraury, Conn..-.............
                                                         Roanoka, Va...................
                                                         Joliat, 111..'..	
                                                         Lincoln, Nebr	
                                                         Saislgh, K.C	
                                                         Greensboro,  H.C...............
                                                         K^laaaxoo, Mich...............
                                                         Lubbock, Tex	
                                                         Cgd«n, Utah	
                                                         Augusta, Ca.-S.C..............
                                                         Brockton, Mass................
                                                         Es-glaaw, Mich	
                                                         Huntsvllla, Ala	
                                                         ttinston-Salem, K.C............
                                                         Evsr-sville, Ind...............
                                                         Fall River, Mass.-R.I	
                                                         Eugena, Oreg	
                                                         £*onteom#ry, Ala.'..............
                                                         IluluCh-Stiperlor, Minn.^Vls....
                                                         Atlantic City, N.J	
                                                         Ke> Bedford, Mass....,	
                                                         Topeka, Kans..................
                                                         Cedar Rapida, Iowa............
                                                         Kew Britain, Conn.............
                                                         Sxnta Barbara, Calif..........
                                                         Appleton, Vis.................
                 Green Bay,  Vis	
                 Kacon, Ca.....	
                 fenarlllo, Tex.........
                 York, Pa	
                 BUoxl-Culfport,  Mlua.
                 Springfield, llo	
                 Springfield, 111	
                 Waco, Tex.............
                 Racine, Wls	
                 Lancaster,  Pa.........
                 Port Arthur, Tex......
                 Beaumont, Tex.........
                 Waterloo, Iowa	
                 Norwalk. Conn.........
                                                                                           Population
 255,824
 249,463
 247,416
 247,121

 244,653
 244,279
 241,781
 240,751
 236,681
 234,564

 232,917
 229,620
 229,518
 228,399
 225,184
. 223,580
 222,830

 222,616
 212,820
 208,616

 206,084
 205,457
 204,766
 204,205
 200,280
. 192,265
 190,502
 190,060
 184,898
 182,731

 180,335
 178,605
 176,155
 175,263
 167,932

 167,583
 167,224
 166,619
 163,753
 161,370

 160,373
 159,538
 157,662
 157,073
 156,936
 156,621
 155,500
 153,443
 152,289
 152,252

 152,083
 150,135
 149,727
 143,953
 148,844
 147,552
 146,565
  142,58
  142,476
  139,392

  1-39,255
  138,983
  138,352
  134,016
  133,667
 .132,108
  132,00s
  131,349
  129,774
  129,53:

  129,101
  128,06
  127,011
  123,10
  121,60
  121,34
  120,794
  118,84
  117,40
  117,09
  116,47
  116,35
  112,88
  106.7O
                                                              ank
                                                                                                                Urbanized Ar«as
165
166
167
168
169
170
171
172
173
174
                                                                                                         Portland, Main*	
                                                                                                         Modesto, Calif	
                                                                                                         Muskegon-Muskegoo, Heights, Hlch.
                                                                                                         Provo-Oren, Utah.	•	
                                                                                                         Pueblo, Colo	
                                                                                                         Durhan, H.C. ...-••-'-•••••••••"
                                                                                                         Petersburg-Colonial Heights, Va.
                                                                                                         Champaign-Urbane,, 111	
                                                                                                         Decatur, 111	
                                                                                                         Reno, Hev	
175  Berlden, Conn	
176  Wichita Falls, Tex	
177  Johnstown, Pa	
178  Sioux City, lowa-Xebr.-S. Dak.
179  Lawton, Okla...	
180  Manchester, N.H	
181  Springfield, Ohio	
182  High Point, H.C	
183  Seaside-Monterey, Calif.......
 84  Salem, Oreg	..'	
185
188
187
188
189
19O
191
192
193

194
                                                                                                           SheeliBg, W. Va.-Otiia	
                                                                                                           BcAllan-Pharr-Edlnburc,  Tex..
                                                                                                           Baailton, Ohio	
                                                                                                           Abilene-, Tex..........	
                                                                                                           Konroe, La.....	
                                                                                                           Munci*, Ind	
                                                                                                           Lake Charles,  La..	
                                                                                                           Tusealoosa, Ala.........	
                                                                                                           Steubenvllle-Welrton, Oilo-
                                                                                                            W. Va	;	
                                                                                                           Farg-o-tloorhead,  X.  Dak.-Mina.
195  Boise City, Idaho	
196  Kenosha, Wls.....	
197  Texas City-La Marque, Tex.....
198  Altoona, Pa	
199  Odessa, Tex...................
200  Terre Haute, Ind	
201  Anderson, Ind	
202  Lafayette-West Lafayette, Ind.
203  Jackson, tlich	
204  Lafayette, La	
                                                                                                     205
                                                                                                     206
                                                                                                     207
                                                                                                     203
                                                                                                     209
                                                                                                     210
                                                                                                     211
                                                                                                     212.-
                                                                                                     213
                                                                                                     '214

                                                                                                     215
                                                                                                     216
                                                                                                     217
                                                                                                     218
                                                                                                     21S
                                                                                                     220
                                                                                                     221
                                                                                                     222
                                                                                                     223
                                                                                                     224

                                                                                                     225
                                                                                                     226
                                                                                                     227
                                                                                                     228
                                                                                                     229
                                                                                                     230
                                                                                                     231
                                                                                                     232
                                                                                                     233
                                                                                                     234

                                                                                                     235
                                                                                                     236
                                                                                                     237
                                                                                                     238
                                                                                                     239
                                                                                                     24O
                                                                                                     241
                                                                                                     242
                                                                                                     243
                                                                                                     244
                                                                                                     245
                                                                                                     246
                                                                                                     •247
                                                                                                     248
     Bay tity, Ulch	
     Fltchburg-Leomlnster, Mass.
     Tallahassee, Fl»	
     Mansfield, Chip	
     St. Joseph, Ho.-Kans	
     Albany, Ca	.,
     Fort  Solth, Ark.-Okla	
    - Sioux Falls, S. Dak.   	
     Santa Rosa, Calif	
     Yineland-Mlllville, I'.J....
      Ashevllla, N.C....	
      Bristol,  Conn....".......
      Billings, Mont	
      Creat Falls,  Mont	
      Lynchburg, Va...........
      Llaa, Ohio'.	
      Laredo, Tex.............
      Bloonlngton-Nornal, 111.
      Gainesville,  Fla	
      Boulder,.Colo.	
      .Cadsden,  Ala.......	
      Danbury,  Conn	...„.
      Dubuque,  Iowa-Ill.......
      Lewlston-Auburn, Mai;.e..
      San Angelo,  Tex	
      La Crosse,  Wls .-Minn. ...
      Plttafleld,  Mass	
      Salinas,  Calif	
      Calveston,  Tox	
      Nashua, N.H	
                                                                                                            Pine Bluff, Ark	
                                                                                                            Midland, Tex	
                                                                                                            Tyler, Tox	
                                                                                                            Columbia, Mo....	
                                                                                                            Texarkana, Tex.-Ark	
                                                                                                            Wilmington, N.C....;	
                                                                                                            Sim! Valley, Calif	
                                                                                                            Rochester, Minn	,
                                                                                                            Oshkosh, Wls	"
                                                                                                            She man-Den 1 son, Tex	*
                                                                                                            Oiwensboro, Ky.......
                                                                                                            Brownsville, Tex	_
                                                                                                            Bryan-College Station, Tex!
                                                                                                            Harlingcn-San Benlto, Tex..

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                                 REF 1-5



    \    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                          WASHINGTON, D.C.  20460
                             4 DEC 1377
                                                             OFFICE OF
                                                      AIR AND WASTE MANAGEMENT
Subject:  Final Guidelines for Section 174:   Guidance on  Designation
          of Lead Planning Organizations for Nonattainment Areas  and
          on Determination of Agency Responsibilities

ROM:  •   David G. Hawkins, Assistant Administrator
          for Air and Waste Management

TO:       Regional Administrators
          Regions I-X

     The Clean Air Act Amendments of 1977 include important  changes
which provide local governments with the opportunity to assume  addi-
tional responsibilities for state implementation plan (.SIP)  revisions.
Specifically, section 174 requires that for carbon monoxide  and
photochemical oxidant nonattainment areas, state and local elected
officials must jointly determine their respective responsibilities for
plan revisions by February 7, 1978.  In addition, section 174 encourages
that the revisions be prepared by an "organization of elected officials
of local governments."

     Attached are the final guidelines, for implementing, section 174.
Note that they are issued jointly by EPA and the Department  of
Transportation.  Due to the immediacy of the February 7 deadline, these
guidelines were not proposed as regulations..  However, they  have  gone
through an extensive process of review and comment by many of the state
and local public interest groups, including meetings with the National
Association of Counties,. National League.of Cities,  National Governors'
Association, and the National Association of Regional Councils.  In
addition, the guidelines were reviewed by the Departments of Trans-
portation, Housing and Urban Development, and .Interior.   A draft  version
was also circulated to the regions for review through the Air and Hazar-
dous Materials Division Directors.

     The guidelines consist of three parts..  Section 1 explains the
applicability,, purpose*, and background.  Section 2. contains  the criteria
and describes the process for selection of a lead planning organization
for an urbanized nonattainment area.  Local governments can  themselves
agree to designate a planning organization to prepare the nonattainment
plan, if they do so by February 7, 1978.  Such a local designation must  be

-------
certified by the governor.  After February 7, the governor is
responsible for designating, in consultation with local governments,
the planning organization.  The designation of organizations of local
officials, particularly those responsible for transportation or air
quality maintenance planning, is encouraged by the amendments.
In accordance with the EPA policy to consolidate and simplify en-
vironmental planning requirements, the guidelines also encourage
the designation of agencies responsible for preparing other
relevant areawide environmental plans.

     Section 3 describes how state and local officials should
jointly determine the division of responsibilities for development,
implementation, and enforcement of the SIP.  The initial determina-
tion of responsibilities must also be completed by February 7, 1978.
The initial determination is expected to be general  and identify
primarily planning responsibilities, including the development of
an emissions inventory, the completion of an air quality analysis,
and the evaluation of control strategies.  The final determination
must be included in the plan revision submitted by January 1, 1979,
and must address in detail implementation and enforcement.responsibilities

     Copies of these guidelines should be sent to the states in your
region and to appropriate local governments.  The guidelines call  for
states to submit two items to the Administrator through.EPA regional
offices:  (1) a list of all organizations or agencies designated and
certified within the state including a description of their geographic
jurisdictions, a general description, of their responsibilities, and a
brief discussion of the reason for the-ir designation; (2) the initial
joint determination of responsibilities, for the SIP  revisions.  These
two items should be transmitted to EPA no later than April  1, 1978.
Copies of the submittals should be sent by regional  offices to the
offices listed below:

     Office of Transportation and Land Use Policy (AW-445)
     401 M Street, S.W.
     Washington, D.C.  20460
     Attn:  John 0. Hidinger

     Office of Air Quality Planning and Standards
     Research Triangle Park, North Carolina  27711
     Attn:  Walter Barber

ec:  Walter Barber
     Air and Hazardous Materials Division.Directors,. Regions I, III-X;
       Environmental Programs D.ivision. Director, Region II

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              CLEAN AIR ACT
         SECTION 174 GUIDELINES
        Guidance on designation of
        lead planning organizations
        for nonattainment areas and
        on determination of inter-
        agency responsibilities
              December 1977
            Issued Jointly by

The U.S. Environmental Protection Agency

                   and

 The U.S. Department of Transportation

            Washington, D.C.

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                            TABLE OF CONTENTS
Section                                                Page Number
1.   Introduction
          1.1 Applicability	•	1
          1.2 Purposes	1
          1.3 Background	1
2.  Selection of a Lead Planning Organization
          2.1 Criteria for Selecting an Organization ... .3
          2.2 The Selection Process 	 4
3. Joint Determination of Responsibilities	5
          3.1 Joint Determination Process 	 6
          3.2 Notification of Affected Governmental
              Organizations 	 6
          3.3 Establishment of a Determination
              Process 	 7
          3.4 Formal Identification of Responsibilities .  . 7
Appendix A.  List of Key Dates
Appendix B.  Section 174
General questions on any of the material covered by this guideline
should be sent to the Office of Transportation and Land Use Policy (AW-
445), U.S. Environmental Protection Agency, 401 M Street, S.W., Washington,
D.C. 20460, Attention: Ms. Martha Burke.  Ms. Burke's telephone number
is (202) 755-0570.  Questions concerning specific state or local areas
should be directed to the appropriate EPA regional office.

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                            1.  INTRODUCTION
1.1 Applicability
These guidelines are applicable to all metropolitan area regions or
portions of regions where the national ambient air quality stan-
dards for photochemical oxidants or carbon monoxide will not be
attained by July 1, 197.9.

1.2 Purposes

The purposes of these guidelines include:

    1.  To recommend procedures and criteria for determining a
        lead agency to be responsible for coordinating the prep-
        eration of the implementation plan revisions called for by
        the 1977 amendments to the Clean Air Act (P.L. 95-95)
        in metropolitan area regions where carbon monoxide or
        photochemical oxidant standards will not be attained
        by July 1979.

    2.  To assist state and local governments in identifying the
        initial planning, implementation, and enforcement responsi-
        bilities for the plan revisions and in establishing a process
        for further definition of responsibilities as development of
        the revisions progresses.

    3.  To encourage further coordination and consolidation of
        federally sponsored planning programs.  This includes the
        integration of the new transportation related air quality
        requirements under P.L. 95-95 into the transportation
        planning process required by federal transportation grant
        statutes.

1.3 Background

On August 7, 1977, President Carter signed into law the first compre-
hensive amendments to the Clean Air Act since 1970.  Among
the more important changes in the Clean Air Act are provisions en-
couraging local governments and organizations of local elected
officials to assume additional responsibilities in the development,
implementation, and enforcement of plans to attain national ambient
air quality standards.  Such plans were first required under the
1970 amendments to the Clean Air Act..  The 1977 amendments require
plan revisions for areas where standards have not been attained.

The assumption of additional responsibilities by local governments
and local officials is specifically encouraged in those areas where
photochemical oxidant and carbon monoxide standards will not be
attained by July 1, 1979 (section 174(a)).  The first identification
of nonattainment areas for these and other pollutants under the
requirements of the 1977 amendments must have been made by states by
December 5, 1977.  The Administrator of the Environmental Protection

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Agency (EPA) must publish a list of these areas, with any modifica-
tions he deems necessary, by February 3, 1978.

For areas where standards for photochemical oxidants and carbon
monoxide will not be attained by July 1, 1979, state and local
elected officials must jointly determine by February 7, 1978, their
respective responsibilities for the plan revisions necessary to
attain standards by the new deadlines in the 1977 amendments.  The
plan elements for which responsibilities are to be jointly determined
encompass control measures for all pollutants for which standards
have not been attained, not just photochemical oxidants and carbon
monoxide.

The amendments require that, where possible* the implementation
plan revisions be prepared by an organization of local elected
officials designated by agreement of local governments.  The amendments
strongly encourage preparation by the organization now responsible
for transportation planning under section 134 of title 23, ILS.C.,
or for air quality maintenance planning (or for both).  The desig-
nated organization and its responsibilities must be certified
by the state  (or states if an interstate area is involved).  Where
local governments have not reached agreement by February 7, 1978,
the governor  must, in consultation with the elected officials
of local governments in the affected area, designate an organization
of local elected officials or a state agency to prepare the plan
revisions.  The designation by the governor must be in accordance with
the joint determination of responsibilities made by state and local
elected officials.

The governor  must, under regulations which the EPA. will propose dur-
ing December  1977, submit a notice to the EPA certifying the designated
agency for each nonattainment area or identifying the organization
that he or she has designated.  The notice must include a brief
summary of the process involved in selecting the designated agency.  A
more detailed documentation of the selection process shall be included
as part of the plan revisions to be submitted to the EPA by January 1,
1979.  Evidence of the involvement of state legislatures and local
governments is required as part of the plan revision submittal (section
172(b)(9)).

Only organizations of local elected officials of general purpose
governments certified by the governor will be eligible for the
grants authorized under section 175 of the amendments.  In each urban
area which is wholly or partially classified as a nonattainment area,
only one organization will be eligible to receive a grant.  The org-
anization receiving the grant may use the grant funds to support
plan revision activities carried out by other governmental organiza-
tions, public interest groups, or private consultants.

In addition to further defining the process for implementation of
the Clean Air Act amendments, the EPA and the Department of Trans-
portation also encourage in these guidelines further coordination and
consolidation of federally sponsored planning programs.  Such encourage-
                                    -2-

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ment is consistent with President Carter's Environmental Message of May
1977 and with subsequent actions taken by the President to eliminate,
consolidate, or simplify federal planning requirements.  The Environ-
mental Message in part stressed the need for improved implementation of
environmental laws through more efficient delivery of federally funded
programs.  The encouragement for coordination and consolidation
does not imply the advocacy of any particular institutional mechanism.
A wide variety of mechanisms ranging from concentration of authority or
responsibility in a  single organization to development of memoranda
of  understanding among several organizations are available to achieve
the same objectives.
                                      -3-

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                2.   SELECtlON OF A LEAD PLANNING ORGANIZATION

 2.1  Criteria for Selecting  an Organization

 These  guidelines are  intended to assist state and  local officials
 in reaching agreement on the lead planning organization to be res-
 ponsible for plan revisions called for by the 1977 Clean Air Act
 amendments.  The role of the lead planning organization may vary
 from developing almost all  elements of the plan revision to acting
 as a forum for  decisionmaking by elected officials on elements
 developed almost entirely by other organizations.  In most instances
 the  lead organization will  probably develop some elements,_coordi-
 nate the development  of other elements, and serve as a forum for
 deciding the ultimate nature of the plan revisions.

 The  amendments  require that, where feasible, the organization des-
 ignated and certified to prepare the plan revisions shall be (1) the
 metropolitan planning organization (MPO) responsible for the con-
 tinuing, cooperative, and comprehensive transportation planning
 process for the affected area; (2) the organization responsible for
 the  air quality maintenance planning process; or (3) an organization
 responsible for both  planning processes.  Coordination of the devel-
 opment of a plan revision with the MPO transportation planning process
 is particularly important in those nonattainment areas where transpor-
 tation control  measures appear necessary to attain standards.   Only
 through the MPO process can the federal funds available under Federal
 Highway Administration and Urban Mass Transportation Administration
 programs be used to implement necessary transportation management
 measures and capital  projects.

 The  Administrator of  the EPA also strongly encourages that, in
 addition to meeting the requirements described above, the designa-
 tions  made pursuant to section 174 contribute to a consolidation
 within a single organization of responsibilities for air quality
 planning and for other environmental  planning carried out under
 federal laws administered by the EPA.  These laws include the
 Federal Water Pollution Control  Act,  the Safe Drinking Water Act,
 and  the Resource Conservation and Recovery Act.   The EPA believes
 that, where properly applied, consolidation of environmental  planning
 efforts is an essential  step in the development of comprehensive
 environmental  strategies that are able to take into account the
 interrelated nature of environmental  problems.  Comprehensive strategies
can also result irr a more efficient and effective use of resources in
 achieving environmental  benefits.

The following criteria should be considered by local  elected offi-
cials and by the governor when determining the lead planning organi-
zation for urban nonattainment regions:

     1.  The organization should be the forum for .cooperative  deci-
         sionmaking  by principal  elected  officials, of general  purpose


                                   -4-

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          local  governments.  The principle elected officials of gen-
          eral  purpose local governments should have adequate (prefer-
          ably majority or larger)  representation in the organization
          but membership need not be limited to them or their designees.
          There should be participation by agencies that may be respon-
          sible for implementation of portions of the plan.

     2.    The organization should have a planning jurisdiction that includes
          the current urbanized area and the area likely to  be urbanized
          at least over the period to be covered by the revised plan.

     3.    The organization should have the ability to produce the necessary
          plan revision for the planning jurisdiction described above
          by the January 1, 1979, submittal deadline.  The organization
          should have the capability to perform the necessary analysis
          and planning tasks itself or be able to enter into binding
          agreements with other organizations to perform such tasks.

     4.    The organization should have the capability to coordinate
          the development of the plan revision with other relevant
          planning processes, if it does not have responsibility for
          those processes, and with agencies that may have responsibil-
          ity for implementation or enforcement.  Relevant planning
          processes include the continuing, cooperative, and compre-
          hensive planning process; other environmental planning pro-
          cesses assisted through EPA-administered programs; and com-
          prehensive planning processes established in accordance with
          Part IV of the Office of Management and Budget Circular A-95
          (41 FR 2052).

2.2 The Selection Process

Local governments within a nonattainment area for photochemical
oxidants or carbon monoxide may, by agreement, designate an  organ-
ization of elected officials of local government to prepare  the
plan revision for the pollutants for which standards in that area have
not been attained.  A resolution by the governing body of an organi-
zation meeting the criteria in section 2.1 of these guidelines is suffi-
cient to demonstrate agreement of local governments.  Such a designation
must be submitted to the governor by February 7, 1978.  Local govern-
ments intending to designate an organization should consult  with the
state during the designation process.

If local governments agree on an organization by February 7, 1978, the
governor shall certify that organization by April 1, 1978, unless he or
she finds that the designated organization does not meet the criteria in
section 2.1.  If local governments have initiated, but have  not com-
pleted,  designation of an organization by February 7, 1978,  they should
inform the governor that an on-going process exists.

If local governments are unable to agree by February 7 on a  single lead
organization of local elected officials to be responsible for the


                                   -5-

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coordination of the plan revision, the governor shall, in consultation
with local elected officials of general purpose local governments, desig-
nate an organization or a state agency by April 1, 1978.  If more
than one organization meeting the criteria in section 2.1 is self-
designated in an area and proposed to the governor for certification,
the governor shall certify the organization which, in his or her
opinion, is most capable of completing the required plan revisions.

The governor may designate a state, local, or regional agency, but that
designation shall be in accordance with the joint determination of
responsibilities required by section 174 of the Clean Air Act amend-
ments and discussed in the following section of these guidelines.
In making a designation, the governor shall take into considera-
tion any on-going process of local designation in existence on
February 7, 1978, even though no formal agreement among local gov-
ernments has been reached.

The governor shall submit to the Adminstrator of the EPA by April 1,
1978, through the appropriate EPA regional office, a list of all
organizations or agencies certified or designated within the state,
a description of the geographic jurisdictions of these organizations
and agencies, and a general description of their responsibilities.
Regardless of the agency finally designated or certified, the deci-
sions should reflect an examination of all reasonable alternatives
for consolidation of environmental and other planning functions.  The
submission should include a brief discussion of the alternatives
investigated and the basis for the ultimate choice.  lf^ the organi-
zation designated or certified by the governor is not o'ne of the
organizations encouraged by the amendments and by the Administrator
in these guidelines, the reasons that such an organization should
not have the lead responsibility for planning should be specifically
addressed.  More detailed descriptions, including documentation of
the consultation that occurred, shall be submitted by January 1, 1979,
with the implementation plan revision.
                                    -6-

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               3.  JOINT DETERMINATION OF RESPONSIBILITIES


3.1 Joint Determination Process

The determination of responsibilities made jointly by state and
local elected officials will  necessarily have to be relatively
general for many areas.  The  nature  and extent of the air quality
problem may not be adequately defined by the February 7, 1978, deadline
specified in the amendments.  In addition, the planning process guide-
lines for photochemical oxidant and  carbon monoxide nonattainment areas,
required to be prepared by the EPA also by February 7, will not be
available for consideration in the joint determinations.  The nature of
the process recommended in the EPA guidelines should influence the
ultimate determination of responsibilities.

Because agency responsibilities, especially for plan implementation
and enforcement, will undoubtedly change or become more specific
by the time a plan revision is actually submitted to the EPA for
approval, the determination of responsibilities should be viewed as
a process, the first phase of which  is to be completed by February 7,
1978.  The final product of the joint determination process should
be included as part of the plan revision submitted by January 1, 1979.
Possible steps in this phased process are set forth below.   Because
institutional arrangements differ from region to region and from
state to state, specification of a generally applicable process for
joint state-local determination of agency responsibilities is not
possible.

Many state and local governments already have initiated such a
process.  As long as the approach taken provides for substantial
involvement of all parties -  local governments, regional agencies,
and states - and results in the identification of agencies  and res-
ponsibilities as described in these guidelines, such an existing
process is sufficient to meet the requirements of section 174(a).
The activities described in the following section should be com-
pleted by February 7, 1978, to comply with the requirements of sec-
tion 174.

3.2 Notification of Affected  Governmental Organizations

The state should, by correspondence or other established notifica-
tion procedures, ensure that  all affected governmental  organizations
within the nonattainment region are informed of the purpose and
schedule of the joint determination process.  In many instances, an
entire state may be designated as a nonattainment area for  photo-
chemical oxidants.   However,  many control strategies will still generally
focus on urban regions.   As a minimum, the following organizations
should be notified in each region:

     a.   General  purpose local governments.
                                    -7-

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     b.  Organizations of local elected officials (including all
         metropolitan planning organizations).

      c.  Air pollution control agencies (including the agency or
          agencies responsible for air quality maintenance planning

      d.  Areawide A-95 clearinghouses.

      e.  Areawide and statewide water quality planning agencies
          designated under section 208 of the Federal Water Pollu-
          tion Control Act.

      f.  AreaV/ide solid waste management agencies.

      g.  Areawide comprehensive planning agencies.

      h.  Coastal management agencies.

      i.  Interested citizen groups.

3.3 Establishment of a Determination Process.

The state should ensure the establishment of a process for determination
of agency responsibilities that will provide state and local  elected
officials of all major political subdivisions within a region with an
opportunity for substantial involvement and that will enable the con-
cerns of these officials to be adequately-addressed.  This may be done
through a variety of mechanisms including the establishment of  task
forces with state and local government representatives and the use of
public meetings or hearings with elected officials of all  major general
purpose local governments within the affected regions invited.   Where
appropriate, existing forums such as meetings of organizations of local
elected officials or meetings of air quality maintenance policy advisory
groups should be used in the determination process.

All state and local officials participating in the determination of
agency responsibilities should have the opportunity to propose agencies
and their respective functions.  All proposals should be made available
to affected agencies and the general public for comment.

3.4 Formal Identification of Responsibilities.

The initial joint determination of responsibilities shall  at a mini-
mum establish which level of government (although notrnecessarily the
specific agency) - the state, local governments, regional  agencies or
any combination of these - shall be responsible for:  (1)  the development
of an accurate, comprehensive, and current emission inventory; (2) the
completion of an air quality analysis, using modeling techniques, to
                                   -8-

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determine the level of control needed to attain standards; and
(3) the evaluation and selection of control strategies for
mobile sources, point sources, 'and area sources.  An initial
assignment of responsibilities for implementation and enforcement
must be considered.  However, it is expected that the final
determination of such responsibilities will occur after the
measures to be included  in the plan revision have been relatively
well defined.

When agreement is reached among the state  and the participating
local elected officials, memoranda of understanding or other
comparable joint acknowledgements of responsibilities should be
signed.  Because duties  and responsibilities for implementation
and enforcement of plan  revisions may change as development of the
plan revisions proceeds, the  determination of agency responsibilities
need not be  incorporated in the state implementation plan until
the revisions are  submitted for federal approval.  The initial
determination of responsibilities made by  February 7, 1978, to meet
the requirements of  section 174, should be submitted by April 1, 1978,
to the  EPA with the  certifications of lead planning organizations
discussed  in section 2 of these guidelines.
                                     -9-

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                               APPENDIX A
                            LIST OF KEY DATES
      Date                                    Action

August 7, 1977                     Clean Air Act amendments are
                                   signed into law.

December 5, 1977                   States identify nonattainment
                                   areas.

February 3, 1978                   EPA publishes list of nonattain-
                                   ment areas.

February. 7, 1978                   Local governments designate org-
                                   anizations of local officials.

                                   State and local elected officials
                                   complete joint determinations of
                                   responsibilities.

April 1, 1978                      Governors transmit to EPA certifi-
                                   cation of lead planning organizations
                                   and joint determinations of responsi-
                                   bilities.

January 1, 1979                    Governors transmit to EPA plan revi-
                                   sion for nonattainment areas.

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                                         APPENDIX B
                                         SECTION T74
•48-TEC7504*     ttSx& 17«? air quality mMtiten ««!>>. pi my.
                                                        tlwt section, or the orgBr
              hensive transportation •planning process require
              title 23, United State*- Codev a&d r-hq H-U* <|T^R}itj' tnaiTttanane^ pianninj?
                             '.ujj^jgjj sflCQo^L. H0« and.* sncn I^IAJBLDSAJZ^ nrocesses snaJ^  «nft» PP*

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                                        REF I-*
                   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

   DATE:    0   S£p J97g

         Questions  and  Answers  on 1979 SIP Revisions
SUBJECT.
   FROM:   G.  T.  Helms   Chief
         Control  Programs  Operations  Branch

    T0.   See Addressees  Below

              Enclosed is  the sixth issue  of monthly  questions and answers on

         the 1979 SIP  revisions.   In  an  effort to  keep the questions and answers

         current, question number  11  in  the May 4  issue has been modified by

         recent policy guidance  (copy enclosed).   Questions number 1 through 3

         of  this  issue deal with the  clarification of the VOC RACT requirement in

         oxidant  nonattainment areas.

         Enclosures

         Addressees:

         Thomas Devine,  Region I
         William  Baker,  Region II
         Howard Heim,  Region  III
         Winston*"Smith,  Region IV
         Steve  Rothblatt,  Region V
         Jack Divita,  Region  VI
         Art Spratlin, Region  VII
         Robert OeSpain, Region VIII
         Wayne  Blackard, Region IX
         Clark  Gaulding, Region X

         cc:  R.  Campbell
             R.  Rhoads
             D.  Tyler
tPA FORM 1320-6 (REV. 3-76)

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 1.  Q.   Does Hawkins1 August 4 memo on requirement for VOC RACT regulations'
 mean  that  linear rollback and EKMA should no longer be used for the  1979
 oxidant  SIPs?  Must detailed photochemical dispersion modeling now be done?

    A.   Mr. Hawkins1 memo was not intended to discredit the use of less
 rigorous oxidant control strategy techniques such as rollback and EKMA.
 Further, it does not require detailed photochemical dispersion modeling
 in  the 1979 SIPs for all large urbanized nonattainment areas.  Instead,
 the memo was intended to provide consistency between the control require-
 ments for  urbanized and rural nonattainment areas.  We believe that where-
 conditions of uncertainty and/or lack of'precision exist, it is the prudent
 course of  action to regulate large VOC emitters in major urbanized areas
 to  at least the same degree as similar sources in rural nonattainment areas.

 2.  Q.   How should cutoff sizes be established in VOC regulations for
 large urbanized areas that get extensions beyond 1982 to attain the oxidarit
 standard?

    A.   The 100-ton per year limit does not apply here.  If a State chooses
 to  include a cutoff size other than one explicitly in the CTG documents,
 it  should  reflect a consideration of the nature of sources in an individual
 nonattainment area.  It should not be arbitrarily derived.  Factors such
 as  the magnitude of emissions and the economics of control must be con-
 sidered.   You are encouraged to consult with OAQPS (John Calcagni) as
 individual cutoff limits are established.

 3.  Q.   For purposes of the 1979 SIP submittal, do all  11  RACT categories
 contained  in the first round of CTGs have to be adopted for rural  nonattainment
 oxidant*SIPs?

    A.   Yes.  RACT regulations for all 11 CTG categories must be included
 in  the 1979 SIP for large VOC emitters (100 tons/yr potential  emissions).
 However, practically speaking, there may not be any large point sources
 in  certain CTG categories in some areas.   A positive showing  in the SIP
 submittal  that no such size sources exist in the affected  nonattainment
 area would obviously negate the need to require adopting of regulations
 for this or any other source category.  Service stations can  be assumed
 to be less than 100 tons without a detailed showing for the purposes  of
 exempting rural  areas from Stage I requirements.

4.  Q.   Is Appendix J an acceptable procedure for calculating percent
reduction required to achieve the oxidant NAAQS?

    A.  Present guidance permits the use of Appendix J.   However,  there
has been much adverse comment in the technical  community regarding its  •
adequacy; and its limitations are well known.  Therefore,  States should
be discouraged from using Appendix J because it is not  the best technique

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                                   - 2 -

available.  States should also be advised that EPA has proposed to rescind
Appendix J in its proposed revision to the NAAQS for ozone.  Regional
Offices should not use Appendix J in any calculations made for any urban-
ized area since it will not be considered-appropriate after the standard
is revised.

5.  Q.  The rollback equation accounting for transport is different in
the workbook used in the "Workshop on Requirements for Nonattainment
Area Plans" from the equation presented in the "Users" document.  Which is
correct?

    A.  Both are correct.  The equations are algebraically the same.

6.'  Q.  For CO SIPs, what is needed to demonstrate reasonable further
progress  (RFP) by 1982?

    A.  The requirement to demonstrate RFP will, in most areas, reflect
a continuous phased implementation of transportation control measures
(TCMs).  These TCMs will most likely stress overall vehicle miles
traveled  (VMT) reductions.  Also included in the RFP line would be
reasonable controls for point sources (in areas which have them), reduc-
tions from the Federal motor vehicle control plan (FMVCP) and where
required, I/M emission reductions for a decentralized program (1981) and
for a centralized program (1982).  Most CO violations are "hot spot"
type problems and some evaluation of progress toward attainment should
be made in these smaller areas as well as in the larger regional CO
nonattainment areas.

7.  0. *1
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                                   - 3 -

becomes involved.  In this case, it is current EPA interim policy to
approve the relaxation based on dividing equally between the two States,
the consumption of growth potential.  That is, each State will have use
of one-half the air quality difference between the NAAQS and the ambient
concentration now allowed at the border.  This concentration represents
the air quality level which would exist if sources in the area were to
emit at the level allowed by the applicable SIP.  The "one-half growth
allowance" concept should also apply to areas internal to the other
State.  That is, where an applicable source would have significant
impacts well within the geographic boundaries of the other State, then
that impact should also be evaluated using the "one-half growth allowance1
criteria.  If the relaxation would consume more than one^-half of any
applicable growth increment, then it will be disapproved.

9.  Q.  Can a Regional Office have a more stringent PSD monitoring program
or ask for additional monitoring in support of a permit application than
is recommended in the OAQPS guideline?

    A.  Yes, a Regional Office may exceed the minimum sampling requirements
specified in air guidance.  However, to assure some degree of regional
consistency, they should have sufficient justification when additional
monitoring or more frequent quality assurance tests are required from a
particular source.,

10. Q.  When are the State reviews for plan adequacy, as required by
Section 124, due for submission to the Regional Offices?

    A.  The results of the State reviews were due August 7, 1978.
       •«.
11. Q.  Has guidance been developed for implementing Section 124?

    A.  A draft guidance memorandum was distributed for Regional  Office
review on January 23, 1978.   That memo reflected a very detailed  review
process.   On July 31, 1978,  a final  guidance memorandum was sent to the
Regional  Offices;  however, it did not mandate the detailed review as
described in the earlier draft memo.  The final memo pointed out  that the
earlier draft could  be followed if a detailed review was necessary, but in
some cases, depending on conditions  within a State, a shorter, qualitative
approach  would suffice.   For further information on what constitutes a
qualitative approach, contact Roger  Powell  (FTS:   629-5437).

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   \   UNITED STATES  ENVIRONMENTAL PROTECTION  AGENCY

   /                     WASHINGTON, D.g. '20460
                                  AUG' 1978
       OFFICE OF
AIR AND WASTE MANAGEMENT
SUBJECT:  Requirement for VOC RACT Regulations in all
          Oxidant Monattainment Areas.

FROM:     David G. Hawkins, Assistant Administrator
            for Air, Noise and Radiation (AW-443)

TO:       Regional Administrators             ,   \
          Regions I-X
     This is a follov;-up to Mr. Costle's February 24, 1978, memorandum
entitled "Criteria for Approval of 1979 SIP Revisions", and to my recent
discussions with the Regional Air and Hazardous Materials Division
Directors in Houston.  It is intended to clarify the 1979 SIP require-
ments for volatile organic compound (VOC) RACT regulations for all
oxidant nonattainment areas.

     The issues of long range oxidant transport and background make it
difficult to develop oxidant control strategies with the degree of
precision normally associated with more stable air pollutants.  Further,
certain of the available analytical techniques will tend to under-
estimate the degree of control required'for attainment.  The use of
less rigorous analytical techniques such as rollback support 1979 SIP
revisions is acceptable in areas where reasonably available control
measures are scheduled for implementation.  However, for the reasons
stated above this technique is not acceptable as a demonstration that
RACT regulations on VOC sources are rot needed to attain and maintain
the oxidant standard.  Accordingly, for every cxidant plan which
relies on the rollback technique for its control strategy demonstration,
the plan must, as a mimimum, include legally enforceable provisions
for the control of large VOC sources- (more than 100 tons/year potential _
emissions) for which EPA has issued a Control Technology Guideline (CTG)'.
Plans which rely on  the rollback technique and do not contain these
provisions will not be approvable.  The only exception to this policy   .
is the situation in which the  control agency certifies that there  are no
affected sources for a particular source category in the nonattainment
area.

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                               2
     States which wish to attempt to demonstrate that the oxidant standard
can be attained and maintained without adopting one or more of such RACT
regulations for large VOC sources may do so but must employ more
rigorous analytical techniques than the rollback method.; i.e., photo-
chemical dispersion modeling.

     I ask that you proceed immediately to advise your States  and to
integrate this policy clarification into1.the ongoing SIP development
process.

cc:  M. Burning
     J. Bernstein
     Director, Air and Hazardous Materials
       Division, Regions I, III-X
     Director, Environmental Programs Division,
       Region II

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                           REF  1-7

    »
    =%    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                           WASHINGTON. D.C.  20460

                            11 SEP  1378
                                                             OFFICE OF
                                                      AIR AND WASTE MANAGEMENT
 SUBJECT:  Continuity of SIP Regulations
 FROM:     David G. Hawkins, Assistant Administrator
            for Air, Noise, and Radiation

 MEMO TO:  Regional Administrator, Regions I - X

     Pursuant to Sections.107; and 172 of the Clean Air Act,  many States
 have had areas designated as nonattainment and will be required  to
 submit revisions to their State Implementation Plans to provide  for
 attainment.  While many of these regulations will bring previously
 uncontrolled sources under the purview of control regulations, there
 will also be a significant degree of regulation tightening.   This sub-
 mittal of more stringent regulations probably will result in judicial
 challenges to the new regulations and requests for temporary relief, in
 the form of variances or delayed compliance orders, from the more onerous
 regulatory provisions.  In these situations, it is imperative that.
 the plan retain an enforceable regulation in order to minimize any
 further deterioration of air quality in nonattainment areas. In order
 to ensure that this deterioration does not occur, it is essential to
 inform affected States of the procedures to be followed in submitting
 and approving plan revisions.

     In approving a SIP revision, EPA will  provide that the  emission
 limitation'contained in the existing regulations remain in effect.
 New requirements imposed by th;e plan revision will normally  be treated
 as being in addition to, rather than in lieu of, those imposed by
 existing regulations.  For example, if the new regulations are judi-
 cially challenged, or if the source is granted a delayed compliance
 order or variance which exempts it temporarily from the provisions  of
 the new regulations, it must comply with the pre-existing regulations.
 Failure to meet these pre-existing standards will subject the source
 to appropriate enforcement actions, including the imposition of  non-
compliance penalties under Section 120 of the Act.

     EPA's policy should be set forth in the FEDERAL REGISTER notices
 proposing to approve, and approving, SIP revisions.  Also, the States
 should be informed of this policy immediately.  EPA will  disapprove
any SIP revision to the extent it is inconsistent with this  approach.

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     The one major exception to this rule would be when the new regulations
are "inconsistent" with those currently in effect.  In this situation,
the State may exempt the source from the requirements of the pre-existing
regulations, provided the source demonstrates that it cannot physically
meet the new regulations and continue to comply with the existing require-
ments.  If the State expects to grant such exemptions, it must establish
an appropriate exemption review mechanism in its nonattainmeht plan.
Exemptions approved by the State must be submitted to EPA as SIP revisions
to ensure that every exemption will be drawn as narrowly as possible.
EPA will review these exemption requests strictly.  An exemption request
may be granted only when the construction or installation of the new
equipment can no longer proceed while existing controls remain in operation.
No request may be granted, however, if to do so would interfere with the
demonstration of reasonable further progress required by the Act.

     Enclosed is suggested wording for EPA's FEDERAL REGISTER notices
proposing to approve, and approving, State Implementation Plan revisions.

cc:  M. Durning
     J. Bernstein

Enclosure

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                             ENCLOSURE
     This proposal/final action would/will replace measures in the
current SIP with the new measures submitted by the State to EPA for
approval.  Under this proposal/action, the current emission control
regulations applicable to any source would/will remain in effect
until such time as the newly revised regulation becomes effective and
the source achieves full compliance with its provisions.  This provision
applies to all revised SIP regulations, not merely those that are
subjected to judicial challenge.  Failure of the source to satisfy
the requirements of the former regulation would/will  result in appro-
priate enforcement actions.

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                 REF  II-l
    U.S. ENVIRONMENTAL PROTECTION AGENCY
                     AND
      U.S. DEPARTMENT OF TRANSPORTATION
TRANSPORTATION-AIR QUALITY PLANNING GUIDELINES
                  June 1978

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                              FOREWORD
The U.S. Environmental Protection Agency and  the  U.S.  Department of
Transportation are jointly issuing these transportation-air  quality
planning guidelines in response to Section  108(e) of  the  Clean  Air Act,
as amended August 1977.  Section 108(e) requires  EPA  to consult with  DOT
in preparing guidelines for the development of  transportation system
components of State Implementation Plans for  areas  that are  designated
air quality nonattainment areas with respect  to photochemical oxidants
and/or carbon monoxide.  EPA and DOT view these guidelines as a signifi-
cant step forward in our mutual efforts to  integrate  our  related planning
processes and better meet the objectives of both  agencies.
                                       \
                                          v
  «  *J
-<« /i.t.t £.. .-'L-i
                                                 Brock Adams
                                                  Secretary

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                              PREFACE


Section 108(e) of the Clean Air Act as amended, August 1977, directs
the U.S. Environmental Protection Agency in consultation with the U.S.
Department of Transportation and other agencies to supplement these
guidelines "from time to time."  This guidance issued jointly by EPA and
DOT may well be supplemented in the future as experience is gained
through actual applications.  These guidelines in their current form do,
however, describe an acceptable process for accomplishing the continuing
tasks of transportation-air quality planning and programming required by
the Clean Air Act.

