DRAFT CRITIQUE OF GUIDELINES FOR PREPARATION OF A 10-YEAR AIR QUALITY MAINTENANCE PLAN MAY, 1974 Prepared for U.S. ENVIRONMENTAL PROTECTION AGENCY Research Triangle Park, North Carolina alan m. voorhees & associates, inc.* TRANSPORTATION & URBAN PLANNING ------- CRITIQUE OF THE GUIDELINES FOR PREPARATION OF A 10-YEAR AIR QUALITY MAINTENANCE PLAN DRAFT REPORT May 31, 1974 Prepared by ALAN M. VOORHEES & ASSOCIATES, INC. Westgate Research Park McLean, Virginia 22101 Contract N. 68-02-1388 EPA Project Officer: Thomas Donalson Prepared for ENVIRONMENTAL PROTECTION AGENCY Office of Air and Water Programs Office of Air Quality Planning and Standards Research Triangle Park, North Carolina 27711 ------- INTRODUCTION A. Based on Problems in Attempting to Follow in Actual Prototype Plan Development B. 10-Week Period II. REVIEW AND ANALYSIS OF DRAFT EPA GUIDELINES DOCUMENTS A. Documents Reviewed (Annotated Bibliography) B. Analysis of Each Guidelines Document C. Suggested Additions D. Suggestions for a Similar Document in 5 Years III. CRITIQUE OF EPA APPROACH TO AIR QUALITY MAINTENANCE A. Overview B. Unresolved Issues C. Recommendations for Resolution of These Issues and Alternative Approaches ------- CHAPTER I INTRODUCTION A. GENERAL The purpose of this report is to present a critique of the U.S. Environ- mental Protection Agency's (EPA) guideline documents available for use in the development of ten-year Air Quality Maintenance Plans (AQMP). This critique is part of a larger Task Order which requires the preparation of a sample AQMP for the St. Louis, Missouri-Illinois Air Quality Mainte- nance Area (AQMA). The critique requires an analysis of the scope, content, potential applicability, and usefulness of the available guideline documents. As such, the critique will be based primarily on problems that have been encountered in attempting to use the guidelines in the development of the sample AQMP for St. Louis. This approach was taken because it was felt that the critique of the guidelines should be based on attempting to actually use them rather than on a theoretical basis. The results from such an approach would produce much more meaningful results in terms of the applicability and usefulness of the guidelines. The overall project is scheduled for 10 weeks. Because of the limited time duration, many of the procedures suggested in the guidelines to be accomplished in a sequential order had to be completed along a parallel time frame. This situation has caused assumptions to be made that would not occur during the development of the actual plan. These assumptions will be noted in the critique. ------- B. ST. LOUIS AREA BACKGROUND In order to more fully understand the comments contained in this critique, it would be helpful to point out some background information about the St. Louis area. St. Louis was chosen as a sample city for AQMP development principally because it is an interstate region. In addition, the jurisdiction of the various federal agencies emanate from two regional centers: Chicago for the Illinois portion, and Kansas City for the Missouri portion. This means that all planning review must be done by two federal regions, depending upon which is involved. The St. Louis area is composed of seven counties and one independent city. More than 400 taxing agencies exist in the metropolitan area. A total of over 300 municipalities exist, each with their own zoning power (Illinois also has a law which allows for zoning by municipality of the land up to 1.5 miles outside its boundaries). In addition to the munici- palities, over 100 other taxing bodies exist. These consist of counties, special districts, school districts, etc. Planning for the area is done by a variety of agencies. The A-95 and 3C agency is the East-West Gateway Coordinating Council. It is a voluntary planning agency which has no power of implementation. Any of the member governments can withdraw from the Council at anytime. The three Illinois counties have formed the Southwest Illinois Metropolitan Area Planning Commission which does the planning for the three counties. The City of St. Louis, St. Louis County and St. Charles Counties in Missouri have active planning agencies with professional staff who do the planning for these governmental agencies. Franklin County has a part-time planner who also works in the county engineer's office. Jefferson County has no planning and, in 1971, eliminated its zoning ordinance. In addition to ------- these county agencies, each community has a planning board which may or may not have professional staff. The larger communities do, the smaller areas don't. The smaller communities usually contract with private consultants or, in St. Louis County, with the county planning department for their planning needs. Politically, the area is also quite diverse. Illinois has a Democratic administration; Missouri a Republican. The City of St. Louis is Democratic; St. Louis County is Republican. Since the 1920s, several attempts have been made to form an areawide type of government between the City of St. Louis and St. Louis County. All attempts have failed by wide margins at the polls. With this local information in mind, greater insight may be obtained from the comments in the critique. ------- CHAPTER II REVIEW AND ANALYSIS OF DRAFT EPA GUIDELINE DOCUMENTS A. DOCUMENTS REVIEWED Annotated Bibliography of EPA Guideline Documents Mechanics of 10-Year Plan Preparation and Implementation. Final Report Task 1. Guidelines for Preparation of 10-Year Air Quality Maintenance Plan, March 8, 1974, prepared for U.S. Environmental Protection Agency, Research Triangle Institute. This document is primarily introductory, presenting an overview of the requirements placed upon the individual states for the development of an Air Quality Maintenance Plan (AQMP). It deals with those areas within each state which currently or in all likelihood will exceed the National Ambient Air Quality Standards (NAAQS) within the 1975 through 1985 period. These areas will be identified by the states as Air Quality Maintenance Areas (AQMA). Included is a general summary of the purpose of the AQMP and a schedule for the plan development. Although the AQMP is primarily the state's responsibility, coordination efforts between state and local governments are stressed as vital to the development and implementation of the AQMP. Five alternative modes for the division of this responsibility are presented along with general conditions warranting their use. These are: o The State agency conducts all air quality maintenance planning and implementation activities within the State. e The State agency participates with local agencies in preparing and implementing the AQMP. ------- e The State agency conducts planning operations, but delegates implementation activities to local agencies. Planning is done jointly by State and local agencies; implemen- tation is done by local agencies. o Planning is done jointly by State and local agencies, but all implementation is done by State. Since each AQMA is unique, it will require a tailored approach. When interstate management situations arise, the approach is formation of a task force on interstate cooperation to define the coordination problem, determine the appropriate course of action, and establish the arrangements needed. Two methods of coordination are noncomoactual and compactual. In addition to the interstate coordination, methods of cooperative working relationships between the states are suggested. These include data sharing, utilization of joint personnel and equip- ment, centralized legal research, etc. The report includes a step-by-step procedure for preparing a 10-year AQMP. The outline suggests a plan preparation sequence, generally explaining each task in the action sequence, a time schedule for the plan, an applicable bibliography of EPA guidelines that should be used, and a general plan format indicating the items to be included. A short discussion is included on procedure and context of the state and local plan review. The document was developed to assist states with: Plan Development Intra- and Intergovernmental Coordination o Plan Review Institutionalization of the Air Quality Maintenance Process, Draft Report, Task 2, Guidelines for Preparation of 10-Year Air Quality Mainte- nance Plans. April, 1974, prepared for U.S. Environmental Protection Agency, Research Triangle Institute ------- This document is intended to assist State and local governments in the identification of the relationship between the AQMP and other community goals, plans, and activities. It is also intended to suggest ways in which the AQMP and its development and implementation can be integrated into overall community activities. This takes the form of functional programs with which the AQMP must be coordinated, the existing framework available for this coordination, and the suggested process for the implementation of the air quality maintenance for an AQMA. The functional programs requiring coordination can be separated into three basic areas: environmental, transportation, and land use. The programs identified are: ENVIRONMENTAL Air Pollution Control e State Implementation Plans (SIP) e Stationary Source Review o New Source Performance Standards e The Federal Motor Vehicle Control Program (FMVCP) e Transportation Control Measures e Indirect Source Review Water Planning and Control Federal Water Pollution Control Act 1972 as amended Section 303 Section 208 Section 201 Section 402 Solid Waste Federal Solid Waste Disposal Act, 1970 as amended ------- Other Programs Noise Abatement TRANSPORTATION Federal-aid Highway Act of 1970 This act must be interfaced with air quality maintenance activities because of its effect on the growth and development patterns of urban areas due to its making funds available for the construction of transportation facilities. LAND USE PROGRAMS Coastal Zone Management Act of 1972 National Land Use Policy Legislation on national land use is currently in Congress and no final action has been taken. Should the legislation come about in the near future, it will have an impact on the AQMPs required by 1975. The coordination of these various programs should be at the regional level. Two coordination mechanisms are discussed: the A-95 and the Environmental Impact Statements (EIS). Two coordinating agencies are also