The Transportation-Air Quality Planning Guidelines must be adapted
to the specific circumstances of each nonattainment area.  Lead planning
agencies along with other participating agencies and groups are encouraged
to meet quickly with EPA and DOT Regional Offices to discuss detailed
questions on guideline interpretation and implementation.  For example,
two areas that particularly require further discussion and guidance are
the: (1) exact form of transportation provisions in the 1979 SIP
submittal and (2) the precise scope of the alternatives analyses.

Additional guidance that will supplement these guidelines is currently
being prepared to implement Section 110(a)(3)(D) of the Act.  This section
requires nonattainment areas demonstrating the need for a standard attain-
ment deadline extension to 1987 to submit a public transportation
improvement program.  This SIP revision must establish, expand or improve
public transportation to meet basic transportation needs as expeditiously
as practicable.  A commitment to prepare and carry out such a program
must be included in the January 1, 1979 SIP submission.  The additional
procedural and substantive guidance will explain the analysis of
transportation needs and the development of a public transportation
improvement program as part of the alternatives analyses discussed in
Section III. E. of these guidelines.

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                               111

                        TABLE OF CONTENTS

         TRANSPORTATION-AIR QUALITY PLANNING GUIDELINES

                                                         Page

     FOREWORD                                              i

     PREFACE                                              11

           Table of Contents for Guidelines              111
           Table of Contents for Appendices               1v
           Organization of Guidelines                      v
           Guideline  Development Schedule                 vi
           Major Dates of  SIP Revision  Process           vii

     EXECUTIVE  SUMMARY                                  viii

  I.  INTRODUCTION                                          1

       A.  Purpose                                        1
       B.  Applicability                                   1
       C.  Funding                                        2
       D.  Background                                     4

 II.  SIP POLICY                                           6

       A.  Overall Summary                                6
       B.  Selected SIP Requirements                       7

III.  PROCESS                                              14

       A.   Introduction                                   ]4
       B.   Interagency Coordination                      J*
       C.   Involvement of Elected  Officials               15
       D.   Public Information and  Consultation            15
       E.   Evaluation of  Alternative Strategies          17

 IV.  MODIFICATION AND DOCUMENTATION OF EXISTING          21
      PLANNING ACTIVITIES

       A.   Introduction                             •     |]
        B.   Planning Work  Programs                          21
       C.   Transportation Plan                            21
        D.   Transportation Improvement Program             22
        E.   Documentation  of Alternatives Analysis         22
        F.   Consistency Determination Documentation        23
       G.   SIP                                            23

  V.   PROGRESS REPORTS                                     23

       A.   Introduction                                   23
        B.   Content                                        5*
        C.   Annual Report                                  24

      FOOTNOTES                                            25

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                                  iv

                   TABLE OF CONTENTS FOR APPENDICES  '

APPENDIX                                                       Page
   A       TRANSPORTATION-RELATED PROVISIONS OF                  1
           THE CLEAN AIR ACT
   B       CRITERIA FOR APPROVAL OF 1979 SIP                     9
           REVISIONS
   C       SIP REVISION PROCESS                                 23
   D       DEFINITIONS                                          27
   E       BACKGROUND INFORMATION ON TCP PROGRAM                31
   F       FUNDING                                              35
   G       EVALUATION OF ALTERNATIVE STRATEGIES                 42
   H       FHWA/UMTA ACTION MEMO                                45
   I       HUD-EPA AGREEMENT                                    47
   J       SUMMARY OF RELATED EPA GUIDELINES AND                50
           REGULATIONS
   K       DOT PLANNING AND PROGRAMMING REGULATIONS             52
           (23 CFR 450)

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                   ORGANIZATION OF THE GUIDELINES


Following the PREFACE which contains five subsections and the EXECUTIVE
SUMMARY begining on page vii, the Guidelines are organized into five major
chapters and a separate accompanying document with 11 Appendices (A-K).
The APPENDICES contain extensive supporting and reference material that
while relevant is not an integral part of the guidelines.

The INTRODUCTION covers the following aspects of the guidelines:
(1) Purpose, including the basic policy goal; (2) Applicability, including
the primary roles of the lead agency as well as DOT and EPA Regional
Offices; (3) Funding — authorized (but not yet appropriated) and available
funds; and (4) Background, including the relationship of the guidelines
to the original transportation control planning process and the existing
process administered fay DOT.

Chapter II, SIP POLICY, summarizes and elaborates upon the trans-
portation portions of a major EPA policy memorandum, "Criteria for
Approval of 1979 SIP Revisions."  This memorandum signed by the EPA
Administrator on February 24, 1978 is wholly contained in Appendix B.
Chapter II also provides an abbreviated checklist of the major trans-
portation-related requirements of an acceptable 1979 SIP.

Chapter III, PROCESS, presents the procedural part of the guidelines
by describing the elements of the integrated transportation-air quality
planning process designed to accomplish the policy goal and SIP require-
ments of Chapters I and II.  Chapter III defines procedures for:
(1) Interagency Coordination, (2) Elected Official Involvement, (3) Public
Information and Consultation, and (4) Evaluation of Alternative Strategies.

Chapter IV describes: (1) modifications to ongoing transportation
planning activities required by the Clean Air Act and (2) documentation
of those modifications.  Chapter IV discusses the Planning Work Programs,
Transportation Plan, Transportation Improvement Program, Alternatives
Analysis, Consistency Determination and the SIP.

Chapter V concludes the Guidelines with a discussion of the purpose,
frequency and content of progress reports.

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                                vi


                       DEVELOPMENT SCHEDULE

    EPA TRANSPORTATION-AIR QUALITY PLANNING PROCESS GUIDELINES


November 28, 1977                    ° First Draft Circulated

November 28-29, 1977                 ° Review by MPO Steering Group
                                       (NARC Grant)

February 1, 1978                     ° End of Comment Period on First
                                       Draft

February 9, 1978                     ° Review by Panel  of Transportation
                                       Experts

February 27, 1978                    ° Second Draft Circulated

March 13, 1978                       ° Briefing for EPA Regional Offices
                                       on Second Draft

March 14-15, 1978                    ° Major EPA-DOT Workshop on Second
                                       Draft (NARC Grant)

June 1978                            ° EPA and DOT Jointly Issue Planning
                                       Process Guidelines

Post June 1978                       ° Joint EPA-DOT Regional Meetings

                                     0 Modifications of FHWA-UMTA Regulations
                                       to Reflect Guidelines

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                                 vii
                  MAJOR DATES OF SIP REVISION PROCESS


February 7, 1978               ° Jointly Determined Division of
                                 Responsibilities

                               0 Lead Planning Organization Designated
                                 by Local Officials

April 1, 1978                  ° Governor Certifies or Designates Lead
                                 Planning Organization*

January 1, 1979                ° State Submits Revised Plan

July 30, 1980                  ° Suggested Date for Completion of
                                 Comprehensive Alternatives Analysis

July 1, 1982                   ° Second State Submittal of Revised Plan
                                 if Extension Granted

December 31, 1982              ° Standards Attainment Deadline Where No
                                 Extension Granted

                               0 Initiation of Extensive Transportation
                                 Measures

1983 - December 31, 1987       ° Standards Attainment Deadline Where
                                 Extension Granted
*If for example the MPO prepares the transportation portion of the
 SIP, then one key decision at the local level would be the interim
 date by which the MPO submits the transportation portion to the
 state so that adequate time remains to integrate this portion with
 the stationary source part of the SIP and meet the statutory submittal
 deadline of January 1, 1979.

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                                  viii


                          EXECUTIVE SUMMARY


Selected Requirements of the Clean Air Act

The Clean Air Act as amended, August 1977, establishes various federal,
state and local requirements aimed at the expeditious attainment of the
air quality health standards.  The Act requires achievement of these
standards by December 31, 1982.  However, for carbon monoxide (CO) and
photochemical oxidants (Ox) a five-year extension to 1987 can be granted.
This extension is contingent on a state demonstrating in its 1979 State
Implementation Plan (SIP) that attainment is not possible by 1982 despite
the implementation of all reasonable stationary and transportation
control measures.

Most major urban areas with CO and Ox problems will be unable to meet
the air quality health standards by 1982 through reliance on stationary
source controls and federal new car standards alone.  These areas there-
fore will be required to develop and implement such transportation
strategies as mass transit improvements, preferential bus and carpool
treatment, areawide carpool programs, parking management, pricing, auto-
restricted zones, etc. — which are all designed to reduce auto emissions.
Revised SIPs that include programs to reduce both stationary and trans-
portation system emissions must be submitted to EPA by January 1, 1979.
(Table 1 on page 8 provides an abbreviated checklist of the major
transportation-related requirements of an acceptable 1979 SIP.)

The Act emphasizes — especially for the transportation portion of
SIPs — locally developed plans that result from: (1) extensive consulta-
tion among federal, state, regional and local agencies; (2) public
education and participation; (3) elected official involvement; and
(4) the documented analysis of a wide range of alternative strategies.
The Act specifies that the transportation-air quality planning process
be coordinated with the continuing, cooperative, and comprehensive
t"3C") transportation planning process administered by the Department
of Transportation.

local governments and organizations of local elected officials are
explicitly encouraged.to assume greater responsibilities in the develop-
ment and implementation of SIPs.  The Clean Air Act indicates a preference
for the certification by Governors of metropolitan planning organizations
(i.e., the DOT "3C" agencies) as the lead agencies for preparing control
plans in urban areas that are nonattainment with respect to CO and Ox.
The Amendments of 1977 authorize new planning funds ($75 million) to
organizations of local elected officials for a two-year period and also
provide for new funding sanctions for failure to develop and implement

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                                  IX
adequate plans.  It appears that approximately $25 million may be
appropriated in fiscal year 1979 to support the first year of the
planning process.

The Act calls for EPA to cooperate with DOT in preparing information
documents on the costs, effects and analytical techniques for selecting
transportation measures and developing strategies.  (Information is
being prepared on an extensive array of transportation improvements,
covering: public transit, traffic operations, parking management, pricing,
and auto-restricted zones among others.)  EPA must also consult with
DOT and other officials in the development of guidelines on the basic
elements of the planning process for nonattainment areas.  These jointly
issued transportation-air quality planning guidelines are the result of
that consultation.

SIP Policy

EPA has established reasonable and achievable SIP requirements and will
take a firm posture on the imposition of sanctions where the requirements
are not achieved.  An extension of the deadline to 1987 for standard
attainment is not automatic; a demonstration of need must be made and
the state must fulfill the other statutory requirements in the Act.  The
transportation requirements of the 1979 SIP place primary emphasis on
a commitment to a continuing process.

Since reliance on stationary controls and federal new car standards
alone will not enable most areas with Ox and CO problems to meet
standards by 1982, additional specific measures must be included
in the 1979 SIP to reduce transportation system emissions.  The 1979
SIP requirements include a commitment to: (!) accelerated implementation
of specific strategies (e.g., transportation improvements contained in
the current or recent annual element (AE)); (2) the incremental phase-
in of additional strategies (e.g., other measures contained in the
transportation improvement program (TIP) that appear reasonable and
effective on the basis of preliminary analysis); and (3) a schedule of
activities leading to implementation of an inspection/maintenance
(I/M) program by 1981 (decentralized system) or 1982 (centralized
system).

However, in addition to this commitment to specific measures, the 1979
SIP submittal places, as noted above, primary emphasis on a commitment
to a continuing process for the transportation planning and programming
requirements.  This commitment to a process should lead to the expeditious
development, evaluation, selection and implementation of comprehensive
transportation control strategies.  The process should extensively
involve the public as well as state and local elected officials.  An
acceptable 1979 SIP should contain these process elements: (1) identifi-

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cation of tasks and responsibilities of all participating agencies;
(2) a schedule for developing and analyzing ambitious, alternative
packages of transportation measures; (3) verification that such an
analysis is underway; (4) a schedule for adoption of package(s) of
measures determined to be reasonably available; and (5) a commitment  to
justify any decision not to adopt difficult measures.

Transportation-Air Quality Planning Guidelines

These guidelines address the transportation-related sections of the
Clean Air Act and describe an integrated transportation-air quality
planning process for developing the transportation system component of
SIPs for areas that are nonattainment with respect to Ox and/or CO.  The
basic policy goal of this process is to reduce transportation system
emissions and adverse air quality impacts while maintaining compati-
bility with other community goals.  The guidelines build upon the
existing planning process by providing specific procedures designed to
result in a program of transportation strategies that provide for
incremental reductions in transportation system emissions as expeditiously
as practicable.

These guidelines describe an acceptable planning process intended
to satisfy Clean Air Act requirements for the transportation portions
of an approvable SIP.  That process as outlined in these guidelines must
result in the expeditious development and implementation of all reason-
ably available measures.  Reasonably available measures are determined
through an analytical, participatory and negotiatory process.  Early and
frequent involvement of EPA and DOT in the process will best insure the
development of a SIP that meets the requirements of the Act.

These guidelines apply to all public agencies with responsibilities in
planning or implementing the transportation portions of SIPs in
nonattainment areas.  The lead planning agency has the primary respon-
sibility for implementing these guidelines.  EPA and DOT Regional
Offices are primarily responsible for monitoring the guideline imple-
mentation process.  The Inter-modal Planning Group (IPG) should be the
federal coordinating mechanism.  Modifications to these procedures by a
state, regional or local agency should be closely coordinated with the
Regional Offices.

The procedures outlined below are a realistic starting point and
undoubtedly will be improved upon by experience gained through actual
applications.  The guidelines should be implemented through ongoing
planning processes and flexibly applied.  However, modification of
guideline elements will require substitution by a comparably effective
approach.

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                                  xi


Chapter III of the Guidelines describes  in detail the elements of
the planning process needed to accomplish SIP requirements.  The scope
and.intensity of planning activities undertaken should be commensurate
with the size of the metropolitan area and the complexity of its
transportation and air quality problems.  These elements include:

          0 Interagency Coordination:  The lead agency in
            cooperation with other participating agencies should
            establish a program for developing the joint responsi-
            bilities and working relationships (e.g., through
            interagency agreements) of all agencies and organi-
            zations involved in the process.  The objective is
            to determine who should do what when.
          o
            Involvement of Elected Officials:  The lead agency
            should coordinate the joint development of procedures
            to increase the involvement of elected officials.
            The objective is to increase the probability of
            obtaining the commitment of officials to support
            and fund needed transportation improvements.

            Public Information and Consultation:  The lead agency
            should also make a parallel effort to insure adequate
            public information and consultation.  The public and
            interest groups should specifically participate in the
            development and analysis of alternative transportation
            strategies..  The minimum basic elements of a public infor-
            mation and consultation process should include: (1) an
            inventory and assessment of agency programs and
            interest groups; (2) the joint development by agencies
            and groups of a program for information and partici-
            pation based on the assessment.

            Evaluation of Alternatives:  The analysis of alternatives
            develops information essential to local decisionmaking
            and federal review on the costs and effects of various
            actions.  Alternatives should be developed and analyzed
            in most cases under the auspices of the metropolitan
            planning organizations in cooperation with federal,
            state and local planning, transportation, and
            environmental agencies, interest groups, elected
            officials, the public and others.  For the purpose of
            alternatives analysis each of the transportation measures
            listed in the Act for which EPA will publish information
            documents is considered reasonably available.  In
            evaluating the costs and effectiveness of alternatives,

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                                  Xii
            the full range of potential impacts should be taken
            into account including not only air quality but also the
            locality's transportation and urban development needs,
            economic, social and other environmental impacts as well
            as feasibility of implementation.

Chapter IV deals with both modifications to ongoing planning activities
required by the Clean Air Act and documentation of those modifications.
Those activities include: planning work programs, the transportation
plan including the transportation systems management and long range
elements, TIP/AE, alternatives analysis, consistency determinations, and
SIP.  Chapter V discusses the content and frequency of progress reports
stressing that such reports should be brief and should not substitute
for the more effective mechanism of direct staff contact for demonstrating
and determining progress.

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           TRANSPORTATION-AIR QUALITY PLANNING GUIDELINES


I.  INTRODUCTION

A.  Purpose

These guidelines implement Section  108(e) of the Clean Air Act as amended,
August 1977.'*  Section 108(e) directs EPA to provide guidelines on the
basic elements of the planning process for nonattainment areas.2  This
procedural guidance addresses the transportation-related sections of the
Clean Air Act.  These guidelines describe an integrated transportation-
air quality planning process  (hereafter called the integrated planning
process) for developing the transportation system component of State
Implementation Plans (SIPs) for areas that are designated nonattainment
with respect to photochemical oxidants (Ox) and/or carbon monoxide
(C0).3>4  EPA will subsequently provide more technical information on
costs, effects and analytical techniques for selecting measures and
developing strategies as  required by Section 108(f).

The basic policy goal of  the  integrated planning process described herein
is to reduce transportation system  emissions and resulting adverse air
quality impacts while maintaining compatibility with other community
goals.  The guidelines  build  upon the existing planning process by
providing specific procedures designed to result in a program of trans-
portation strategies that provide for incremental reductions in ,-
transportation system emissions as  expeditiously as practicable.   The
guidelines stress continuing  development and expeditious implementation
of all reasonably available measures, but particularly those that can be
planned and implemented by 1982 or  during the following five years to
1987 as provided for  in the Clean Air Act.  Major long-term trans-
portation improvements  necessary  for maintenance of the air quality
health standards beyond 1987  also should be considered within the inte-
grated planning process.

B.  Applicability

These guidelines apply  to all public agencies with  responsibilities  in
planning  or implementing the  transportation  portions  of  SIPs  in nonattain-
ment areas.6   (Section  174 of the Act  requires:  (1) designation of a
lead planning  organization and,  (2) state and  local elected officials  to
determine jointly  the  coordinated and  combined  responsibilities of the
state,  local  governments and  regional  agencies  in  the SIP  revision
process.)
V /
 *Footnotes are at the end of the guidelines beginning on page 25.

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The guidelines describe an acceptable approach for accomplishing the
continuing tasks of transportation-air quality planning and programming
required by the Clean Air Act.  These procedures are a realistic starting
point.  They should be improved upon by experience gained through actual
applications.  The guidelines build upon and should be implemented^
through the ongoing comprehensive planning processes.  They recognize
that institutional arrangements and planning procedures vary by area
and, therefore, can be flexibly applied.  But, while individual guideline
elements need not be viewed as mandatory, the objective of each element
is a necessary part of an effective process — a process required by
the Act.  Therefore, modification of guideline elements will require
substitution of a comparably effective approach.

The lead planning agency has the primary responsibility for implementing
these guidelines.  EPA and DOT Regional Offices are primarily responsible
for monitoring the guideline implementation process.  The Intermodal
Planning Group (IPG) should be the federal coordinating mechanism.
Modifications to these procedures by a state, regional or local agency
should be closely coordinated with the appropriate EPA and DOT Regional
Offices.

C.  Funding

This section describes both authorized (but not yet appropriated) and
currently available funds for conducting the transportation-air quality
planning activities required by the Act.  Appendix F describes funding
for plan implementation and related planning.

    1.  Authorized Funds

Section 325 of the Act authorizes the appropriation of $75,000,000
(available until expended) to carry out Section 175 beginning in fiscal
year (FY) 1978.  Section 175 directs EPA to make grants to meet the
reasonable costs of plan development to any organization of local elected
officials with transportation or air quality maintenance planning
responsibilities recognized by the state under Section 174(a).  Grants
would cover 100 percent of any additional costs of developing a SIP
revision for a nonattainment area for the first two fiscal years following
grant receipt.  Grants would supplement any other federal funds available
to such organization for transportation or air quality maintenance
planning.  Grants could not be used for construction.

    2.  Available Funds

        a.  Section 175:  Prior to the announcement of the President's
urban policy, no Section 175 grant funds were included in the FY 1979
federal budget submitted to Congress.  Funds to implement an EPA-DOT
joint transportation-air quality planning process were, however,
included as a contingency item in that budget.  These funds were to be

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made available when a DOT-ERA memorandum of  understanding was signed.
Release of these funds would require  Congressional approval.  However,  the
urban policy announced on March  27, 1978 included $25 million in
grant funds to be requested from Congress for FY 1979 for planning in
nonattainment areas.  As of late April  the following summarizes the
status of the $25 million:

The funds will be requested for  inclusion in EPA's budget under Section
175.  No decision has been reached on distribution procedures — i.e.,
whether EPA or DOT grant procedures will be  used.  The Office of
Management and Budget (OMB) has  not announced whether the $25 million
replaces or adds to the contingency fund for FY 1979.  Congress may,
of course, appropriate an amount different from that requested by the
Administration.  Allocation formulas  and procedures are being developed.

        b.  Section 105:  EPA has earmarked $2 million, available under
Section 105 (Control Agency Grants),  for FY  1978 to assist Section 174
agencies in completing the requirements for an approvable 1979 SIP
submittal.  Small amounts of funds under current Section 105 grants
might also be available for FY 1979.

        9-  DOT Funds;  At the direction of the President, OMB requested
integration of EPA's transportation-related air quality planning require-
ments into the transportation planning  process administered by DOT.
This integration should produce:  (1)  joint planning regulations to meet
DOT and EPA objectives, (2) joint DOT-EPA administration of the air
quality aspects of the planning  process, and (3) a common, jointly
administered federal funding mechanism  for transportation and air
quality planning.

As a follow-up to the OMB request, the  Federal Highway Administration
(FHWA) and Urban Mass Transportation  Administration (UMTA) Administrators
sent the following memorandum to their  Regional Administrators (Appendix
H contains the entire memorandum):

     "Because of the imminence of the January 1, 1979, deadline, we
     are directing that the following actions be initiated promptly by
     the regional staffs of UMTA and  FHWA:

        1.  The EPA should be invited to participate in the Intermodal
     Planning Group (IPG) so as  to insure coordination of all activities
     pertaining to the urban transportation planning process;

        2.  The EPA should be consulted to determine which areas are
     likely to require [transportation  control plans] TCPs and what the
     estimated magnitude of TCP  effort will  be in those areas;

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        3.  For areas requiring TCPs, funds within already approved
     Unified Planning Work Programs (UPWPs) may be reprogramed as
     appropriate to support the identification and analysis of
     transportation control measures in coordination with the SIP
     revision process;

        4.  Air quality planning tasks in support of the SIP revision
     process should be given a high priority in UPWPs now being
     developed.  Air quality planning is a national priority and
     must be given appropriate emphasis in the conduct of the
     transportation planning process;

        5.  The transportation improvement program (TIP)/annual element
     (AE) review process should be conducted with a renewed emphasis
     on the inclusion of projects benefiting air quality in the TIP/AE;
     and
                                                 \

        6.  The certification review process should be conducted with a
     renewed emphasis on the coordination of air quality planning and
     transportation planning as required by the joint regulations."

D.  Background

Appendix E traces the history of EPA's transportation control program
previous to the Clean Air Act Amendments of 1977.  The amended Act
addresses problems of the original transportation control planning
process by requiring locally developed plans based on these major
elements: extensive agency interaction among all governmental levels;
significant involvement of local elected officials; effective public
education and participation; and integration with ongoing planning
processes, particularly emphasizing the DOT continuing, cooperative and
comprehensive (30) process (23 CFR 450).  The amended Act also provides
sanctions to insure both an effective planning process and the imple-
mentation of an approved or promulgated SIP (Sections 176 and 316).
These guidelines describe the elements of an acceptable planning process
intended to correct many of the earlier problems and to result in
approvable SIPs for nonattainment areas.

The following sections provide additional background on the objectives
and implementation of these guidelines:

   1.  Integration With Ongoing Planning Processes.  Planning conducted
under these guidelines should be integrated to the fullest extent possible
with existing comprehensive transportation and air quality planning
processes (including AQMP where applicable), and should include the use
of common data bases, modeling applications, and coordinated planning
activities among staffs of the participating agencies.  This guidance
builds upon and selectively expands the DOT joint planning regulations
(23 CFR 450), a knowledge of which is essential to users of the guide-
lines (Appendix K).

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Integrated DOT and EPA planning should result in a more efficient process
and in products that better meet the objectives of both agencies.  Related
activities required by both agencies should be merged and duplication
eliminated.  Establishing separate and costly planning processes should
be avoided.

   2.  A Continuing Process.  Preparing the transportation portion of
the SIP is not merely the one time development of short range tactics
to improve air quality, but rather the entire process of regularly
taking air quality needs into account in all transportation decisions.
Urban areas with actual or potential violations of the national air
quality standards for transportation-related pollutants should re-
evaluate their transportation plans and programs on a continuing basis.
If necessary, these areas should revise the transportation plan, including
the transportation systems management (TSM) element, and the Transportation
Improvement Program (TIP) to achieve continual incremental air quality
improvements and prevent future air quality problems.  Areas which violate
the health standards should demonstrate continuing, expeditious progress
in planning, programming and implementing measures that improve air
quality.  These areas may have to forego or postpone projects that would
cause adverse air quality impacts and reprioritize other projects to
achieve expeditious improvements in air quality.

   3.  Designation and Role of the Lead Agency or MPO.  Where feasible
the lead organization designated to conduct and/or coordinate the planning
and implementation process in nonattainment areas (and thus primarily
responsible for applying these guidelines) should be either the metro-
politan planning organization (MPO] designated to conduct transportation
planning under Section 134 of title 23, USC, or the organization responsi-
ble for the air quality maintenance planning process.  Where such agencies
are not so designated, their relationship with the designated lead
agency and their role in such planning should be clearly identified.  Also,
the relationships among the lead organization, comprehensive planning
agency and the A-95 clearinghouse should be identified where those
agencies are not the same.

Both EPA and DOT view the role of the MPO as providing a forum for coopera-
tive decisionmaking by principal elected officials of general purpose
local government.  The designation of the MPO as lead agency or the
process established by these guidelines should np_t preclude other state,
regional or local agencies from acting through this forum.  In fact,
Section 174 of the Clean Air Act envisions a SIP revision process
involving a combination of state, regional and local agencies.  Manage-
ment of an efficient, effective process may require the MPO or lead
agency to allocate responsibilities to other agencies with better expertise
for specific tasks.  The lead agency should regard the integration of
the mobile and stationary components of the SIP as a joint task of great
significance demanding the close cooperation of all participating agencies.
Clearly, development of an approvable 1979 SIP requires a commitment  on
the part of all appropriate agencies with planning and/or implementation
authority.

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II.  SIP POLICY

These transportation-air quality planning guidelines are designed
to describe an acceptable planning process intended to satisfy Clean
Air Act requirements for the transportation portions of an approvable
SIP.  Specifically, in regard to the transportation-related requirements
of the 1979 SIP revision, primary emphasis is placed on a commitment to
a continuing process.  That process as outlined in these guidelines must
result in the continuing development and expeditious implementation of
all reasonably available measures necessary, together with stationary
source controls, to attain the standards.  Reasonably available measures
are determined through an analytical, participatory and negotiatory
process.  Early and frequent involvement of EPA and DOT in the process
will best insure the development of a SIP that meets the requirements of
the Act.

Appendix B contains for reference purposes a major policy memorandum,
signed fay the EPA Administrator and dated February 24, 1978, "Criteria
for Approval of 1979 SIP revisions."  Chapter II draws upon key sections
of this policy memorandum applicable to the transportation portion of
SIPs.

A.  Overall Summary of SIP Policy

The Clean Air Act requires the demonstration of attainment of the primary
air quality standards as expeditiously as practicable, but not later than
December 31, 1982.  However, for CO and Ox, the Act allows up to a five-
year extension if a state can demonstrate that attainment is not possible
by 1982 despite the implementation of all reasonable stationary source
and transportation control measures.  In such cases the plan revisions
must still demonstrate attainment as expeditiously as practicable but
not later than December 31, 1987.  An extension is not automatic; a
demonstration of need must be made and the states must fulfill the other
statutory requirements.  EPA has established reasonable and achievable
SIP requirements and will take a firm posture on the imposition of
sanctions where these requirements are not achieved.

Since reliance on stationary controls and federal new car standards alone
will not enable most areas with Ox and CO problems to meet standards by
1982, additional specific measures must be included in the 1979 SIP to
reduce transportation system emissions.  The 1979 SIP requirements
include a commitment to: (1) accelerate implementation of specific
strategies (e.g., transportation improvements contained in the current
or recent annual element (AEII; (2) the incremental phase-in of additional
strategies (e.g., other measures contained in the transportation improve-
ment program (TIP! that appear reasonable and effective on the basis of
preliminary analysis!; and (.3). a schedule of activities leading to
implementation of an inspection/maintenance  (I/M) program by 1981
(decentralized system) or 1982 (centralized system).

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However, as noted above primary emphasis is pla.ced on a commitment to a
continuing process for the transportation planning and programming
requirements in the 1979 SIP submittal.  This commitment to a process
should lead to the expeditious development, evaluation, selection and
implementation of comprehensive transportation control strategies.  The
process should extensively involve the public as well as state and local
elected officials.  In addition to the commitment to specific measures
previously outlined, an acceptable 1979 SIP must contain these process
elements: (1) identification of tasks and responsibilities of all
participating agencies; (2) a schedule for developing and analyzing
ambitious, alternative packages of transportation measures; (3) verifi-
cation that such an analysis is underway; (4) a schedule for adoption
of package(s) of measures determined to be reasonably available; and (5)
a commitment to justify any decision not to adopt difficult measures.

DOT, Housing and Urban Development (HUD) and EPA are seeking to integrate
the transportation-air quality planning and implementation required by
the Clean Air Act into existing planning and programming procedures.
Air quality-related transportation planning activities should be included
in the UPWP required by DOT.  Adopted air quality-related transportation
measures should be included in the TIP/AE required by DOT.  The HUD-EPA
Agreement on coordinating air quality planning and HUD's Comprehensive
Planning Assistance (701) Program (Appendix I) is also important.  Inte-
gration of air, transportation, and comprehensive planning which incorporates
growth management concerns should improve the effectiveness of air
quality planning and reduce the need for future enforcement measures.

B.  Specific Selected SIP Requirements

The following selected requirements draw upon the "Criteria for Approval
of the 1979 SIP Revision" memorandum, apply primarily to the trans-
portation portion of the SIP and expand summary information presented in
Section A.  (Again, Appendix B contains the entire memorandum.)  Table 1
provides an abbreviated checklist of the major transportation-related
requirements of an acceptable 1979 SIP.

    1.  Transportation-Related Requirements of all 1979 SIP Revisions

        a.  Adoption in legally enforceable form8 of all measures
necessary to attain standards by the prescribed date.  Where adoption
of all such measures by 1979 is not possible (e.g., certain trans-
portation control measures) a staged schedule for the expeditious
development, adoption, submittal, and implementation of these measures
should be included.  Each schedule should provide for implementation of
all reasonably available control measures as expeditiously as practicable.
Prior to attainment, these measures must be implemented on a schedule
that demonstrates annual  incremental  emission reductions.  (See below in
subsection Ic on reasonable further progress.)  As part of the SIP each

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                                 8


                               Table 1


Checklist of Transportation-Related Provisions  of the 1979 SIP

A.  Problem Definition

    1.  Definition of nonattainment area and geographic area covered
        by transportation control measures;

    2.  Accurate, comprehensive and current emissions inventory;

    3.  Estimation of emission reductions needed to demonstrate
        standard attainment by 1982 and 1987 (including emission growth
        projections); and

    4.  Determination of whether federal new car standards and proposed
        transportation and stationary source controls demonstrate
        attainment by 1982.  Demonstration of need for attainment dead-
        line extension to 1987;

B.  Process

    1.  Designation and certification of a lead agency for nonattainment
        areas;

    2.  Identification of agency tasks and responsibilities;

    3.  Schedule for comprehensive  alternatives analysis  and  demonstration
        that analysis is underway;

    4.  Schedule for adoption of reasonably available measures;

   ^5.  Commitment to justify decision not to adopt difficult,  but
        reasonably available measures (see page 7 in the  guidelines
        for additional information  on B.  2-5);

    6.  Process for public, interest group, and elected official
        consultation and involvement in:  defining transportation-
        air quality issues, establishing the planning process,
        development and analysis of alternatives (see pages  14-15);

    7.  Identification of estimated financial  and manpower resources
        necessary to carry out the  process described by these guide-
        lines.   A commitment to the first year of this process
        should be demonstrated in the UPWP;

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    8.   Evidence that the SIP was adopted by the state after reasonable
        notice and public hearing;

    9.   Provisions for progress reporting throughout the planning and
        implementation period (pages 22-23);

        Additional Transportation-Related Provisions for Areas
        Unable to Attain by 1982

   10.   Schedule of activities leading to implementation of I/M
        (see pages 6, 10); and

   11.   A commitment to use (insofar as is necessary) available grants
        and funds to establish, expand or improve public transportation
        measures to meet basic transportation needs as expeditiously
        as practicable (page 10).  (As indicated in the Preface, further
        guidance will be provided.)

C.  Strategy Development/Implementation

    1.   UPWP air quality-related transportation planning tasks being
        performed by each agency during FY 792 (pages 19-20);

    2.   Emission reduction estimates for adopted measures and/or packages
        of measures.  Rough estimates of annual emission reductions
        through 1987 for packages of measures currently being
        developed and analyzed;

    3.   Preliminary identification of analytical methodologies for
        determining air quality, travel, economic, energy, social
        etc. effects of plan provisions.  Summary of any public comment
        on such methodologies (pages 18-19); and

   ,4.   Commitment to: (1) accelerate implementation of transportation
        improvements in current or recent AE, (2) incremental  phase-in
        of additional reasonable measures (page 6).
   The required provisions can be loosely placed in three categories:
   Problem Definition, Process, Strategy Development/Implementation.

   The SIP should summarize planning activities by major categories
   (e.g., long term public transit improvements, TSM elements).  However,
   as noted in the Preface, the exact form of SIP provisions should be
   worked out fay the lead agency and DOT and EPA Regional Offices.

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                                 10


schedule will represent a commitment by the state to provide for attain-
ment by the prescribed date.  The schedule of key milestones should  be
viewed as a series of sequential, step by step commitments.  For example,
the initial commitment to be made in the January 1979 SIP is to the
thorough analysis of alternatives.  Subsequent commitments should advance
measures found to be reasonable and effective through programming and
implementation steps.  Adequate substitutions must be made for measures
determined to be ineffective or impracticable.

        b.  Emission reduction estimates for adopted or scheduled
measures or for packages of measures where estimates for individual
measures are impractical.

        c.  Provision for reasonable further progress toward attainment
of the primary and secondary standards prior to the prescribed attain-
ment date.  "Reasonable further progress" means annual incremental
reductions in total emissions (from new as well as existing sources) to
provide for attainment by the prescribed date.  The SIP should be
designed to provide for substantial  reductions in the early years with
regular reduction thereafter, although the most substantial reductions
from transportation sources may occur in later years due to longer
planning and implementation lead times.

Demonstration of reasonable further progress requires in most areas
designated nonattainment for Ox or CO, a continuing phased implementation
of transportation control measures.   Reliance only on the Federal Motor
Vehicle Control Program as a demonstration of reasonable further progress
is not acceptable in areas unable to attain the standards by 1982.

        d.  Identification and quantification of: (1) growth rates for
stationary and mobile sources and (2) a procedure to monitor emission
growth from stationary and transportation sources to assure compliance
with the amounts specified in the SIP.  The growth rate identified in
the SIP must be consistent with the growth rates used (or implied by)
the other planning activities in the area (e.g., FWPCA Section 208 [201],
HUD Section 701, FHWA Section 134).

        e.  Provision for annual reporting on: (1) progress toward meeting
the schedules noted in (a), and (2)  growth in emissions from mobile
sources, minor new stationary sources, major new or modified stationary
sources, and reduction in emissions  from existing sources to provide for
reasonable further progress as noted in (c) above.  This should include
an updated emission inventory.

        f.  Identification of estimated financial and manpower resources
necessary to carry out the process described by these guidelines.  A
commitment to the first year of this process should be demonstrated  in
the UPWP.

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                                 n


        g.  Evidence of public, local government and state legislative
involvement and consultation.  The SIP should also identify and analyze
the air quality, health, welfare, economic, energy, and social effects
of the plan revisions considered and provide a summary of public comment
on such analyses.  The 1979 SIP may contain a preliminary evaluation
with a commitment and schedule for further, more intensive and compre-
hensive analysis.

        h.  Evidence that the SIP was adopted by the state after reasonable
notice and public hearing.

    2.  Additional Transportation-Related Requirements for CO and Ox
        Revisions Which Provide for Attainment of the Primary Standards
        Later Than 1982

For those SIP revisions which demonstrate that attainment of the primary
standards for CO and/or Ox is not possible prior to December 31, 1982
despite the implementation of all reasonable emission control measures, the
following must be included in the January 1, 1979 submission in addition
to the general requirements listed above in subsection 1:

        a.  An inspection/maintenance program or a schedule endorsed and
committed to fay the Governor for the expeditious development, adoption,
and implementation of such a program.

        b.  A commitment by responsible government officials to:
(1) establish, expand, or improve public transportation measures to
meet basic transportation needs as expeditiously as practicable and
(2) use (insofar as necessary) available grants and funds, consistent
with the terms of the legislation providing such grants and funds, to
establish, expand, or improve public transportation measures to meet
basic transportation needs.  (As noted in the Preface, additional
substantive and procedural guidance on this requirement will soon be
issued.)

    3.  Pollutant Specific Requirements (CO and Ox)

The 1979 Ox SIP submissions must represent a comprehensive strategy
for each nonattainment area providing for sufficient control of volatile
organic compounds from stationary and mobile sources necessary to attain
the oxidant standard.  SIP submissions that address only selected portions
of nonattainment areas are not adequate.  For oxidant plan development,
major urban areas are those with an urbanized population of 200,000 or
greater (U.S. Bureau of Census, 1970).  Although specific boundaries may
be defined somewhat flexibly, the boundaries must be large enough to
cover the entire urbanized' area and adjacent fringe areas of development.

SIP revisions must provide for expeditious implementation of reasonably
available control measures.  At a minimum the following transportation
measures for which EPA will publish information documents are considered,
for the purpose of analysis, to be reasonably available:

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                                 12
    1.  To be published by February 1978

        a.  inspection/maintenance
        b.  vapor recovery
        c.  improved public transit
        d.  exclusive bus and carpool lanes
        e.  area wide carpool programs

    2.  To be published by August 1978

        a.  private car restrictions
        b.  long range transit improvements
        c.  on street parking controls
        d.  park and ride and fringe parking lots
        e.  pedestrian malls
        f.  employer programs to encourage car and
              vanpooling, mass transit, bicycling
              and walking
        g.  bicycle lanes and storage facilities
        h.  staggered work hours (flexi-time)
        i.  road pricing to discourage single occupancy
              auto trips
        j.  controls on extended vehicle idling
        k.  traffic flow improvements
        1.  alternative fuels or engines and other
              fleet vehicle controls
        m.  other than light duty vehicle retrofit
        n.  extreme cold start emission reduction programs

The above measures (either individually or in packages) should be analyzed
promptly and thoroughly.  This alternatives analysis for each urban area
will produce the essential information needed to determine precisely
what comprehensive strategies are reasonably available.  The selected
strategies should then be scheduled for: (1) more detailed analysis, if
necessary, (2) submittal to, and adoption by, policy boards, and
(3) implementation.  Because all analyses of every measure or package
cannot be completed by January 1979 for inclusion in the SIP, where
necessary a submitted schedule may provide for subsequent completion.
(Where subsequent analyses demonstrate that certain measures may be
unnecessary, ineffective or infeasible, a decision not to implement them
may be justifiable.  Such decisions will, however, be reviewed carefully
by EPA and DOT Regional Offices.)

As described previously, annual incremental reductions in total emissions
must occur to demonstrate reasonable further progress prior to attainment
of the standards.  Therefore, implementation activities should not be
delayed until completion of the comprehensive analyses of alternative

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                                  13


transportation improvement packages.  For example, feasibility studies
and demonstration projects are often essential steps in the planning and
implementation of specific measures (e.g., auto-restricted zones,
specialized transit service).  Where demonstration projects are appro-
priate, they should be scheduled for implementation prior to the end of
1980.

Planning and implementation of certain air quality-related transportation
measures and strategies may be a complicated and lengthy process extending
beyond 1982 in areas with severe CO or Ox problems.  Implementation of
even very extensive transportation measures, however, must be initiated
before December 31, 1982.

Where revised SIPs justify an extension of the attainment date, the adopted
transportation portion must provide:

   1.  Specific procedures and criteria developed by the agencies
designated according to Section 174 for determining whether the
transportation planning process conforms to the SIP.

   2.  A schedule for the expeditious implementation of already planned,
reasonably available transportation measures including transportation
provisions in existing SIPs and other transportation measures with
demonstrable air quality benefits developed as part of the transporta-
tion process administered by DOT.

   3.  A program for evaluating alternative packages of transportation
options covering at least those measures for which EPA will develop
information documents.  The analyses must identify a package of measures
which will attain the emission reduction target ascribed to trans-
portation sources in the SIP.  The comprehensive analysis of alternative
must be completed by July 1980 unless the lead agency can demonstrate
a need for additional time.

   4.  A program for evaluating long range (post-1982) transportation and
growth policies.  Alternative growth policies and/or development patterns
must be examined to determine the potential for modifying total travel
demand.

   5.  A schedule for adoption of needed transportation control measures
as expeditiously as practicable.  Adopted measures must be expeditiously
implemented on a continuous schedule demonstrating incremental emission
reductions from 1979 to the attainment date.  The reasonableness of
a schedule will be determined by the nature of the existing or
planned transportation system and the complexity of implementing an
individual measure or package of measures.

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                                 14


III.  PROCESS

A.  Introduction

The integrated planning process described in Chapter III should accomplish
the policy goals identified in the Introduction and satisfy the SIP
requirements outlined in Chapter II.  Again, the DOT joint planning
regulations should be used in conjunction with these guidelines as the
basis for all transportation-air quality activities carried out under
the Clean Air Act.  The scope and intensity of planning activities
discussed in this chapter should be commensurate with the size of the
metropolitan area and the complexity of its transportation and air
quality problems.  Special emphasis should be placed on the following
elements of the existing planning process: public participation,
involvement of elected officials, alternatives development and evalu-
ation, and plan implementation.  Numerous provisions from DOT and EPA
legislation further define requirements of the transportation-air quality
planning process that must be met.'0

B.  Interagency Coordination

The designated lead agency should first establish a program, in cooperation
with other agencies identified under Section 174, for developing the
joint responsibilities and working relationships of all agencies and
organizations involved in the transportation-air quality planning and
implementation process.  The program should include:

   1.  Documenting roles and responsibilities of all agencies having
transportation and/or air quality planning and implementation functions
for the area.