discussed: the Regional Planning Commission (RPC) and the Council of Governments (COG). Limitations of these two agency types are presented. The implementation mechanism is briefly discussed, but reference is made to the Task 1 report for a more detailed discussion. Included, as a supplement, is a discussion of legal constraints and general considerations. There are two legal constraints: e The institutional structure which must provide legally enforce- able procedures for ensuring the attainment and maintenance of NAAQS. ------- 9 The structure and arrangements for plan development and implemen- tation which must be such that ultimate responsibility rests with the State. The document was developed to provide an impetus to State and local decision-makers faced with air quality maintenance requirements. In this manner, they could determine specific institutional arrangements and roles tailored to their own jurisdictional needs. Maintenance Strategies, Draft Report, Task 3. Guidelines for Preparation of 10-Year Air Quality Maintenance Plan, May 1974, prepared for U.S. Environmental Protection Agency, Research Triangle,Institute and PEDCO Environmental, Inc. This document is intended to describe several alternative administrative and technical approaches for the maintenance of air quality standards in designated AQMAs. It suggests a general procedure for selecting approaches which are best suited for a particular AQMA. These procedures assume, however, that certain detailed projections are available from an analysis of the AQMA. The method for conducting this analysis is presented in another guideline document. The evaluation procedure for selecting a maintenance strategy uses the results of the analysis and other infor- mation to screen potential measures for: Administration feasibility Contributing source control effectiveness o Compatibility with other control measures The measures are then grouped as to their capability of maintaining air quality standards and are selected using cost and social acceptability as primary considerations. The report indicates that two basic types of maintenance measures are available: administrative and emission control. ------- Initial Screening e Project Emissions and Ai. Quality Estimate Emissions to be Prevented 0 Estimate Further Reduction from Existing Sources o Determine Potential Source Category Condi dates o Determine Maintenance Measure Applicability o Determine Contribution to Emission Reduction and/or Air Quality Impact o Determine Compatibility of Measures o Develop Alternative Maintenance Measures Alternative Maintenance Strategies Evaluation o Social Effects o Economic Effects o Select Preferred Maintenance Strategy The report then explains in greater detail the measures that could be used for the maintenance strategies. Administrative Measures Emission Allocation Procedures e Regional Development Planning Emission Density Zoning a Zoning Approvals and Other Indirect Regulatory Controls e Transportation Controls Emission Charges o Transfer of Emission Source Location e Indirect Source Review e Environmental Impact Statements (EIS) ------- Emission Control Measures New Source Performance f'andards Revision of Existing SIP Control Measures Phaseout or Prohibition of Emission Sources Fuel Conversion Energy Conservation and Utilization o Combination of Emission Sources e Special Operating Conditions o Stack Height Regulations o Control of Fugitive Dust Sources The report then presents a technical procedure for assessing the interaction between the various control measures. Legal authority requirements are also presented. This authority eminates from the states police power and comes from four legislative areas: zoning, direct regulation, licensing, and taxation. Relation of Land Use and Transportation Plans to Air Quality, Draft Report, Guidelines for Preparation of a 10-Year Air Quality Maintenance Plan, April 26, 1974, Alan M. Voorhees and Associates, Inc. prepared for U.S. Environmental Protection Agency. The purpose of this document is to indicate the relationship between land use and transportation planning and air quality. The document accom- plishes this end by first explaining what the land use plan is and how it fits into the overall comprehensive planning program for an AQMA. The land use plan is then shown to be a map for potential patterns of air pollution. The sources of this pollution can be put into three categories: Point, Source, Line Source, and Area Source. Data needs are then presented which will be used for more detailed analysis of these various sources and their relationship to land use. A discussion is then presented on the power that land use planning has in terms of implementability of the ------- plan. Two mechanisms are mentioned as needed to implement the plan: mechanics of enforcement and the integrative aspects of the plan as it relates to other components of the comprehensive plan. In line with the integrative aspect of the plan, the "3-C Process" is out- lined. This process comes from the wording of the Federal-aid Highway Act of 1962 for projects approved after July 1, 1965 in urban areas of more than 50,000 population. It required that a Continuing, Comprehensive transporta- tion planning process must be carried on Cooperatively in the state and local communities. By its very nature this process requires integration of all planning activities. A generalized methodology is presented for the consideration of air quality within the overall planning process. This process should include: o Land Use Planning e Transportation Planning e Social Planning e Environmental Planning Other Planning Aspects Tools and information requirements are presented that are needed to relate land use to air quality. Some of these requirements are illus- trated in a review of related studies that have been completed in various sections of the country. A series of conclusions are drawn with regard to the state-of-the-art of relating land use to air quality for AQMAs. The last section of the document presents a procedure for utilizing existing land use and transportation plans to project and allocate emissions. This procedure is based on a set of assumptions and criteria outlined in the document. A general approach is given for pollutant and ------- source problem definition and for problem area and time period analysis. A methodology is then presented for projecting and allocating emissions and/or air quality in AQMA's. This methodology is for four source categories: e Area Source Emissions Power Plant Emissions 0 Point Source Emissions o Mobile Source Emissions The document concludes with a summary. It states that the methodologies described in the document represent an approach which is considered to be applicable in most urban areas within the period for the plan analysis and development. It may be expected that each area will make modifica- tions to the method described, based on local conditions. It may also be anticipated that refinements will be made, both to the plan and to the guidelines over time. Manual of Instruction for Projecting County Emissions. Preliminary Draft. May 15, 1974, Booz-Allen Hamilton. This document was not received in time to be placed in the annotated bibliography. However, its contents were reviewed for use in the course of performing this Task Order. ------- B. ANALYSIS OF EACH GUIDELINE DOCUMENT Task 1 -- Mechanics of 10-Year Plan Preparation and Implementation As noted in the annotated bibliography, this document was to provide the states and local agencies with alternative methods of developing the coordination needed for plan preparation and to provide a sequence of tasks required for the plan preparation. Five modes were indicated as possible methods of coordination between state and local governments with regard to plan preparation and plan implementation. In addition, situations were presented for when these modes would be applicable. The five modes are as follows: e The state agency conducts all air quality maintenance planning and implementation activities within the state. e The state agency participates with local agencies in preparing and implementing the AQMP per a mutual agreement. o The state agency conducts planning operations but delegates implementation activities to local agencies. o Planning is done jointly by state and local agencies; imple- mentation is done by local agencies. e Planning is done jointly by state and local agencies, but all implementation is done by state. These five modes were applied to the situation in St. Louis and all were found not to fit the local situation. The principle reason was the inter- state nature of the area and the lack of implementing power given to the regional agency, East-West Gateway Coordinating Council. The Council is the logical agency to do the planning and implementing for St. Louis; however, because of its voluntary nature, implementation of the AQMP would be impossible. Discussions with East-West Gateway staff indicated that they are willing to undertake such work, but require Federal directions, instructions, and most importantly, additional funds. These would be ------- needed for the incorporation of the AQMP into the overall comprehensive planning program. Based on a similar effort in Baltimore, funding for such an undertaking could be up to 50<£ per person depending upon indus- trial and municipality complexities. The report then indicated approaches that could be used for coordination within an interstate AQMA, such as St. Louis. Two approaches were presented: noncompactual mechanisms and interstate compacts. In addition, it was suggested that an interagency task force on interstate coordination be formed. Given the multiplicity of agencies within the St. Louis AQMA, this task would be very time consuming and the task force would be extremely large and unmanageable. An interstate compact would probably not work in St. Louis, because it would be a regional type of government. This, in the past has been unacceptable at the polls especially given the failure rate which is not palpable in today's climate. It appears that for St. Louis, a noncompact type of solution would be required. Both states could mutually agree on both the problem areas and the implementation methods. One possibility that has not been discussed in this document is the formation