   2.  Jointly defining necessary formal and informal working relationships
among programs and agencies to achieve an integrated comprehensive
planning process.

   3.  Jointly developing mechanisms to maintain or establish (where
necessary) these working relationships, including: assessing the
adequacy of informal coordination among staffs, setting up interagency
advisory groups, and developing more formal interagency agreements or
memoranda of understanding as needed.  These mechanisms should address
the following tasks as well as others the agencies find necessary:

        (a)  Modifying existing institutional and technical
     transportation and air quality planning processes to achieve
     integration at and between local and regional levels.

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                                15
       (b)  Applying criteria and procedures for evaluation and
    revision of projects, plans and programs to ensure their
    conformity with the  SIP.   (Criteria and procedures are being
    developed and will be provided subsequently.)

       (c)   Incorporating into  the SIP major air quaility-related
    elements of the UPWP and  specific transportation control measures
    from the transportation plan, TSME, TIP and AE.

       (d)   Implementing, operating, and  enforcing  transportation-
    related elements  of  the SIP.

        (e)   Monitoring air  quality and  transportation trend
     indicators.

C. Involvement of Elected Officials

The lead  agency should insure  joint  development of procedures,  where
necessary, to increase involvement of appropriate  elected officials  in
transportation-air quality decisionmaking including:

   1   Providing preliminary information to such officials regarding
both*the range of individual measures and packages of measures  being
considered that could require an implementation commitment by such
officials.

   2   Providing increasingly more detailed information to officials  as
specific transportation  strategies are developed, evaluated and sub-
jected to interagency and public consultation.

   3   Obtaining the commitment from officials to support and fund the
adopiion and implementation of  reasonably available transportation
projects and programs within  their areas of jurisdiction.

   4   Advising officials of  proposed modifications to air quality-
relaied  trlnspomtion projects and programs within their -junsdictional
 areas.
 D.   Public Information and Consultation
 A parallel procedure should be developed for adequate  public
 and consultation on transportation,  air q^nty and Pu^_^^ld
 as well  as the integrated planning process.   Interest  groups  should


                                                 s

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                                 16


and consultation program must be worked out under the auspices of the
lead agency by participating state, regional and local agencies in
consultation with appropriate citizen groups.  The basic elements of any
program should be conducted by the agencies or interest groups best
equipped to carry out the tasks effectively.

An effective public information and consultation process should include
the following elements:

        !•  Inventory:  An inventory of agency public information programs
and interest groups is essential for a well managed, effective and
efficient public consultation process.  This inventory should cover:
(1) agency information and consultation programs aimed at the public
and/or elected officials, identifying duplicative tasks and those
receiving inadequate attention and (2) special interest groups
(e.g., environmental advocacy groups, Chambers of Commerce) and major
local citizen's associations.

        2.  Assessment of Existing Programs:  Periodically the programs
and the working relationships of the agencies and groups inventoried
should be jointly assessed — for example by the lead agency and an ad
hoc committee of public interest groups such as a citizen advisory
committee or public counsel mechanism.  Public information and consul-
tation programs should be evaluated for: (1) reaching other agencies and
interest groups; (2) informing and educating the public and elected
officials about air quality, transportation, public health, and the
integrated planning process; C3) responding to and acting on issues
raised by the public; and (4) effectively involving the public in the
transportation-air quality planning process.

        3.  Program Development:  The public consultation program should
correct deficiencies found in the assessment and cover two areas: information
and participation.

Information on air quality, transportation and public health should be
scaled and targeted toward appropriate agencies and interest groups.  It
should cover the magnitude of the air quality problem, inventory and
assessment of programs and groups, integrated planning process concepts,
procedural steps of that process, the alternative transportation improve-
ments being developed and evaluated including their incidence of the
costs and benefits, and so forth.

Second, mechanisms should be developed and implemented, where necessary,
to allow the public and elected officials to participate in all phases
of the integrated planning process.  For example, where such mechanisms
do not exist or are determined ineffective, the process could be revised
to include: (1) a Citizen Advisory Committee reflecting a representative

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                                  17
cross section  of interest groups,  (2)  a  Technical  Advisory Conmittee
that includes  representatives  of the Citizen  Advisory  Committee  and
staff from state and local  environmental  and  transportation agencies,
and (3)  procedures  to allow timely and effective  exchanges between these
two committees,  agency policy  committees,  and elected  officials.

E.  Evaluation of Alternative  Strategies

Alternatives analysis systematically develops and evaluates a wide
range of transportation actions, individually and in combination.
Alternatives analysis develops infsrmation on costs and  effects  of
various  actions  for local decisionmaking and  federal review.  The periodic
reassessment of  transportation plans and programs provides both  the
occasion and opportunity for alternatives  analysis.  Appendix G  summarizes
pertinent DOT  and EPA legislation requiring alternatives analysis, along
with selected  information supplementing  the following  subsections.

    1.  Assignment of Responsibility

°MPOs should in most cases take lead responsibility for overseeing the
implementation of these guidelines on  evaluating  alternatives because
of their central role in the urban transportation planning process
administered by  DOT.  These alternatives analysis guidelines should  of
course be applied by the MPO in cooperation with  federal,  state, and
local planning,  transportation, and environmental  agencies, public
interest groups, elected officials, and  others.   Detailed institutional
arrangements and assignments of responsibility should  be tailored to the
particular situation in each metropolitan nonattainment  area.

    2.  Agency, Elected Official and Public Consultation

Other agencies,  local elected  officials  and the public should participate
in developing  transportation-air quality strategies.   Information should
be made  available on the alternatives  being considered and their likely
effects, both  beneficial and adverse.   Interested and  affected partici-
pants should be  given the opportunity  to express  their views early
enough in ~ and throughout — the study process  to  influence both the
course of studies and implementation decisions.

    3.  Generation of Alternatives

Areas that will  not attain the standards by 1982  and  that currently
have an  EPA-approved or promulgated transportation control plan  (TCP)
as part  of their SIP should first evaluate measures;in the TCP.   Imple-
mented TCP measures should be  noted, while those  not yet implemented

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                                 18


should be reviewed and their current status indicated (e.g., study
underway, project programmed for implementation, stalled for lack of
funds, not considered, studied and rejected).  Measures determined
ineffective or infeasible or whose impacts are highly deleterious may be
dropped from the TCP if the action is supported fay properly documented
analysis.  Any suspension or elimination of an existing SIP provision
must be included in the January 1979 sufamittal.

In areas where new transportation control measures are needed, trans-
portation agencies should identify those that appear potentially capable
of contributing to air quality improvements consistent with other community
goals.  The measures should span a broad range of inter-related air
quality and community effects so that further analysis can reveal trade-
offs and possibilities for packaging the measures into strategies.
Measures or groups of measures identified at this stage should be ones
that appear to be worthy of further analysis and should not exclude
ambitious measures that could be controversial.  (EPA will subsequently
be providing guidance on packaging transportation measures as part of
the information documents required by Section T08(f).l  To insure that
ambitious packages of measures are analyzed and considered for implementa-
tion, one of the alternative packages should include a mix of transportation
measures that would either:

   a.  Achieve the emission reduction target assigned to transportation
sources (according to Section 174 procedures and after consultation
with EPA) needed to attain ambient air quality standards for CO and Ox
by 1987.  This target should reflect expected pollutant decreases from
the federal motor vehicle control program, non-transportation source
controls, and vehicle inspection/maintenance program.  Or,

   b.  Reduce transportation CO and HC emissions by a percentage
jointly determined (according to Section 174 procedures and after con-
sultation with EPA) to represent the most expeditious progress toward
attainment that can ambitiously be accomplished by 1987 (e.g., one such
target could be a 15-20 percent reduction).12  This emission reduction is
in addition to reductions achieved through the federal motor vehicle
control program and an inspection/maintenance program.

   4.  Analysis of Alternatives

        a.  Analysis Considerations:  Consistent with DOT's joint planning
regulations, the detail_and resources used to develop and evaluate
transportation alternatives should be commensurate with the magnitude
and geographic extent of the air quality problems facing each nonattain-
ment area.  Areas with severe and persistent air quality problems should
make a major effort toward finding solutions, while areas with less
extensive or shorter term problems may find a lower level of effort
sufficient.  Regionwide air quality problems (e.g.. high Ox levels) will

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                                  19


require investigation of regionwide strategies; more localized air
quality problems (e.g., high CO concentrations) may also require region-
wide solutions but in some cases may only require sub-area studies and
corrective strategies.

The level of detail of analysis also should reflect the planning horizon
of the actions under consideration.  Approximate, or "sketch planning,"
analysis is appropriate for the long range plan because long range
projections are sufficiently uncertain that additional detail may provide
only marginally better information.  More detailed analysis should be
carried out on the projects and packages of projects contained in the
TIP.  The planning analyses should primarily focus on the Congres-
sional^ mandated deadlines of 1982 and 1987.

Simplified analysis techniques should be used initially to assess the
impacts of alternative measures and strategies, followed by more detailed
analysis on those strategies that survive this initial screening.  The
information produced — including the incidence of social, economic and
environmental impacts — should clarify the critical issues of choice
available to involved communities and should point out the trade-offs
among alternatives.

Key assumptions made in the analysis (e.g., choice and sensitivity of
demand models, trip assignment techniques, network speeds, meteorology,
emission factors) should be fully documented.  In some cases, real-life
variations from such assumptions may alter significantly the course of
implementation or may invalidate projections upon which plans are based.
Under changed conditions, the desirability and feasibility of certain
measures may change significantly.  For this reason, alternatives analysis
should explore the sensitivity of key impact predictions and project
choices to key assumptions and parameters.  For example, where alternative
population and land use projections result in significantly different
estimates of travel demand, it is important to examine how alternative
demand estimates affect the proposed system performance and point to
alternative mixes of transportation measures.  Where sensitivity analyses
identify significant differences in air quality under varying assumed
conditions, procedures for monitoring those conditions and updating
plans and programs in accordance with observed conditions should be
developed.

        b.  Criteria for Evaluation of Alternatives:  In evaluating the
costs and effectiveness of alternatives, all potential impacts should be
taken into account.  This includes not only air quality but also imple-
mentation feasibility as well as transportation and urban development
needs, economic, social and other environmental impacts.  Measures that
create serious hardships obviously should not be selected simply because
they appear to improve air quality.  For each alternative package of

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                                 20
measures or strategy the following factors should be considered  at  least
qualitatively, but also quantitatively where data and methodologies  are
available.

        (1)  Air quality: regional and local impacts by pollutant;
     other environmental impacts;

        (2)  Energy consumption: fuel consumed by each alternative;

        (3)  Effects on the community: employment and employment
     patterns; retail sales and other business activity indicators;*
     effects on the tax base; changes in land use patterns; impacts  on
     regional development; urban development plans; property acquisition
     requirements; neighborhood disruption and displacement; and
     compatibility with community goals;

        (4)  Financial analysis: funding sources and uses  (e.g., matching
     requirements, opportunities foregone);

        (5)  Economic analysis: present and future capital and operating
     costs;

        (6)  Economic impacts: present and future indirect costs and
     benefits, including incidence of costs and benefits by:

             0 public and private sector
             0 income group
             0 geographic area
             0 social group;

        (7)  Travel impacts: changes in auto usage, vehicle-
     miles of travel, modal split, travel time, level of service and
     accessibility, convenience, volume of travellers by: mode,
     origin-destination, time-of-day, and trip purpose;

        (8)  Political feasibility: required public and elected
     official support, new legislation, promotional efforts, success-
     ful applications elsewhere, potential controversy;

        (9)  Institutional feasibility: assessment of need for new
     agency authority, special interagency agreements, extensive
     cooperation among agencies, dependence on other actions
     for successful implementation; and

       (10)  Other factors considered important by the local community.

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                                 21


IV.  MODIFICATION AND DOCUMENTATION OF EXISTING PLANNING ACTIVITIES

A.  Introduction

This chapter describes:  (1) modifications to ongoing transportation
planning activities required by the Clean Air Act and  (2) documentation
of those modifications.  The modifications and documentation require
minimal alteration of existing procedures and reporting requirements.

B.  Planning Work Programs

    1.  General

Proposed transportation  planning work required under the Clean Air Act
should be included as part of the UPWP currently prepared by MPOs in
response to DOT requirements (23 CFR § 450, Subpart A).  This should
be accomplished by all nonattainment areas that establish planning
procedures in accordance with Section 174 of the Act,  regardless of
whether the MPO is the certified lead agency or whether any Section 175
funding is provided.

    2.  Prospectus

The UPWP prospectus should be modified to: (a) summarize the integrated
planning process including discussion of the important air quality-
related transportation issues facing the area; and (b) describe the
interrelationships of the functional responsibilities  of participating
planning and operating agencies, including air quality agencies.

    3.  Unified Planning Work Program

The UPWP should describe all air quality-related transportation planning
activities anticipated within the area regardless of funding source.  Work
funded under Section 175 of the Clean Air Act should be described in the
UPWP format prescribed by the Intermodal Planning Group (IPG) or in a
modified version agreed  upon by EPA and the IPG.

C.  Transportation Plan

        1.  Development  of the short-range or transportation system
     management element  (TSME) of the transportation plan should
     consider measures which will quickly reduce transportation
     system emissions including traffic engineering, public trans-
     portation, regulatory, pricing, management, operational
     and other TSM improvements.

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                                22


        2.  Development of the long-range element of the transportation
     plan should consider new transportation policies and facilities
     and/or major changes in existing facilities with long-range
     potential for reducing transportation-related emissions and
     contributing to attainment and maintenance of the ambient
     health standards.

        3.  ATI short-range (TSM)  and long-range measures in Section
     108(f) of the Act are, for the purpose of analysis, reasonably
     available.  They should be specifically considered in the analysis
     and development of alternative TSMEs and long-range elements.

D.  Transportation Improvement Program (TIP)

The TIP, including the annual element, should identify from the TSM
and long-range elements of the transportation plan improvements that
produce incremental emission reductions and air quality improvements.
These improvements should expeditiously advance toward implementation
during the program period consistent with SIP planning and programming
schedules.  Priorities assigned to transportation improvements should be
consistent with the requirements of Section 176(d) of the Clean Air Act
(i.e., federal agencies conducting or supporting programs with air
quality-related transportation consequences shall give priority, consistent
with other statutory requirements, to the implementation of measures in
approved or promulgated plans under Section 110 of the Clean Air Act).

E.  Documentation of Alternatives  Analysis

The MPO or lead planning agency should coordinate the development of a
working reference document describing the methods and results of
alternatives analysis.  This work  document should use and supplement,
as necessary, technical reports required by the DOT joint regulations.
While the entire alternatives analysis document will not normally be
submitted with EPA's periodic progress reports (Chapter V), it should be
kept updated and available for review at all times by other agencies and
the public.  This document plays a key role in the integrated planning
process as the basic resource for  the joint determination by parti-
cipants that all reasonable measures are being implemented as expeditiously
as practicable-.

The document should: (1) describe  the alternative measures and packages
of measures selected for preliminary analysis; (2} provide reasons for
rejection or selection of alternatives for more detailed analysis.   (The
initial list of alternative measures shall include all those listed  in
Section 108(f) of the Clean Air Act.); (3) describe the effects considered
in both the preliminary and more detailed alternatives analysis (e.g.,

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                                  23


air quality, travel, economic effects — see Section  III  E.4.b) and  the
methodology used in estimating these effects;  (4)  summarize results  of
the alternatives analysis to date; and  (5) explain why alternatives  were
finally rejected, or selected for  implementation.

F.  Consistency Determination Documentation

Procedures established to satisfy FHWA  requirements for determining
consistency of areawide transportation  plans with  SIPs (required under
23 USC 109(j)) should be used to  respond to the transportation-related
requirements of the Clean Air Act.  Documentation  of  annual consistency
determinations should continue to be provided  to EPA  according to
existing procedures.  This documentation can be used  to:  (1) demonstrate
that all reasonable measures are  being  implemented as expeditiously  as
practicable (in accordance with Section 172(b)(2)), (2) demonstrate
reasonable further progress (S 172(b)(3}}, and (3) assure conformity
(S 176(c)}.  EPA will consider the consistency determination along with
the nonattainment plan provisions submitted in response to Section
172(b) in assessing SIP progress.

G.  SIP

The required 1979, 1982 and subsequent  SIP revisions  should include
major air quality-related work elements of the UPWP and specific trans-
portation control measures from the transportation plan, TSME, TIP and
AE.  Chapter II above outlines the transportation-related contents of an
approvable 1979 SIP.  Appendix B  contains the  complete, more detailed
description of the elements of an approvable 1979  SIP.

V.  PROGRESS REPORTS

A.  Introduction

EPA will require periodic reports to: (1) monitor  and assess progress in
developing and implementing the transportation-related provisions of the
Clean Air Act; (2) develop uniform review criteria for assessing SIP
progress; and (3) develop information for decisions on: (a) planning
funds allocation, (b) conformity  and consistency determinations, and
(c) imposition of Section 176 sanctions.  The  reporting requirements
described below are designed to minimize time  spent on documenting and
reviewing routine activities, allowing  staffs  to concentrate on identi-
fying and resolving significant problems.  These reports should not
substitute for the more effective mechanism of direct staff contact  for
demonstrating and determining progress.

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                                 24


 Although  progress  reports will normally be expected every  six months,
 alternative arrangements are possible by agreement between the  lead
 agency  and the  EPA Regional Office.  Existing reports and  reporting
 procedures should  be  used to comply with Clean Air Act requirements;
 i.e., wherever  a progress report of similar format and content  is
 currently prepared for another agency and/or program, such a report may
 be  modified as  necessary to satisfy EPA requirements.

 B.   Content

 The progress  report should briefly summarize the status of the  air
 quality-related elements of the: (1) UPWP, (2) transportation plan
 (including TSME),  (3) TIP, and (4) annual elements of the  TIP for both
 the current and proceeding year.'3  Specific elements of the progress
 reports for each nonattainment area should be worked out individually
 with the  EPA  Regional Office.  An acceptable report should include, but
 need not  be limited to, the following:

    1.   UPWP

 The status of major air quality-related work elements (.including but not
 limited to alternatives analysis, procedures for interagency coordination,
 involvement of  elected officials, public information and consultation),
 covering: (a) brief summary (two or three sentences) and percentage of
 work accomplished  to  date; (b) description of outstanding  issues and
 problems, if  any,  that may alter scope or completion times; and (c)
 program contact person responsible for each work element.

    2.   Transportation Plan

 The  status of each major air quality-related portion of the transportation
 plan.

   3-   TIP

 The  status of each major air quality-related transportation improvement
 listed  in the annual elements of both the current TIP and  that  of the
 previous year,  including but not necessarily limited to EIS status,
 funding commitment, and implementation status.

 C.  Annual Report

 The Annual Report required by the "Criteria for Approval of 1979 SIP
 Revisions" (p.  14, Appendix B) shall describe: (1) progress toward meeting
 SIP schedules for development and implementation of transportation control
 measures, (2)  contribution of transportation source controls to the
 incremental  emission reductions required for standard attainment,
 (3)  growth of mobile sources, and (4) an updated mobile source  emission
 inventory.  The Annual Report should be based upon and may incorporate
appropriate parts of the progress reports described above.

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                                  25
Footnotes
1  42 USC 7401 et seq. hereafter referred to as  "The Act" or  "The Clean
   Air Act."

2  Section 108(e) requires publication of guidelines for the  planning
   process assisted under Section 175 of Part D, Plan Requirements for
   Nonattainment Areas.  The Guidelines must include information on:

      1.  methods to identify and evaluate alternative planning and
          control activities (this information is principally contained
          in Chapter III (Process) of the guidelines);

      2.  methods of reviewing plans on a regular basis as conditions
          change or new information is presented (Chapters III (Process),
          IV (Documentation), V (Progress Reports));

      3.  identification of funds and other resources necessary to
          implement the plan, including interagency agreements on
          providing such funds and resources (Chapter I and Appendix F,
          Identification of Funds to Implement the Plan);

      4.  methods to assure participation by the public in all phases
          of the planning process (Chapter III (Process)); and

      5.  such other methods as the Administrator determines necessary
          to carry out.a continuous planning process.

3  Appendix A is a summary of the transportation-related sections of the
   Clean Air Act.

4  Appendix C illustrates how the transportation-air quality planning
   process could fit into the entire SIP revision process.

5  Sections 171(1), 172(B)(2)(3).

6  EPA identified nonattainment areas in a press release on February 23,
   1978 and also in the March 3, 1978 Federal  Register.

7  EPA and DOT jointly issued Section 174 guidelines in December 1977.
   This guidance concerns designation of lead  planning organizations for
   nonattainment areas and determination of agency responsibilities.   By
   April 1,  1978, the Governors of all  states  with nonattainment areas
   must transmit to EPA a certification of the lead planning organization
   and a joint determination of agency responsibilities for those areas.

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                                    26


 8  Written evidence that the state, the general  purpose local government
    or governments, or a regional  agency designated by general purpose local
    governments for such purpose,  have adopted by statute, regulation, ordinance
    or other legally enforceable document the necessary requirements and
    schedules and timetables for compliance and are committed to implement
    and enforce the appropriate elements of the SIP.  The relevant organiza-
    tions shall provide evidence that the legally enforceable attainment
    measures and the "criteria, standards and implementing procedures necessary
    for effectively guiding and controlling major decisions as to where growth
    shall and shall not take place," prepared by state and local governments
    in compliance with Section 701  of the Housing Act of 1954, as amended, are
    fully coordinated in the attainment and maintenance of the NAAQS.

 9  As defined by the U.S. Bureau  of Census, urbanized areas generally include
    core cities plus any closely settled suburban areas.

10  The transportation-air quality planning process should:

      (1)  Consider social, economic, energy, transportation, air quality,
           and other environmental  effects, in support of the require-
           ments of 23 USC 109(h),  Sections 5(h)(2) and 15 of the UMT
           Act [49 USC 1604(h)(2)  and 1610). and Sections  108(f)(2)(C)
           and 172Cb}(9] of the Clean Air Act (42 USC 7408(f)(2)(C)  and
           7502(b)(9)).

      (2)  Be coordinated with transportation planning pursuant to
           23 USC 134, 49 USC 1607(a)_ and 23 USC  450.120, 109(F)
           and 307(c) in support of the requirements of Section 174(b)
           of the Clean Air Act (42 USC 7504(b}).

      (3)  Ensure public, local government and state legislatures
           involvement in support  of the requirements of  Sections
           172(bK9), 121, and 127  of the Clean Air Act (42 USC
           7502 (bK.9), 7421, and 7427).

11   Section 172(b)(9) of the Clean  Air Act specifies that 1979 SIP revisions
    shall:

          evidence public ...  involvement and consultation in accordance
          with Section 174 (relating to planning  procedures) and include
          ...  a summary of public  comment on [the] analysis [of the
          effects of plan provisions]

    Section 127,  Public Notification, requires SIPs to contain effective
    measures for  public notification of air quality standard violations:

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                                 27
         to advise  the  public of the health  hazards  associated with  such
         pollution, and to enhance public awareness  of the  measures
         which  can  be taken to prevent such  standards  from  being  exceeded
         and  the  ways in which the public can  participate in  regulatory
         and  other  efforts to improve air quality.

   Most specifically, Section 108(e)(4) directs that the transportation
   planning guidelines  shall include information on:

         methods  to assure participation by  the public in all phases
         of the planning process.

   Finally, the DOT joint planning regulations (CFR  450.120)  specify that
   the urban  transportation planning process shall  "include provisions
   to ensure  involvement of the public."

12 The selection of an  ambitious emission reduction  target  such  as
    15-20%  is  necessary to insure that a sufficient range of measures
    is adequately evaluated.  Certain ambitious and possibly contro-
    versial classes of measures (e.g., parking management,  pricing, auto
    limitation)  should be included when evaluating alternatives  to
    meet ambitious  targets.  A priori rejection of these measures is
    not acceptable.   All agencies engaged in  the SIP  revision process
    in each urban area should jointly decide  for that urban  area  a
    specific,  ambitious emission reduction target for the  purpose of
    developing and  analyzing alternative transportation strategies.
    The 15-20% figure is not meant to be an arbitrary selection
    of an achievable emission reduction for all urban areas, but
    rather is one example of such a  target.

13  Progress reports are expected to be brief,  but complete (e.g., not
    exceeding 6 to  12 pages).  Longer reports may be necessary in non-
    attainment areas requiring extensive air quality-related
    transportation  activities.

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                 REF I1-1









     ENVIRONMENTAL PROTECTION AGENCY



                APPENDICES



                    TO



TRANSPORTATION-AIR QUALITY PLANNING GUIDELINES
                 June  1978

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                   TABLE OF CONTENTS FOR APPENDICES


APPENDIX                                                       Page

   A       TRANSPORTATION-RELATED PROVISIONS OF                  1
           THE CLEAN AIR ACT

   B       CRITERIA FOR APPROVAL OF 1979 SIP                     9
           REVISIONS

   C       SIP REVISION PROCESS                                 23

   D       DEFINITIONS                                          27

   E       BACKGROUND INFORMATION ON TCP PROGRAM                31

   F       FUNDING                                              35

   G       EVALUATION OF ALTERNATIVE STRATEGIES                 42

   H       FHWA/UMTA ACTION MEMO                                45

   I       HUD-EPA AGREEMENT                                    47

   J       SUMMARY OF RELATED EPA GUIDELINES AND                50
           REGULATIONS

   K       DOT PLANNING AND PROGRAMMING REGULATIONS             52
           (23 CFR 450)

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                                APPENDIX A

TRANSPORTATION-RELATED PROVISIONS IN THE CLEAN AIR ACT AMENDMENTS OF 1977

I.   Introduction

     This Appendix contains a general summary and description of the

provisions of the Clean Air Act that primarily concern or most directly

affect the transportation-air quality planning process.

     These sections include:

          0 § 108:  AIR QUALITY CRITERIA AND CONTROL TECHNIQUES (S 108(e):

      Planning Process Guidelines, § 108(f): Information Documents)

          0 S 110:  IMPLEMENTATION PLANS

          0 § 121:  CONSULTATION

          0 § 172:  NONATTAINMENT PLAN PROVISIONS

          0 S 174:  PLANNING PROCEDURES

          0 S 175:  EPA GRANTS

          0 S 176:  LIMITATIONS ON CERTAIN FEDERAL ASSISTANCE

     The statutory authority for: requiring transportation controls, the

transportation planning guidelines and the information documents on
             /
control techniques is contained in the following sections of the Act:
                             /
     Section 110(a)(2) of the Clean Air Act enumerates the requirements for

state implementation plans.  This section specifies that:

          	The Administrator shall approve such plan	if he
          determines that...(B) it includes...such other measures
          as may be necessary to insure attainment and maintenance
          of such primary or secondary standards including but not
          limited to, transportation controls....

     Section 108(e) specifies that the guidelines should include informa-

tion on:

          "(1) methods to identify and evaluate alternative planning

               and control activities;

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          (2)  methods  of reviewing  plans  on  a  regular basis  as
              conditions change or  new information  is presented;
          (3)  identification of funds  and other resources  necessary
              to implement the plan,  including interagency agreements
              on providing such funds  and resources;
          (4)  methods  to assure participation  by the  public  in  all  phases
              of the planning process; and
          (5)  such other methods as the Administrator determines
              necessary to carry out a continuous planning process."
     Section 174(b) requires the preparation of implementation  plan
provisions for nonattainment areas  to  be  coordinated  with  the continuing,
cooperative and comprehensive transportation planning process required
under Section  134 of title 23, USC, and the  air quality maintenance
planning process required under Section 110  of the  Clean Air Act
(42 USC 7410).
     Finally,  Section  108(f) directs the  Administrator to  publish
information documents  on processes, procedures and  methods to control
pollution and  explicitly identifies a  broad  range of  transportation
projects and system management measures to be included in  the information
documents.
     The amendments significantly expand the requirements  and procedures
for developing and implementing transportation measures as part of State
Implementation Plans (SIPs).  Specifically,  the Act:

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         (1)  establishes new plan submittal and attainment
              deadlines (S 172(a)),
         (2)  requires the development of information documents
              and process guidelines  (S 108(e),(f)),
         (3)  Specifies a planning process  that includes
              extensive consultation  among  agencies, the public
              and local elected officials along with coordination
              with  related planning  (S 121, S  174),
         (4)  requires nonattainment  plans  to  document consul-
              tation  and  contain  a commitment  to implement
               (S  172(b)),
          (5)  authorizes  new planning funds (S 175),
          (6)  provides for new  funding sanctions for failure
               to  develop  and implement adequate plans  (S 176).
II.   Plan Deadlines  and Criteria
     The new requirements  of  the Act  are  intended to  insure  state submission
of SIP revisions adequate  to  attain and maintain the  air quality standards
for the auto-related pollutants.   Any nonattainment area for carbon
monoxide and photochemical  oxidants must  submit a SIP revision  by
January 1,  1979  that:  (1)  provides for the  implementation of all
reasonably  available control  measures as  expeditiously  as practicable
(§ 172(b)(2))  and  (2)  demonstrates attainment of the  air quality standard
not later than December  31,  1982 (§  172(a)(l)).
     If a state  demonstrates  in  the  1979  SIP submittal  that  attainment
of the carbon  monoxide and oxidant standard is not  possible  despite
the imolementation of all  reasonably  available measures,  EPA may  grant

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                                  4

an extension beyond December 31,  1982 to provide for attainment as
expeditiously as practicable but  not later than December 31, 1987.  In
cases where such a demonstration  is made, the 1979 SIP submission must:
(1) establish a program of alternatives analysis prior to issuance of
permits  for construction or modification of major emitting facilities,
(2) establish a specific schedule for implementing a vehicle inspection
and maintenance program and (3) identify all other measures necessary to
provide  for attainment not later  than December 31, 1987.
     Also according to S 110(a)(3)(D), 1979 SIP submittals that demonstrate
attainment beyond December 31, 1982 shall be revised by July 1, 1979 to
include  written evidence on comprehensive measures listed in S 110(c)(5)(B)
that:
           (i)  establish, expand, or improve public transportation
                measures to meet basic transportation needs,
                as expeditiously as is practicable; and
          (ii)  implement transportation control measures necessary
                to attain and maintain national  ambient air quality
                standards.
The revised plan shall, for the purpose of implementing such comprehensive
public transportation measures, include requirements to use (insofar as is
necessary) federal  grants,  state or local funds, or any combination of
such grants and funds as may be consistent with  the terms of the legislation
providing such grants and funds.   (EPA is currently developing guidelines
on the minimum elements of the public transportation plan SIP revision.)

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     Section 110(c)(5) also allows states to eliminate existing TCP
bridge toll requirements on bridges located entirely within a city.  If
bridge tolls are eliminated, the Governor must certify that a plan will
be submitted by August 7, 1978, which satisfies the requirements of
Section 110(c)(5)(B).  The public transportation plan submitted in
August must at least compensate for the air quality and mass transit
benefits which were reasonably expected to be achieved from use of the
eliminated tolls.
     Other measures in existing plans may be suspended until January 1,
1979, under Section 110(c)(4) of the Act, including requirements for
retrofits on non-commercial vehicles, gas rationing provisions and
on-street parking restrictions.  A suspension will  not be granted unless
the state agrees to prepare, adopt and submit a plan revision by
January 1, 1979, which meets the requirements of the Administrator.
     Section 110(a)(5)(A) also prohibits the Administrator from requiring
states to include indirect source review (ISR) programs in their SIPs.
Further, EPA may not promulgate ISR regulations except for federally-
assisted highways, airports and other major federally-assisted or
operated indirect sources (S 110(a)(5)(B)).   Any ISR program in an
existing SIP may be suspended or revoked if, in all respects except
attainment and maintenance of the air quality standards,  the plan meets
the requirements of S 110(a); and with respect to attainment and mainte-
nance, the state is preparing in good faith a plan  revision to meet

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                                  6
the requirements of Part D by January 1, 1979, for all  nonattainment
areas [s llO(a)(5)(A)(111); 43 FR 10708 (March 15, 1978)],
     Finally, those states that demonstrate a need in the 1979 SIP
submittal for a deadline extension to 1987 must submit a SIP revision
before July 1, 1982 that contains enforceable measures  to assure
attainment no later than December 31, 1987.
III.  Planning Process
     The Act emphasizes locally developed plans resulting from extensive
consultation among agencies (S 121, S 174), public education and
participation (§ 127, S 172(b)(9)), elected official  involvement and
the documented analysis of a wide range of alternative  measures and
strategies (S 172(b)(9)).   The Act specifies that the transportation-air
quality planning process be coordinated with the continuing, cooperative,
and comprehensive ("3C") transportation planning process administered by
DOT (§ 174(b)).
     Local governments and organizations of local elected officials are
explicitly encouraged to assume greater responsibilities in the development,
implementation and enforcement of SIPs (S 121, S 174(a)).  Section 174(a)
specifically states that "where possible" nonattainment plans
          ... shall be prepared by an organization of elected
          officials of local governments designated by
          agreement of the local governments in an affected
          area and certified by the State for this purpose.
This section gives specific preference to designation of metropolitan
planning organizations or the agencies responsible for air quality
maintenance planning.  EPA has established April 1, 1978 as the deadline
by which states submit: (1) a list of designated agencies, their boundaries,

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responsibilities, and a brief discussion of the Governor's designation
or certification decision.
     The Act also directs EPA to consult with DOT, HUD and state and
local officials in the development of planning process guidelines (S 108(e)),
Furthermore, the Act calls for EPA to cooperate with DOT in the prepara-
tion of information documents on a wide range of transportation measures
including: mass transit improvements, carpool programs, exclusive bus
lanes, parking management, employer-incentive programs, work schedule
changes, selected auto restrictions, road user charges and bicycle lanes
and facilities (S 108(f)).
IV.  EPA Grants
     Section 175 directs EPA to award grants to cover 100 percent of
the additional costs of nonattainment plan development to organizations
of local elected officials with transportation or air quality maintenance
planning responsibilities and certified by the state in accordance with
Section S 174(a).   Section 325 authorizes $75 million to be appropriated
beginning in fiscal year 1978 for this purpose.
V.  Sanctions
     Section 176 provides for limitations on certain federal  assistance
as follows:
          1.  Plan Submittal.  Where the Administrator finds  that the
              Governor has failed to submit an adequate plan  which
              considers the nonattainment plan provisions specified
              in Section 172, EPA is prohibited from approving projects
              or awarding grants  authorized by the Clean Air  Act.

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                                 8

             Similarly, the Secretary of Transportation is pro-
             hibited from approving projects or awarding grants
             under title 232   (5 176(a)).
         2.  Plan Implementation.  In areas where the state, local
             government(s), or designated regional agency fails
             to  implement any  requirement of an approved or promul-
             gated plan under  Section 110, the Administrator is
             prohibited from making grants under the Clean Air Act
              (S  176(b)).
         3.  Plan Conformity.  No federal department or agency shall
             support or approve  any activity that does not conform to
             a plan approved or  promulgated under Section 11(5.   No
             metropolitan planning organization designated under
              23  USC 134 shall  approve any project, program
              or  plan that does not conform with a plan approved
              or  promulgated  under Section 110.  The assurance of
              conformity shall  be the affirmative  responsibility  of
              the head  of  such  department or agency  (S  176(c)).
          4.   Priority  to  Implementation of  Plan  Provisions.   Federal
              agencies  and  departments  conducting  or  supporting  programs
              with air  quality-related  transportation  consequences
              shall  give  priority,  consistent  with statutory  require-
              ments,  to the  implementation  of  measures  in  approved
              or promulgated plans under Section  110 (S 176(d)).
Footnotes
1  Or make reasonable  efforts toward submitting an adequate plan.
2  Safety,  mass transit and other transportation  projects  with air
   quality benefits are not affected.

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                              9
                                             APPENDIX B
      UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                  "   WASHINGTON. D'.C. 20460
                                                 OFFICE OF
                                           AIR AND WASTE MANAGEMENT
                          24 1978


 SUBJECT:   Criteria for Approval of 1$79 SJ.P  Revisions

 FROM:      The Administrator (A-100)

 TO:        Regional Administrators, I-X


       The attachment to this memo  summarizes  the  elements
 which a 1979 State Implementation  Plan (SIP)  revision
 for a non-attainment area must contain in order to be
 approved by EPA as meeting the requirements of Part D of
 the Clean Air Act.

       In summary, the Act requires the demonstration  of
 attainment of the air quality standards (primary  and
 secondary) as expeditiously as practicable, but in the
 case of national primary standards not later  than
 December 31,  1982.  However, for carbon monoxide  (CO)  and
 oxidants (Ox),  if the State can demonstrate attainment
 is  not possible by 1982 despite the implementation of all
 reasonable stationary source and transportation control
 measures,  the Act provides for up  to a five-year  extension.
 In  those cases  the plan revisions  must demonstrate
 attainment as expeditiously as practicable but no later
 than December 31, 1987.   The extension is not automatic;
 a demonstration of need must be made and the State must
 fulfill the other statutory requirements.

      It is the  intent of the Agency to establish  reasonable
 and achievable  goals  for SIP submissions  and to take  a firm
 posture on the  imposition of sanctions where the  reasonable
 goals  are  not achieved.   Accordingly,  while the policy
 requires a commitment to many specific strategies in  the
 1979  submissions  (e.g.,  RACT on stationary sources, inspec-
 tion/maintenance  programs  where attainment for carbon
monoxide or oxidants  extends  beyond 1982, other reasonable
 transportation  control measures, etc.)  the memo also
 requires (for carbon  monoxide and  oxidants) a commitment
 to*a continuing process.   This  process  must be one which
extensively involves  the  public as  well  as State  and  local
elected officials  and which  ambitiously  pursues a wide
range of alternatives.

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                             10


      Since  reliance  on  stationary controls and Federal
 new car standards  alone will not enable most areas with.
 oxidant and carbon monoxide problems to attain these
 standards by 1982, each Regional Office will need to put
 particular  emphasis  on  additional measures to reduce
 transportation  system emissions.  The process committed
 to  in the 1979  plan  submission must lead to the
 expeditious selection and implementation of comprehensive
 transportation  control  measures.  In judging the adequacy
 of'the 1979 plan submission for the transportation
 sector,  each Regional Administrator should ensure that
 ambitious alternatives  (as described in the draft
 "Transportation Planning Guidelines" which have been
 circulated)  will be  analyzed.

      The Department  of Transportation (DOT), Housing and
 Urban Development  (HUD) and EPA are seeking to integrate
 the transportation/air  quality planning and implementation
 required by the Clean Air Act into existing planning and
 programming procedures.  The air planning activities should
 be.-included in  the Unified Work Program required by DOT
 aji4 the  adopted transportation measures should be included
 in  the Transportation Improvement Program required by DOT.
 In  complying with  the Clean Air Act requirements, the Regions
 should also  keep in mind the requirements of the HUD-EPA
 Agreement which provides for coordination of air quality
 planning and planning assisted under the HUD Comprehensive
 Planning Assistance  (701) Program.  Integration of air
 and  transportation planning with comprehensive planning
 which incorporates growth management concerns should improve
 the  effectiveness of air quality planning and could reduce
 the  need for enforcement measures in the future.

       States will be provided some discretion regarding
 the  amount  of emissions growth to be accommodated within
 the  SIP.  EPA generally will not question the growth rates
 desired  by  the  State so long as reasonable further progress
 is demonstrated and there is a demonstration of attainment
by the statutory deadline (1982 or 1987).  However, the
 growth rate  identified  in the SIP must be consistent with
 growth rates used  (or implied by) other planning programs
 in the area  (e.g.,  FWPCA §208,  201,  HUD §701, FHWA
 §134).

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                              n


     You  should  note that  there  are  other SIP revisions
which  are not  discussed in the attachment but which are
required  by  the  1977 Amendments.   These  include:

     1.   Section 128 (relating to  State  boards)

     2.   Section 126 (relating to  interstate pollution)

     3.   Section 127 (relating to  public notification)

     4.   Part  C  (relating  to  prevention  o£ significant
                  deterioration)

     5.   Section 110(a)(2)(K)  (relating  to permit fees)

     6.   Section 123 (relating to  stack heights for
           existing  source  in other  than non-attainment
           areas)

     7.   Section 121 (relating to  consultation)

     Although  incorporation of these provisions is required
by the law,  failure  to  achieve final approval by
July 1, 1979 does not trigger the  new source prohibition
of Section 110(a)(2)(I).

     It is important to emphasize  to the States that all
current SIP requirements remain in effect despite the
development of the 1979 revisions.  Any suspension or
discontinuance of an existing SIP provision must be
submitted for EPA approval.   This  should be done as part
of the revision  submitted in January 1979.   Exceptions
to this procedure may be found in  certain new provisions
of §110 relating to  reduction of on-street  parking, bridge
tolls,  and other measures.

     The development of the January 1979 SIPs to meet the
minimum requirements of the Clean Air Act Amendments of
1077 is a complex and demanding program.  It will reqtiire
the commitment of significant resources on  the part of the
air programs staff of the Regional Office to ensure that
the States develop and submit a comprehensive and
approvable plan.   We are working with your  staff to develop
the necessary guidance and follow-up programs which will
assist  your office and the State to carry out this very
difficult  but important part of the overall air program.

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                                     12
      Criteria for Approval of 1979 State Implementation  PIan  Revisions
                       for Non-Attainment Areas

 Purpose

      The purpose of this document is to define the criteria by which
 State Implementation Plan (SIP) revisions for non-attainment  areas
 required by the Clean Air Act Amendments of 1977 (the Act) will  be
 approved.   These revisions are to be submitted to EPA by January 1,  1979.

 Categories  of SIP Revisions

      SIP revisions submitted by January 1, 1979 can be divided into
 two categories:

      1.   Those which provide for attainment of the Primary Ambient
 Air Quality Standards (primary standards) for aVL criteria pollutants
 on  or before December 31, 1982.
      2»   Those which provide for attainment of the  primary standards
for sulfur dioxide, nitrogen, oxides, and particulate matter  on  or before
December 31,  1982 but show that despite the implementation of all
reasonable transportation and stationary source emission control  measures
attainment of the primary standards for carbon monoxide and/or  oxidants
cannot be achieved until after this date.  In these cases, the  revisions
must demonstrate attainment as expeditiously as practicable  but no later
than December 31, 1987.

      In  order for an adequate SIP revision to fall  into the  second
category,  the State has an affirmative responsibility to demonstrate
to  the satisfaction of EPA that attainment of the primary carbon
monoxide and/or oxidants standards is not possible  in an area prior
to  December 31, 1982.

      It  should be noted that SIP revisions of either category should
^tlso provide  for attainment of Secondary Ambient Air Quality Standards
(secondary standards) as expeditiously as practicable although  there  is
no  specific deadline contained in the Act.

Gsnaral  Requirements of All 1979 SIP Revisions

      Each  1979 SIP revision must contain the following:

      1.  A definition of the geographic areas for which control
strategies have been or will be developed.  Consideration  should be
given to the  practical benefits of defining areas which correspond
whenever possible to those substate districts established  pursuant
to  Part  IV, Attachment A of OMB Circular No. A-95.

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     2.    An accurate, comprehensive, and current (1977 calendar year)
inventory of existing emissions.

     3.    A determination of the level of control needed to  demonstrate
attainment by 1982 (including growth).  This demonstration should be
made by the application of modeling techniques as set  forth  in  EPA's
Guideline on Air Quality Models.   For ox-idants,  any legit ir.ate  modeling
technique (e.g., those referenced in "Use, Limitation  ana Technical
Basis of Procedures for Quantifying Relationships ' dtween Photochemical
Oxidants and Precursors."  EPA 450/2-77-021 a.  November 1977)  can be
used.  Consideration of background and transport for oxidants should
generally be in accordance with the procedures documented in  "Procedures
for Quantifying Relationships Between Photochemical  Oxidants  and
Precursors."  In developing photochemical oxidant control strategies
for a particular area, states may assume at a minimum  that the  standard
will be attained in adjacent states.

     If a state can demonstrate that the level of control necessary for
attainment of the primary standards for carbon monoxide and/or  oxidant
is not possible by 1982 despite the application of all  reasonable
measures, an extension past 1982 (but not beyond 1987)  is authorized.

     4.    Adoption in legally enforceable form!  of all  measures necessary
to provide for attainment by the prescribed date or, where adoption of
all such measures by 1979 is not possible, (e.g., certain transportation
control  measures, and certain measures to control the  oxides  of nitrogen
and total suspended particulate) a schedule for expeditious  development,
adoption, submittal, and implementation of these measures.   The
situations in which adoption of measures may be scheduled after 1979
are discussed in the pollutant specific sections of this document.  Each
schedule must provide for implementation of all  reasonably available
control  measures as expeditiously as practicable.  During the period
prior to attainment, these measures must be implemented rapidly enough
to provide at a minimum for reasonable further progress (see discussion
     ^Written evidence that the State, the general  purpose local
government or governments, or a regional agency designated by general
purpose local governments for such purpose, have adopted by sta-tute,
regulation, ordinance or other legally enforceable  document, the
necessary requirements and schedules and timetables for compliance,
and are committed to implement and enforce the appropriate elements
of the plan.  The relevant organizations shall provide evidence that
the legally enforceable attainment measures and the "criteria,
standards and implementing procedures necessary for effectively guiding
and controlling major decisions as to where growth  shall and shall not
take place," prepared by State and local governments in compliance with
Section 701 of the Housing Act of 1954, as amended, are fully coordinated
in the attainment and maintenance of the NAAQS.

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                                  14


below).  Each schedule will  be considered  part of the applicable
implementation plan and thus will  represent a commitment on the part
of the State to meet the key milestones  set forth in the submitted
schedule.

     5.   Emission reduction estimates for each adopted or scheduled
control measure or for related groups of control measures where
estimates for individual measures  are impractical.  It is recognized
that reduction estimates may change  as measures are more fully
analyzed and implemented.  As such estimates change, appropriate
responses will be required to insure that  the plan remains adequate
to provide for attainment and for  reasonable'further progress.

     6.   Provision for reasonable further progress toward attainment
of the primary and secondary standards in  the period prior to the
prescribed date for attainment. Reasonable further progress is defined
as annual incremental reductions in  total  emissions (emissions from
new as well as existing sources) to  provide for attainment by the
prescribed date.  The plan shall provide for substantial reductions in
the early years with regular reductions  thereafter.

     Reasonable further progress will be determined for each area
by dividing the total emission reductions  required to attain the appli-
cable standard by the number of years between 1979 and the date pro-
jected for attainment (not later than 1937).  This is represented
graphically by a straight line drawn from  the emissions inventory sub-
mitted in 1979 to the allowable emissions  on the attainment date.
However, EPA recognizes.that some  measures cannot result in immediate
emission reduction.  Therefore,, if a State can show that some lag in
emissions reduction is necessary,  a  SIP  will be acceptable even though
reductions sufficient to produce decreases at the "straight-line rate"
are not achieved for a year or two after 1979.  This lag in achieving
the "straight-line rate" for emissions reduction is to be accepted
only to accommodate the time required for  compliance with the first set
of regulations adopted on or before  January 1, 1979, if immediate
compliance is not possible.   It does not authorize delays in adoption
of control requirements.

     The requirement to demonstrate  reasonable further progress will,
in most areas designated non-attainment  for oxidant or carbon monoxide,
necessitate a continuous, phased implementation of transportation
control measures.  In areas where  attainment of all primary ambient
standards by 1982 is not possible  EPA will not accept mere reliance  on
the Federal Motor Vehicle Control  Program  by itself as a demonstration
of reasonable further progress.

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                                        15
                                         *

     In determining "reasonable further progress", those emission
raductions obtained from compliance between August 7, 1977,  and  '
December 31, 1979, with (1) SIP revisions that have been submitted
after August 7, 1977, and (2) regulations which were approved  by the
Agency prior to the enactment of the 1977 Clean Air Amendments,  can
;,e treated as having been achieved during 1979.  Ther? should  be an
Assurance, however, that these are real emission reductions  and  not
just "paper" ones.

     7.   An identification and quantification of an emissions growth
increment which will be allowed to result from the construction  and
operation of major new or modified stationary sources within the area
for which the plan has been developed.  Alternatively, an emissions
offset regulation can be adopted to provide for major new source growth.

     The growth rates established by states for mobile sources and new
minor stationary sources should also be specified, and in combination
vith the growth associated with major new or modified stationary sources
vrill be accepted so long as they do not jeopardize the reasonable further
progress test and attainment by the prescribed date. However,  the growth
rato identified in the SIP must be consistent with the growth  rates  used
(or implied by) the other planning programs in the area (e.g., FV1PCA
Section 203 [201], HUD Section 701, FHWA Section 134). A system  for
monitoring the emission growth rates from major and minor new  stationary
sources and from transportation sources and assuring that they do not
i;xc-?ed the specified amounts must also be provided for in the  revision.

     8.   Provision for annual reporting on the progress toward  meeting
•Ihs schedules summarized in (4) above as well as growth of mobile
sources, minor new stationary sources, major new or modified stationary
"ources, and reduction in emissions from existing sources to provide for
reasonable further progress as in (6) above.  This should include an
uodated emission inventory.

          A requirement that permits be issued for the construction  and
          of new or modified major sources in accordance with  Section
173 and 110(a)(2)(D).

    10.   An identification of and coirmitment to the financial and
ij-nnpower resources necessary to carry out the plan.  The commitment
should be made at the highest executive level having responsibility for
SfP or that portion of it and having authority to hire new employees.
This commitment should include written evidence that the State,  the
general purpose local government or governments, and all state,  local or
regional agencies have included appropriate provision in their respective
budgets and intend to continue to do so in future years for which  budgets
iiave not yet been finalized, to the extent necessary.

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                                    16  .


    11.   Evidence of public, local  government, and state legislative
involvement and consultation.  It shall  also  include an identification
and brief analysis of the air quality,  health, welfare, economic,
energy, and social effects of the plan  revisions and of the alternatives
considered by the State, and a summary  of the public comment on such
analysis.

    12.   Evidence that the SIP was  adopted by the state after reasonable
notice and public hearing.

Additional Requirements for Carbon Monoxide and Oxidant SIP Revisions
which Provide for Attainment of the  Primary Standards Later than 1982
     For those SIP revisions which demonstrate  that attainment of _
primary standards for carbon monoxide and/or oxidants is not possible
in an area prior to December 31, 1982 despite the implementation of all
reasonable emission control measures the following items must be
included in the January 1, 1979 submission  in addition to all the
general requirements listed above:

     1.   A program which requires prior to issuance of any permit for
construction or modification of a major emitting facility an analysis
of alternative sites, sizes, production processes, and environmental
control techniques for such proposed source which demonstrates that
benefits of the proposed source significantly outweigh the environmental
and social cost imposed as a result of its  location, construction, or
modification.

     2.   An inspection/maintenance program or  a schedule endorsed by
and committed to by the Governor for the development, adoption, and
implementation of such a program as expeditiously as practicable.
Where the necessary legal authority does not currently exist,  it must
be obtained by June 30, 1979.  Limited exceptions to the requirement
to obtain legal authority by June 30, 1979  may  be possible if  the  state
can demonstrate that (a) there was insufficient opportunity to conduct
necessary technical analyses and/or (b) the legislature has had no
opportunity to consider any necessary enabling  legislation for inspection/
maintenance between enactment of the 1977 Arnendements to the Act  and
June 30, 1979.  In addition, where a legislature has adequate  opportunity
to adopt enabling legislation before January  1, 1979, the Regional
Administrator should require submission of  such legal authority by
January 1, 1979.  In no case can the schedule submitted provide for
obtaining legal authority later than July 1,  1980.

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                                      17


     Actual implementation of the inspection/maintenance program must
proceed as expeditiously as practicable.  EPA considers two and one half
years from the time of legislative adoption to be the maximum time
required to implement a centralized inspection/maintenance program and
one and one half years to implement a decentralized program.  In no case
may implementation of the program, i.e., mandatory inspection and
mandatory repair of failed vehicles be delayed beyond 1982 in the case
of a centralized program (either state lanes or contractor lanes) or
beyond 1981 in the case of a decentralized (private garage) system.

     3.   A commitment by the responsible government official or
officials to establish, expand, or improve public transportation
measures to meet basic transportation needs as expeditiously as is
practicable.

     4.   A commitment to use insofar as is necessary Federal grants,
state or local funds, or any combination of such grants and funds as
may be consistent with the terms of the legislation providing such
grants and funds, for the purpose of establishing, expanding or
improving public transportation measures to meet basic transportation
needs.

     Note that HUD has prepared guidelines for local development codes
and ordinances to provide special requirements for areas which for
significant periods of time may exceed the primary standards.  These
guidelines specify criteria for new construction operation of buildings
which minimize pollutant concentrations to ensure a healthy indoor and
outdoor environment.  States are encouraged to adopt such measures as
part of the SIP.

Pollutant Specific Requirements

                            Sulfur Dioxide

     Specifically, with regard to item (4) of the General Requirements,
the January 1979 plan revisions dealing with sulfur diox •   "lust cont:
all the necessary emission limitations and legally enforceable pr--
to"provide for attainment by no later than December 31, 1982 (i.e.,
schedules for the development, adoption, and submittal of regulations
will not be acceptable).


*Written evidence On comprehensive public transportation measures
 must be submitted in a  SIP revision by July 1,  1979.

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                                   18
                      Nitrogen Oxides

     For NOX, the January 1979 plan must contain all the necessary
emission limitations and the legally enforceable procedures, or  as a
minimum, the appropriate schedules to adopt and submit the emission
limitations and legally enforceable procedures which provide for
implementation so that standards will be attained  by no later  than
December 31, 1982.  EPA is currently evaluating the need for a short
term NOg standard and expects to promulgate such a standard during
1973.  If such a standard for air quality is promulgated, a new  and
separate SIP revision will be required for this pollutant.

                    Particulate Matter

     The January 1979 plan revisions dealing with  particulate  matter
must contain all the necessary emission limitations and legally  enforce-
able procedures for traditional sources.  These emission limitations and
enforceable procedures must provide for the control of fugitive
emissions, where necessary, as well as stack emissions from these
stationary sources.  Where control of non-traditional sources  (e.g.,
urban fugitive dust, resuspension, construction, etc.) is necessary for
attainment, the plan shall contain an assessment of the impact of  these
sources and a commitment on the part of the state  to adopt appropriate
control measures.  This commitment shall take the  form of a schedule to
develop, submit, and implement the legally enforceable procedures, and
programs for controlling non-traditional particulate matter sources.
These schedules must include milestones for evaluating progress  and
provide for attainment of the primary standards by no later than
December 31, 1982, and attainment of the secondary standards as  expe-
ditiously as practicable.  States should initiate  the necessary  studies
and demonstration projects for controlling the non-traditional sources
as soon as possible.

                Carbon Monoxide and Oxidant

An adequate SIP for oxidant is one which provides  for sufficient
control of volatile organic compounds (VOC) from stationary and  mobile
sources to provide for attainment of the oxidant standard.  Accordingly,
the 1979 plan revision must set forth the necessary emission limitations
and schedules to obtain sufficient control of VOC  emissions in all non-
attainment areas.  They must be directed toward reducing  the peak
concentrations within the major urbanized areas to demonstrate attainment
as expeditiously as practicable but in no case later  than  December 31, 1937.
This should also solve the rural oxidant problem by minimizing VOC
emissions and more importantly oxidants that may be transported  from
urban to rural areas.  The 1979 submission must represent a comprehensive
strategy or plan for each non-attainment area; plan submissions  that
address only selected portions of non-attainment are  not  adequate.

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                                      19

      For  the purpose of oxidant plan  development, major urban areas are
 those with  an urbanized population  of 200,000 or greater (U.S. Bureau
 of Census,  1970).   A certain degree of flexibility will be allowed in
 defining  the specific boundaries of the  urban area.  However, the areas
 must  be large enough to cover the entire urbanized? area and adjacent
 fringe areas of development.   For non-attainment urban areas, the highest
 pollutant concentration for  the entire area must be used in determining
 the necessary level  of control.   Additionally, uniform modeling tech-
 niques must be used throughout the  non-attainment urban area.  These
 requirements apply  to interstate as well as intrastate areas.

      Adequate plans must provide for  the adoption of reasonably
 available control measures for stationary and. mobile sources.

      For  stationary sources,  the 1979 oxidant plan submissions for
 major urban areas must include,  as  a  minimum, legally enforceable
 regulations to reflect the application of reasonably available control
 technology  (RACT)3  to those  stationary sources for which EPA has
 published a Control  Techniques Guideline (CT6) by January 1978, and
 provide for the adoption and  submittal of additional legally enforce-
 able  RACT regulations on an  annual  basis beginning in January 1980, for
 those CTGs  that have been published by January of the preceeding year.

      For  rural  non-attainment areas,  the Ox plan must provide the
 necessary legally enforceable procedures for the control of large HC
 sources (more than  100 ton/year  potential emissions) for which EPA
 has issued  a CTG by January  1978, and to adopt and submit additional
 legally enforceable procedures on an  annual basis beginning in
 January 1980,  after publication  of  subsequent CTGs as set forth above.

      For  mobile sources  in urbanized  area (population 200,000) SIPs
 must  provide for expeditious  implementation of reasonably available
 control measures.   Each  of the measures  for which EPA will  publish
 information documents during  1978 is  a reasonably available control
 measure.  These measures  are  listed on the following page:
     2As defined by the U.S. Bureau of Census, urbanized area generally
include core cities plus any closely settled suburban areas.

     3While it is recognized that RACT will be determined on  a case-by-
case basis, the criteria for SIP approval rely heavily upon the
information contained,in the CTG.  Deviations from the use of the CTG
must be adequately documented.

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                                     20
      1.   To be published by February l'?7'i

          a.   inspection/maintenance
          b.   vapor recovery
          c.   improved public transit
          d.   exclusive bus and carpool  lanes
          e.   area wide carpool programs

      2,   To be published by August 1978

          a.   private car restrictions
          b.   long range transit improvements
          e.   on street parking controls
          d.   park and ride and fringe parking lots
          e.   pedestrian malls
          f.   employer programs to encourage car and van pooling,
               mass transit, bicycling and walking
          g.   bicycle lanes and storage facilities
          h.   staggered worfc hours
          i.   road pricing to discourage single occupancy auto  trips
          j.   controls on extended vehicle idling
          k.   traffic flow improvements
          1.   alternative fuels or engines and other fleet
               vehicle controls
          m.   other than light duty vehicle retrofit
          n.   extreme cold start emission reduction programs

     The above measures (either individually or combined  into packages
of measures) should be analyzed promptly and thoroughly and  scheduled
for expeditious implementation.  EPA recognizes that not  all analyses
of every measure can be completed by January 1979 and,  where necessary,
schedules may provide for the completion of analyses after January 1,
1979 as discussed below.  (If analysis after January 1979 demonstrates
that certain measures would" be unnecessary or ineffective, a decision
not to implement such measures may be justifiable. However, decisions
not to implement measures will have to be carefully reviewed to avoid
broad rejections of measures based on conclusory assertions  of
infeasibility.)
             j
     As described previously, annual incremental reductions  in total
emissions must occur in order to achieve reasonable further  progress
during the period prior to attainment of the standards.  Therefore,
not all transportation measure implementation activities  should wait
until  the comprehensive analyses of control measures are  completed.
Demonstration studies are important and should accompany  or  precede

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                                     21

full scale implementation of the comprehensive, strategy.   It is EPA's
policy that each area will be required to schedule a representative
selection of reasonable transportation measures (as listed above)  for
implementation at least on a pilot or demonstration basis  prior to the
end of 1980.

     Every effort must be made to integrate the air quality related
transportation plan and implementation required by the Clean Air Act
into planning and programming procedures administered by DOT.   EPA will
publish "Transportation Planning Guidelines" which will, if followed
carefully, insure that an adequate transportation planning process
exists.

     EPA recognizes that the planning and implementation of very
extensive air quality related transportation measures can  be a complicated
and lengthy process, and in areas with severe carbon monoxide or oxidant
problems, completion of some of the adopted measures may extend beyond
1932.  Implementation of even these very extensive transportation
n-easures, however, must be initiated before December 31, 1982.

     In the case of plan revisions that make the requisite showing to
justify an extension of the date for attainment, the portion of the 1979
plan submittal for transportation measures must:

     1.   Contain procedures and criteria adopted into the SIP by  which
it can be determined whether the outputs of the DOT Transportation
planning process conform to the SIP.

     2.   Provide for the expeditious implementation of currently
planned reasonable transportation control measures.  This  includes
reasonable but unimplemented transportation measures in existing SIPs
and transportation controls with demonstrable air quality  benefits
developed as part of the transportation process funded by  DOT.

     3.   Present a program for evaluating a range of alternative
packages of transportation options that includes, as a minimum, those
measures listed above for which EPA will develop information documents.
The analyses must identify a package of transportation control measures
to attain the emission reduction target ascribed to it in  the SIP.

     4.   Provide for the evaluation of long range (post-1982) trans-
portation and growth policies.  Alternative growth policies and/or
development patterns must be examined to determine the potential for
modifying total travel demand.  One of the growth alternatives evaluated
should be that prepared in response to Sectio~ri,.701 of the  Housing  Act of
1954, as amended.

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                                  22


     5.    Include a schedule for analysis and adoption of transportation
control measures as expeditiously as practicable.   The comprehensive
analysis of alternatives (item 2 above)'must be completed by July 1980
unless the designated planning agency can demonstrate that analysis
of  individual components (e.g., long range transit improvements) may
require additional time.  Adopted measures must be implemented as
expeditiously as practicable and on a continuous schedule that demonstrates
reasonable further progress from 1979 to the attainment date.   Deter-
minations  of the reasonableness of a schedule will be based on the
nature of  the existing or planned transportation system and the com-
plexity of implementation of an individual measure.

     Additional Carbon Monoxide and Oxidant Monitoring Requirements

     It is EPA's policy to require that all SIPs which provide for
attainment of the oxidant standard after December 31, 1982, must con-
tain commitments to implement a complete oxidant monitoring program in
major urbanized areas in order to adequately characterize the nature
and extent of the problem and to measure the effectiveness of the
control strategy for oxidants.  The 1979 plan submittal  must provide
for a schedule to conduct such CO monitoring as necessary to correct
any deficiencies as identified by the Regional Office.

     SIPs  for Unclassified Areas Redesignated Non-Attainment

     With  respect to unclassified areas which are later found to be
non-attainment areas the state will  be required to submit a plan
Vaithin nine months of the non-attainment determination.   During plan
development, the state will be required to implement the offset policy
for that area.  However, it should be noted that in many cases, because
of previous plan revisions or adoption of previous control regulations,
the baseline for offsets will be more restrictive and thus offsets may
be more difficult to obtain.  For oxidants, state-wide regulatory
development (for at least all sources greater than 100 tons/year),
however, would permit the state to utilize the regulations developed
for the entire state as the applicable plan for the newly designated
non-attainment area.  This would normally constitute an approvable SIP
per the above criteria and could essentially accommodate the proposed
growth within the previously submitted state plan and not require
offsets once the area is designated as non-attair.msnt.

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                                23
                             APPENDIX C

                        SIP REVISION PROCESS

      Appendix C provides one general illustration of how the transportation

 portion of the implementation plan could be developed and implemented

 within the context of the entire SIP revision process.  In this illustration

 (see Figure 1) the MPO has been assigned the responsibility for the

 transportation portion of the SIP, while other agency responsibilities

 are as shown in 5d-f.  (The acronyms are defined at the end of the Appendix.)

 Explanatory Notes for Flow Chart

      1.  Blocks # 1-4 concern scoping the problem.  Blocks # 5-6 concern
 the development of a control strategy.

      2.  All tasks are to be performed in accordance with the planning
 procedures jointly determined by the state and local elected officials
 as specified in Section 174 of the Clean Air Act, as amended August 1977.
 Section 174 indicates that elements of a revised implementation plan should
 be planned, implemented, and enforced by either the state, local govern-
 ments or regional agencies or some combination of the three.  This cooperative
 approach will probably require some involvement by all appropriate agencies
 in each task, although a single lead agency may be assigned to specific
 tasks  (e.g., see tasks 5a-c).  Tasks 5 and 6 will require full participation
 by all key agencies.

      3.  Jask__l:  The Emissions Inventory will be periodically revised as
 new and more" accurate information becomes available for stationary and
 mobile sources.
2
O
t
UJ

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                                        24
                                   FIGURE 1
                       FLOW CHART FOR DEVELOPMENT/REVISION
                       •OF 1979 SIP TO ATTAIN NAAQS BY 1987
                         . Develop/Revise Comprehensive
                               Emissions, Inventory
                   d. Keview Air Quality Data and Determinej
                        Necessary Emissions Reductions to
                     	     Attain NAAOS
                3. Estimate/Update Emissions for Each Calendar
                      Year Through 1987 Factoring in RACT,
                      FMVCP. I/H. Committed RACM, and Growth __
                  4. Determine Emissions Shortfall for Each
                      Calendar Year Through 1987 to Achieve
                    RFP Line by 1982 and Attain NAAQS bv 198?!
                 5. Develop/Revise Target Emission Reduction
                   Goals for Transportation/Stationary Sources
              Transportation           w                 Stationary Source
±a.  Develop/Revise Planning!                Id.  Develop/Expand RACT Guidance
 •I         Process (MPO)       I                I	(EPA)	
 ]b.  Select RACM for Implementation^          \ e.  Apply RACT (State Env. Agency)|
   c.  Determine  Progress  in  Developing/1       | f7 Determine Progress in Applying
tm ' ^  —•^•^^••••••p t-^f f t ^ ^j f ^*^ *« ••• iiwv

l_	   RACT (Env.  Aqencv)
                      6.  Periodic  Review of Achievement
                     	of Emission  Reduction  fioals

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                                 25


     4.  Task 2:  In the crudest, most straight-forward approach the gross
magnitude of emission reductions for standard attainment can be roughly
determined with air quality and emission data using the simple roll-back
technique.  The emission reduction line in the graph on page 23 is shown
to be straight for simplicity's sake only.  The line represents emission
reductions from both stationary and mobile source controls and in actuality
will not, of course, be straight.  The general slope aVid shape of the line
will -- especially for transportation controls — be other than straight
due to, among other factors, the non-linear hydrocarbon (emission)-oxidant
(air quality) relationship and the implementation lag times (e.g., substan-
tial emission reductions from transportation sources is likely to occur in
later years closer to 1987 because of longer planning and implementation
lead times).  The graph on page 23 actually represents an emission reduction
schedule that is jointly negotiated, reviewed, and periodically revised
(e.g., in Tasks 5 and 6).

     The graph can be used to communicate fundamental Agency policy concepts
if the difficulties and uncertainties of drawing such a line are temporarily
set aside.  For example, by 1982 emissions should be reduced ~ and air
quality improved — sufficient to reach the emission reduction line.
(This allows the necessary lead time for the application of RACT and the
implementation of certain RACM.)  From 1982 to 1987 the line represents
reasonable further progress (RFP) (the annual incremental emission
reductions called for in Section 171).  If an area is below the line
after  1982 additional growth of major stationary sources is permitted.
If an area is on or above the line, growth will only be permitted as
part of the Agency offset policy.

     5.  Task 3 will show the annual decrease in emissions between 1979
and 1987 that will result from certain (hard) control strategies.

     6.  Task 4 will show the additional emission reduction required from
other  stationary and mobile sources (to be achieved from the future
application of RACT and the implementation of RACM).

     7.  Task 5 produces an estimate of emission reduction goals achievable
through future RACT and RACM  (soft strategies) jointly determined by all
appropriate agencies identified in accordance with Section 174.  This
estimate is one of the major decisions to be made in the SIP revision process.

     8.  Task 5a:  The 1979 SIP submission must contain a well-defined,
functioning planning process complete with interagency agreements,
memoranda of understanding, etc.

     9.  Task 5b:  The 1979 submission should contain evidence that certain
measures currently in the TIP are being implemented as rapidly as possible.
However, because of planning and lead times it is expected that the
majority of transportation RACM will be selected and implemented after  1979.

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                                 26


    10.   Task 5c and the feedback arrow to 5a  acknowledges that implementa-
tion progress will  be highly dependent on the  adequacy of the planning
process  (i.e., RACM is largely a question of public and political  accepta-
bility whereas RACT is more of a technological  and economic determination;.

    11.   Task 5d indicates that future control  progress with other stationary
sources  will be determined by EPA's schedule for promulgating RACT documents.

    12.   Task 6 is  another critical joint decision that should be  made at
least annually by all participating agencies,  followed by another  run
through  all the tasks as part of the continuous SIP revision process.


                      Definition of Acronyms
                 (from top to bottom in Figure 1)

SIP      = State Implementation Plan

NAAQS    = National Ambient Air Quality Standard

RACT     = Reasonable Available Control Technology (applied to
           stationary sources)

FMVCP    = Federal  Motor Vehicle Control Program

I/M      = Inspection and Maintenance program  for in-use vehicles

RACM     = Reasonably Available Control Measure (generally applied to
           transportation, measures)

RFP      = Reasonable Further Progress: annual incremental emission
           reductions

MPO      = Metropolitan Planning Organization

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                                  27


                             APPENDIX D

                             DEFINITIONS


     1.  "Clean Air Act, as amended August 1977 (CAAA)":  The Clean Air
Act as amended by the Clean Air Act Amendments of 1977, P.L. 95-95, 91
Stat. 685, 42 USC 7401 et seq (formerly 42 USC 1857 et seq).

     2.  "State Implementation Plan (SIP)":  The plan which each state is
required to develop under Section 110 of the Clean Air Act.  If the state
fails to submit an approvable plan, EPA is required to promulgate one
for the state.  The SIP must provide for the attainment and maintenance
of the established air quality standards within the time frames set forth
in the Act.

     3.  "Approvable SIP":  A SIP which satisfies the requirements outlined
by the Administrator of EPA in a memorandum dated February 24, 1978.

     4.  "Air Quality Maintenance Plan (AQMP)":  The plan required in areas
where, based on current emission inventory and the projected growth rate,
national ambient air quality standards will be exceeded over a 10-year
period.  The AQMP is usually required to assure attainment as well as
maintenance of the air quality standards, and thus must contain control
strategies to ensure that projected emissions are compatible with
attainment and maintenance of the national standards.

     5.  "Transportation Control Plan (TCP)":  That pprtion of the SIP
which describes the transporjttion-air quality planning process and the
transportation system mea-sures applicable to each area.

     6.  "Transportation Control Measure (TCM)":  Any measure directed
toward reducing emissions of air pollutants from transportation sources,
such as, reducing vehicle use, changing traffic flow patterns, decreasing
emissions from in-use motor vehicles, or altering existing modal split
patterns (see 40 CFR S 51.1).

     7.  "Reasonably Available Control Measure (RACM)":  The determination
of reasonably available measures will be made on a case-by-case basis
through the existing transportation policy decision apparatus by all
agencies identified according to § 174 of the CAAA.  This determination
results from an analytical, participatory and negotiatory process
that involves both EPA and DOT.  The transportation measures listed in
S 108(f) of the Clean Air Act, as amended, provide an initial list of
measures that are considered reasonably available for the purpose of
analysis.  The applicability, scale and speed of implementation of
specific measures and strategies for specific areas will vary.  The
reasonableness of a measure will generally depend on the severity of the
pollution problem, other available alternative means of attaining or
maintaining air quality standards and the social and economic impact of
the measure.

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                                  28
     8.  "174 Planning Organization":  The  organization designated under
S 174 of the CAM to conduct or coordinate the  planning process and
eligible for assistance under § 175 of the CAAA.

     9.  "Short Term Measures":  Those transportation measures with the
potential of reducing transportation system emissions which can be
developed and implemented by 1982.

    10.  "Longer Term Transportation Improvements":   Those transportation
measures which may be necessary for attainment  and maintenance of the
air quality health standards beyond 1982.

    11.  "Attainment":  For any pollutant, the  status of an area which
has met the national ambient air quality standard for such pollutant.

    12.  "Nonattainment":  For any pollutant,  the status of an area which
is shown by monitored data or which is calculated by air quality modeling
to exceed any national ambient air quality standard for such pollutant
(see S 171(2) of the CAAA, 42 USC 7501 (2)).

    13.  "Emission Inventory":  The comprehensive, accurate, current
inventory of actual emissions taking into account the implementation of
strategies in the transportation plan and program, so that the need for
additional reductions to assure attainment may be assessed, as required
in § 172(b)C4) of the CAAA.

    14.  "Incremental Progress in Reducing Emissions from the Trans-
portation System":  The requirement that the transportation-related portion
of the SIP show progress toward attainment and/or maintenance of the air
quality standard.  "Incremental Progress":  demonstration of which will
initially be based on progress made in developing, programming and
implementing measures to reduce emissions, and later will be based on
progress in actually reducing emissions.

    15.  "Conformity" (as related to transportation):  A determination
under  S 176(c) of the CAAA that DOT has assured that transportation
plans  and programs in an area conform to the transportation-related
requirements of the SIP.

    16.  "Consistency":  The requirement in 42 USC 109(j) that proposed
transportation plans and projects be consistent with the approved  SIP.

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                                 29


    17.  "Public Participation and Education; Interagency Consultation":
The process of effectively involving citizens, local elected officials
and state officials and legislators in air quality related planning,
programming and decisionmaking.

    18.  "Metropolitan Planning Organization (MPO)":  That organization
designated by the Governor as being responsible, together with the state,
for urban transportation planning under the Federal-Aid Highway Act
(23 USC § 101 et seq) and the Urban Mass Transportation Act (49 USC 1601
et_se£).  This organization is the forum for cooperative decisionmaking
by principal elected officials of general purpose local governments
(see 23 CFR § 450.104(b)).

    19.  "Unified Planning Work Program (UPWP)":  The document that must
be developed by the MPO under 23 CFR S 450.112(a) and satisfy the require-
ments of 23 CFR S 450.114(c).  The UPWP describes all urban transportation-
related planning activities within the area during the next 1- or 2-year
period, regardless of funding sources and documents work to be performed
with planning assistance under Section 9 of the UMT Act (49 USC 1607a)
and 23 USC 104(f) and 307(c).

    20.  "Modified UPWP":  The UPWP currently prepared for an area by the
MPO in response to DOT requirements which has been modified to include
transportation-related air quality planning activities in response to CAAA
requirements.

    21.  "Prospectus":  That part of the UPWP which summarizes the planning
program and generally describes the status and anticipated accomplishments
of each element, the procedures to be used in carrying out each element and
the functional responsibilities of each participating agency (see 23 CFR
§ 450.1T4(b)).

    22.  "Regional Transportation Plan (RTF)":  The plan that must be
developed under the DOT urban transportation planning process to satisfy
the requirements of 23 CFR § 450.116.  The RTF includes a transportation
systems management element and a long range element and must be consistent
with the area's comprehensive long-range land use plan and overall social,
economic, environmental, system performance and energy conservation goals
and objectives.

    23.  "Transportation Systems Management Element (TSME)":  That part
of the RTP which provides for the short-range transportation needs of the
urbanized area, not including new 4i"ansportation facilities or major changes
in existing facilities (see 23 !      450.116(b)).

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                                 30


    24.  "Long-Range Element (LRE)":   That part of the RTP which must
identify new transportation policies  and facilities or major changes in
existing facilities (see 23 CFR S 450.116(c)).

    25.  "Transportation Improvement  Plan (TIP)":   A staged multi-year
program of transportation improvements including an annual element listing
transportation improvement projects proposed for implementation during
the first program year (see 23 CFR S  450.304(b)).

    26.  "Annual Element (AE)":  A list of transportation improvement
projects proposed for implementation  during the first program year of
the TIP (see 23 CFR S 450.304(b)).

    27.  "Intermodal Planning Group (IPG)":  A group composed of repre-
sentatives of all DOT administrations, and other agency representatives
on an ad hoc basis, which serves as a forum for coordinating trans-
portation planning programs funded individually by the different DOT
administrations.  In all regions EPA is represented by an ad hoc member,
and HUD and state agencies are represented in some regions.  The IPG has
no decisionmaking power.

   28.  "Highway Planning and Research Funds (HPR Funds)":  Funds apportioned
to the states under 23 USC S 104 and  made available under 23 USC S 307 for
expenditure on request by the state for statewide planning, urban planning
and highway-related research.  The amount available is a 1 and 1/2 percent
deduction from sums apportioned to any state for all federal-aid systems
under 23 USC S 104.  The funds may be used only for planning and research.

    29.  "Planning Funds (PL Funds)":  Funds apportioned to the states
under 23 USC S 104 and made available through the states to MPOs for
carrying out 23 USC 134.  The funds may be used to establish and maintain
a continuing, comprehensive and cooperative (3C) process in urban areas
with more than 50,000 population.  The amount of funds available are based
upon 1/2 percent of funds to be apportioned to all states for federal-aid
systems.  This amount is then apportioned to the states as a ratio of
urbanized area population.

    30.  "Planning and Research Funds  (PR Fui.>  )":  Construction funds
which may be used for planning and research, or demonstration projects
in connection with highway-related research.  The amount of funds is
limited to 1/2 percent of sums apportioned for f°deral-aid primary,
secondary and urban systc.  •

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                                  31
                            APPENblX E
    BACKGROUND INFORMATION OF ERA'S TRANSPORTATION CONTROL PROGRAM
     Under the Clean Air Act, as amended in 1970, each state was required
to develop a State Implementation Plan  (SIP) that provided for the
attainment and maintenance of the established air quality standards
within the time frames set forth in the Act.  If a state failed to submit
an approvable plan, EPA was required to promulgate one.  Controls on
stationary sources and the federal new  car emission control program went
a long way toward achieving the air quality standards.  However, despite
the substantial emission  reductions from these  controls, many areas were
in need of further controls if the standards were to  be attained and
maintained;*  Recognizing this need for further controls, the Act
(Section  110(a)(2)(B)) specifically required the use  of transportation
control measures where necessary.  As a result  of a suit filed by the
Natural Resources Defense Council  (NRDC v. EPA, 475 F.2d 968), the U.S
Court of  Appeals for  the  District of Columbia Circuit ordered the
Administrator to require  submission of  complete implementation plans
(including  transportation control measures) during  1973.
     The  extremely  tight  time constraints  imposed by  the Court took
their toll  on the quality of transportation control plans that were
produced.   Some states decided that it  was  impossible to produce a plan
 *This was  true  in  many cases  even  assuming all  cars  on  the road  were
  actually  meeting  the  original  statutory standards.   However,  this
  assumption was  contingent on having the necessary inspection  and
  maintenance  programs  to  ensure that in-use performance matched  the
  capability demonstrated  in certification.

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                                32

within the time limit because of manpower and funding shortages, leaving
EPA with the responsibility of preparing and promulgating the plans.
Other states submitted only partial plans, again leaving EPA with the
responsibility of promulgating additional measures as necessary for
attainment.  Overall, the effect of the Court decision was to require
extremely rapid adoption and implementation of some very substantial,
and  in some cases -- potentially disruptive — changes in urban trans-
portation systems for which the public and the political process were
largely  unprepared and about which they were largely uninformed.  By
December 1973, EPA had approved or promulgated transportation control
measures in all the  then demonstrably deficient areas.   (Originally 31
urban areas required transportation control plans.  Many other areas
were strongly  suspected to have similar air quality problems, but adequate
monitoring data was  not available  in 1973.)
      The transportation control measures  can be divided  into classes of
measures that  reduce in-use automobile emission rates  (emissions per
mile) and classes of measures  that both  reduce vehicle  usage and promote
transit. The  former class includes inspection/maintenance and  vehicle
retrofit programs.   The latter includes  transit improvement, carpooling,
and  selected restrictions on  the  use of  automobiles.   These  latter  measures
are  identified in Section 108(f)  of the  Clean Air  Act  and are  similar
to the Transportation System  Management  (TSM) measures  identified by
the  Department of Transportation  in their joint planning regulations
(23  USC  450).

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                                  33
     In developing the original plans for reducing emissions from the
                *-
transportation system, emphasis was placed on controlling the in-use
automobile emissions  (27 areas required inspection/maintenance).  Measures
to reduce auto trips were used where in-use controls were not sufficient.
In the case of hydrocarbons the Agency first examined additional
stationary source controls before either type of mobile source control
was used.  The promulgation of gasoline marketing vapor recovery regulations
is an example.
     The implementation phase since December 1973, was a mix of successes
and failures.  Some metropolitan areas made good faith efforts to adopt
and implement transportation control measures.  However, there have also
been unsuccessful examples.  There are various reasons for this failure
to implement transportation control measures.  First, information on the
effectiveness, costs,  and implementability of transportation options in
1973 was limited.  Time did not allow for the investigation of social
and economic effects-oh a case-by-case basis.
     In addition, experience was lacking at all levels of government
to plan and implement effective measures.  Due to the time restrictions,
many of the transportation control requirements could not be adapted to
the existing institutional framework, to ongoing planning schedules and
processes, and to agency budget cycles.  Also the 1977 time deadline for
achieving health related national air quality standards did not allow
credit for long-range measures such as mass transit  improvements.  Conse-
quently, both the alternatives considered and the effects analyzed were

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                                 34
limited.  Perhaps the greatest deficiency was the lack of inter-
governmental coordination and citizen participation.   A considerable
amount of the opposition to the plans centered not so much on the
measures but rather on the manner in which the measures were developed
and imposed.

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                                 35
                            APPENDIX F
                             FUNDING
IDENTIFICATION OF FUNDS TO IMPLEMENT THE PLAN AND TO CONDUCT RELATED PLANNING
     (a)   FHWA
          The United States Code, Title 23 provides funds for transportation
improvements in a number of categories identified by highway system.  In
addition* funds for planning and research programs are provided which
could be used to plan for and implement transportation control measures.
These funds are apportioned under Section 104 or made available for
expenditure on planning and research activities under Section 307.
              (1)  Construction
                   Funds that are available for project development and
                   construction in urbanized areas which could be used to
                   implement certain transportation control measures
                   include:
                       0 Federal-Aid Primary
                       0 Federal-Aid Interstate
                       0 Federal-Aid Urban
                   These funds are available for use statewide and are not
                   specifically earmarked for use in urbanized areas.  One
                   exception is the portion of urban system funds that are
                   attributable to urbanized areas of 200,000 population
                   or more.

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                   36
     Funds also are available for special categories of
     improvement, such as control of outdoor advertising,
     control of junkyards, special bridge replacement, priority
     primary routes, pavement marking demonstration, projects
     for  high-hazard locations, elimination of roadside
     obstacles, highways crossing federal projects, bicycle
     transportation and pedestrian walkways and safer off-
     system roads.  Most of  these funds are for special
     purposes  and are not generally applicable to  trans-
     portation control measures.
(2)   Planning
     Funds commonly referred to as PL funds are apportioned  to
     states under Section 104(f) and made available through
     the  states to metropolitan planning organizations  (MPOs)
     for  carrying out the provisions of Section 134,
     Transportation planning in certain urban areas:
         0 To  establish and  maintain a continuing, compre-
          hensive, and cooperative  (3C) planning  process  in
          urbanized areas  (urban areas with more  than  50,000
          population).
         0 Funds are based  on one-half percent of  funds  to be
          apportioned to all states for federal-aid  systems.
          This amount is then  apportioned  to  the  states as
          a  ratio  of urbanized area population, except that
          no  state receives less  than one-half  percent of
          the total apportionment.

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                             37

         (3)  Planning and Research
              Funds commonly referred to as HPR and PR funds are
              made available for expenditure on request by the
              state for statewide planning, urban planning, and
              highway-related research.
                  0 Amount of HPR funds available is a 1-1/2 percent
                    deduction from sums apportioned to any state for
                    all federal-aid systems under Section 104.
                  0 Since the HPR funds are used for statewide planning,
                    research, and to satisfy certain planning data
                    reporting requirements of the FHWA, the amounts
                    available for urban planning are limited.  These
                    funds, however, are to be used only for planning
                    and research.
                  0 PR funds are construction funds which may be used
                    for planning and research.   These funds may also
                    be used for demonstration projects in connection
                    with highway-related research.  The amount of
                    funds is limited to one-half percent of sums
                    apportioned for federal-aid primary, secondary,
                    and urban systems.
(b)   UMTA
     (1)   Construction
          Section 3:  Federal Financial Assistance

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                     38
     0 Assists  states  and  local  agencies  in  financing
       (1)  the  acquisition,  construction,  reconstruction,
       and  improvement of  facilities and  equipment  for  use
       in mass  transportation service  in  urban areas and in
       coordinating  such service with  highway and other
       transportation  in such areas, and  (2) the establishment
       and  organization of public and  quasi-public  transit
       corridor development  corporations or entities.
     0 Eligible facilities and equipment include buses and
       other rolling stock and real property including land
       (but not public highways) within the entire  zone
       affected by the construction and operation of transit
       improvements, including station sites, needed for any
       efficient and coordinated mass transportation system.
       Up to one-half of any financial  assistance provided
       under this Act (other than Section 5)  may be used
       for the payment of operating expenses  incurred in
       connection with the provision of mass  transit service
       in an urban area.
Section 5
    0 For use  in urbanized areas.
      Funds available for construction of mass  transportation
      facilities  (with construction covering a  broad range
      of activities).