of special districts within each state and then the coordi- nation of the two districts for the purpose of implementing the AQMP. Both sides of the river have special districts presently which traverse city and county boundaries. In Missouri there is the Metropolitan Sewer District, and the Zoo-Museum District. In Illinois, there is the East Side Levee and Sanitation District. This indicates that districts could be formed and then given the power to implement the AQMP and to coordinate this implementation between themselves. This implementing power could be through zoning or taxation. Planning would remain the function of the East-West Gateway Council. The remainder of the discussion on coordination seems relevant and could be carried out within the St. Louis AQMA. *L 1" ------- The second section deals with the actual sequence of tasks required to prepare an AQMP. One of the required components of the AQMP, as shown on page 24 of the Task 1 Report, is a description of resources available to the state and local agencies over the 10-year period. Such a commitment of resources by any agency exceeds normal funding and administrative planning horizons and would probably be no more than conjecture if it were submitted. Several of the agencies that might participate in implementation of parts of the SIP in St. Louis would do so in a manner for which it would be difficult to estimate manpower allocations. Also, the air pollution control agencies will have many ongoing programs that are included in the SIP but are not described in the AQMP. Thus, the values submitted would be subject to many different interpretations and could not be used to evaluate the adequacy of the resource commitments, For most maintenance measures, submittal of compliance timetables for emission source categories would not be applicable (page 24). This requirement should be enlarged to include timetables for initiation of new regulatory measures, such as an emission density zoning regulation or designation of critical environmental areas. Also on page 24, the draft guidelines state that if the timetable for attaining NAAQS is different than shown in the SIP, the difference must be explained in the AQMP. Unless an extension is officially requested from and granted by the Administrator, the states cannot change the attainment dates prescribed in the Clean Air Act. Nor do they have authority to establish new attainment dates if they miss the required ones. Presumably, attainment must be achieved as soon there- after as possible. ------- IFf The time schedule shown in Figure III-l does not seem to provide enough ime to prepare the required plan. Therefore, the responsible agencies are left with options such as: e refuse to prepare the plan under the indicated schedule e assemble material necessary for submittal and neglect inter- agency coordination and careful selection of optimum mainte- nance strategy select a strategy without the quantitative analysis described and attempt to justify it with data assembled subsequently Even with considerable contractual assistance and a major commitment of agency effort, the proposed schedule does not appear sufficient to permit the necessary interactions and checking of indirect effects that the guidelines advise. Given the choice between 1) developing the AQMP in an incomplete manner in order to meet a court-ordered deadline or 2) developing more meaningful AQMPs in a more realistic schedule one would obviously choose the second option. Therefore, the June 18, 1975 submittal data could be relaxed. However, if a decision is to be made by EPA to relax the schedule, it would be more effective if if were done as part of the guidelines rather than submitting the AQMPs next April or May after the agencies have already opted for one of the three alternatives described above. Task 2 -- Institutionalization of the Air Quality Maintenance Process As mentioned in the bibliography, this document is intended to assist State and local governments in the identification of the relationship between the AQMP and other community goals, plans, and activities. It ------- is also intended to suggest ways that the AQMP and its development and implementation can be integrated i^to and coordinated with overall community plans, goals, activities, and institutional arrangements. The document is intended to provide an impetus to State and local decision-makers faced with air quality maintenance requirements to determine for themselves the specific institutional arrangements and roles suitable to their own jurisdiction. Given the above two intentions, the document does not present these intentions to the reader. The document appears to be more of introduc- tory material to the guideline document on land use and transportation relationships to air quality. No information is presented to aid the state and local decision-makers to make a decision as to which institu- tion, federal program, and review process would be the most useful in various situations. The institution, federal program and review processes are presented and explained, but their situations application is omitted. The document could have been more meaningful if some