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                        39

         0 The federal share available for construction  under
           this section is 80 percent.
         0 The federal share available for operating subsidies
           is 50 percent.
           Funds made available on the basis of a formula under
           which urbanized areas will be entitled to receive
           an amount equal to:
               (a)  one-half the total amount apportioned X the
                    ratio which the population of the urbanized
                    area bears to the total population of all
                    the urbanized areas in all the states
               (b)  one-half the total amount so apportioned X a
                    ratio for that urbanized area determined on
                    the basis of population weighted by a density
                    factor
         0 To-obtain these funds, the recipient must certify
           that public hearings have been conducted and must
           submit a report indicating the consideration given
           to the economic, social, environmental and other
           effects of the proposed project.
(2)   Planning
     Section 9:  Grants for Technical  Studies
         0 Available to states and local  governments for the
           planning, engineering, designing, and evaluation of
           urban mass transportation  projects or for other

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                                    40
                     technical  studies  to  be  included  in  a  program for a
                     coordinated  urban  transportation  system as  a  part
                     of the comprehensively planned  development  of the
                     urban area.
                   0  Activities which qualify for  funding include:
                         (1)  studies relating to  management,  operations,
                              capital requirements,  and economic feasi-
                              bility;
                         (2)  preparation  of  engineering  and architectural
                              surveys,  plans  and specifications;
                         (3)  evaluation of previously funded  projects; and
                         (4)  other  related activities in preparation  for
                              the construction, acquisition, or  improved
                              operation of mass transportation systems,
                              facilities,  and equipment.
          (3)  Other
               Section 6:  Research,  Development and  Demonstration  Projects
                   0  The Secretary may  contract or provide  grants  for
                     RD&D in all  phases of urban mass  transportation.
     (c)  HUD
          Transportation control  planning  activities are  eligible  to
receive HUD funding under S 701 grant program (S 701 of Housing  Act of
1954, 40 USC 461, as  amended by the  Housing and Community Development

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                                   41

Act of 1974, 42 USC 5301 et seq; 24 CFR Part 600).  However, the availa-
bility of funds for transportation planning is limited.  While $57 million
is available for land use and housing planning ($21.5 million is available
to A-95 metropolitan planning agencies), most areas exhaust their allotment
satisfying HUD directives.  If any funds remain after required planning
activities have been performed, a local decision could be made to use
remaining funds for transportation planning.

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                                  42
                           APPENDIX G
      SUPPLEMENTARY  INFORMATION ON THE  EVALUATION OF ALTERNATIVES
1.   Legal  Mandate
    Section 172(b)(9)  of the  Clean Air  Act, as amended  1977,  specifies
that the plan for nonattainment areas shall include:
          ... an identification and  analysis  of  the air quality,
          health, welfare,  economic, energy and  social  effects
          of the plan  provisions  ... and  of alternatives considered
          by the state.
(Section 129(c] of the Clean  Air  Act Amendments  of  1977 (Pub. L. No.  95-95,
91  Stat. 750-51) indicates  that this plan shall  be  submitted  by January 1,
1979.)  In addition, Section  108(f)  requires  the preparation  of information
on a wide range of alternative transportation measures, including  an
assessment of "the relative effectiveness, ... potential effect on
transportation systems and  the provision  of transportation  services,  ...
and the environmental, energy and economic impacts."
     The joint planning regulations  issued by FHWA  and  UMTA on  September 17,
1975 (23 CFR 450) specifically call  for alternative analyses:
     The urban transportation planning  process  shall  ... include:
          (ii)  An evaluation of  alternative  transportation
                systems management improvements  ...
          (iv)  Analysis of alternative transportation  invest-
                ments to meet areawide  needs  for new  transportation
                facilities.
     The joint regulations  further state  that energy  conservation, air
quality improvement, and increased social and environmental amenities
are purposes of the transportation systems management requirement.  The
regulations also specify "the urban transportation planning process

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                                 43

shall:  (1) Provide for the consideration of social, economic and environ-
mental  effects ... (2) Be coordinated with air quality planning conducted
pursuant to 42 USC 1857 (Clean Air Act)."
     The DOT regulations direct urban areas in developing the TSM element
to consider a wide range of options.  The Appendix to the regulation
presents a lengthy list of measures which are suggested for consideration.
The categories of measures include: traffic operations improvements;
preferential treatment for high occupancy vehicles; provision for pedestrians
and bicycles; management and control of parking; changes in work schedules,
fares and tolls; reduced vehicle use incentives; transit service improve-
ments; and transit management improvements.  Significantly, the Appendix
also contains the following guidance in an "Actions to be considered"
section:
          ... While the feasibility of and need for individual
          actions may differ with the size of an urbanized area
          or the extent of congestion all categories of actions
          should be considered.  It is expected that some actions
          in each category will be appropriate for any urbanized
          area.
2.  Scope of Analysis
    Effective transportation planning requires analysis not only of
individual transportation measures but also of different options for
implementing measures and of overall transportation strategies, or
packages of measures.  Because the feasibility and effectiveness of
certain measures may be influenced by the presence or absence of certain
other transportation activities in a particular sub-area or corridor,
studies of combinations of measures may be appropriate in  some  cases.

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                                 44
For example, an urban area might combine studies of park and ride facili-
ties and transit circulator service with an auto-restricted zone study.
In addition, the areawide effects of proposed transportation programs on
factors such as oxidant concentrations often must be assessed.   Thus,
depending on local circumstances and the pollutant to be controlled the
alternatives that are analyzed might consist of individual  measures,
combinations of measures applicable to certain corridors or sub-regional
areas, or entire transportation programs.
3.  Assignment of Responsibility
    The detailed institutional arrangements and assignments of responsi-
bility in the analysis of alternatives should be tailored to the particular
conditions in each metropolitan area.   For example, a number of the measures
to be considered in TSM and transportation control planning traditionally
have been the responsibility of various operating agencies — city planning
departments, transit authorities, traffic divisions, county transportation
commissions, and enforcement agencies.  In many urban areas, these
organizations will continue to play the major role in the generation of
alternatives, assessment of their impacts and feasibility, and implementation.
In these areas the MPO may wish to coordinate study efforts, perform special
supplementary studies and areawide analyses, and integrate the recommenda-
tions of the local agencies into a TSM plan and a TIP.  In some urban
areas, the MPOs may wish to develop additional capabilities to conduct
its own short range planning and analysis.

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          . 5-73)
                                 APPENDIX H
UNITED STATES GOVERNMENT

  Memorandum
                                                                      45
                                         DEPARTMENT OF TRANSPORTATION
                                            FEDERAL HIGHWAY ADMINISTRATION
    ACTION -  Integration of Air Quality
    Requirements into the Transportation
    Planning  Process

    Federal Highway Administrator
FROM 'urban Mass  Transportation Administrator
                                             DATE:   1 FEB 1978
                                             In reply
                                             r.f.r to:  HHP-23
                                                  UTP-21
TO
^Regional  Federal Highway Administrators, Regions 1-10
 Urban Mass  Transportation Administration Regional
   Directors,  Regions I-X
     The  Clean Air Act Amendments of 1977 were signed into law by
     the  President on August 7, 1977.  These Amendments require
     State and local governments to develop revisions to State
     Implementation Plans (SIP)s, for all areas where national
     ambient air quality standards have not been attained, by
     January 1, 1979.  In most major urbanized areas of the country,
     the  revised SIPs will require transportation controls, i.e.,
     strategies designed to reduce emissions from transportation-
     related sources by means of structural and operational changes
     in the transportation system.

     The  Office of Management and Budget has directed DOT and EPA
     to integrate and fund air quality planning within DOT's trans-
     portation planning process.  The DOT and EPA are, therefore,
     negotiating an agreement linking air quality and transportation
     planning; meanwhile, criteria for transportation control plans
     (TCP)  and SIP revisions are being prepared with the intent of
     prompt joint DOT-EPA issuance of transportation regulations
     and  guidelines by February 9, 1978.

     Because of the imminence of the January 1, 1979, deadline, we
     are  directing that the following actions be initiated promptly
     by the regional staffs of UMTA and FHWA:

          1.  The EPA should be invited to participate in the
              IntermQdal Planning Group  (IPG) so as to insure
              coordination of all activities pertaining to the
              urban transportation planning process;

          2.  The EPA should be consulted to determine which areas
              are likely td require TCPs and what the estimated
              magnitude of TCP effort will be in those areas;

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                              46
    -3.  For areas requiring TCPs, funds within already approved
         Unified Planning Work Programs (UPWPs) may be
         reprogramed as appropriate to support the identification
         and analysis of transportation control measures in
         coordination with the SIP revision process;

     4.  Air quality planning tasks in support of the SIP
         revision process should be given a high priority in
         UPWPs now being developed.  Air quality planning is
         a national priority and must be given appropriate
         emphasis in the conduct of the transportation planning
         process;

     5.  The transportation improvement program (TIP)/annual
         element (AE) review process should be conducted with a
         renewed emphasis on the inclusion of projects benefiting
         air quality in the TIP/AE; and

     6.  The certification review process should be conducted
         with a renewed emphasis on the coordination of air
         quality planning and transportation planning as
         required by the joint regulations.

The President has requested the establishment of a single Federal
mechanism to integrate transportation and air quality planning.
We are confident that through the mutual commitment of FHWA and
UMTA, we can meet this goal.  Regional Administrators and
Directors should furnish their respective modal administrators
with a progress summary on each of the six items in their
periodic reports (in UMTA, the Biweekly Highlights Report to
the Administrator)  beginning with the March 1978 report.
Richard S. Page   //                  William M. Cox

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                                 47

                            APPENDIX I


                         INTERAGENCY AGREEMENT

                                BETWEEN

            THE DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT

                 THE ENVIRONMENTAL PROTECTION AGENCY
I.   PURPOSE:

     This Interagency Agreement has been developed to:  (1) coordinate
the planning and management activities of the two signatory agencies,
the Department of Housing and Urban Development (HUD) and the Environ-
mental Protection Agency (EPA) in accordance with the Administration's
objectives; (2) encourage interagency cooperation and coordination of
planning between local levels of government; (3) ensure that any land
use policies and control strategies undertaken for air quality improve-
ment are developed and implemented within a broader framework of compre-
hensive planning and management; and (4) ensure that comprehensive
planning and management reflects the constraints attendant in attaining
and maintaining the National Ambient Air Quality Standards (NAAQS) and
in preventing, significant deterioration of air quality.


II.  PROGRAMS INVOLVED:

     The following programs are involved:

     Comprehensive Planning Assistance Program (Section 701) of the
Housing Act of 1954, as amended;

     State Implementation Plan (SIP) Program of the Clean Air Act,
as amended.
III. PROVISIONS

     1.  To the extent that resources are available, the HUD 701  land
use element shall provide basic land use planning including:  (1)  long
and short term policies regarding where growth should and should  not
take place; (2) the type, intensity and timing of growth; (3) studies,
criteria, standards and implementing procedures necessary for effec-
tively guiding and controlling major decisions as to the location of
growth; and should include, as an objective, policies and management
programs which contribute to the attainment and maintenannce of NAAQS
and to the prevention of significant deterioration of air quality.

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                                  48

     To the extent that resources are available,  any evaluation of
potential land use measures performed under section 110 of the Clean
Air Act shall analyze land use/air quality relationships to determine
what revisions could be made to existing or proposed land use plans,
policies, and regulations in order to reduce'or prevent air pollution
from stationary and mobile sources.

2.   In those geographic areas where land use elements  are to be developed
pursuant to the Comprehensive Planning Assistance Program and where land
use related provisions are to be added to a SIP,  HUD and EPA shall  en-
courage through appropriate guidelines that units of government and
planning agencies involved in the two processes consult in the process
of developing their work programs so that:  (1) there is no duplica-
tion of effort; (2) completed land use elements and SIP provisions are
consistent; and (3) the objectives of ijoib the Comprehensive Planning
Assistance and the SIP d€velopment.;progTa3S are achieved.

3.   The OMB Circular A-95 Clearinghouse procedures shall.be used for
review of SIP land use provisions by State and areawide 701 recipients.
The 701 land use element will be reviewed by air quality planning and
management agencies prior, to submission to HUD,  Criteria to assist the
Clearinghouses in making this review will be developed.  The principle
intent of the review and comment is  to allow interested parties to
point out potential inconsistencies  between the SIP and the land use
element for further consideration by the appropriate planning agencies.
Neither HUD nor EPA will approve a land use element or a land use related
provision of a SIP,, respectively, unless such an opportunity for review
1s granted,,

4*  In activities funded under the Comprehensive Planning Assistance
Program, grant recipients shall, as  a condition of continued eligibility
for funding (1) incorporate any land use related measures identified in
the SIP as necessary for the attainment and maintenance of the NAACS
as performance critieria, and (2) reflect any State or Federal programs
for prevention of significant deterioration of air quality.

5.   EPA will encourage the designation and continuous substantive involve-
ment of qualified State and areawide cornprehensive planning agencies in
(1) the development of land use related SIP provisions and (2) State
or Federal programs for prevention of significant deterioration of air
quality.

6.   All HUD 701 recipients and EPA or State designated agencies responsi-
ble for the SIP development will be actively encouraged to use common
data bases, common analytic techniques snd consistent criteria in their
planning activities and to adopt compatible work programs and  imple-
mentation strategies.

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                                  49


8.   HUD and EPA regional or field offices will develop lines of commu-
nication and effective means to jointly address issues, problems or
disputes that may impede the timely and effective implementation of
either the HUD 701 land use elements or the land use related portions
of the SIP.  Where these impediments are the result of planning assisted
or required by a Federal agency,  the HUD and EPA field offices will
invite representatives of interested Federal, State, areawide and local
agencies to review the situation  and whenever possible remove the impedi-
ments .

9.   Existing coordination mechanisms such as the A-95 Clearinghouse
procedures and the Federal Regional Councils will be used to the extent
that they prove capable of meeting the objectives of this agreement.

10.  HUD and EPA will develop  such procedures as may be required to
implement the above  provisions.   These will be developed in accordance
with Executive Orders and regulations governing both programs and will
require joint approval prior to issuance.

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                               50
                                            APPENDIX J
    SUMMARY OF SELECTED EPA GUIDELINES AND           «TT
     TOTHE TRANSPORTATION REQUIREMENTS OF THE CLEAN AIR ACT
Guideline:
Purpose:
 Status!
             "Clean Air Act Section 174 Guidelines" isf^d jointly
             by the Environmental Protection- Agency and the Department
             of Transportation.

             To implement Section 174 of the amended Clean Air Act _
             which requires (1) that state and local governments jointly
             determine responsibilities for developing, implementing and
             enforcing plans  for areas where national ambient air quality
             standards for carbon monoxide and photochemical oxidants
             have not been attained and (2) that a lead planning organiza-
             tion be  designated to coordinate plan development for  such
             areas.   State and local responsibilities must- be jointly
             determined  and lead plan development organizations nominated
             by local governments by February 7, 1978.  Governors must
             certify  by  April 1, 1978, a lead organization nominated
              by local officials for plan development or must designate
             an alternative organization.

              Issued. December 14* 1977.
Guideline:


Purposes
Status:.


Regulation:
               "Criteria  for Approval of 1979 SIP Revisions."  Memorandum
               from the EPA  Administrator to all Regional Administrators.

               To Implement  subpart D of the amended Clean Air Act which
               sets forth the  requirements  for revising a state  imple-
               Bwitation  plan  CSIP) for any area, for which national  ambient
               air quality standards have not been attained,- The SIP
               revisions  must  be submitted  by states to the  Environmental
               Protection Agency by January 1, 1979, and must provide  for
               attainment of standards  no later  than December 31, 1S82.  If
               a state is able to demonstrate that attainment of the standards
               for carbon- monoxide and  photochemical oxidants is not possible
               by I982r an extension of the attainment deadline  up  to
               December 31,  1987,. is possible.   The- guidelines summarize
               the elements  of an approvafale 1979 SIP  that must  be  Included
               trr order to- avoid imposition of sanctions provided for 1r
               the Act.

               Issued February 24-, 1978.
               Establishment of a process for consultation with general
               purpose local governments, organizations of local elected
               officials and federal  land managers.

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                                     51
Purpose:
 Status:
To .implement the requirements of Section 121 of the amended
Clean Air Act which requires states to provide a satisfactory
process of consultation for provisions of state implementation
plans dealing with  (1) transportation controls, air quality
maintenance and new source review;  (2) control measures for
nonattainment areas; and  (3) measures for prevention of
significant deterioration of air quality.  The consultation
process requirement is applicable to all implementation plan
revisions for the three categories  listed that are adopted
after August 7, 1978.  The consultation processes established
by states must be in accordance with regulations promulgated
by the  Environmental Protection Agency.  The Act requires
regulations to be promulgated, after notice and opportunity
for public hearing, by February 7,  1978.

Drafts  of the Environmental Protection Agency regulation have
undergone extensive review and will be proposed 1n the
Federal Register  1n March 1978.
 Guideline:

 Purpose;
 Status::
 Information documents for transportation  control measures.

 To Implement Section 108(f)  of the amended. Clean A1r Act which
 requires the Administrator of the Environmental Protection
 Agency to publish, in cooperation with the Secretary of the
 Department of Transportation, information about processes,
 procedures arid methods to reduce transportation-related air
 pollution.  The information must Include  assessments of
 0) the relative effectiveness of such processes,  procedures
 and: methods;. (2) the potential effects on transportation
 systems- and- on the provision of transportation services; and
 (3) environmental,. energy and-economic effects.   Information
 about programs for vehicle inspection and maintenance, control
 of vapor emissions from fuel transfer and storage  and from
 solvent operations, improved public transit, exclusive bus
 and carpool lanes and areawide carpool programs must be
 published by February 7, 1978.  Information on a  number of
 other programs including long-range transit improvement,
 central of on-street parking,. Construction of park-and-ride
 facilities, staggered work hours and road user charges
 must be published by August 7, 1978.

 Information documents covering vehicle inspection  and
 maintenance,, control of vapor emissions from fuel  transfer
 and. storage, improved public transit/exclusive  bus and
 carpool lanes and areawide carpool programs have been  drafted
 and sent to the Department of Transportation for review.
 Contracts to develop the additional information  documents
 to be available by August 7, 1978, are under development.

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       52
DOT PLANNING AND PROGRAMMING REGULATIONS   APPENDIX K
        WEDNESDAY, SEPTEMBER 17, 1975
        PART II:


         DEPARTMENT OF
        TRANSPORTATION

            Federal Highway
             Administration
         Urban Mass Transportation
             Administration
           TRANSPORTATION
            IMPROVEMENT
              PROGRAM

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                                                           53
 12976

          Title 23—Highways
CHAPTER I—FEDERAL HIGHWAY ADMIN-
  ISTRATION,  DEPARTMENT OF TRANS-
  PORTATION

PART  450—PLANNING ASSISTANCE AND
             STANDARDS
      Urban Transportation Planning

  The purpose of  this document  is to
issue  final regulations  implementing
certain provisions of title 23, U.S.C., and
the Urban  Mass Transportation Act of
1964,  as amended, 49 U.S.C. 1601, et seq.
(UMT Act), governing urban transpor-
tation  planning   under  the  Federal
Highway Administration and the  Ur-
ban  Mass  Transportation  Administra-
tion programs.
  In  the November 8, 1974,  edition of
the FEDERAL  REGISTER (39 FR 39660).
the  Federal   Highway  Administration
(FHWA) and the  Urban Mass Trans-
portation Administration (UMTA) pub-
lished a notice of  proposed rulemaking
(the "notice") to add a new Part  450,
Subpart A, to 23 CFR, Chapter I,  and
a new Part 613,  Subpart B, to 49 CFR,
Chapter VI.
  The public was invited to participate
in this  rulemaking through submission
of written  comments. Over  120  inter-
ested groups and  individuals provided
comments,  including  the House  Com-
mittee on Public Works and Transpor-
tation, the Senate Committee on  Pub-
lic Works,  the American  Public Transit
Association, the American  Association
of State Highway and Transportation
Officials, State departments of transpor-
tation, cities, and  a  number of metro-
politan  planning organizations. In ar-
riving at the linal  regulations set forth
below. FHWA and UMTA  have  given
consideration to all comments received
in response to the notirc  of proposed
rulemaking insofar as they  related to
matters within the scope of that notice.
Review  of the comments received indi-
cated the desirability of making changes
in the  regulations as  originally  pro-
posed. In view of the  interest expressed
in these regulations, except for editorial
revisions, those sections  of these final
regulations which have been revised or
were  the subject of major interest are
discussed in this commentary.
  Since the publication of the notice of
these  proposed rules.  Congress has en-
acted the National  Mass Transportation
Assistance Act of 1974 (Pub. L. 93-503.
88 Stat. 1565). which  amended the UMT
Act to add  among  other matters a new
formula grant program under which both
capital  and operating assistance  may
be provided, and to make the "3-C" plan-
ning process described in 23 U.S.C. 134
applicable to all UMTA-assisted capital
and operating projects. While the enact-
ment of Pub. L, 93-503 did require some
modification of these  regulations, these
changes were essentially technical in na-
ture, and, where made, do not represent
any overall substantive change  except
for the addition of the Transportation
Systems Management  (TSM) element
(discussed infra).
  In, response  to the notice, some con-
cern was expressed that the role of the
      RULES AND  REGULATIONS

Metropolitan   Planning   Organization
  and 1.50(f),
Chapter I of title 23 and Chapter VI of
title  49 of the Code of Federal Regula-
tions are  hereby amended by  adding a
new  Part 450,  Subpart A as  set forth
below.
  Effective date: These regulations  take
effect on October 17, 1975.
  Issued on: Septmber 11,1975.
           L. P.  LAMM,
               .Executive Director,
     Federal Highway Administration.

           ROBERT E. PATRICELLI,
        Urban Mass Transportation
                      Administrator.
                           FEDERAL REGISTER, VOL, 40, NO. 181—WEDNESDAY, SEPTEMBER  17, 1975

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                                                      54
   Subpart A of Part 450 Is adde > as set
 forth below:
   Subpart A—Urban Transportation Planning
 Sec.
 450.100  Purpose.
 450.102  Applicability.
 £50.104  Definitions.
 450.106  Metropolitan  Planning  Organiza-
          tion: designation.
 450.108  Metropolitan  Planning  Organiza-
          tion: agreements.
 450.110  Metropolitan  Planning  Organiza-
          tion: geographic scope.
 450.112  Metropolitan  Planning  Organiza-
          tion: responsibilities.
 450.114  Urban   transportation   planning
          process: planning work programs.
 450.116  Urban   transportation   planning
          process: transportation plan.
 450.118  Urban   transportation   planning
          process:  transportation  improve-
          ment program.
 450.120  Urban   transportation   planning
          process:  elements.
 450.122  Urban   transportation   planning
          process:  certification.

 Appendix: Advisory Information on Develop-
   ment  of Transportation  Systems Manage-
   ment  Elements.

   AUTHORITY: 23 U.S.C. 104(f)(3), 134, and
 316; Sections 3, 4(a),  and 5  of the Urban
 Mass Transportation Act of 1964, as amended,
 (UMT Act)  (49 U.S.C. 1602, 1603(a), and
 1604); and 49 CFR 1.48(b)  and 1.50(f).
     Subpart A-
-Urban Transportation
 Planning
 § 450.100   Purpose.
  The purpose of this subpart is to im-
 plement 23 U.S.C. 134, and Sections 3 (a)
 (2), 4(a), 5(g) (1), and 5(1) of the Urban
 Mass Transportation Act  of 1964, as
 amended, (49 U.S.C. 1602(a) (2), 1603 (a),
 and 1604(g)(l)  and (D), which require
 that each urbanized area, as a condition
 to the receipt of Federal capital or op-
 erating assistance, have a continuing, co-
 operative, and comprehensive transpor-
 tation planning process that results in
 plans and programs consistent with the
 comprehensively planned development of
 the urbanized area.
 § 450.102  Applienl.ilily.
  The provisions of this subpart are ap-
 plicable to the  transportation planning
 process In urbanized areas. Certification
 under this subpart shall be a prerequisite
for program approvals in urbanized areas
pursuant to 23 U.S.C. 105(d) and 134(a),
section 5(g) of the UMT Act (49 U.S.C.
 1604 (g}), and Subpart C of this part.
 §450.101  Definition*.
  (a)  Except  as  otherwise  provided,
terms denned in  23  U.S.C.  101 (a)  are
used in this subpart as so defined.
  (b)  As used in this subpart:
  "Governor" means the Governor of any
 one of the fifty  States, and includes the
 Mayor of the District of Columbia.
  "Metropolitan Planning Organization
 (MPOl " means  that organization desig-
 nated by the Governor as being respon-
 sible,  together with the State, for carry-
 ing out the provisions of 23 U.S.C.  134,
 as provided in 23 U.S.C. 104(f) (3),  and
 capable of meeting the requirements of
 sections  3(aM2)  and  (e)(l), 4(a),  and
 5
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                                                        55
42978

merits may be made to further combine
these documents with work program re-
quirements of other Federal sources of
physical  planning funds  (e.g., Depart-
ment of  Housing «,nd  Urban  Develop-
ment, Environmental Protection Agency,
and Department of the Interior).

§ 450.116  Urban  transportation  plan-
    ning process: transportation plan.
  (a) The urban  transportation  plan-
ning process  shall include the develop-
ment of  a transportation  plan consist-
ing of a transportation systems manage-
ment element and a long-range element.
The transportation  plan  shall be re-
viewed annually to confirm its validity
and its consistency with current trans-
portation and land use conditions.
  (b) The transportation systems man-
agement  element of the transportation
plan shall:
  (1) Provide for the short-range trans-
portation needs of the urbanized area by
making efficient use of existing  trans-
portation resources and providing for the
movement of people in an efficient man-
ner; and
  (2) Identify traffic engineering, pub-
lic  transportation,  regulatory, pricing,
management,  operational  and   other
improvements to  the  existing  urban
transportation  system  not  including
new transportation  facilities  or major
changes in existing facilities.
  (c)  The  long-range  element of  the
transportation plan shall:
  (1) Provide for the long-range trans-
portation needs of the  urbanized  area;
and
  (2) Identify new transportation poli-
cies and transportation facilities or ma-
jor changes in existing facilities  by lo-
cation and modes to  be  implemented.
  (d) The transportation plan shall be
consistent with the area's comprehensive
long-range land use  plan,  urban devel-
opment objectives, and the  area's overall
social, economic, environmental, system
performance  and  energy  conservation
goals and objectives.

§ 450.118  Urban  transportation  plan-
    ning  process:   transportation  im-
    provement program.
  (a) The urban  transportation  plan-
ning process  shall include development
of a  transportation "improvement  pro-
gram including an  annual element  as
prescribed in Subpart C of this part.
  (b) The program shall be a  staged
multiyear program  of  transportation
improvement projects  consistent  with
the transportation plan developed under
§450.116 of this subpart.
§450.120  Urban  transportation  plan-
    ning process: elements.

  (a)  The urban transportation  plan-
ning process shall:
  (1)  Provide for the consideration of
social, economic, and environmental ef-
fects,  in support of the  requirements of
23 U.S.C. 109(h), and sections 5(h) (2)
and 14 of the UMT Act (49 U.S.C. 1604
(h) (2) and 1610);
  (2)  Be  coordinated  with air quality
Planning   conducted  pursuant   to  42
U.S.C. 1857 (Clean Air Act);
      RULES AND REGULATIONS

   (3) Include provisions to ensure in-
 volvement of the public;
   (4) Be consistent with Title VI of the
 Civil Bights Act of 1964 and the Title VI
 assurance executed by each State under
 23 TJ.S.C. 324  and 29 U.S.C. 794, which
 ensure that no  person  shall  on  the
 grounds  of race, color,  sex,  national
 origin, or physical handicap be excluded
 from participation in, be denied benefits
 of, or be otherwise subjected to discrimi-
 nation under  any  program receiving
 Federal assistance from the Department
 of Transportation;
   (5)  Include special efforts to plan pub-
 lic mass transportation  facilities  and
 services  that can effectively be utilized
 by elderly  and  handicapped persons
 pursuant to section 16 of the UMT Act
 (49 U.S.C.  1612)  and section 165(b) of
 the Federal-Aid Highway  Act of  1973,
 as amended;
   (6)  Provide  for the consideration of
 energy conservation:
   (7)  Include  consideration  of existing
private mass transportation services; and
   (8)  Include the following technical ac-
 tivities to the degree appropriate for the
 size of the  metropolitan area  and the
 complexity  of  its transportation prob-
 lems:
   (1)  An analysis of existing conditions
 of  travel, transportation facilities,  and
 systems management;
   (ii)  An   evaluation  of   alternative
 transportation systems management im-
 provements  to make more efficient use
 of existing  transportation resources and
the development  of the transportation
systems  management  element of  the
 transportation plan.
   (iii> Projections of  urban area  eco-
 nomic, demographic, and land use activi-
ties consistent with urban development
 goals and the  development of potential
 transportation demands based on these
 levels of activity;
   (iv) Analysis of alternative transpor-
tation investments to  meet areawide
needs  for  new transportation  facilities
and the  development  of the  long-range
element of the transportation plan;'
   (v)  Refinement of the transportation
 plan  through  the conduct of  corridor,
transit technology, and staging studies;
and subarea, feasibility, location, legis-
lative, fiscal,  functional  classification,
 and institutional studies;
   (vi) Monitoring and reporting of urban
 development and  transportation indica-
tors and a regular program of reappraisal
of the transportation plan; and
   (vii)    Implementation   programing
which merges -the results of plan refine-
ment of the long-range element and the
improvements   recommended  in  the
transportation  systems management ele-
ment of the transportation plan to pro-
duce a transportation improvement pro-
gram as  specified in Subpart C of  this
part.
   (b) The  urban transportation plan-
ning process shall include preparation of
technical  reports  to assure documenta-
tion of the development, refinement, and
reappraisal  of the transportation plan.
 § 450.122  Urban  transportation  plan-
     ning process: certification.

   (a)  The Federal Highway and Urban
 Mass   Transportation   Administrators
 jointly will review and evaluate annually
 the transportation planning process in
 each urbanized area to determine if the
 process meets the requirements of this
 subpart.
   (b)  If, upon the review and revaluation
 conducted under  paragraph  (a) of this
 section, the Administrators jointly deter-
 mine that the  transportation  planning
 process in an urbanized area  meets or
 substantially meets the requirements of
 this subpart, they may take one of the
 following actions, as appropriate:
   (1)  Certify the transportation  plan-
 ning process; or
   (2)  Certify the transportation  plan-
 ning process subject to one of the follow-
 ing  conditions:
   (i) That  certain specified corrective
 actions be token; or
   (ii)  That the process  is  a basis for
 approval of only those categories of pro-
 grams or projects  that the Administra-
 tors may jointly detremine and that cer-
 tain specified corrective actions be taken.
   (c) The State and the MPO shall  be
 notified of the actions taken under para-
 graph  (b) of this section.
     A  certification under paragraph
 (b»  of this section will remain  in  effect
 until a new certification determination is
 made.
                APPENDIX
 ADVISORY INFORMATION ON DEVELOPMENT  OF
  TRANSPORTATION SYSTEMS MANAGEMENT ELE-
  MENTS UNDER UMTA AND FHWA JOINT REGU-
  LATIONS,  23 CFH PART 450, SUBPARTS A  AND C,
  AND 49 CFB PART B13, SUBPAHTS A AND B
  1.  Purpose. The preamble to  the National
 Mass Transportation Assistance Act of 1974
 states that  efficient,  economical and con-
 venient mass transportation Is a vital public
 service  essential to the health and welfare
 of urban areas. The resources provided by the
 Act are intended to assist  communities  in.
 preserving  and revitalizing their mass transit
 systems. An essential part of this goal is to
 Improve the efficiency of transit service—not
 only to achieve greater economies  of opera-
 tion, but also to help contribute to  the wider
 national objectives  of energy conservation,
 improved air quality,  and  increased  social
 and  environmental  amenity. The  1974 Act
 provides additional resources to enable  lo-
 calities to  improve  the efficiency of  transit
 operations.
  Similarly, Section 135 of title 23 declares it
 to be iti the  national  interest that there
 should be a continuing program within urban
 areas "designed to reduce traffic congestion
 and to facilitate the flow of traffic." Improve-
 ments which "directly facilitate and control
 traffic flow" are made eligible projects for
 Urban Extension and Urban System funds.
  Pursuant to the  planning requirements
 established  for urbanized areas in title  23
 and  the Urban Mass Transportation Act of
 19G4, as amended, UMTA and  FHWA have
 Jointly  issued regulations (23 CFR Part 450
 and 49 CFR Part 613) that require the urban
 transportation planning process to develop
 (1) a Plan containing a Transportation Sys-
 tem  Management (TSM) element, and (2)
 a  Transportation  Improvement  Program
 (TIP) for each urbanized area.
  The  purposes  of  these  supplementary
guidelines Is to Jointly provide additional def-
initions  and explanation ol the intent and
scope of the  Transportation Systems Man-
agement requirements specified in the Joint
                           FEDERAL REGISTER, VOL. 40, NO. 181—WEDNESDAY,  SEPTEMBER 17,  1975

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                                                              56
planning  regulations.  Each Administration
(l.e., UMTA and FHWA) will be using its own
regulations or policy mechanisms to specify
further conditions  In  order to meet  their
requirements for approval  of programs or
projects under their Jurisdiction.
  2. Introduction. Automobiles, public tran-
sit, taxis, pedestrians,  and bicycles should
be considered as elements of one single urban
transportation system. The objective of ur-
bator transportation system management is to
coordinate these Individual elements through
operating, regulatory and service policies so
as to achieve maximum efficiency and pro-
ductivity for the system as a whole.
  Controlling the flow of traffic, Influencing
the volume, pattern and mix of traffic, and
giving priority to buses and other high-occu-
paucy vehicles may be the single most -effec-
tive set of measures to improve the efficiency
and productivity of both mass transportation
service and the entire urban  transportation
system. However, other actions can also be
effective.  Mass  transit efficiency can be In-
creased through  internal  management ac-
tions, such as more flexible routing, dispatch-
ing and scheduling of transit vehicles. Urban
transportation  system efficiency can be in-
creased by the provision of para-transit serv-
ices, incentives for carpools, and greater off-
peak use of transportation facilities. Con-
flicts between pedestrians and vehicles can
be  reduced by developing  explicit and co-
ordinated policy to balance competing claims
•n  street space. Economic or other disincen-
tives can be introduced to discourage low-
occupancy auto use, reduce  traffic in con-
gested areas,  and  persuade  commuters  to
shift to ntess transit;  the quality of public
transit seivUse can be  Improved to compen-
sate fOr.any reductions in auto accessibility.
  8. Planning requirement. The UMTA and
PHWA do not intend  to.prescribe efficiency
standards or the particular measures that
an  urbanized area must adopt to meet the
requirement  to  develop  a Transportation
Systems Management  element. Formulation
of an  overall policy strategy, assessment of
candidate measures, and selection, program-
Ing  and  Implementation  of actions  are
clearly a local responsibility to  be carried
out as part of  continuing  transportation
planning  and  implementation  process. In
accordance with  the Joint regulations, the
Metropolitan Planning Organization (MPO)
In each urbanized area in cooperation with
the State and in cooperation  with publicly-
owied operators of mass transportation serv-
ice^ is responsible .for  the development and
periodic  updating   of the  Transportation
Systems Management element.
  The plan should set forth the underlying
goals and policy objectives and the strategy
selected to accomplish them. .Since the plan
will have official  status as a product of the
areawlde  planning process,  once  it  is en-
dorsed by the  MPO,  it  should  represent
agreement on  the  part  of those agencies
identified as  responsible  for carrying out
each  action.  The   programing for  imple-
mentation of Transportation Systems Man-
agement  projects In the annual element of
the Transportation Improvement  Program
represents a commitment for carrying out
each action.
  4. Actions to be considered. The following
major categories of action should be con-
sidered for Inclusion In the Transportation
Systems  Management  element.  While  the
feasibility of and need for individual actions
may  dufer with the'  slae of an  urbanized
area or 4b» extent of its congestion, all cate-
gories of actions should be considered. It Is
expected  that some actions in each category
Will be appropriate  for any urbanized area.
  m. Actions to ensure the efficient use of
 existing road space through
      RULES AND  REGULATIONS

  (l)  Traffic  operations  improvements to
manage and control the flow of motor ve-
hicles, such as:
  Channelization of traffic
  One-way streets
  Better slgnalizatlon and progesslve timing
    of traffic signals
  Computerized traffic control
  Metering access to freeways
  Reversible traffic lanes
  Other traffic engineering Improvements
  (2) Preferential treatment for transit and
other high-occupancy vehicles, such as:
  Reserved or preferential lanes  on freeways
    and city strrets
  Exclusive lanes to bypass congested points
  Exclusive lanes at toll plazas  with provi-
    sion for no-stop toll collection
  Conversion of selected 'downtown streets
    to exclusive bus use
  Exclusive access ramps to freeways
  Bus preemption of traffic signals
  Strict  enforcement  of  reserved  transit
    rlghts-of-way
  Special  turning  lanes  or exemption of
    buses from turning restrictions
  (3) Appropriate provision for pedestrians
and bicycles, such as:
  Bicycle paths and exclusive lanes
  Pedestrian malls and other means of sep-
    arating pedestrian and  vehicular traffic
  Secure  and  convenient storage  areas for
    bicycles
  •Other bicycle facilitation measures
  (4) Management and control of parking
through:  •
  Elimination of on-street parking, especially
    during peak periods
  Regulation of the  number and price of
    public and private parking spaces
  Favoring parking by short-term  users over
    all-day commuters
  Provision of fringe and transportation cor-
    ridor  parking to  facilitate  transfer to
    transit   and   other   high-occupancy
    vehicles
  Strict enforcement of parking restrictions
 • (5) Changes in work schedules, fare struc-
ture and  automobile tolls to reduce pfeak-
perlod travel and to encourage off-peak use
of transportation facilities and transit serv-
ices, such as:
  Staggered work hours
  Flexible work hours
  Reduced transit fares for off-peak transit
    users
  Increased  peak-hour commuter tolls on
    bridges and access routes to the city
  b. Actions  to reduce vehicle  use  in  con-
gested areas through:
  Encouragement  of carpooling and  other
    forms of ride sharing
  Diversion, exclusion and metering of auto-
    mobile access to specific areas
  Area licenses, parking surcharges and other
    forms of congestion pricing
  Establishment of car-free zones and clo-
    sure of selected streets to vehicular'traf-
    fic or to through traffic
  Restrictions  on  downtown  truck  delivery
    during peak hours
  c.  Actions  to  improve  transit  service,
through:
  Provision of  better collection,' distribution
    and Internal circulation services (includ-
    ing route-deviation and demand-respon-
    sive services) within low-density areas
  Greater flexibility  and responsiveness  in
    routing, scheduling. and dispatching of
    transit vehicles
  Provision  of  express bus  services  in coor-
    dination with  local collection and dis-
    tribution services
  Provision of  extensive park-and-rlde serv-
    ices from fringe and transportation cor-
    ridor parking areas
                                   42979

  Provision of shuttle transit services from
    CBD fringe parking areas to downtown
    activity centers
  Encouragement of jitneys and other flexi-
    ble paratranslt services and their Inte-
    gration In the metropolitan public trans-
    portation system.
  Simplified fare collection systems and poli-
    cies
  Provision of shelters  and other  passenger
    amenities
  Better passenger Information systems and
    services
  d. Actions to Increase internal transit man-
agement efficiency, such as:
  Improve marketing
  Developing cost accounting and other man-
    agement tools to improve declsionmak-
    ing
  Establishing  maintenance  policies • that
    assure greater equipment reliability
  Using  surveillance and  communications
    technology to develop real time monitor-
    ing and control capability
  5. Planning  assistance. Development of
the program Is an eligible activity for Inclu-
sion In the Unified Work Program for trans-
portation planning In  any urbanized area.
It can be assisted  with UMTA and FHWA
planning  funds.  In addition.  Management
Improvement  planning studies can be  In-
cluded  in the  Unified Work Program or
funded by special UMTA grants. Some local-
ities may wish to propose amendments to on-
going work  programs In order to accelerate
development of the Plan. Such requests will
be given priority consideration. It Is expected
that there will be relatively continuous work
activity relating to this requirement: some
feasibility studies  will take  longer  than
others,  some  actions  will  become  feasible
only after others  have been  defined, com-
pleted actions will have to be evaluated, and
the program must be  periodically updated
as the effects of other developments influence
the feasibility of various actions.
  6. Technical   Assistance.    Substantial
amounts  of technical material are available
concerning  possible strategies and  the  ac-
tions that should be considered for Inclusion
in  local programs. Further research and a
number  of demonstrations are  underway
which can be expected to contribute addi-
tional data to assist In evaluating the fea-
sibility and planning the Implementation of
some actions. The FHWA and UMTA Intend
to maintain surveillance over these develop-
ments and provide timely and useful docu-
mentation to assist localities in meeting this
requirement.
  7. Implementation Assistance. Implemen-
tation of actions In the local program may
be  eligible  for assistance with UMTA Sec-
tions 3 and 5 funds and Federal-aid highway
funds  (Urban  Systems, Urban Extension,
Primary and Interstate).
  [PR Doc.75-24896 Filed 9-l«-7&;B:45 am]
   PART 450—PLANNING ASSISTANCE
             AND STANDARDS
   Transportation Improvement Program
   The purpose of this document is to is-
 sue final regulations which  Implement
 certain provisions of title 23, U.S.C., and
 the Urban  Mass Transportation Act of
 1964,  as amended. 49 UJ3.C. 1801, et sea.
 (UMT Act), governing the planning and
 programing  of  urban  transportation
 improvement! under the Federal High-
 way  Administration  and  Urban Mass
 Transportation   Administration   pro-
 grams* *  •>  0
                                FEOEIAL MGfSTHt, V
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                                                         57
  'In consideration of the foregoing,  and
under  the authority of 23 U.S.C.  105,
134. and 135
and 5  of the UMT Act (49 U.S.C. 1602,
1603, 1604). and the delegation of au-
thority by the Secretary of Transporta-
tion at  49  CFR  l.48<6) 'urban systems
projects);
   <2>  23 U.S.C.  I03'ei<4)  'Interstate
substitution projects) ;
   '3> Sections 3 and 5 of the Urban Mass
Transportation Act of 1964, as amended
'UMT Act)  (49  U.S.C.  1602 and 1604-
UMTA capital and operating assistance
projects);
   <4> 23 U.S.C.  104'b><3> (projects on
urban extensions of primary and second-
ary systems i, except as provided in  this
subpart;
   •5) 23 U.S.C.  104<5> 'projects on
l.hc Interstate System', except as pro-
vided in this subpart.
    Projects under paragraphs ta)  (4)
and 151  of this  section, which are in-
rluded in the highway safety  improve-
ment program,  may be excluded from
the transportation improvement program
at the option of the State.

S 150.301  Definitions.

     Except as  otherwise  provided,
terms defined  in 23 U.S.C.  101(a»  are
used in this subpart as so defined.
  'b> As used herein:
  "Annual  element" means  a list of
transportation  improvement  projects
proposed for implementation during the
first program year.
  "Governor" means  the  Governor of
any one of the fifty States, and includes
the Mayor of the District of Columbia.
  "Highway  safety improvement pro-
gram" means a program prepared by the
State pursuant to 23 CFR, Part 655, Sub-
part E.
  "Interstate  substitution    projects"
means projects funded under  23 U.S.C.
103te) (4) (Withdrawal of Interstate seg-
ments and  substitution of nonhighway
public mass transportation projects).
  "Interstate System  projects"  means
projects funded under 23 U.S.C.  104
•,5>.
  "Metropolitan Planning Organization"
means that  organization designated by
the Governor as being responsible,  to-
gether with  the State,  for carrying  out
the provisions of 23 U.S.C. 134, as pro-
vided in 23 U.S.C. 104(f) (3), and capable
of meeting the requirements  of Sections
3  il>, and4(a),  and 5 
(1) and  <1> of the UMT Act (49 U.S.C.
1602  ia><2>   and  (eMP,  1603(a)  and
1604 (g) (1)  and (li. This organzation is
the forum for cooperative decisionmak-
ing by principal elected officials of gen-
eral purpose local government.
  "Transportation  Improvement  Pro-
gram" means a  staged multiyear pro-
gram of  transportation  improvements
including an annual element.

§ 450.306  Transportation  improvement
    program: general.
  (a) The transportation  improvement
program shall be developed and updated
annually  under  the  direction of  the
Metropolitan   Planning   Organization
(MPO) in cooperation with:
  (1) State and  local officials;
  (2) Regional and local transit opera-
tors;
  (3) Recipients authorized  under sec-
tion 5(b) (2) or (3) of the UMT Act (49
U.S.C. 1604(b))  (2) or  (3);  and
   ' 4) Other affected transportation and
regional  planning  and  implementing
agencies.
   (b) The transportation improvement
program  shall consist  of improvement
recommended from the  transportation
systems  management  and  long-range
elements of the transportation plan de-
veloped under S 450.116 of this part.
    Identify transportation impr6ve-
ments recommended for advancement
during the program period;
    indicate the area's priorities;
   'c> Group  improvements  of similar
urgency and anticipated staging into ap-
propriate  staging periods;
   < d) Include realistic estimates of total
costs and revenues  for  the.  program
period;  and
    Include a discussion of  how im-
provements recommended from the long-
range element and the  transportation
systems management element prepared
pursuant  to §450.116 of  this part  were
merged into the program.
§ '450.310  Annual clement:  project ini-
     li.ilioii.
  Federally funded projects shall be ini-
tiated for  inclusion in  the annual ele-
ment at all stages in the development of
the   transportation  improvement  for
which program action is proposed. These
projects shall be initiated as follows:
   (a) Proposed  urban  system highway
projects shall be initiated by local offi-
cials in whose jurisdiction the project is
located.
   (b) Proposed  urban system nonhigh-
way public mass transportation projects
and  Interstate substitution nonhighway
public mass transportation projects shall
be initiated by principal elected officials
of general purpose local governments in
consultation with local transit operating
officials or by local transit operating of-
ficials.
   (c) Proposed UMTA section 3 projects
(49 U.S.C. 1602)  shall be initiated by
recipients authorized under section 5(b)
(2> or (31 of the  UMT Act (49 U.S.C.
1604(bi (2) or (3)), by local transit op-
erating  officials, or by principal elected
officials of general purpose local govern-
ments in  cooperation with local transit
operating  officials.
   id) Proposed UMTA section 5 projects
(49 U.S.C. 1604)  shall be initiated by
recipients authorized under section 5(b)
(2> or (3>  of the UMT Act (49 U.S.C. 1604
(b) (2)  or (3)). Nothing  in this subsec-
tion  is intended to prohibit  or discour-
age the initiation by such recipients of
projects recommended  by local transit
operating officials or by principal elected
officials of general purpose local govern-
ments in  cooperation with local transit
operating officials.
   (e) Proposed urban extension and In-
terstate System  projects shall be ini-
tiated by  the State highway agency.
                           FEDERAL REGISTER, VOL. 40,  NO.  181—WEDNESDAY, SEPTEMBER  17, 1975

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                                                       58
 § 150.312  Animal rlcincul: roiitrnl.
  (a;  Except as provided in  S 450.302
  For  informational  purposes,  all
 nonfederally   funded  projects  recom-
 mended from the transportation systems
 management element.
  (b) With respect to each project under
 paragraph (a) of this section the annual
 element shall include:
  (1)  Sufficient descriptive material 'i.e.,
 type of work,  termini, length, etc.i  to
 identify the project;
  (2) Estimated  total cost  and  the
 amount of Federal funds proposed to be
 obligated during the program year;
  (3) Proposed source of Federal and
 non -Federal funds;  and
  (4)  Identification of the recipient and
 State and local agencies responsible for
 carrying out  the  project.
  (c)  Projects proposed for Federal sup-
 port that are not  considered by the State
 and MPO to  be of appropriate  scale for
 individual  inclusion in the annual ele-
 ment may be grouped by functional clas-
 sification,  geographic  area,  and  work
 type.
  (d» The annual element shall be rea-
 sonably consistent with the amount  of
 Federal funds  expected to be available
 to  the  area. Federal  funds  that have
 been allocated  to the  area pursuant  to
 23 U.S.C. 150 shall be Identified.
  (e)  The total Federal share of  proj-
 ects included in the annual element and
 proposed for funding under section 5  of
 the TTMT Act (49 U.S.C. 1604 1  may not
 exr ,u ; pportioned section 5 funds avail-
 able to the urbanized  area during the
 program year.
Aiiniiiil  clriiicnl :
§ 150.311
     tion.

  The annual element may be modified
at any time  consistent with the proce-
dures established in this subpart for its
development.

§ 450.316  Action rccpnrrd In llio Mrlro-
     polilau Planning Organization.

  (a) The transportation  improvement
program, including the annual element,
shall be endorsed annually by the MPO.
  (b) The  MPO shall submit the trans-
portation improvement program includ-
ing the annual element :
  (1) To the Governor and the Urban
Mass  Transportation   Administrator;
and
  (2> Through the Stale to the Federal
Highway Administrator.

§ 150. 3 1 3!  Srlwliou of pruji-rl- for im-
  (a> The projects proposed to be im-
plemented with Federal assistance under
sections 3 and 5 of the UMT Act  (49
U.S.C. 1602 and 1604> shall be those con-
tained in  the  annual  element of the
transportation  improvement   program
submitted by the MPO to the Urban Mass
Transportation Administrator.
     RULES AND  REGULATIONS

   Upon receipt  of  the  transporta-
tion improvement program, the State
shall include in the statewide program
of projects required under 23 U.S.C. 105:
  (1) Those  projects drawn from the
annual element and  proposed to be im-
plemented with Federal assistance under
23 U.S.C. 104(b)(6)  (Federal-aid urban
System) and 103(e) (4;  (Withdrawal of
Interstate segments  and substitution of
public mass transportation projects), in
which it concurs; provided, however, that
in any case  where the State does not
concur in  a nonhighway public  mass
transportation project, a statement de-
scribing the reasons  for the  nonconcur-
rence shall accompany  the statewide
program of projects;  and
  (2) Those  projects drawn from the
annual element and  proposed to be im-
plemented with Federal assistance under
23 U.S.C.  104(b)(3)  (Extensions  of the
Federal-aid primary and secondary sys-
tems in urbanized areas)  and 23 U.S.C.
104 Upon the  determination  by the
Federal Highway  Administrator and the
Urban Mass Transportation Administra-
tor that the transportation improvement
program  or portion thereof is in con-
formance with this subpart and that the
area is under planning certification, pro-
grams of projects  selected for implemen-
tation  under § 450.318 of this  subpart,
will  be  considered  for approval  as
follows:
  (1 > Federal-aid urban system projects
included  in the  statewide  program of
                                •12083

projects under 23 U.S.C. 105 will be ap-
proved by:
  (i)  The Federal Highway Administra-
tor with respect to highway projects;
  (ii) The Urban Mass Transportation
Administrator with respect to nonhigh-
way public mass transportation projects;
and
  (iii> The  Federal Highway Adminis-
trator and the Urban Mass Transporta-.
tion Administrator jointly  in any case
where the statewide program of projects
submitted pursuant to 23 U.S.C. 105 does
not include all Federal-aid urban sys-
tem nonhighway public mass transporta-
tion projects  contained in the annual
element.
  (2) Interstate substitution nonhigh-
way public mass transportation projects
included  in the statewide  program of
projects under 23 U.S.C. 105 will be ap-
proved by the Urban Mass  Transporta-
tion Administrator.
  (3) Projects  proposed  to be  imple-
mented under sections 3 and 5  of the
UMT Act (49  U.S.C. 1602 and 1604) in-
cluded in  the  annual  element  of the
transportation  improvement program
will be approved by the Urban Mass
Transportation Administrator after con-
sidering any comments received from the
Governor within 30 days of the submittal
required  by  § 450.316(b) (1)  of  this
subpart.
  (4) Federal-aid urban  extension and
Interstate projects included in the state-
wide program of projects under 23 U.S.C.
105  will  be  approved  by  the  Federal
Highway Administrator.
  (b) Approvals by the Federal High-
way Administrator or joint approvals by
the Federal Highway Administrator and
Urban Mass Transportation Administra-
tor will be in accordance with the provi-
sions of this subpart and with 23  CFK
630, Subpart A. Approvals granted under
this section will constitute:
  (1) The  approval  required under 23
U.S.C. 105; and
  (2) A finding that the progi'am Is based
on a Continuing, comprehensive planning
process carried  on cooperatively by the
States and local communities In accord-
ance with the provisions of 23 U.S.C. 134.
  (c> Approvals by the  Urban Mass
Transportation Administrator will be in
accordance with the provisions of this
subpart and with other applicable provi-
sions of 49 CFB 613, Subpart B. These
approvals will constitute:
  (1) The approval required under sec-
tion 5tg> (2) of the UMT Act (49 U.S.C.
1604(g)(2)):
  (2) A  finding that the projects are
based on a  continuing  comprehensive
transportation planning process carried
on  in accordance with the provisions of
sections 3 (2) or 5(g> (1) of the UMT
Act (49  U.S.C. 1602(a)(2>  or  1604
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                                                       59
42984

        Title 49—Transportation
CHAPTER VI—URBAN  MASS TRANSPOR-
  TATION   ADMINISTRATION,  DEPART-
  MENT OF TRANSPORTATION
  PART 613—PUNNING ASSISTANCE
           AND STANDARDS
      Urban Transportation Planning
  The purpose of this document is to is-
sue final regulations implementing cer1
tain provisions of Title 23, United States
Code, and the Urban  Mass Transporta-
tion Act of 1964, as amended (49 U.S.C.
1601, et seq.), which govern urban trans-
portation  planning under  the Federal
Highway Administration (FHWA) and
Urban Mass Transportation Administra-
tion (UMTA) programs.
  In the November 8, 1974, edition of
the FEDERAL REGISTER (39  FR  39660),
FHWA and UMTA published a notice of
proposed rulemaking to add a new Part
450, Subpart A, to 23 CFR, Chapter I,
and a new Part 613, Subpart B, to 49
CFR, Chapter VI.
  The final regulations are published in
full under 23 CFR, Part 450, Subpart A.
rhe purpose of the regulations published
below is to  incorporate 23 CFR, Part 450,
Bubpart A, into 49 CFR,  Part 613, Sub-
part A. The original notice  indicated
that the Urban Transportation Plan-
ning  regulations  under  23 CFR, Part
450, Subpart A, were to be  incorporated
into 49 CFR, Part 613,  Subpart B. For
reasons of  continuity, these regulations
are published as being incorporated into
49 CFR, Part 613, Subpart A rather than
Subpart B.
  The preamble to  the  joint FHWA/
UMTA regulations, Title 23, CFR Part
450, Subpart A, published at page 42976 of
tills edition of the FEDERAL REGISTER and
to be incorporated by reference in 49
CFR, Part  613, Subpart A,  is hereby  in-
corporated  as the preamble for the fol-
lowing regulations.
  Pursuant to Sections 3, 4(a). and 5 of
the Urban  Mass Transportation Act of
1964,  as amended  (49 U.S.C. 1602, 1603
(a) and 1604), and 23 U.S.C. 104(f) (3),
134, and 315, and the delegation of au-
thority by the Secretary at 49 CFR 1.48
(b) and 1.50 (f), Chapter VI o^Title 49
of the Code of Federal  Regulations is
amended by adding a new Subchapter B,
Part 613, Subpart A, as set forth below.
  Effective  date: These regulations take
effect on October 17,1975.
  Issued on: September 11,1975.
           L. P. LAMM,
               Executive Director,
     Federal Highway Administration.
           ROBERT E. PATRICELLI,
        Urban Mass Transportation
                     Administrator.

  Subpart A of Part 613  is added as  set
forth below:
   Subpart A—Urban Transportation Planning
Sec.
613.100 Urban transportation planning.
  AUTHORITY: 23 IT.S.C.  104 (f) (3), 184, and
315; 55 3. 4(a), and 5 of  the Urban Man
Transportation Act of 1964, as amended  (49
      RULES AND  REGULATIONS

U.S.C.  1602,  1603(a), and 1604);  49 CPR
S§ l.48(b) and 1.50(f).

    Subpart A—Urban Transportation
               Planning
§ 613.100
     ning.
Urban transportation  pltin-
  The  urban transportation planning
regulations implementing 23 U.S.C.  134
and sections 3,4(a), and 5(g) (1) and (Z)
of the Urban Mass Transportation Act
of  1964, as amended (49 U.S.C. 1602,
1603(a) and 1604(g)(l) and (Z)), which
require  comprehensive   planning  of
transportation improvements which are
set forth in 23 CFR Part 450, Subpart A,
are incorporated into this subpart.
  [PR Doc.75-24698 Piled 9-16-75:8:45 am]
   PART 613—PLANNING 'ASSISTANCE
           AND STANDARDS
   Transportation Improvement Program
  The purpose of this document is to issue
final regulations which implement  cer-
tain provisions of title 23, United States
Code, and the Urban  Mass Transporta-
tion Act of  1964, as amended, 49 U.S.C.
1601, et seq., governing the planning and
programing, of urban transportation im-
provements  under  the Federal Highway
Administration  (FHWA)  and   Urban
Mass   Transportation   Administration
(UMTA) programs.
  In the November 8, 1974, edition of the
FEDERAL REGISTER (39 FR 39665), FHWA
and UMTA  published a notice  of pro-
posed rulemaking to add a new Part 450,
Subpart C, to 23 CFR, Chapter I, and a
new Part 613, Subpart A, to 49 CFR,
Chapter VI.
 , The final  regulations are published in
full under 23 CFR,  Part 450, Subpart C.
The purpose of these  regulations, pub-
lished below, is to  incorporate 23 CFR,
Part 450, Subpart  C, into 49 CFR, Part
613, Subpart B, and to set forth certain
additional requirements applicable to the
UMTA administered program. The origi-
nal notice indicated that the Transpor-
tation Improvement Program regulations
under 23 CFR, Part 450, Subpart C, were
to be incorporated into 49 CFR, Part 613,
Subpart  A.  For reasons of continuity,
these  regulations are published as being
incorporated into 49 CFR, Part 613, Sub-
part B rather than Subpart A.
   The preamble  to the joint FHWA-
UMTA regulations, Title 23 CFR, Part
450, Subpart C, published at page 42976
of this edition of the  FEDERAL REGISTER,
and to be incorporated by reference in
49  CFR Part 613,  Subpart B, is hereby
incorporated as the preamble for the fol-
lowing regulations.
   Pursuant  to sections 3, 4,
and 135(b), and the  delegation of au-
thority by the Secretary at 49 CFR 1.48
(b) and 1.50(f). Chapter VI of Title 49
of  the Code of Federal Regulations,  is
hereby amended by adding a new Sub-
chapter B, Part 613,  Subpart B, as set
forth below.
   Effective date: These regulations take
 effect on October 17, 1975.

   Issued on: September 11, 1975.

            ROBERT E. PATRICELLI,
                       Urban Mass
        Transportation Administrator.

                      L. P. LAMM,
                 Executive Director,
      Federal Highway Administration.

   Subpart B of Part 613 is added as set
 forth below:
    Subpart B—Transportation Improvement
                Program
 Sep.
 613.200  Transportation  Improvement  Pro-
          gram.
 613.202  Additional criteria for urban  mass
          transportation  Administrator's
          approvals under 23 CFR 450.320.
  AUTHORITY:  23  U.S.C.  105. 134(a), and
 135(b);  g§ 3. 4(a),  and 5 of the Urban Mass
 Transportation Act of 1964, as amended (49
 U.S.C. 1602, 1603(a), and 1604); and  H 49
 CFR 1.48(b) and 1.50(f).

 Subpart B—Transportation Improvement
               Program
 §613.200  Transportation  Improvement
     I'rogru in.
  The transportation improvement  pro-
gram regulations  establishing guidelines
for the  development, content, and proc-
essing of a cooperatively developed trans-
 portation improvement program in ur-
 banized areas and also prescribing guide-
 lines for the  selection, by implementing
 agencies, of annual programs of projects
 to be advanced in urbanized areas which
 are set forth in 23 CFR Part 450, Subpari
 C. are incorporated into this subpart.

 §613.202  Additional criteria for urban
     mass transportation Administrator's
     approvals under 23 CFK 450.320.
  uu This section establishes certain ad-
ditional criteria to be considered by the
Urban Mass Transportation'Administra-
tor in his program approval pursuant to
23 CFR 450.320(a)(3>  for  all  projects
proposed for  implementation with Fed-
eral assistance under sections 3  and 5 of
the Urban Mass  Transportation Act of
 1964, as amended (23 U.S.C. 1602 and
 1604), in urbanized areas having a pop-
ulation of 200.000 or more.
   (b) After March 30,  1976, the Urban
 Mass Transportation Administrator will
 grant  program   approval  for  projects
 under paragraph  (a) of this section only
 alter he has determined that:
   (i) The transportation plan developed
 pursuant to 23 CFR 450.116 contains a
 Transportation   System   Management
 i.TSM)  clement; and
    After March 30,  1977, the Urban
 Mass Transportation Administrator will
 grant program  approval  for  projects
 under paragraph  (a) of this section only
 after he has determined that reasonable
 progress has been demonstrated in im-
 plementing  previously programed proj-
 ects.
  [FR Doc.75  24699 Filed 9 I6-75;8:45  am]
                            FEDERAL RMISTER, VOL 40, NO. 181—WEDNESDAY, SEPTEMBER  17, 1975

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                            REF  II-2



                     MEMORANDUM OF UNDERSTANDING

                                BETWEEN

                  THE DEPARTMENT OF TRANSPORTATION

                                  AND

                 THE ENVIRONMENTAL PROTECTION  AGENCY

                              REGARDING

     THE INTEGRATION OF TRANSPORTATION AND AIR QUALITY  PLANNING


I.  Introduction

The Clean Air Act Amendments of 1977 were signed  into law  by  the  President
on August 7, 1977.  These Amendments require state  and  local  governments
to develop for all areas where national  ambient air quality standards  have
not been attained, revisions to state implementation  plans  (SIPs).  The
revised SIPs must be submitted by the state to the  Environmental  Protection
Agency (EPA) by January 1, 1979.  These  revised plans must  provide  for
attainment of the national ambient air quality standards by 1982  or, in
the case of areas with severe photochemical oxidant or  carbon monoxide
problems, not later than 1987.  The revised plans must  also provide for
incremental reductions in emissions ("reasonable  further progress") between
the time the plans are submitted and the attainment deadline.

In many major urbanized areas of the country the  revised SIPs will  require
transportation controls, i.e. strategies designed to  reduce emissions  from
transportation-related sources by means  of structural and  operational  changes
in the transportation system.  A mechanism is  required  that will  enable
state and local governments to: (1)'develop a  wide  range of alternative
transportation control strategies, (2) analyze the  air  quality and  other
impacts of the strategies, and (3) select among the alternatives  in a
timely and informed manner.

Federal transportation planning requirements in urbanized  areas are imple-
mented by the Department of Transportation (DOT)  through a joint  delegation
of authority to the Federal Highway Administration  (FHWA)  and the Urban
Mass Transportation Administration (UMTA).  The FHWA and UMTA provide  funds
to states and local governments to plan, develop, and improve transportation
systems and services.  In urbanized areas improvements  are implemented
according to a continuing, comprehensive, and cooperative  transportation
planning process carried out pursuant to FHWA/UMTA joint regulations.   It

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is in this context that "DOT"  is  utilized  in  this, document.   In  order  to
effectively achieve the objectives  of  the  1977 Clean Air Act  Amendments,
the DOT and Environmental  Protection Agency  (EPA) agree that  the trans-
portation-related air quality  planning requirements of EPA will  be  integrated
with the transportation planning  process administered by the  DOT.   Closer
integration of the planning  requirements of  DOT and EPA will  ensure the
timely consideration of air  quality concerns  and will reduce  potentially
duplicative, overlapping,  and  inconsistent activities at the  state  and
local level.  DOT administers  other planning  programs through other
administrations (e.g. FAA  and  FRA)  which have lesser impact on air
quality but may be subject to.future discussion.

II.   Purpose

This Memorandum of Understanding, developed  pursuant to the President's
request, is designed (1) to  establish  certain principles which DOT  and EPA
agree to follow in the preparation  of  more detailed regulations  and
administrative procedures  required  to  achieve the objective of integrating
the air quality and transportation  planning  processes; (2) to identify
specific areas of agreement  with  regard to the joint administration of the
air quality aspects of the planning process.

III.  Principles that Mill Guide  the Integration of the Air Quality
      and Transportation Planning Processes

 A.   The reduction of air  pollution is an  important national  goal and
     must be among the highest priorities  of  the transportation  planning
     process in areas not  meeting primary  Air Quality Standards.  However,
     the transportation planning  process must also consider other national
     and local objectives  such as mobility,  safety, energy conservation,
     urban economic development,  full  employment and orderly  metropolitan
     growth.

 B.   It is the affirmative responsibility  of  federal, state and  local
     agencies involved in  funding or conducting transportation planning
     and implementation to ensure that evaluation of an adequate range
     of alternative transportation  control strategies is conducted  in
     order to furnish local, state  and federal officials with an adequate
     basis on which to reach informed  decisions.

 C.   Any transportation planning  activites conducted pursuant to this
     agreement must continue to provide for  an adequate process  of
     consultations with and  involvement of the general purpose local
     government, responsible state  agencies  and the public as called for
     in the joint UMTA/FHWA  Urban Transportation Planning regulations.

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 D.   It Is the objective of the activities undertaken pursuant  to  this
     agreement to contribute to the maximum extent feasible,  in com-
     bination, with other emission reduction measures, to  a reduction of
     emissions necessary to meet the prescribed air quality standards.

IV.   Joint Administration of the Air Quality Aspects of the
     Urban Transportation Planning Process

     The Department of Transportation and Environmental  Protection
Agency agree to modify existing procedures concerning the  administration
of the urban transportation and air quality planning processes  in
nonattainment areas as follows:

     1.  DOT and EPA regional/division offices will have the  opportunity
for joint review of and concurrence in the Unified Work Program (UWP)
required pursuant to paragraph 450.114 of the Joint Planning  Regulations
(23 CFR 450), to ensure that adequate air quality planning tasks are
included in the planning programs.  Any disagreements at the  regional
level shall be referred to the DOT Secretary for resolution.  Before
making his final decision on the UWP, the Secretary will consult with
the EPA Administrator and will, notify EPA of the disposition  of its
comments, with appropriate supporting materials.  In addition,  where an
MPO has failed, without adequate reason to carry out the analysis  or
other activities committed in its Unified Work Program, DOT will prescribe
conditions which will require specified remedial actions to be  taken in
order to correct the identified failure in the Unified Work Program.
DOT and EPA will develop in the near future a document identifying
appropriate categories of remedial actions.

     2.  DOT  and EPA regional/division offices will have the  opportunity
for joint review of transportation plans (including TSM elements)  in
nonattainment areas required pursuant to paragraph 450.116 of the
Joint  Plannning Regulations, to ensure that air quality considerations
are adequately addressed.  DOT and EPA will consult with the  planning
agency on how air quality related planning deficiencies will  be
corrected.  DOT will also explicitly consider EPA comments in taking
subsequent actions on program approvals and will notify EPA of  the
disposition of its comments, with appropriate supporting materials.

     3.  DOT  and EPA regional/division offices will have the  opportunity
for joint review in connection with the annual planning certification
required pursuant to paragraph 450.122 of the Joint Planning  Regulations,
on the adequacy of the planning process to address air quality  considerations,
DOT and EPA will consult with the planning agency on how air  quality
related planning deficiencies will be corrected.  DOT will also explicitly
consider EPA  comments in making any certification decisions and will
notify EPA of the disposition of its comments, with appropriate
supporting material.

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                                   4


     4.  DOT and EPA regional/division offices  will  have the opportunity
for joint review of the Transportation Improvement Program (TIP) and its
annual element required pursuant to paragraph 450.118 of the Joint
Planning Regulations for consistency with the air quality elements of
the transportation plan and/or the SIP.   DOT will explicitly consider
EPA's comments in program approvals, and will notify EPA of its disposition
of the comments.   If EPA disagrees with the disposition of its comments,
the procedures for resolution set forth in Addendum 1 to this memorandum
will be followed.

     5.  DOT and EPA regional/division offices  will  have the opportunity
for joint review of the revised SIPs, for compliance with the objectives
of statutes administered by DOT TeT?., Title 23 USC and the Urban Mass
Transportation Act) to provide for mobility and for safe and efficient
transportation.  EPA will explicitly consider DOT comments in approving
or disapproving SIP revisions, and will  notify DOT of its disposition of
the comments, with appropriate supporting materials.  If DOT disagrees
with the disposition of its comments, the procedures for resolution set
forth in Addendum 2 to this memorandum will be followed.

     6.  DOT and EPA agree to work toward greater coordination in the
administration of their respective grants for local  planning activities
by including these grants in the UWP, to ensure that such grants support
effectively the related objectives of both agencies while avoiding
duplication and overlapping planning activities.

DOT and EPA will take appropriate steps to alter their existing internal
procedures and to issue a joint appendix to the existing transportation
planning regulations to implement the above understandings.

     DOT and EPA agree to consult one another in the development of
criteria and procedures required by Section 176 of the Clean Air Act,
including insuring that all major capital improvement projects are
consistent with the SIP.
Signed in Washington, D.C. this  14th  day of      June       1973.


Department of Transportation                Environmental Protection Agency
                                                                 Y

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                         ADDENDUM 1
If the EPA Regional  Administrator disagrees with the disposition
of his comments by DOT, he will so notify the DOT Regional/Division
Administrator within seven days.  In such a case, the DOT Regional/
Division Administrator will not approve the element or elements of
the TIP in disagreement until so advised by headquarters.

Within 30 days after the EPA Regional Administrator notifies DOT
of his disagreement, the EPA Administrator will notify the Secretary
of Transportation if the EPA Administrator disagrees with the DOT
field staff disposition of EPA comments, and the reason for the EPA
Administrator's disagreement.

If such notification is received within 30 days, the Secretary of
Transportation will carefully  consider the EPA Administrator's views
and  in the  event of disagreement will notify the EPA Administrator
of the disposition of  his  commentsj  with appropriate supporting
materials before making his  decision.

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                         ADDENDUM  2


If the DOT Regional/Division Administrator  disagrees  with  the
disposition of his comments by EPA,  he  will  so  notify the  EPA
Regional Administrator within seven  days.   In  such  a  case,  the
EPA Regional Administrator will  not  approve the SIP until  so
advised by headquarters.

Within 30 days after the DOT Regional/Division  Administrator
notifies EPA of his disagreement,  the Secretary of  Transportation
will notify the EPA Administrator  if the Secretary  of Transportation
disagrees with the EPA field staff disposition  of DOT comments,  and
the reason for the Secretary's disagreement.

If such notification is received within 30 days, the  EPA Administrator
will carefully consider the Secretary of Transportation's views  and
in the  event of disagreement will  notify the Secretary of the
disposition of his comments, with appropriate supporting materials
before making his decision.

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                            REF
       UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                       ANN ARBOR, MICHIGAN  48105
                       JUL 17 «978                    AIR AND WATER PROGRAMS
SUBJECT:  Inspection/Maintenance Policy

FROM:     David G. Hawkins, Assistant Administrator
          for Air and Waste Management

MEMO TO:  Regional Administrators, Regions I - X
     As you know, the Clean Air Act Amendments of 1977 set forth
specific requirements for the implementation of motor vehicle
inspection/maintenance  (I/M) programs.  Attached is a policy paper
indicating what EPA will consider a minimally acceptable program
wherever I/M is required by the Act.  It should aid your efforts to
provide for adequate I/M submissions for the State Implementation
Plan (SIP) revisions of January 1, 1979.  Please continue to contact
me if problems in I/M implementation develop.

cc:  Air and Hazardous Materials Division
      Directors, Regions I, III - X
     Environmental Programs Division Director,
       Region II
     Air Programs Branch Chiefs, Regions I - X

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                                        ref III-l


           Policy for the Development and Implementation of
                    Inspection/Maintenance Programs


     The Clean Air Act Amendments of 1977 provide new direction for the
development and implementation of motor vehicle inspection/maintenance
(I/M) programs.  If states are not able to demonstrate attainment of the
standards for oxidant (Ox) or carbon monoxide (CO) by December 31, 1982,
a specific schedule for the implementation of I/M must be included in
the State Implementation Plan (SIP) revisions of January 1, 1979 for the
plan to meet the requirements, of Section 172.   The general requirements
for the I/M programs are set out in a February 24, 1978 memorandum from
the EPA Administrator to the Regional Administrators (reprinted in the
Federal Register on May 19, 1978, 43 F.R.  21673).  The requirements, for
these programs, are explained in more detail below.

A.  I/M SIP Revision Development and the January 1, 1979. Submittal

     In producing an I/M SIP revision, the states should provide for:

          1.  an analysis of the benefits and costs of the program;

          2.  a public information effort;

          3.  a legislative proposal; and

          4.  a schedule for I/M implementation.

A copy of suggested steps for development of the SIP revision is attached
(Attachment 1).  Before the January 1, 1979 submittal, the SIP revision
must be adopted by the state air pollution control board or agency head as
appropriate.  As a part of the SIP revision submittal itself, there must
be a commitment by the Governor to implement the I/M program according to
the schedule submitted.*
*Sections 172(b)(7) and (10) provide that the plan revisions required
for nonattainment areas shall —

     (7)  identify and commit the financial and manpower resources
necessary to carry out the plan provisions required by this subsection;
[Emphasis added]

and shall —

     (10)  include written evidence that the state, the general purpose
local government or governments, or a regional agency designated by general
purpose local governments for such purpose, have adopted by statute, regu-
lation, ordinance, or other legally enforceable document, the necessary
requirements and schedule and timetables for compliance, and are committed
to implement and enforce the appropriate elements of the plan;  [Emphasis
added]

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                                          REF III-l

These plan elements should be prepared in accordance with  the guidance
on pages 186-188 of the Compilation of Presentations prepared by EPA's
Office of Air Quality Planning and Standards  (OAQPS) for the "Workshops
on Requirements for Nonattainment Area Plans" February -March 1978
(pages 218-220 in the April 1978 edition).


B.  The I/M Implementation Schedule

     The specific items listed below must be  included as a part of the
States' I/M implementation schedules with specified dates  for implementation
of each item.  The stringency planned for the program and  other factors
affecting the potential for emission reductions should also be indicated.
Additional items if necessary because of local factors may be required by
USEPA Regional Offices.

          1.  Initiation  (or continuation)  of public information
              program  including publicizing the I/M program in the
              media, meeting and speaking with affected interest
              groups,  etc.

          2.  Preparation of a draft legislative package and
              submittal of legislation package to legislature
              if additional legislative authority is needed.

          3.  Certification of adequate legal authority by approp-
              riate state official.

          4.  Initial  notification of garages explaining program
              and  schedule of implementation.*

          5.  Development and issuance of RFPs.*

          6.  Award  to contractor(s)-*

          7.  Initiation  of  construction of facilities.*

          8.  Completion  of  construction of facilities.*

          9.  Adoption of procedures and guidelines  for testing
              and  quality control  including emission analyzer
              requirements  (and  licensing requirements for private
              garages, if applicable*).

          10.  Notification  of  and  explanation to  garages  of  actions
               in step  9.*

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                                   3       REF III-l

         11.   Completion of equipment purchase and delivery of
              equipment.

         12.   Development and adoption of cutpoints.

         13.   Initiation of hiring and training of inspectors or
              licensing of garages.*

         14.   Initiation of introductory program (voluntary main-
              tenance with either voluntary or mandatory inspection)
              if not previously initiated.

         15.   Initiation of mechanics training and/or information
              program.

         16.   Initiation of mandatory inspection.

         17.   Initiation of mandatory repair for failed vehicles.

     If certification of adequate legal authority occurs after January 1979,
the States may modify previous commitments to implement and enforce the elements
of the schedule to conform to the legal authority.**   These modifications will be
approved by the EPA Regional Offices and must be consistent with the Administra-
tor's February 24, 1978, policy memorandum.  The documents should be submitted
to the EPA Regional Offices for inclusion in the SIP  revisions already submitted
by January 1, 1979.  Any necessary adjustments to the schedule may be made at
this time but must be approved by the EPA Regional Offices.

C.  Authority to Implement I/M

     Normally, adequate legal authority to implement  a SIP revision must exist
for a revision to be approved.  Where a legislature has had adequate
opportunity to adopt enabling legislation before January 1, 1979, the
Regional Administrator should require certification that adequate legal
authority exists for I/M implementation by January 1, 1979-  However,
for many states there will be insufficient opportunity to obtain adequate
legal authority before their legislatures meet in early 1979.  Therefore,
a certification of legal authority for the implementation of I/M in
these states must be made no later than June 30, 1979.  An extension to
July 1, 1980, is possible, but only when the state can demonstrate that
(a) there was insufficient opportunity to conduct necessary technical
analyses and/or (b) the legislature has had no opportunity to consider
any necessary enabling legislation for inspection/ maintenance between
enactment of the 1977 Amendments to the Act and June 30, 1979.  Certifi-
cation of adequate legal authority, or other evidence that legal authority
has been adopted, must be submitted to the EPA Regional Offices to be
included in the SIP revision already submitted.  Failure to submit evidence
of legal authority by the appropriate deadline will constitute a failure
to submit an essential element of the SIP, under Sections 110(a)(2)(I)
and 176(a) of the Act.


*Dependent on type of system chosen (state-run centralized, contractor
centralized,  or decentralized).

**See footnote on page 1.

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                                          REF  III-l
     Prior to the respective deadlines for initiating mandatory inspection
and mandatory repair of failed vehicles, the state, local government, or
regional agency should adopt whatever legally enforceable requirements
are necessary to ensure that vehicles are not used unless they comply
with the inspection/maintenance requirements.  Written evidence of
adoption of these requirements should be submitted to the EPA Regional
Offices, to be included in the SIP revision already submitted by January
1, 1979-*

D.   I/M Implementation Deadlines

     Implementation of I/M "as expeditiously as practicable" shall be
defined as implementation of mandatory repair for failed vehicles no
later than two and a half years after passage of needed legislation or
certification of adequate legal authority for new centralized systems
and one and a half years after legislation or certification for decen-
tralized systems or for centralized systems which are adding emission
inspections to safety inspections.  For the normal legislation deadline
of June 30, 1979, new centralized programs must start by December 31,
1981, and all others must start by December 31, 1980.  For the case of
the latest possible legislation date, July 1, 1980, this means that a
new centralized program must start by December 31, 1982, while all other
programs must start by December 31, 1981.  Where I/M can be implemented
more expeditiously, it must be.  Each state implementation schedule must
be looked at individually to determine if it is as expeditious as practi-
cable.  Implementation dates ordered by courts, if earlier than these
dates, take precedence.

E.   Geographic Coverage.

     I/M should focus on metropolitan areas and should include the entire
urbanized area and adjacent fringe areas of development.  Boundaries of the
area affected may be adjusted if an equivalent emission reduction is achieved.
For urbanized areas of 200,000 population or greater which need I/M to obtain
an extension of the 1982 attainment date, full mandatory I/M must be implemented
by the deadlines indicated above.  Statewide programs are encouraged, especially
for those states which are small and highly urbanized.

     It should be emphasized that all nonattainment areas must have SIPs
which are adequate to attain and maintain the National Ambient Air
Quality Standards (NAAQS) by 1982 or by no later than 1987 should an
acceptable nonattainment demonstration be made.  For areas under 200,000,
EPA will not at this time automatically require I/M schedules in 1979 as a
condition for SIP approval or an extension.  However, areas under 200,000
still have to attain and maintain NAAQS as expeditiously as practicable,
and I/M is encouraged as a means of helping to provide for an adequate
SIP.  EPA will review the need for I/M in areas under 200,000 after the
1979 SIP revisions are submitted, and will consider additional require-
ments at that time.
*See footnote on page 1.

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                                  -5-               REF III-l

 F.   Emission Reductions  Required  for  I/M

      I/M programs must produce  at least  a  25  percent  reduction in light
 duty vehicle (LDV)  exhaust  emissions  of  hydrocarbons  and  a  25  percent
 reduction in LDV emissions  of carbon  monoxide by December 31,  1987,
 compared to  what emissions  would  be without I/M on  the basis of the  most
 recent motor vehicle  emission factors.   However, the  choices of stringency
 factor to be used and other actions affecting the potential  for emission
 reduction should be made by the states.  States should of course be
 encouraged to develop programs  which  produce  more emission reduction
 when possible.  The final revision to Appendix N (40  C.F.R., Part 51)
 when promulgated (along  with its  minimum program requirements)  should be
 used to  determine if  the program  described in the implementation schedule
 will meet the minimum 25 percent  CO/25 percent HC criterion. Should  a
 program  not  need to be this stringent to attain and maintain the NAAQS
 by  1982,  the I/M program need be  only as stringent as needed to assure
 conformity with NAAQS.   Should  a  state want to emphasize  control of  one
 particular pollutant  at  the expense of the other, the plan for  such  an
 I/M program  must be submitted to  the  appropriate EPA Regional Office for
 approval.

 G.   Minimum  Program Requirements

      In  addition to the  emission  reduction requirement above, all  I/M
 programs must:

           1.  provide for regular periodic inspections  of all  vehicles
              for which  emission reductions are claimed;*

           2.  provide for maintenance and retesting of failed vehicles
              to provide for compliance with  applicable emission
              standards;

           3.  prohibit registration or provide some equally effective
              mechanism  to  prevent vehicles which do not comply with
              the applicable exhaust emission requirements from operating
              on public  roads;

          4.  provide for quality control regulations and procedures
              for the inspection system including:


*Random roadside checks,  while a useful addition to an I/M program,
are not an acceptable substitute for regular periodic inspections.

-------
                                            REF III-l
                                  -6-

               a.   minimum specifications for emission analyzers

               b.   required calibrations of all types on analyzers and

               c.   minimum record keeping;

          5.   provide for either a mechanics training program or a program
              to inform the public of service establishments with approved
              emission analyzers; and

          6.   inform the public of the reason for the I/M program plus
              the locations and hours of inspection stations.

     Decentralized systems must also comply with the following require-
ments .

          1.   All official inspection facilities must be licensed.
              Provisions for  the licensing of inspection facilities
              must insure that the facility has obtained, prior to
              licensing, analytical instrumentation which has been
              approved for use by the appropriate state, local, or
              regional government agency.  A representative of the
              facility must have received instructions in the proper
              use of the instruments and  in vehicle testing methods
              and must have demonstrated proficiency in these methods.
              The facility must agree to maintain records and to submit
              to inspection of the facility.  The appropriate government
              agency must have provisions for penalties for facilities
              which fail to follow prescribed procedures and for mis-
              conduct.

          2.  Records required to be maintained should include the
              description  (make, year,  license number, etc.) of each
              vehicle inspected, and its  emissions test results.
              Records must also  be maintained  on the calibration of
               testing equipment.

          3.   Summaries  of these inspection records should be submitted
               on a periodic basis  to the  governing agency for auditing.

          4.  The  governing agency should inspect each  facility
               periodically to check the facilities' records, check
               the  calibration of the testing equipment  and observe
               that proper  test procedures are followed.

          5.   The  governing  agency should have an effective  program
               of unannounced/unscheduled  inspections  both as a  routine
               measure and  as  a complaint  investigation  measure.   It is
               also recommended that such inspections  be used to check
               the  correlation of instrument readings  among inspection
               facilities.

-------
                                          REF III-l
                        -7-

6.  The governing agency should operate a "referee"  station
    where vehicle owners may obtain a valid test to  compare
    to a test from a licensed station.  At least one referee
    station must be present in each I/M metropolitan area.

-------
                                                REF III-I
                            Attachment 1
                       Suggested I/M Milestones
1.   Complete plan for preparing and implementing I/M SIP revision
     including:

     a.   technical analysis

     b.   public information program

     c.   development of necessary legislation

     d.   development of I/M implementation schedule.

2.   Complete technical analysis including:

     a.   emission reduction benefits

     b.   fuel economy benefits

     c.   costs.

3.   Complete elements of a continuing public information program
     including:

     a.   further publicity concerning oxidant  (and/or carbon
          monoxide) episodes

     b.   meeting with and speaking to affected interest groups
          (including the public and public officials)

     c.   news releases.

4.   Complete development of legislative proposals.

5.   Complete development of I/M implementation schedule.

6.   Receive approval of I/M,  including implementation schedule, from
     air pollution control board or agency head as applicable and
     introduce into state legislature.

7.   Submit SIP revision for I/M, including implementation schedule, to
     EPA  (due no later than January 1, 1979).

8.   Obtain legal authority needed to implement I/M  (required by July 1,
     1979, with some exceptions allowed until July 1, 1980).

-------
                            REF V-3
QUESTIONS AND ANSWERS CONCERNING THE BASIS FOR THE AGENCY'S

   POSITION ON CONTROLLING HYDROCARBONS TO REDUCE OXIDANT
        Office of Air Quality Planning and Standards
            Monitoring and Data Analysis Divison
        Research Triangle Park, North Carolina 27711
                     September, 1978

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     The Environmental  Protection  Agency is  sometimes  asked what the basis
is for the strategy of controlling organic emissions to  reduce ambient
levels of photochemical  oxidant.   Recently,  concern about the strategy has
been voiced by State/local  air pollution agencies  and  others in light of a
report prepared for the Manufacturing Chemists  Association.*  This  report
concludes that existing ambient air quality  data do not  necessarily support
the hypothesis that reducing hydrocarbon emissions reduces  ambient  ozone
levels.  The Agency believes that  convincing evidence  exists that reducing
hydrocarbons will  reduce ambient concentrations of ozone.   This position rests
primarily upon experimental  and theoretical  studies which  have clearly
established a physical  cause-effect relationship between organic pollutants
and ozone in the presence of oxides of nitrogen.   In addition, there are
a limited number of areas having ambient air quality and emission estimates
over sufficiently long periods of  record which  tend to confirm the  theory
of smog formation.  Following is a series of questions and  answers  pertaining
to the strategy of controlling organic emissions to reduce  ambient  levels of
ozone.  The questions/answers first discuss  the theoretical  and experimental
basis for control  of organic emissions.  Next,  the issue of oxidant transport
and its impact on  control strategies is referred to.   Third, the uses and
difficulties of trend analyses are mentioned.  Finally,  statistically signi-
ficant associations of downward trends in ozone with precursor trends are
presented.  The answers to the questions posed  are intentionally concise.
*  Radian Corporation, Examination of Ozone Levels  and Hydrocarbon Emissions
   Reduction, Final  Report DCN 77-100-151-04 submitted to the Manufacturing
   Chemists Association, (November 1977).

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                                    2
As such, they cannot go into the detail required for complete understanding
of the State of the Art.  Lists of references pertaining to each major
subject area are enclosed.  These may be pursued by the interested reader.

-------
1.   What roles are organic pollutants and oxides of nitrogen believed to play in the
     formation of ozone?
     Synthesis of ozone (CL) is formed through several  reactions involving oxides
     of nitrogen (NO ), organic pollutants and sunlight.   Most anthropogenic
                    /\
     sources emit NOX as nitric oxide (NO).   NO is then oxidized by ambient ozone
     or organic species to form nitrogen dioxide (N02).
                    NO + 03   	>  N02  + 02                     (la)
          or

               NO + [organics]  	~^ ^or^nics^     +  N02         ^lb^

     N02 is next photolyzed by sunlight to form more NO and atomic oxygen (0).
                    N02  	^v	>  NO + 0                           (2)
     The atomic oxygen then reacts with abundant atmospheric oxygen (Op) to
     form ozone.
                         Q + .<>    	->   Q                         (3)
     Reactions 0) - (.3), some of which produce ozone,  others of which destroy
     ozone, are all very fast.  The result is a chemical  equilibrium which
     is established among 0^, N02 and NO:
                                      [N02]
                         [0]  =  k	4	                        (4)
                           3          [NO] •
     where k = a constant value reflecting reaction rate constants and sunlight
               intensity.

     Equation (4) is sometimes called the  "photostationary state."  It can be
     seen from Equation (4) that anything  which increases N02 concentrations
     and/or decreases NO concentrations, increases 03<   Reaction (Ib) is more
     effective than reaction O.a) in converting NO to N0? because:

-------
     (a)   other organic species which may also convert NO to ML
          are formed, and
     (b)   ozone is not destroyed as it is in reaction (la).

Summarizing the previous discussion, organic pollutants are  important
precursors of 03 because they cause the equilibrium among N02> NO and 03
to be shifted towards higher N02 and 03 and lower NO.  The role of NO  is
more ambiguous.  Near sources of NO it diminishes 03 levels.  Further downwind,
more of the NO is converted to N02 which, in turn, reacts with sunlight to form
ozone.
What observations exist to support the roles of organic pollutants and
oxides of nitrogen in the formation of ozone?
     The roles of organics and NO  in ozone formation have been studied
                                 rt
extensively in smog chambers.  A smog chamber is a transparent container
which can be as large as a room.  The usual experimental procedure is to
inject known amounts of organic and NO  precursors into the chamber and
                                      /\
then irradiate the mixture with artificial lights or sunlight.  Measurements
are then made of ozone and other compounds which are formed during the
ensuing chemical reactions.  Chemical kinetics models (mechanisms) are
then hypothesized to explain the observed behavior of pollutants in smog
chamber experiments.  By altering only the initial concentration of
organic pollutants or of NO  and repeating chamber experiments a number of
                           J\
times, the sensitivity of maximum ozone concentrations to organics and NOX
concentrations can be observed.  Using either kinetics models or chamber
data directly, one can plot maximum hourly ozone as a function of precursor
concentrations, as shown by the ozone isopleths in Figure 1.  For a variety
of different chambers and kinetics models employing different assumptions,
ozone isopleths have an essentially similar shape to the L-shape shown in
Figure 1.  It can be seen from Figure 1, that the effectiveness of organic
or NO  controls depends on the relative amounts of organics or NO  available
     x                                                           «
to react to form ozone.  For example, maximum ozone concentrations are much
more sensitive to organic controls if the NMHC/NO  ratio is low than  if

-------
                                         -» ^5^ "•«.
0.28
0.24
                                                                                                             40
                                                                                                1.8
                                                    NMHC, ppmC
        FIGURE  1.   Example  set  of maximum hourly ozone isopleths expressed as a function of
                   ambient  organic and NO  precursors.

-------
    this  ratio  is high.  Thus, if NMHC/NO  ratios  are  less  than about
                                         A
    15-20:1,  smog chamber experiments and kinetics models suggest controlling
    VOC emissions should be an effective strategy  for  reducing ozone.  The
    lower the ratio, the more effective such a  strategy  is  likely to be.
    Examination of available NMHC and NOV data  suggests  that most cities
                                        A
    experience  ratios in the order of 6-12:1.   If  isopleths generated by
    kinetics  models (typified by Figure 1) are  considered in conjunction with
    meteorological changes, the next step in sophistication is reached--
    photochemical dispersion models.  Much work has been conducted in develop-
    ing  photochemical dispersion models in the  past few  years.  Extensive
    efforts are currently underway to validate  these models.  However, limited
    comparisons which have been undertaken in Denver and San Francisco have
    produced  reasonably good agreement with observed ozone  data.  Simulations
    with  these models suggest that controlling  organic pollutants will reduce
    both  maximum concentrations of ozone and areawide  exposure to ozone.
    The  results obtained thus far with simulations of  NO controls are ambiguous.
                                                        A
    These results suggest that controlling NO  will  increase ozone near sources
                                             A
    of NO, but that this effect becomes less pronounced  as  one proceeds
    downwind.  There is good reason to believe  that if one  were to proceed
    downwind  still further, a beneficial impact would  be observed for NOX
    control.   In addition to the previously discussed  theory, Sunday-weekday
    comparisons of ozone concentrations in the  northeast suggest this is the case.


3.   How  is long  range transport likely to affect  previously described Organic-
    NO -Ozone  relationships?
      
          Long  range Covernight) transport of significantly high C>-08 ppm)
    concentrations of ozone has been well established in the northeastern
    quadrant of the nation under some circumstances.  Although measurements of rural
    organic  and NO  precursor concentrations are  very much lower than those
    measured in urban areas, it is conceivable that non-negligible amounts of
    precursors may occasionally be transported over long distances as,well.
    The  understanding of the role of precursors transported overnight is  hindered
    by the fact that their significance may depend on the  ability of  very low
    concentrations of N02 to remain or be reformed in the  atmosphere.   Because

-------
the concentrations involved are so low, the usefulness of smog chamber
experiments to shed light on this process is a center of controversy.
Only a limited number of overnight chamber simulations have been run to
date.  These suggest that organic emission controls may be less effective
in reducing the second day's maximum ozone concentration (.in the absence of
fresh precursor emissions on the second day).  Although the applicability
of kinetics models is less certain in the absence of confirmatory chamber
data, these models may be useful in addressing the question of how
previously described ozone-precursor relationships are affected by long
range transport.  Studies conducted by EPA to date suggest that ozone
transported from upwind of a city exerts a greater impact on maximum
ozone downwind of the city than do transported upwind precursors.  This
impact appears to be only about 50 percent or less of what one might at
first expect.  For example, if .12 ppm 03 were transported from upwind,
the  impact on maximum ozone downwind of a city might only be about .06 ppm.
Because measured data suggest that fresh urban precursors greatly exceed
transported precursors, fresh precursors overwhelm those transported from
afar.  Hence, the impact of transported precursors in major urban areas is
probably relatively small.
     The problem of organic-NO -On relationships in rural areas is not
                       [       A  O
sufficiently resolved. >[High NMHC/NOV ratios in such areas together with
                       *•             /\
some N0x plume data which suggest the possibility of 03 buildup far downwind
provide hints that the ability of new 03 to be generated in rural areas is
limited by the amount of available NOYJ.  Kinetics model  simualtions  and
                                     s\
limited smog chamber data suggest that urban control  programs  based upon
VOC reductions which reduce 03 immediately downwind of urban areas will  have
some, less dramatic beneficial impact on 0, in rural  areas further downwind.

  How should  observed trends  in  ambient air quality data  be  used  to assess
  the effectiveness  of control  programs for ozone?
       In utilizing  trend data,  it is desirable to keep all  variables besides
  emissions constant so that changes in 03 which result can  be more readily
  attributed to the changes in emissions.  In practice, of course, this is

-------
                                8

impossible to do.   Nevertheless, for trend analysis to be most meaningful,
one should strive to meet the following ground rules:
     (a)   comparisons should be made at identical locations;
     (b)   identical or similar measurement procedures, instrument
          configurations and quality assurance checks should be
          employed;
      (c)   similar dates  of observation should be compared  to  remove
           seasonal  bias  in the data;
      (d)   enough  days should be included from each year  to reduce bias
           which may be introduced by  weather system  patterns;
      (e)   enough  years should be considered  so that  the  importance
           of meteorological bias" can  be discounted;
      (f)   similar configurations  of sources  should exist near the monitoring
           location during each year.

 Because  the need  to adhere to point (e). may  cause the most frustration to State
 and local agencies trying to document the effectiveness  of previously imple-
 mented controls,  this point will  be elaborated upon.  A  number of statistical
 studies  which have attempted to explain the  variance in  day to day fluctuations
 in maximum On concentrations have found that a much  greater portion of the
 variance is explained by chang-es  in meteorological parameters.  Thus, despite
 the fact that fairly substantial  differences in emissions  may be possible when
 the wind blows in different directions, the  impact of changes  in emissions  is
 overwhelmed by more significant changes in meteorology.  Hence, when one  attempts
 to compare fairly small  changes in emissions, which  may  occur over a 2-3 year
 period of record, to changes in ambient ozone levels, the  effect of the emission
 changes  may be obliterated by unfavorable changes in meteorology.  It had been
 generally believed by EPA that at least a five year  period of record may  be
 needed to discern a trend in air quality attributable to changes in emissions.
 A recent review of ozone trend data conducted for EPA in areas having long  period
 of record suggest that periods as long as eight years may  be  required.  Thus,

-------
while efforts are underway within EPA to develop procedures for "normalizing
trends" for differing meteorology during short periods of record, at the
present time trend analysis is only useful in a limited number of areas.
Do ambient air quality trend data exist which suggest that reducing
organic emissions will lead to reductions in ambient 03/oxidant levels?
     Statistically significant downward trends in ambient oxidant levels
have been observed in two urban areas:  the Los Angeles Basin and the
San Francisco Bay area.  Statistically significant relationships between
organic emission reductions and oxidant levels appear to exist in these
two areas.  In addition, significant downward trends have been observed
in highest oxidant concentrations and in the frequency with which the
.08 ppm Federal standard for oxidants is exceeded at central city CAMP
sites in 5 of 6 cities over a 10-year period of record.  Tables 1 and 2
show the trends observed at the CAMP sites.  The,downward trends are
likely attributable to reductions in organic emissions as well as
increases in  NO emissions near each site.
     Table 3  is derived from a recent report prepared by the California
Institute of  Technology on oxidant and precursor trends observed in the
South Coast Air Basin (i.e., the. Los Angeles area) over a 9-year period.
The air quality trends (i.e., rows 3 and 4) represent composite trends
for all sites within each of the indicated counties.  Note that trends
in organic emissions  (row 1) are generally down and oxidant (row 3) are
generally down, whereas trends in NO  emissions and ambient N0? are generally
                                    X                         £
up.  Figure 2 depicts countywide organic and NO  emission trends for each
                                               X
county and ambient oxidant  trends at  individual sites  in the  basin.  Note
the spatial distribution of trends. Downward oxidant trends are most
dramatic  in Los Angeles County where  the bulk  of the organic  emission
reductions have occurred and where the  relative  increase in NOX  is less.
At counties on the downwind (I.e., eastern) edge of the basin (i.e.,
Riverside and San Bernardino), oxidant  has  remained about the same or
gone up.  These observations are consistent with the decreases  in  organic
emissions and the increase  in ambient N02  observed  throughout the  basin.

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                                          TABLE  1

                    '  Comparisons  of Average  Highest and 2nd Highest Annual 1 Hr

                      Maximum Oxidant for  Three  Year Intervals 1964-66 & 1971-73

Site
Chicago
Cincinnati
Denver
Philadelphia
St. Louis
Washington, D.C.

Average 1964-66 Values
Highest
0.125
0.175
0.2153
0.24
0.205
d.u

2d High
0.11
"0.13
0.1853
0.205
0.145
• 0.145

Average 1971-73 Values
Highest
0.125
0.14
' 0.165b '
0.12C
0.135
0.145C

2d High
0.11
0.11
0.12b
0.115C
-0.11
OJ35C _

% Change
Highest
' 0
-20
-23
- -50
.-34
-14

2d High
0
-15
-36
.44
-24
-- 7

        '1965-1967
}1970, 1972, 1973
'1970, 1971, 1973
Reference:  Altshuller., A.  P., "Evaluation  of Oxidant Results at CAMP Sites in the United States",
            JAPCA 25 (Jan 1975) pp.  19-24.

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                                        TABLE 2
                     Comparisons of Total  Number of (Observed)  Days that Oxidant
                     Concentration Fell  In Intervals  Aboye  0.08. ppm for Three-Year
                               Intervals 1971-73 and  1964-66

Site
Chicago
Cincinnati
Denver
Philadelphia
St. Louis
Washington, D. C.
' 1964-1966
0.085-
0.12 t>pm
9
' 59
72
sd
• ,85
87
0.125 ppm
& above
2
. 19
39
. 35
12
14
1971-1973
0.085-
0.12 ppm
14
' • 37 '
34
21
14
42' •
0.125 ppm
& above
2
6
9
2
4
4 '
% Change
• 0.085 ppm-
0.12 ppm
+36
- -37
' -53
-74
-84 ..
.-52
0.125 ppm
& above
0
• -68
-77
. -94
-67
-71 ' .
Reference:  Altshuller, A. P., "Evaluation of Oxidant Results  at  CAMP  Sites  in  the  United  States",
            JAPCA 2j (Jan. 1975) pp. 19-24.

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                                TABLE  3  — Emission and Air Quality Trends in the
                                           South Coast Air Basin, 1966 - 19741   •
                                        Prevailino Wind Direction
County
% Change in
RHC Emissions
% Change in
NO Emissions
/\
% Change in
County -wide
Oxidant
(? of Stations)
% Change in
County-wide
N0? (# of
stations)
Santa
Barbara
-9%
+69%
No
data
No •
data
Ventura
-2%
+42%
./
No
data
- No /
data
Los
Ar.oeles
-24%
+25%
-31%
(B sites)
+19%
(6 sites)
Oranae
+6%
+89%
-12%*
(2. sites)
+93%
(2 sites)
Riverside
-8%
+69%
+12%
(2 sites)
r
No
data
Bernardino
-17%
+38%
+2%
" (1 site)
+47%
(1-site) •
Basin-wide
Averaqe
TOO/
— I O ;t
+36%
-19%
(13 sites)
+35%
(11 sites)
% of  Basin
Population  .
(1970)
2.6
3.7
68.7
13.9
4.5
6.7
                                                                                                                  ro
*0ne site reported an increase of +7%, the other a decrease  of .-31%.  .

-------
                           i.  (wT.)
             •>—'
           {+<*?#)
\(5>    Lo3 An,*!., 4

  \0^>           _    I
  f-40%    •"*

             -351-

        -341
16%


 -III'1
                                                                        V   „__
+2*  .(J^s^;
                                                                           ,y   +23%
                                                        -44%  •  /* +71 XX  Ol
                                                                   -311
BASINWIDE  RHC EMISSION CHANGE:  K


BASINWIDE  NOX EMISSION CHANGE:   (+36%)


AVERAGE QXIDANT CONCENTRATION CHANGE (13 STATIONS);    -194'
                            \01     ^»v'«r3/^e         L.

                                           @)      j—J


                                           (t fif &)
                      TRENDS IN R!1C BlISSIONS AND OXIDANT AIR QUALITY, 1965-1974
                                        Figure 2

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                                 14
        Table 4 depicts trends observed over a 13-year period of record at
   representative monitoring sites in counties within the San Francisco
   Bay Area Air Basin.  Note that over this long period of record, the trend
   in oxidant concentrations is  downward at all sites.  The data at
   San Jose serve to   illustrate why  it is a good idea to study the effect
   of emission controls over a long period of record.  If one only had
   data for 1972-74 at San  Jose, he would be led to conclude (falsely)
   that emission controls exercised over this period have led to a deteriora-
   tion in oxidant levels.  As discussed earlier, it is likely that emission
   changes exercised  over such a short period are. overwhelmed by other,
   unrelated factors.
6.   What  are  the  implications  of  a  recent  report,  "Examination of Ozone Levels
    and Hydrocarbon.Emissions  Reduction",  which  has  been prepared for the
    Manufacturing Chemists  Association?
         This study  was  divided  into  three phases.   In  the first phase,trends
    in ambient ozone were compared  with  estimated  organic emission reductions
    in five cities.   The period  of  record  was  a  short one—two, or at most,
    three years.   In some of the  cities, observed  oxidant levels increased
    while in others  observed levels remained about the  same.  The authors of
    the study conclude that existing  data  did  not  necessarily support the
    hypothesis that  reducing hydrocarbon emissions reduces ambient ozone levels.
    However,  they also conclude  that  there are not sufficient amounts of good
    quality data  with which to draw more definite  conclusions.  For the reasons
    discussed in  the responses to questions 4  and  5, a  review of trends over" a
    2-3 year period  is likely  to  be an exercise  in futility.  This is because
    more  significant changes in meteorology occur  from  year to year.  One of
    the cities reviewed  in  the MCA  report  is Houston, Texas.  Houston is of
   particular interest because large  reductions  in organic emissions are claimed
    over  the  period  studied for  the MCA  and the  city experiences very high ozone
    concentrations.   Despite the  20-30 percent reduction in organic emissions claimed
    over  the  period  of record, ambient non-methane hydrocarbon (NMHC) concentrations

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                                                 TABLE 4

              AVERAGE HIGH-HOUR OXIDANT CONCENTRATIONS FOR DAYS WITH  COMPARABLE TEMPERATURE AND
                INVERSION CONDITIONS,   (APRIL THROUGH OCTOBER OXIOANT SMOG  SEASONS,  1962-1974}
         (Source:  Information Bulletin 3-25-75:   A Study of Oxidant  Concentration Trends:  Technical
                          Services Division, Bay  Aret Air Pollution Control  District.)
Monitoring
Station
V.
San Francisco
San Leandro
San Jose
Redwood City
Walnut Crook
San Rafael
BAAPCD
Average*
Liveiwore**
'62
.14
.13
• 11
.13
.10
.08
.12
—
'63
.12
.16
.17
.10
•H.
.09
.12
—
'64
-.15
.19
.14
.10
.10
.07
.13
--
Average High-Hour Oxidant Concentration
(KI parts per million)
'65
.09
.19
.16
.14
.11
.08
.13
--
'66
.08
.14
.11
.10
.10
.07
.10
—
'67
.08
.12
.13
.09
.13
.07
.10
.13
'68
.05
.11
.13
.00
.10
.06
.09
.18
'69
.04
.12
'•'.13
.09
.13
.07
.10
.18
'70
.07
.12
.12
.08
.09
.08
.09
.13
'71
.05
.11
.08
.07
.09
.07
.08
.11
'72
.03
.10
.08.
.09
.05
.08
.09
'73
.04
.11
.11
.07
.08
..05
.08
.12
'74
.05
.10
.16
.07
.08
.06
.09
..13
13-yr , 'Oxidant Trend
• Direction
U9/0-
74 only)
.08 • —
.13
r
.13 . +
,09
. .10 .••• -
.07
.10
.13 +
Al 1
Data
-
_
—
-
-
—
-
 *  For benchmark stations above,  with  13 years  of  record.
**  Station with a years of record.

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                                16

Increased at one of two sites in the city.  Further, there is some  "
question about whether a significant fraction of the claimed emission
decrease occurred before or at the beginning of the period of record
for reported ozone observations.  Ozone trends obviously would not
reflect such changes even if there were no complications introduced
by meteorology, monitor location and other extraneous factors.
Interpretation of the trends is, however, further complicated by more
adverse meteorology which occurred during the latter portion of the
study (1976).
     The second phase of the study for MCA reviewed levels of NMHC and
NO,  NO? and NO  which occurred during periods of high ozone.  In some
       C.       J\
cases ozone Increased as observed NMHC and/or NO  went up.  In other
                                                J\
cases there were no obvious relationships.  It is generally difficult
to draw any conclusions from observations of this sort, because much
of the variability in ozone concentrations has been eliminated before
the analysis is even begun.  Hence, the changes in ozone levels one is
asked to explain are generally small and  the number of possible explana-
tions are  still large.  The authors conclude that precursor-ozone
relationships  cannot be readily derived without also considering meteoro-
logical changes.  Other studies described in previous responses would
certainly  support this conclusion.
     The third and final phase of the study for MCA attempted to relate
high ozone levels to the passage of weather fronts  (by inference
implicating  stratospheric  intrusion).  The authors found that ozone
decreases  with the passage of a weather front and then increases again
several days later.  Such  observations are consistent with those in
earlier studies conducted  for EPA.  These observations do not provide
support for  the hypothesis that stratospheric intrusion is a significant
factor  leading to widespread high concentrations of ozone which have
been reported  in certain parts  of the country.

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                      REFERENCES  FOR  FURTHER READING


 I. General  References on Atmospheric Chemistry Related to Ozone  Formation


   1.    U.S.  Department of  Health, Education and Welfare, Ai_r
         Quality  Criteria for  Photochemical Oxidants, AP-63,
         (March 1970), Ch. 2

   2.    Altshuller,  A.P., and J.J. Bufalini, "Photochemcial Aspects
         of Air Pollution:   A  Review,"   Environmental Science and
         Technology,  _5, 39 (January 197177

   3.    Dimitriades, B., Photochemical  Oxidants in the Ambient
         Air of the United States, EPA-60Q/3-76-017,  (February 1976),
         Ch. 3.

   4.    U.S.  EPA,  Air Quality Criteria  for Ozone and Other Photochemical
         Oxidents,  Volume I, EPA-600/8-78-004, (April 1978), Ch.  4.


II. Laboratory and  Modeling  Observations Related to Oxidant Control Strategies


   1.    Dimitriades, B,, "Effects of Hydrocarbon and Nitrogen Oxides
         in Photochemical Smog Formation," Environmental Sciences and
         Technology,  j5, 253   (1972).

   2.    McCracken, M.C., et al., Development of an Air Pollution Model
         for the  San  FrancTsoTBay Area. Volume I, NTIS No. UCRL-51920,
         (October 1975).

   3.    Dodge, M.C., Combined Use of Modeling Techniques and Smog
         Chamber  Data to Derive  Ozone-Precursor Relationships,
         FPA-600/3-77-001b,  p. 881, (January 1977).

   4.    Dimitriades, B., "Oxidant Control Strategies, Part 1:  An
         Urban Oxidant Control Strategy  Derived from  Existing Smog
         Chamber  Data," Environmental Science and Technology 11,
         p. 80 (1977).

   5.    Anderson,  G.E., et  al.,  Air  Quality in the Denver Metropolitan
         Region 1974-2000, EPA-908/1-77-002, (May 1977), Ch. 2.

   6.    U.S.  EPA,  Uses, Limitations  and Technical Basis of Procedures
         for Quantifying Relationships Between Photochemical Oxidants
         and Precursors, EPA-450/2-77-021 a.  (November 1977).

-------
     7.    Seinfeld,  J.H.,  and K.R.Wilson,  International  Conference
          on Oxidants,  1976 - Analysis of  Evidence and Viewpoints.
          Part VI, The  Issue of Air Quality Simulation Model  Utility,
          EPA-600/3-77-118, (November 1977).

     8.    U.S. EPA,  Air Quality Criteria for Ozone and Other  Photochemical
          Oxidants,  Volume I, EPA-600/8-78-OQ4,  (April 1978),  Ch. 6.


III.  Impact of Transport on Control Strategies

     1.    Research Triangle Institute, Investigation  of Rural  Oxidant
          Levels as  Related to Urban Hydrocarbon Control  Strategies,
          EPA-450/3-75-036, (March 1975).

     2.    Jeffries,  H.J.,  et al., Outdoor  Smog Chamber Studies:   Effect
          of Hydrocarbon Reduction on Nitrogen Dioxide,  EPA-650/3-75-001,
          TJune 1975).'~

     3.    Martinez,  E.L.,  and E.L. Meyer,  "Urban-Nonurban Ozone  Gradients
          and Their Significance," Proceedings,  Ozone/Oxidant Interaction
          with the Total Environment Speciality  Conference, APCA, (March 1976)

     4.    Decker, C.E., et a!., Formation  on a Tranport of Oxidants Along
         - Gulf Coast and in Northern U.S.', EPA-450/3-76-033,  (August 1976).

     5.    Sickles, J.E., e t al., Oxidant and Precursor Transport Simulation
          Studies in the Research Triangle Institute  Smog Chambers,
          EPA-600-3-77-001a', p. 319 (January 1977).

     6.    Dimitriades,  B., Oxidant Control Strategy;  Recent Developments,
          EPA--600/3-77-001 b, p. 1143, (January 1977).

     7.    Ludwig, F.L., and E. Shelar, Ozone in  the Northeastern United
          States, EPA-901/9-76-007, (March 1977).

     8.    U.S. EPA,  Uses,  Limitations and Technical Basis of  Procedures
          for Quantifying Relationships Between  Photochemical  Oxidants
          and Precursors,  EPA-450/2-77-021a. Ch. 3, (November 1977).

     9.    Pack, D.H., et al., International Conference on Oxidants, 1976 -
          Analysis of Evidence and Viewpoints.  Part  V.   The  Issue of
          Oxidant Transport, EPA-600/3-77-117, (NovemberT9777.

    10.    U.S. EPA,  Procedures for Quantifying Relationships  Between
          Photochemical Oxidants and Precursors:  Supporting  Documentation,
          EPA-450/2-77-021b, (>ebruary 1978).

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    11.    U.S.  EPA,  Air Quality  Criteria  for Ozone and Other Photochemical
          Oxidants,  Volume I,  EPA-6QO/8-78-004, Ch. 3-5,  (April  1978).

    12.    Cleveland, W.S., and J.E.  McRae,  "Weekday-Weekend Ozone Concentrations
          in the Northeast United  States,"  ES&T 12 p. 558 (May 1978).

    13.    Decker, C.E., et al.,  Project Da  Vinci  II:  Data Analysis and
          Interpretation,  EPA-450/3-78-028, (June 1978).


IV.   Observed Air Quality  Trends and Their  Underlying Explanations

     1.    U.S.  EPA,  Guideline  for  the Evaluation  of Air Quality  Trends,
          Guideline  Series OAQPS No.  1.2-014,  (February 1974).

     2.    Altshuller, A.P., "Evaluation of  Oxidant Results at CAMP Sites
          in the United States," Air Pollution Control Association J,
          25, 19 (January  1975).   ~~

     3.    Trijonis,  J.C.,  et al.,  Emissions and Air Quality Trends in
          the South  Coast  Air  Basin, EQL  Memo  No. 16, Environmental Quality
          Laboratory, California Institute  of  Technology,  Pasadena, CA  91125.

     4.    Wayne, L., et al., Detection and  Interpretation of Trends in
          Oxidant Air Quality, EPA-450/3-76-034,  (October 1976).

     5.    Gise, J.P., Recent Ozone Trends in Texas, AIChE, 83rd  National
          Meeting, Houston, Texa¥, (March 1977).

     6.    Trijonis,  J., et al.,  Verification of the Isopleth Method for
          Relating PhotochemicalOxidant  to Precursors, EPA-600/3-78-019,
          Ch. 2-3, (February 1978);

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                                      REF VI-1

                   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

 ' DATE, 2 8 APR  1978   .'  f                               ,
                      /
                      t,
SUBJECT: Development of Regulations  for HC RACT from CTG's


  FROM: Walter  C.  Barber,  Director  (J2/
       Office  of  Air Quality Planning and Standards

    TO: Robert  Duprey, Director
       Air & Hazardous Materials Division, EPA Region V
             The Control Techniques Guideline documents were published to aid
        in developing RACT-type regulations for sources of volatile organics.
        It appears that they are being interpreted too narrowly and that
        regulations based on the GTG1s •documents arc usinp only iho
        presumptive emission number and neglecting to include the qualification
        that this number may be either too restrictive or too lenient for some
        facilities.  The CTG documents contain the statement "It must be
        cautioned that the limits reported in this Preface are based on
        capabilities and problems which are general to the industry, but  may
        not be applicable to every plant".  This caveat was noted in the  memo
        on implementation of RACT for. HC sources from Dave Hawkins to all
        R.A 's on February 2, 1978 "Where economics or other circumstances
        justify regulatory requirements less stringent than those contained^
        within the CTG's, such justification should be clearly documented in
        the SIP submittal."

             Tough presumptive numbers were selected assuming that they did
        not have to be achievable or reasonable for every source.  If the
        presumptive CTG number is used verbatim in a regulntion, there
        should be a provision or a procedure to allow relaxation after a
        case-by-case demonstration of infeasibility,  (technical or economic)
        either during  the proposal period or as a later SIP revision.

             The example RACT-type regulations for VOC that OCA did for
        Region V use the presumptive CTG numbers as absolutes.  You should
        consider adding the  appropriate general provision or noting in the
        package that a form  of a variance procedure is needed if the
        limitation in  the example regulations are to be applicable  to all
        sources.

        cc:  D. Goodwin
             J. Calc^gni
             D. Rhoad's
             R. Wilson

             Air & Hazardous Materials Division Directors  (Regions  I-IV,  VI-X)
           tx-R'egional Air Branch Chiefs  (Regions  I-X) -
 EPA FORM 1320-6 (RliV. 3-76)

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  July 10, 1978
                                 REF VI-4
                 STATIONARY SOURCES OF VOLATILE ORGANIC COMPOUNDS
            AND SCHEDULE FOR APPLICABLE CONTROL TECHNIQUES GUIDELINES^
       SOURCE CATEGORY
NATIONWIDE EMISSIONS,
1,000 metric tons/yr
  FINAL REPORT DATE
Petroleum Refinery Fugitive
 Emissions (Leaks)
Surface Coating of Miscellaneous
 Metal. Parts and Products
Vegetable Oil Processing
Factory Surface Coating of
 Flatwood Paneling
Large Appliance Manufacture
Magnet Wire Insulation
Gasoline Bulk Plants
Metal Furniture Manufacture
Petroleum Liquid Storage,
 Fixed Roof Tanks
Degreasing
Bulk Gasoline Terminals
Petroleum Refinery Vacuum Systems,
 Wastewater Separators and Process
 Unit Turnarounds
Cutback Asphalt Paving
Surface Coating of Automobiles,
 Cans, Metal Coils, Paper, and
 Fabric Products
Service Stations, Stage I
Pharmaceutical Manufacture
Rubber Products Manufacture
Graphic Arts  (Printing)
Service Stations, Stage  II
Petroleum Liquid Storage,
 Floating Roof Tanks
        150

        200

         70
         50

         35
         10
        150
        100
        700

        700
        250
        700

        700
        900

        400
         50
        150
        400
        500
        150
   Enclosed

   Enclosed

   Enclosed
   Enclosed

     1977
     1977
     1977
     1977
     1977

     1977
     1977
     1977

     1977
     1977
Control technology
information has been
widely distributed,  ,,.
available on request.—'
  December, 1978
  December, 1978
  December, 1973
  December, 1978
  December, 1978

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       SOURCE CATEGORY
REF VI-4
 - 2 -

  NATIONWIDE EMISSIONS,
  1,000 metric tons/yr
  FINAL REPORT DATE
Organic Chemical Manufacture
 Process Streams
 Fugitive (Leaks)
Dry Cleaning
Architectural and Miscellaneous
 Coatings
Ship and Barge Transport of
 Gasoline and Crude Oil
Wood Furniture Manufacture
Organic Chemical Manufacture
 Waste Disposal
 Storage and Handling
Natural Gas and Crude Oil
 Production
Natural Gas and Natural
 Gasoline Plants
Adhesives
Other  Industrial Surface
 Coatings
Auto Refinishing
Other  Solvent Usage
 Metals  Manufacture
 Other Manufacturing
 Fuel  Combustion
 Forest, Agricultural  and
  Other  Open  Burning
 Solid Waste  Disposal
 TOTAL STATIONARY SOURCES
 TOTAL TRANSPORTATION  SOURCES
        450
        600
        250
        300

         60

        200

        150
        300
        200

        150

        200
        300

        150
      3,000
       4,000
    December,  1978
    December,  1978
    December,  1978
    December,  1978

      June, 1979

      June, 1979

      June, 1979
      June, 1979
Screening studies underway

Screening studies being
initiated
Not yet scheduled
Not yet scheduled

Not yet scheduled
Source strengths of major
categories being confirmed
before initiating CTG
analysis.
None  planned
   16,700,000 metric tons per year
   10,600,000 metric tons per year

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                             REF  VI-4
                               -  3 -
v
—  This inventory was developed  from national production and consumption
   information using average emission factors.  The technique necessarily
   requires assumptions  that cannot be  confirmed in every case.  We
   anticipate that the figures will change  as better information is
   developed and generalized categories such as "other solvent usage" are
   more clearly defined.

 y "Design Criteria for  Stage I  Vapor Control Systems Gasoline Service
   Stations," U. S. Environmental Protection Agency, November, 1975, and
   "A Study of Vapor Control Methods for Gasoline Marketing Operations:
   Volume I -  Industry Survey and Control Techniques," U. S. Environmental
   Protection Agency, EPA-450/3-75-046a, April, 1975.

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REF VI- 6
      FRIDAY, JULY 8, 1977
          PART III
   ENVIRONMENTAL
      PROTECTION
        AGENCY
       AIR QUALITY

    Recommended Policy on Control of
      Volatile Organic Compounds

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 35314

   ENVIRONMENTAL  PROTECTION
               AGENCY
              [FRL 729-6]

              AIR QUALITY

 Recommended Policy on Control of Volatile
           Organic Compounds
               PURPOSE

/  The purpose of  this notice is to rec-
 ommend a policy for States to follow on
 the control of volatile organic compounds
 (VOC), which are a constituent in the
 formation  of photochemical  oxidants
 (smog). This notice does not place any
 requirements on States; State Implemen-
 tation Plan (SIP) provisions which offer
 reasonable alternatives to this policy will
 be approvable. However, this policy will
 be followed  by^EPA whenever  it is re-
 quired to draft State  Implementation
 Plans for the control of photochemical
 oxidants.
 ;             BACKGROUND
1   Photochemical oxidants result  from
 sunlight acting on volatile organic com-
 pounds (VOC)" and oxides of nitrogen.
 Borne VOC, by their nature, start to form
 oxidant after only a short period of Ir-
 radiation in the atmosphere. Other VOC
 may undergo irradiation for a longer
 period  before  they  yield  measurable
 oxidant.
   In its guidance to States for the prep-
 aration, adoption, and submittal of State
 Implementation Plans published in 1971,
 the  Environmental Protection  Agency
 emphasized reduction of total organic
 compound  emissions, rather than sub-
 stitution. (See 40 CFR Part 51, Appendix
 B.) However, in Appendix B, EPA stated
 that substitution of one  compound  for
 another might be useful where it would
 result in a clearly evident decrease in
 reactivity and thus tend to reduce photo-
 chemical   oxidant   formation.  Subse-
 quently,  many  State  Implementation
 Plans  were promulgated with  solvent
 substitution provisions  similar to Rule
 66 of the Los Angeles County Air Pollu-
 tion Control District. These regulations
 allowed exemptions for  many organic
 solvents which have now been  shown
 to  generate  significant  photochemical
 oxidant.
i   On  January 29,  1976, EPA published
 Its "Policy Statement on Use of the Con-
 cept of Photochemical Reactivity of  Or-
 ganic Compounds in State Implementa-
 tion Plans  for Oxidant  Control." The
 notice of  availability of  this  document
 appeared  in the FEDERAL REGISTER  on
 February 5,1976 (41 FR 5350).
   The 1976 policy statement emphasized
 that  the reactivity concept was useful
 as an interim measure  only, and would
 not be considered a reduction in organic
 emissions for purposes of estimating at-
 tainment  of  the  ambient air quality
 standard  for  oxidants. The  document
 also included the following statement:
   Although the substitution portions of Rule
 flfl and similar  rules represent a workable
 and acceptable program at the present time.
 better substitution regulations can be de-
 veloped, based on current knowledge of re-
         REF VI- 6

               NOTICES

 activity and Industrial capability. EPA to
 collaboration with State and Industry repre-
 sentatives will formulate  In  1076 an  Im-
 proved rule for national use.

              SUMMARY

   Analysis of available data and infor-
 mation show that very few volatile or-
 ganic compounds are of such low photo-
 chemical reactivity  that they can  be
 ignored in  oxidant  control  programs.
 For this reason, EPA's recommended
 policy reiterates the need  for positive
 reduction techniques  (such as the reduc- .
 tion of  volatile organic compounds in
 surface  coatings, process changes, and
 the use of control equipment)  rather
 than the substitution of compounds of
 low (slow)  reactivity in the place of
 more highly (fast) reactive compounds.
 There are three reasons for this. First,
 many  of the VOC  that previously have
 been designated as having low reactivity
 are now known  to  be moderately or
 highly reactive in urban  atmospheres.
 Second, even compounds that are pres-
 ently known  to have low reactivity can
 form  appreciable  amounts  of oxidant
 under  multiday stagnation  conditions
 such as occur during summer In many
 areas.  Third, some  compounds of  low
 or negligible reactivity may have other
 deleterious effects.
   Of  the small number of VOC  which
 have only negligible photochemical  re-
 activity, several (benzene,  acetonitrile,
 chloroform,  carbon tetrachloride, ethyl-
 ene dichloride,  ethylene dibromide, and
 methylene chloride) have been identified
 or implicated as being carcinogenic, mu-
 tagenic,  or  teratogenic.  An additional
 compound, benzaldehyde, while produc-
 ing no  appreciable ozone,  nevertheless,-
 forms a strong eye irritant under irradia-
 tion. In view of these circumstances, it
 would -be inappropriate for EPA  to  en-
 courage or support increased utilization
' of these compounds.  Therefore, they are
 not recommended  for  exclusion from
 control. Only the four compounds listed
 in Table 1 are, recommended for exclu-
 sion from SIP regulations and, therefore,
 it is not necessary that they be  inven-
 toried or controlled. In determining re-
 ductions  required  to   meet oxidant
 NAAQS, these  VOC should not  be in-
 cluded in the base line nor should reduc-
 tions in their emission be credited toward
 achievement of the NAAQS.
   It is recognized that the two halo-
 genated compounds listed  in Table  1
 (methyl chloroform and Freon 113)  may
 cause deterioration of the earth's ultra-
 violet  radiation shield since they  are
 nearly  unreactive in the  lower atmos-
 phere and all contain appreciable frac-
 tions   of chlorine.  The  Agency   has
 reached conclusions on the effects of only
 the  fully  halogenated  chlorofluoroal-
 kanes. The  Agency on May 13, 1977 (42
 FR 24542),  proposed rules under  the
 Toxic Substances Control Act (TSCA) to
 prohibit the nonessentlal  use of fully
 halogenated chlorofluoroalkanes as aero-
 sol propellants. The restrictions were ap-
 plied to all members of this class. In-
 cluding Freon 113, since they are poten-
 tial substitutes for Freon  11, Freon 12,
 Freon 114, and Freon 115, which are cur-
 rently used as aerosol propellants. The
 Agency is planning to Investigate control
 systems and substitutes for nonpropel-
 lant uses under TSCA, as announced on
 May 13. Methyl chloroform Is not a fully
 halogenated chlorofluoroalkane. Rather,
 it is among the chlorine-containing com-
 pounds for which the Agency has  not
 completed its analysis; E_PA has not yet
 concluded whether it is or is not a threat
 to the stratospheric ozone. Therefore, it
 has been placed on this list as an accept-
 able exempt compound. As new informa-
 tion becomes available on  these com-
 pounds, EPA will reconsider the recom-
 mendation.
  The volatile organic compounds listed
 in Table 2, while more photochemically
 reactive than those  in Table  1, never-
 theless do not contribute large quantities
 of oxidant under many atmospheric con-
 ditions.
 TABLE  1.—Volatile  Organic  Compounds of
  Negligible Photochemical Reactivity That
  Should Be Exempt From Regulation Under
  State Implementation Plant
 Methane
 Ethane
 1,1,1-Trichloroethane (Methyl Chloroform)1
 Trlchlorotrifluoroethane (Freon 113)1
  'These compounds have been  Implicated
 as having deleterious effects on stratospheric
 ozone and, therefore, may be subject to  fu-
 ture controls.
 TABLE  2.—Volatile  Organic  Compounds of
  Low Photochemical Reactivity
* Propane
 Acetone
 Methyl Ethyl Ketoiie
 Methanol
 Isopropanol
 Methyl Benzoate
 Tertiary Alkyl Alcohols
 Methyl Acetate
 Phenyl Acetate
 Ethyl Amines
 Acetylene
 N, N-dlmethyl formamlde

   Only during  multiday  stagnations do
 Table 2 VOC yield  significant oxidants.
 Therefore,  if resources are limited or if
 the sources are located in 'areas  where
 prolonged  atmospheric stagnations  are
 uncommon, priority should be given to
 controlling more reactive  VOC first and
 Table 2 organics later. Table 2 VOC  are
 to be Included  In base line emission in-
 ventories and reductions in them will be
 credited toward  achievement  of   the
 NAAQS. Reasonably  available control
 technology should be applied  to signifi-
 cant sources of Table 2 VOC where neces-
 sary to attain the NAAQS for oxidants.
 New sources of these compounds will also
 be subject  to new source review require-
 ments.
   Perchloroethylene, the  principal  sol-
 vent employed in the dry cleaning indus-
 try, is also of low reactivity, comparable
 to VOC listed in Table 2. It was not in-
 cluded in Table 2 because of reported ad-
 verse health effects. Uses, environmental
 distribution,  and effects of  perchloro-
 ethylene currently are being studied In-
 tensively by occupational health author-
 ethylene currently are being studied in-
 vestigations may have major Impact on
                                   FEDERAL REGISTER, VOL. 42, NO.  131—FRIDAY,  JULY 8, 1977

-------
Industrial users. In designing control reg-
ulations  for  perchloroethylene sources,
particularly dry  cleaners, consideration
should be given to these findings as well
as Industry requirements and the cost of
applying controls. Available control tech-
nology Is highly  cost effective for large
perchloroethylene dry  cleaning opera-
tions. However,  for coin-operated  and
small dry cleaners, the same equipment
would  represent  a  heavy  economic
burden.
   As part of its continuing program, EPA
will review new  information relative to
the photochemical reactivity, toxicity, or
effects on stratospheric ozone of volatile
organic compounds. Where appropriate,
additions or deletions will be made to the
lists of VOC in Tabels 1 and 2.
              DISCUSSION
   Most air pollution control regulations
 applicable to stationary sources of VOC
 ta the United States are patterned after
 Rule 66 of the Los Angeles County  Air
 Pollution  Control  District  (presently
 Regulation 442 of the Southern Califor-
 nia Air Pollution Control District). Rule
.66 and  similar  regulations incorporate
 two basic strategies to reduce ambient
 oxidant levels, i.e., positive VOC  reduc-
 tion and selective  solvent  substitution
 based on photochemical reactivity. Posi-
 tive reduction schemes such as incinera-
 tion, absorption, and the use of !"w-sol-
 vent coatings are acknowledged means of
 reducing ambient  oxidant levels; they
 should be retained in future VOC control
 programs. In contrast, the utility of sol-
 vent substitution  strategies  has been
 questioned as more information on pho-
 to chemical reactivity has emerged.
   EPA  acknowledged  the shortcomings
 of solvent substitution based on Rule 66
 reactivity criteria in a 1976 policy state-
 ment (41 PR 5350). Findings were cited
 which  Indicated that almost  all VOC
 eventually react In the atmosphere to
 form some oxidant. Concurrently, EPA
 Initiated an investigation to consider im-
 plications of revising the solvent cubsti-
 tuton aspects of Rule 66. Three separate
 forms were conducted with representa-
 tives of State and  local  ah-  pollution
 control agencies, university professors,
 and  Industrial  representatives  with
 knowledge and expertise in the fields of
 btmospheric chemistry and  industrial
 polvent applications.  In  addition,  nu-
 merous discussions were held with ac-
 knowledged experts in the field. Topics
 of particular concern  were:
   Whether Rule  66  substitution  criteria
 could be revised  consistent  with available
 reactivity data  and  yet be compatible with
 industrial processes and with product re-
 quirements.
   Whether some  compounds are of  suffi-
 ciently low reactivity that they are not oxi-
 dant precursors and can be exempted from
 control under State Implementation Plans.
   Whether the Imposition of reactivity re-
 strictions In addition to positive emission
 reductons will delay the development or
 implementation of  promising technologies,
 (particularly  the  use of water-borne  and
 high-solids surface coatings.
        REF VI-6
               NOTICES

  Investigation showed that:
  1.  Solvent substiutton based on Rule
66 has been directlonally correct In the
aggregate and probably effects some re-
ductions In peak oxidant levels.  How-
ever, because of  the relatively high re-
activity of most  of the substituted sol-
vents, the reduction is small compared to
that which can  be accomplished with
positive reduction techniques. Revision
of Rule 66 consistent with current knowl-
edge of reactivity would eliminate  the
solvent substitution  option  for  most
sources in which  substitution is new em-
ployed. Many  of the organic solvents
which  have been categorized  as having
low photochemical reactivity are, in fact,
moderately or highly reactive; they yield
significant oxidant when subjected  to
irradiation in smog chambers designed to
simulate the urban atmosphere.
  2.  A few VOC yield  only  negligible
ozone when irradiated in smog chambers
under  both urban and rural conditions.
Experiments conducted to date indicate
that only methane and ethane, a group
of halogenated paraffins, and three other
organics—benzene, benzaldehyde,   and
acetonitrile—can be so classified. These
compounds react very slowly yielding
little ozone  during the first few days
following their release to the atmosphere.
Available data  suggest that none of the
listed compounds contribute significant
oxidant even during extended irradiation
under multiday stagnation conditions.
  The broad group "halogenated paraf-
fins"  includes  important   industrial
solvents, most of which are chlorinated
methanes and ethanes and chlorofluoro-
ethanes. They find use as metal cleaning
and dry cleaning solvents and as paint
removers.  Halogenated paraffins  also
serve as building blocks in the manufac-
ture  of  other  halogenated   organics; .
these processes do not necessarily release
significant VOC to the atmosphere.
  3.  Besides  focusing  on   VOC  of
negligible  reactivity,   smog  chamber
studies show that a few additional VOC
generate oxidant at a relatively slow rate.
Under favorable atmospheric conditions,
these VOC releases may not form oxidant
until they have  been transported sub-
stantial  distances  and become greatly
diluted. However, under multiday stag-
nation conditions such as occur during
summer in many areas of the middle and
eastern  United  States,  there  is  the
potential for these organics to undergo
appreciable conversion to oxidant.  The
more important VOC in this category are
acetone, methyl ethyl ketone,  parchloro-
ethylene,  methanol,   isopropanol,  and
propane.  All except propane  are indus-
trial solvents.  The latter, a  gas under
normal conditions, is  associated prin-
cipally with crude  oil  and liquefied
petroleum gas  operations.
  4. The vast number of volatile organic
compounds—particularly nonhalogenat-
ed VOC—yield appreciable ozone when
irradiated in the presence of oxides of
nitrogen.  While there  are  measurable
variations in their rates of ozone forma-
tion, all are significantly more reactive
than VOC listed in Table 2. Quickly re-
active VOC  Include almost all aliphatic
                                3531,-)

and aromatic  solvents,  alcohols,  ke-
tones, glycols, and ethers.
  5. Low photochemical-reactivity is not
synonymous with low biological activity.
Some of the negligible or slowly reactive
compounds have adverse effects on  hu-
man health.  Benzene, acetonitrile, car-
bon tetrachlorlde, chloroform, perchlo-
roethylene, ethylene dichloride, ethylene
dibromide, and methylene chloride have
been  Implicated  as  being carcinogens,
teratogens, or  mutagens.  In addition,
benzaldehyde, which produces  no  ap-
preciable ozone,  nevertheless forms  a
strong eye irritant   under irradiation.
While their use might reduce ambient
oxidant levels, it would be unwise to en-
courage their uncontrolled release.  Ad-
ditional halogenated  organics are being
Investigated for possible toxicity.
  Most of the related health informa-
tion available at this time concerns acute
toxicity. Threshold limit values (TLV's)
have  been developed for many  VOC.
They are appropriate for the healthy,
adult work force exposed eight hours a
day, five  days  a  week. Experts suggest
that  more stringent levels  should be
established for the general population.
Hazards represented by chronic and sub-
chronic exposure  are much more diffi-
cult to quantify than acute toxicity.  Ad-
verse health effects  of the VOC cited
above are generally recognized although
not completely quantified. Chlorinated
solvents  currently are  under intensive
study.
  6. Some VOC are of such low  photo-
chemical  reactivity that they persist in
the atmosphere for several years, even-
tually migrating  to  the stratosphere
where they are suspected of reacting and
destroying ozone. Since  stratospheric
ozone Is the principal absorber of ultra-
violet  (UV)  light, the depletion could
lead to an increase  in UV penetration
with  a resultant  worldwide increase in
skin cancer.  The only in-depth analysis
of this potential problem has focused on
the chlorofluoromethanes (CFM), Preon
11  and Preon 12, because of their known
stability  and widespread  use in aerosol
containers. A  report of  the National
Academy of  Sciences concerning envi-
ronmental effects of CPM's  concluded
that:
  * • *  seletcive  regulation of CFM  uses
and releases Is almost certain to be necessary
at some time and to some  extent of com-
pleteness.               _

In  response to the report of the National
Academy of  Sciences and other studies,
EPA on May 13,1977  (42 FR 24542), pro-
posed rules to prohibit nonessential  use-
age of fully halogenated chlorofluoroal-
kanes as areosol propellants. The re-
strictions were applied to all members
of  this class Including Preon 113 since
they are  potential substitutes for Freon
11, Preon 12, Preon 114, and Preon 115
which are currently used  as  aerosol
propellants.
  Other  stable   halogenated  solvents
which are released in volumes compara-
ble to the chlorofluoroalkanes also are
suspected of depleting the earth's UV
shield. Of major concern is  the wlde-
                                   FEDERAl REGISTER, VOl. 42, NO. 131—FRIDAY, JUIY  8, 1977

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                                                   REF VI-6
;;r>;u6

spread substitution of methyl chloroform
il.l.l  trichloroethane)  for  the photo-
rhemically  reactive degreasing solvent
trichloroethylene. Such substitution un-
der Rule 66 generation  regulations has
already influenced industrial degreasing
operations  to  the extent that methyl
chloroform   production  has  surpassed
that of trichloroethylene in the United
States. Any regulation in the area will
.have a marked effect on the production
and atmospheric  emissions of both sol-
vents. Endorsing methyl chloroform sub-
stitution  would increase emissions, par-
ticularly  in industrial States that have
not, heretofore, implemented Rule 66. On
the other hand, disallowing methyl chlo-
roform as a substitute or banning it alto-
gether would significantly increase emis-
sions  of  trichloroethylene even  if  de-
greasers were corilrolled to the limits of
available technology.  Presently,  tech-
nology is only able to reduce emissions by
approximately 50 percent. In metropoli-
tan areas  which  have already  imple-
mented Rule 66, a return to trichloro-
ethylene would have an  adverse effect
on ambient oxidant levels. In addition to
being  highly reactive, trichloroethylene
 has been implicated as a carcinogen.
   Alternatives to the above-cited choices
 would be (1) development and applica-
 tion of highly efficient degreaser control
 systems  and (2)  replacement with an
               NOTICiS

Intermediate solvent which is neither re-
active nor detrimental to the upper at-
mosphere.. Major  revisions  would  be
needed to degreaser designs  to improve
vapor capture  above the  current best
level. Anticipated design changes could
add materially to degreaser costs. No al-
ternative solvent  is  clearly  acceptable
from the standpoints of photochemical
oxidant and stratospheric ozone deple-
tion.  Neither methylene  chloride nor
trichlorotrifluoroethane are reactive, but,
like methyl chloroform, are suspected of
causing  damage to  the  stratospheric
ozone layer. In addition, methylene chlo-
ride  is  a suspect mutagen.  Perchloro-
ethylene, the principal dry cleaning sol-
vent, does not  present a  hazard to the
stratosphere but has  been implicated as
being a carcinogen and also reacts slowly
in the atmosphere to  form oxidant.
  7.  Organic solvents of low or negligible
photochemical   reactivity  have  only
limited use in many industries. Most are
chlorinated organics  that find principal
applications as  cleaners for  metals and
fabrics. A few nonhalogenated VOC such
as  acetone,  methyl  ethyl ketone, and
isopropanol are of low  reactivity but
these can't possibly satisfy all the myriad
needs of the paint, plastics, pharmaceu-
tical, or many  other Industries. While
users of reactive VOC usually can employ
effective control equipment to recover or
destroy VOC emissions, they seldom have
the option  of  applying  reactivity con-
siderations in choosing solvents. Applying
reactivity restrictions to the surface coat-
ing industry would be especially disad-
vantageous since It would greatly Inhibit
the development of low-solvent coatings;
essentially  all  of  the organic  solvents
used to  constitute high-solids  coatings
and water-borne  coatings are, in fact.
highly reactive.
  8. It is recognized that smog chamber
studies conducted  to date are incomplete
because many  organic compounds have
not been examined and it has been im-
possible to duplicate all atmospheric sit-
uations.  For example,  there has  been
only limited examination of oxidant for-
mation under  relatively  high ratios of
VOC to NOX (30:1 and greater), compar-
able to rural conditions. Any policy on
photochemical reactivity necessarily has
to be open to revision as new information
is developed which may show specific
organic compounds  to  be more or less
photochemically reactive than indicated
by current data.

  Dated: June 29, 1977.
               EDWARD F. TUERK,
      Acting Assistant Administrator
     "  for Air and Waste Management.
    [FRDoc.77-18385 Filed 7-7-77;8:45 ami
                                   FEOEKAL REGISTER, VOL. 42, NO. 131—FRIDAY, JULY 8, 1977

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N                                            REFj VK7
%*    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
>,/                      WASHINGTON, D.C.  20460
                            JUL 2 8
                                                            OFFICE OF
                                                     AIR AND WASTE MANAGEMENT
 SUBJECT:   Seasonal Operation of Natural
           Gas-Fired Afterburners

 MEMO TO:   Regional Administrators
      It has been estimated that the use of afterburners for control of
 air pollutants required 0.4 percent of the total 22 trillion cubic feet
 of natural gas consumed in 1975 in the U.S.. While not a high percentage,
 this is a substantial amount of natural gas—equivalent, for example,  to
 the annual amount required to heat 62,000.homes in Washington, D.C.

      Many of these afterburners are required solely to reduce emissions
 of hydrocarbons to control ambient oxidant levels.  However, results
 from both statistical analyses of ambient data and smog chamber tests
 show that oxldants do not readily form at temperatures below about 59°F.
 Thus, in many parts of the U.S., the operation of afterburners required
 for oxidant control may not be needed during the winter months.   This
 fact and tr.c expectation mat natural gas will oe in aiiui u »upp"j  Jui \,,y
 the coming winter support an EPA policy of allowing states to permit
 natural gas-fired afterburners to be shut down during the coming winter
 season provided there is reasonable assurance that this action will net
 jeopardize the attainment or maintenance of the oxidant standard.   The
 situation in future winters should be evaluated in light of then-existing
 circumstances.

      The policy applies to gas-fired afterburners installed to control
 hydrocarbon emissions for the purpose of reducing ambient oxidant  con-
 centration.  It does not. apply to flares (which do not use gas as  an
 auxiliary fuel),  hydrocarbons vented to boilers, afterburners operated
 principally for odor control, or afterburners operated to control  toxic
 substances.  Some afterburners which control  hydrocarbon emissions also
 control, either primarily or secondarily, the emissions of carbon  monoxide
 and particulate matter.  The seasonal shutoff of some of these also could
 be permitted if neither the attainment nor the maintenance of the  ambient
 standards for those pollutants is jeopardized.

      Measurements of oxidant air quality indicate that ambient concentra-
 tions diminish substantially in many northern areas during the winter;
 northern urban areas in which summertime oxidant concentrations  often
 exceed the national standard by large amounts experience greatly reduced
                                 C-9

-------
                                  REF VI-7
concentrations  during  the winter season.  This observed seasonal phe-
nomenon  Is  consistent  with  the  theory of oxidant formation; high ambient
temperatures  and  strong  sunlight assist 1n the production of oxidants
from a complex  photochemical  reaction involving hydrocarbons and
nitrogen oxides.

      A recent analysis of oxidant air quality data and meteorological
data* Identifies  areas of the country which, during specified months,
experience  low  oxidant concentrations.  This analysis shows a high
correlation between maximum daily temperatures and maximum hourly
oxidant  concentrations, with concentrations above the national standard
becoming highly improbable  when maximum daily temperatures are consist-
ently below 59°F.  The analysis suggests that the maximum daily tem-
perature can  be used as a reasonably reliable indicator of the potential
for  oxidant formation and supports a policy which would permit seasonal
use  of natural  gas-fired afterburners in many areas.

      Figure 1 1s  a map of the U.S. on which study results are summarized.
It shows  general  areas (or  zones) in which seasonal shutoff of natural
gas-fired afterburners could be considered.  However, 1t 1s important
to note  that  local conditions may obviate seasonal  control  even though
shutdown  otherwise may appear to be acceptable.   If, for example, winter-
time  oxidant  concentration8; in a particular area are in violation of
the amuient scanuc.'u, or the ccr.ccr.tratlcr,: -re rjfflci^rtl
afterburner shutdown could create violations, you should neither encourage
nor allow seasonal afterburner operation even though the area is in a
theoretically acceptable zone.

     A policy to seasonally control afterburners can only be implemented
through the SIP process — by establishing new oxidant SIPs or by revising
existing SIPs.  Of course, the enforceability of the policy must be care-
fully considered in reviewing each specfic regulation.  The approval  of
SIP changes to permit seasonal afterburner operation need not require
detailed, time-consuming analyses of air quality impacts 1f the seasonal
shutdown time period is consistent with the zones delineated in Figure 1,
and if existing air quality data shows no past violations in the month
during which the afterburners will be shutdown.  The attached staff study,
supported by air quality data where available, normally should be adequate
technical support for a decision to approve the seasonal operation of
afterburners in a given location.  If an occasional high oxidant concentra-
tion has been noted during the winter months but the gas savings to be
achieved by afterburner shutoff appears to warrant favorable consideration
   •       **                               •
*See attached OAQPS "Staff Study:  Oxidant Air Quality and Meteorology,"
dated February 6, 1976.

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                                      KEF  VI-7


of a variance request, a short trial period to test the impact on oxidant
concentrations may be suggested.  If it is found that ambient violations
persist or are exacerbated, the trial program must be terminated.

     It is recommended that you notify those state agencies in your
Region which may be eligible to implement this program that EPA sup-
ports a policy which would permit sources to shut off afterburners
during cold weather months this year when oxidant concentrations are
below the ambient standard.  In discussing this policy with state agency
personnel, it is important to emphasize that the policy pertains only to
oxidant control strategy and that EPA is not encouraging a wide-spread in-
crease in hydrocarbon emissions.  Moreover you must make it clear that,
consistent with §116 of the Clean Air Act, the state is not required in
any way to relax its strategy.
                              Roger jftrelow
                        Assistant Administrator
                      for Air  and Waste Management
 Enclosure

 cc:   Stan  Learo
      William Frick
                                  0-11

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  DATE:
I 4 AUG 15/8  UN'TED STATES ENV|RONMENTAL PROTECTION AGENCY
                                                                     REF  VI-10
SUBJECT:   Clarification of EPA Policy on Emissipns^of Methyl  Chloroform
  FROM:   Walter C.  Barber, Director
         Office of  Air Quality Planning and Standards (MD-10)

    T0:   Regional Administrator, Regions I-X

              The purpose of this memo is to clarify EPA's position with  regard
         to State and Federal regulation of emissions of methyl  chloroform
         (1.1.1. trichloroethane).  On July 8, 1977, EPA published the  present
          Recommended Policy on Control of Volatile Organic Compounds"
         (42 FR 35314).   This policy exempts methyl chloroform from inventory
         requirements and regulations to meet the national  ambient air  quality
         standard for photochemical oxidants.  However,  the policy indicated
         that methyl  chloroform had been implicated as having deleterious effects
         on stratospheric ozone and therefore may be subject to  future  controls.
         Nevertheless, the policy seems to be encouraging a shift to the
         uncontrolled use of methyl chloroform in place  of trichloroethylene and
         other regulated solvents in metal degreasing operations.

              We have been advised by -the Office of Toxic Substances that methyl
         chloroform should be considered potentially harmful to  the ozone layer
         and that they are performing the necessary evaluations  and assessments
         prior to pursuing further regulatory initiatives.   Hence, its  use in an
         uncontrolled fashion should not be encouraged.   Accordingly, OAOPS has
         begun the  necessary actions to propose removal  of  methyl chloroform from
         the list of  exempt volatile organic compounds CVOC).  However, we do not
         expect this  action to be completed before the State Implementation Plans
         for photochemical oxidants are to be submitted.   In addition,  I have
         directed that the new source performance standards  to be proposed for
         solvent metal cleaning operations, as well  as any  other solvent uses,
         require positive control of all  VOC emissions including methyl chloroform.

              I  recognize that many States are well  along in the preparation of
         their regulatory packages and inventories.   In  order not to change the
         existing guidance at this late date, I  am requesting that you  advise
         your State directors that, although we will  not  disapprove a State
         oxidant SIP  submittal  which exempts methyl  chloroform from control, we
         are very concerned with the environmental  risks  associated with wide
         scale substitution to methyl  chloroform;  and  that  the uncontrolled use
         of methyl  chloroform as an approved means  for compliance should be avoided
         wherever possible.

         cc:   Director,  Air & Hazardous Materials  Division,  Regions I,  III-X
              Director,  Environmental  Programs Division,  Regions JI
              Chief,  Air Branch, Regions  I-X
              Steven  D.  Jellinek, Office  of Toxic Substances
              Warren  Muir,  Office of Toxic Substances
  Form 1370-6 
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                       REF VIII-3
 F.      F5
"VJ'KT^*^3* "' •
'••t&.i'O&M11*****- -'
 L^~
                                                   DRAFT
OZONE AND OTHER PHOTOCHEMICAL OXIDANTS

Final Report  (Draft)

August 1978
By:  Richard H.  Thuillier,  Senior Research Meteorologist
     Atmospheric Sciences Laboratory
Prepared  for:

U.S. Environmental  Protection Agency
Research  Triangle Park,  North Carolina  27711

Attn:  Mr.  Norm Dunfee
       Pollutant Strategies  Branch
       SASD,  MD-12

Contract  No.  EPA-68-02-2835
Work Assignment No- 9
 SRI Project 6780
 Approved:
 R.'T".H. Collis, Director
 Atmospheric Sciences Laboratory
        ). Jones, Exec^tiveMDirector
 Advanced Development Division
               Ave. • Menlo Park, California 94025
              Cable: STANRES, Menlo Park • TWX: 910-373-1246

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                               CONTENTS

PREFACE 	  1
   I  INTRODUCTION	2
  II  DEFINITIONS, EFFECTS, AND STANDARDS 	  3
      A.   What are Photochemical Oxidants	3
      B.   Are Oxidants Harmful?	3
      C.   How Clean Should the Air Be?	5
 III  THE OZONE PROBLEM	,
      A.   Where Does Ozone Come From?	7
      B.   Which Sources Contribute Most to Ozone Problems. ...  -i
      C.   How Does the Weather Affect Ozone Pollution	g
      D.   How Serious is the Ozone Problem in the
           United States	g
  IV  OZONE AND THE LAW	.'	"jg
      A.   What is Required?	.'	]Q
      B.   Who is Responsible	10
      C.   What are the Penalties for Noncompliance	1]
   V  APPROACHES TO CONTROL 	 13
      A.   What Can Be Done?	13
      B.   What Measures are Appropriate	14
      C.   How Much Control Will be Necessary	.,
                                                                  14
      D.   How Should Controls be Applied?.  	
                                                                   15
      E.   Who Should be Involved 	
                                                                   16

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                                      PREFACE

     Under provisions of  the  Federal  Clean Air Act,  the U.S. Environmental
Protection Agency  (EPA) has issued  National Ambient  Air Quality Standards
(NAAQS).  These standards specify the maximum amounts of air pollutants to
which the general  public  may  safely be exposed in the interest of health
and welfare.  When the NAAQS  are found to be violated in any location, the
Clean Air Act requires that steps be  taken to bring  the air in that location
into compliance with standards  by a specified date.  Under the Clean Air
Act Amendments of  1977, local governments are empowered and encouraged to
participate fully  in air-quality planning for their  areas.
     Ozone is an air pollutant  for  which NAAQS have  been issued by the EPA.
Frequent and widespread violations  have been recorded and extensive remedial
measures will be required.  Current efforts to mobilize the nation to solve
the problem have been hampered  by the complexity of  the issues and controversy
regarding appropriate solutions.
     To summarize  and clarify the issues, the EPA Office of Air Quality
Planning and Standards has prepared this document under contract.  This
summary attempts to provide the local  decisionmaker  and other interested
persons with an understanding sufficient for informed consideration of
evolving issues and arguments related to oxidant pollution and its control.
     Source material listed in  the  bibliography should be consulted by
persons desiring a treatment of the issues in greater depth.

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                               I    INTRODUCTION

     By the Clean Air Act Amendments of 1970, Congress gave EPA the responsibility
for setting air-quality standards.  As an outgrowth of studies relating
photochemical oxidants to health effects and damage to plant and materials,
EPA in 1971 issued a standard for photochemical  oxidants.   This standard
was set at 0.08 parts of oxidant per million parts of air as a one-hour
average not to be exceeded more than once in any given year.  Subsequent
reevaluation led EPA in June of 1978 to propose a revised primary standard
to apply only to the most abundant oxidant, ozone, as a one-hour average
concentration of 0.10 ppm not to be exceeded more than an average of once
per year.  The proposed secondary, welfare related standard is 0.08 ppm.
      The Clean Air Act Amendments of 1977 require that the states make
steps to achieve the standard by 1987 at the latest, and by 1982 where
feasible.  Because ozone pollution is substantial, widespread, and harmful
to both health and welfare, extensive measures will be required to eliminate
violations of the standard.  The states are required to hold public hearing
to receive comments on the issues before submitting to EPA their plans to
implement appropriate measures.  To further participation in the public
hearing process, this document has been prepared to inform local decisionmakers
and the interested public on the issues related to the nature and control
of ozone pollution in the United States.

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                    II     DEFINITIONS,  EFFECTS,  AND  STANDARDS

A.   What are Photochemical  Oxidants?
     The term "oxidants"  describes  a complex group  of compounds found in
the ambient air.  The  term  "photochemical" indicates that much of these
particular oxidants are formed  in the  air by chemical reactions requiring
-the presence of sunlight.  Oxidants in the ambient  air were first associated
with undesirable effects  on  human health and welfare three decades ago,
when they were found to be major constituents of southern California
"smog."  Since that time, much more has been learned about the photochemical
oxidants and their effects on public health, vegetation, certain ecosystems.
and materials.  Ozone—the most abundant oxidant—has been singled out for
special concern from a public health and welfare standpoint.

B.   Are Oxidants Harmful?
     Numerous studies have been undertaken over the last three decades  to
determine how harmful the oxidants are to public health and welfare.  The
results are detailed in the EPA publication Air Quality Criteria for  Ozone
and Other Photochemical Oxidants.*  It should be noted that with synergistic
effects of ozone and other air contaminants, there has not been a sufficient
study to understand this relationship.  The following is a summary of the
                                       i
most significant effects.
*EPA-600/8-78-004 (April 1978)  An earlier edition was published in 1971,
at the time the original NAAQS was adopted.

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Public Health

o    The mechanical function of the lung is affected by exposure to
     ozone for periods on the order of two hours.   The effect is
     pronounced at concentrations of 0.37 ppm or more; evident but
     less pronounced at concentrations from 0.25 to 0.37 ppm, and
     in some subjects this effect occurs at concentrations in the
     range of 0.15 to 0.25 ppm.

o    Asthma attacks occur more often when ambient concentrations of
     ozone reach 0.20 ppm for a one-hour period.  For some asthmatics
     and other sensitive people, there is a likelihood of effect at
     concentrations from 0.15 to 0.20 ppm.

o    Ozorie exposures in the range of 0.15 to 0.25 ppm for an hour
     or so increase the risk of cough, chest discomfort, headache,
     and eye irritation.

o    There is evidence of impairment of physical performance (athletic
     performance) at ozone concentrations as low as 0.15 ppm.

o    Vigorous exercise is likely to increase the risk of health
     effects from ozone.

o    Existing evidence shows no consistent relationship between
     ozone exposures and mortality rates.

o    No convincing evidence is yet available relating either short-
     term or long-term ozone exposure to chronic health effects.

Public Welfare

o    Ozone cause visible injury to a variety of plant species.

o    Ozone reduce the yields of citrus, cotton, potatoes, soybeans,
     wheat, spinach, and other sensitive crops.

o    Concentrations of ozone as low as 0.1 ppm for a one-hour
     exposure and 0.04 ppm for a four-hour exposure will affect
     some vegetation.

o    Ozone affect entire ecosystems, as evidence by damage to
     mixed conifer forests in California, reduction in the fruit
     and seed diet of small mammals, and alterations in species
     composition and wildlife habitat.

o    Ozone accelerates the deterioration or rubber, textile dyes
     and fibres, and certain paints and coatings.

o    Both health and welfare effects have severe economic impacts,
     which can be measured in terms of monetary losses totalling
     hundreds of millions of dollars each year.

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C.   How Clean Should the Air Be?
     Under the provisions of the Clean Air Act, EPA is charged with the
establishment of standards for  the cleanliness (quality) of the ambient
air.  "Ambient air" means the outdoor air to which the general public,
structures, plants, and animals are exposed.  A standard is a combination
of the amount of pollutant in the air and the length of exposure permitted
as a maximum in the interest of public health and welfare.  Standards are
established by the EPA after consideration of effects and application of an
adequate margin of safety.  Separate standards are authorized by the Clean
Air Act for protection of public health  (primary standards) and for protection
of public welfare (secondary standards).
     On 30 April 1971 the EPA published  a primary (and secondary) standard
for photochemical oxidants of 0.08 ppm as a one-hour average not to be
exceeded more than once in any  given year.  The human health effect category
of most concern is aggravation  of chronic lung disease and the basic work
documenting the effect is the Schoettlin and Landau asthma study.  This was
a key study in determining the  level of  the existing standard.  Based on a
reevaluation of this study, the current  criteria document attributes an
increase in asthmatic attacks to a level of 0.25 ppm and not 0.10 ppm as
presumed when the existing standard was  promulgated.  On 22 June 1978, the
EPA proposed a new one-hour average primary standard of 0.10 ppm for ozone
alone, not to be exceeded more  than one  time per year on the average.
The secondary standard remains  at 0.08 ppm.  This proposed standard anticipates
a few excesses in some years, balanced by years with no excesses at all to
give an average of one excess or less per year.  Because ozone consititutes
the bulk or oxidants in the air and has  been associated with most of the

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health effects previously ascribed to total oxidant, ozone is proposed to
replace total oxidants as the pollutant of concern.  Ozone can also be
measured more reliably than the other oxidants.
     Because of the specific importance of ozone, the probability of a
revised standard, and the confusion attending the alternate use of the
terms "oxidant" and "ozone," the term "ozone" is used exclusively throughout
the remainder of this document.

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                            Ill    THE OZONE PROBLEM

A.   Where Does Ozone Come From?
     Unlike many other pollutants, ozone  is not introduced directly to the
air by man or nature, but forms  in the air by chemical reaction.  The
compounds called "precursors," that  eventually react to form ozone may be
natural constituents of  the atmosphere (as are oxygen and nitrogen), may
be introduced directly as pollutants, or  may be formed (as is ozone itself)
by chemical reaction.
     High  in the upper atmosphere, large  amounts of ozone are produced by
sunlight from the  oxygen present in  the air.  Near the ground, ozone is
produced primarily from  man-made compounds.  While many differenct compounds
are  involved, two  basic  precursor classes control the ozone production
process:   volatile organic  compounds (VOC) and oxides of nitrogen (NOX).
     VOC enters the air  from  a  variety of human activities, among them
fossil  fuel  combustion  (primarily in auto exhaust), chemical processing,
fuel  storage and handling and solvent usage  (such as painting or degreasing).
VOC  also enter  the air  from natural  sources, such as biological decay and
the  vegetative  growth process.   Oxides of nitrogen, a component in the
photochemical  process,  is primarily  emitted  to  the atmosphere from the
burning of fossil  fuels.

B.    Which Sources Contribute Most to Ozone  Problems?
      Because the air moves  readily from one  location  to  another, the air we
breathe at a given place and time will  contain  ozone  from natural as well
as man-made sources. Measurements have shown,  however,  that ozone  concentrations

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in and near large urban centers where man-made sources predominate,  are
frequently far greater than concentrations in remote locations unaffected
by human activity.  These measurements; coupled with a variety of theoretical
studies, point to human activity—especially that concentrated in large
urban centers—as the source of primary concern.  Control  of emissions of
ozone precursors associated with human activity will be instrumental in
achieving the ozone standard throughout the United States.

C.   How Does the Weather Affect Ozone Pollution?
     Ultraviolet radiation from sunlight is required for the photochemical
process.  Ozone episodes therefore occur typically on sunny days in  spring,
summer, and fall, when the sun is high enough to provide sufficient  ultraviolet
radiation.  On cloudy days and during the winter months, ozone levels
rarely exceed the federal standard.  Sluggish air movement aids in ozone
production by allowing air parcels to remain longer over the source  areas
and  permitting large amounts of precursors to accumulate and ozone to form.
Temperature inversions (i.e., layers of warm air several hundred meters
above the cooler air nearer the ground) frequently  trap the pollutants near
the  ground.  Warm temperatures have always been associated with ozone
episodes, although  the precise role of temperature  in ozone production has
not  been adequately defined.

D.    How Serious  is the  Ozone  Problem  in  the  United States?
      Measurements indicate that ozone  levels  in violation of  the standard
occur in virtually  every part  of  the United  States.  Ozone problems have
been found  in  rural as well as  urban areas.   The highest  concentrations  of
ozone are  usually found  a few  miles  downwind from large urban centers,
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which are the principal source areas.  The ozone standard is exceeded
frequently in and near these urban centers, as often as 100 or more days
per year in some locations, and concentrations exceeding as 0.2 ppm are not
uncommon and as high as 0.5 ppm can  occur at times in a few communities.
The seriousness of  the problem is  highlighted by the fact that violations
of the  ozone standard  have been detected  in virtually every area where
measurements have been taken, with the exception of a few predominantly
 rural  locations.

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                            IV    OZONE AND THE LAW

A.   What is Required?
     Under the Clean Air Act, states must submit to EPA State Implementation
Plans (SIPs), detailing approaches toward attainment and maintenance of all
air-quality standards.  In areas where the ozone standard has not yet been
attained (nonattainment areas), SIPs must be revised to include control
strategies which provides for attainment of standards by December 31, 1982.
In areas where the attainment of standards cannot be demonstrated by implementing
reasonably available control measures the deadline can be extended (up to 5
years) until 1987.  Implementation planning for nonattainment areas must be
completed in time for submittal of SIP revisions to EPA by January 1, 1979.

B.   Who is Responsible?
     While the EPA bears ultimate responsibility for enforcing requirements
of the Clean Air Act, the law provides for maximum participation of state
and local governments in the formulation and implementation of plans and
strategies aimed at achieving the air-quality standard for ozone.  Each
state must provide for implementation, maintenance, and enforcement of
primary and secondary air-quality standards in designated areas.  Since
many control measures for ozone reduction will strongly affect local jurisdictions,
the Act provides that attainment plans be prepared, where possible, by an
organization of elected officials of local governments in the affected
areas certified by the state for this purpose.  Otherwise, a state agency
must prepare the plans.  The plan must demonstrate that necessary requirements,
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timetables, and compliance schedules have been adopted through submittal of
a legally enforceable document and that the agency or organization identified
in the plan as being responsible for carrying out the plan are committed to
the implementation and enforcement of appropriate plan elements.  Attainment
plans must be developed with the continuing cooperative, and comprehensive
transportation planning process mandated by federal law and with the general
air-quality maintenance planning process of the SIP.  Attainment planning
requires a coordinated effort and includes local agencies responsible for
transportation and maintenance planning.  In carrying out any requirements
of the Act that bear upon the perogatives of local government, the states
must provide a satisfactory process of consultation with general-purpose
local governments and designated organizations of their elected officials.

C.   What are the Penalties for Noncompliance?
     One of the principal penalties attached to inadequate planning for
nonattainment areas has to do with the construction or modification of
major stationary sources, such as industrial facilities.  After June 30,
1979, no such construction or modification that contributes to violations
of NAAQS may take place in a nonattainment area unless an adequate plan for
attainment exists.  In addition, inadequate implementation planning in
nonattainment areas precludes the approval of projects and grants for
transportation or air quality authorized, under the United States Code,
other than for safety, mass transit, or transportation improvement related
to air-quality improvement or maintenance.
     EPA is required to enforce any requirement of a State Implementation
Plan when it is determined that the state has failed to enforce the plan
effectively.  Enforcement against a source may take the form of an order to
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comply or a civil action.  Persons violating or refusing to comply with any
order of the EPA Administrator or violating requirements of an applicable
implementation plan during a period of federally assumed enforcement can be
subject to a civil penalty of not more than $25,000 per day of violation,
or to permanent or temporary injunction, or both.
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                           V     APPROACHES TO CONTROL






A.   What Can Be Done?



     As discussed earlier, the ozone problem results primarily from chemical



reaction of man-made VOC and NOV.  It is logical, that the control of ozone
                               /x


precursors generated by human activity, particularly in large urban centers,



is necessary to achieve reductions in ambient ozone levels.



     Laboratory studies suggest that control of VOC is an effective approach



to lowering ozone levels in urban areas and their immediate environs.



Significant downtrends in ozone pollution have been recorded in the Los



Angeles Basin and the San Francisco Bay Area, where VOC control programs



have been underway  for some time.  Studies suggest that control of NO  may
                                                                     A


not be as effective in reducing ozone in urban areas.  Because of the



demonstrated effectiveness of VOC control, the current EPA strategy for



reducing of the oxidant problem in urban areas is focused primarily on VOC



control, however  programs such as the FMVCP reduce emission of both VOC and



NO  .  Recent research, has indicated that rural areas may also suffer from
  A


ozone pollution and that urban pollutants—ozone as well as its precursors-



can travel considerable distances at relatively high concentrations.



Because the chemical composition of rural air differs from that of urban



areas, NO  control  may be more effective in controlling rural ozone problems.
         /v

For this reason,  NO control  has received greater attention in recent years
                    X


both for rural areas and for  urban areas affecting rural areas through



transport.


     On the whole,  studies indicate that a more effective  program for



reducing urban ozone concentrations should emphasize the control  of  VOC.



Current strategy  favors a vigorous control program for VOC but a  cautious
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approach to control of NO  beyond that required to attain the ambient air
                         A
quality standard for nitrogen dioxide.  Additional emphasis on NOX control
may be required, however, at a later date.

B.   What Measures are Appropriate?
     State Implementation Plans for areas which have not attained the NAAQS
for ozone, must contain limitations on the amount of ozone precursors that
enter the air and timetables for compliance with such limitations.   Other
measures must be contained, as necessary, including (as a minimum)  transportation
controls, inspection and maintenance plans for autos for cities greater
than 200,000 population when a state has requested an extension beyond 1982,
and preconstruction review of direct sources of air pollution.  State
Implementation Plans may (but are not required to) contain provisions for
land use controls, preconstruction review of indirect* sources of air
pollutants, and other such measures as may be appropriate.

c.   How Much Control Will be Necessary?
     Maximum ozone levels in and around major urban centers are typically
two to three times the federal ambient standard.  Assuming a direct proportion
between VOC and ozone reductions, VOC emissions in these areas will have to
be reduced to one-half to one-third of their current values. This represents
a conservative estimate, since studies have indicated that reductions in
VOC yield less than proportional reductions in ozone concentration.  When
*An indirect source is a facility such as a parking lot that tends to
increase air pollution from mobile sources (e.g., cars).
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ozone contribution from natural sources (including vegetation and particularly
upper atmospheric ozone intrusion) is considered, which amounts to approximately
0.04 ppm, an even greater reduction in the contribution from man-made
activities may be required.
     Methods for estimating required degree of control have been and are
continuing to be developed.  Although no single currently available model
is satisfactory in every respect, evidence from a variety of modeling
techniques indicates a substantial control requirement in many areas.
Research  is continuing at EPA to develop improved models to aid in determining
the most  effective approaches to ozone control.

D.   How  Should Controls be Applied?
     Most urban and many rural  areas now have ozone concentrations greater
than the  national standard.  Since attainment of the ozone standard will be
costly, there is  an obvious and justifiable interest in achieving the most
equitable distribution of the burden and the most efficient application of
 the  control  program.   One of the  most  sensitive  issues at present concerns
 the  division  of responsibility  for control when  a portion of a local ozone
 problem results from pollutants transported from nonlocal source areas.
This  is  especially  sensitive  in those  parts of the United States where
transported  pollutants from urban centers  in close proximity accumulate
under  stagnant  weather conditions  to form  a regional  "blanket" of background
ozone.
     At present it  is difficult to partition responsibility for ozone
control.   Considering, however, the degree of control that will be required
to attain the standard,  it  is reasonable,  until  more  information is  at
hand,  for everyone to exert maximum effort toward local control of VOC
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emissions.  Cooperative efforts in implementation planning among the States
should minimize any gross inequities.

E.   Who Should be Involved?
     The ozone problem is one that affects every citizen:   Very few urban
locations are free of ozone pollution and none are free of sources  of
pollution which cause ozone and virtually everyone is subject to the
health and welfare effects.  Because ozone is a regionwide problem  with a
full spectrum of sources and causes, everyone will bear some portion the
great cost for ozone control.  For these reasons, everyone should involve
themselves in the solution of the ozone problem by keeping well  informed
and cooperating fully in the planning and implementation phases  of  the
solution process.
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