hypothetical situations had been set up and the functional programs and coordina- tion framework had been applied to the situations. This application would have been of much value to the state and local decision-makers. They could have seen how these programs and frameworks would apply in a hypothetical situation and then would have been able to modify this application to meet their own AQMAs specific needs. An area like St. Louis with a multiplicity of agencies and two states would have dif- ferent needs than an intrastate AQMA such as Denver or San Diego. Reviewing the final chapter on the implementation of the air quality maintenance procedures the same lack of any application to hypothetical ------- situation is noted. This chapter could have been the very heart of the guideline document. However, few if any situations are set up that the State and local agencies could use as a basis for selecting the aspects of the various institutional arrangements which would be appropriate for their particular AQMA. Task 3 Maintenance Strategies This document is intended to describe various alternative administrative and technical approaches for maintaining air quality standards in a designated AQMA. A procedure for selecting the approaches best suited for the particular AQMA is also included. Two stages for selection are presented; an initial screening for feasibility and an evaluation of the feasible alternatives on a cost- effectiveness and social acceptability basis. The first step of the initial screening requires projection of emissions and air quality to the years 1980 and 1985. When this step was applied to the St. Louis AQMA it was discovered that no agreement existed between the data that the EPA had in NEDS and the data that the state and local agencies said should be in NEDS. This was for the existing emissions inventory. A base line set of data must be agreed to before projections to 1980 and 1985 can be made. At present there is no data base generally accepted by local agencies in St. Louis. Once this data base is agreed upon, however, the projection could be made. The second step is to estimate emissions which are to be prevented. This estimation is accomplished by comparing the projection emissions to the NAAQS. The problem areas are then noted. Applying this step to the St. Louis situation resulted in discovering that many of the ------- existing pollutant sources have been granted variances by the local and state air pollution agencies. This situation will make compliance of NAAQS more difficult for these future sources will be required to have more stringent controls so that the air quality levels will be maintained. These controls and variances could be contested as being discriminatory in the courts. The remaining steps should pose no great problem provided the data base and the projections are sound and are agreed upon by the state and local agencies. The second stage of the selection indicates that an evaluation must be made of the alternative maintenance strategies which passed the screening process in stage one. This evaluation is done on two levels: the social effects and the economic effects. While it is quite difficult to ascertain the effects of air quality control measures on the social and economic fiber of an AQMA, an attempt will be made to indicate some of the impact that would probably be felt in St. Louis. The first area to be discussed is the social effects. Perhaps the key to the effect of the maintenance program is contained in the two following sentences quoted from page 1-12 of the document: Politicians stake their political lives on what they perceive to be what the public desires. They, therefore, are in a position to assess the social acceptability of proposed maintenance measures. These two sentences basically sum up the situation in the St. Louis AQMA not only for the social effects but also for the economic effects. It may be assumed that political leaders will not accept a plan that will be a detriment to his political life. Should a maintenance plan be produced that would require massive changes in the socioeconomic ------- fiber of the AQMA, no politician would back it unless the plan had the overwhelming support of the majority of his constituents. Should a large industrial plant wish to locate in the AQMA, most politicians would welcome it with open arms because of the economic impact it would have on the community. Variance from the NAAQS might very well be granted if meeting the standards would disuade the plant from locating in the AQMA. A local example might further serve to illustrate the point. St. Louis has a large automobile assembly industry. In fact, it is second only to Detroit as an automobile assembly center. The Volkswagen Company has been looking at possible sites for the location of a new assembly plant within the U.S. St Louis was one of the six areas that was reviewed as a possible location for the multimillion dollar facility. Should St. Louis be chosen as the plant site, every possible effort would be made by the local leaders to ensure that the plant be built. This effort could include a relaxation of the NAAQS for the AQMA and a bending of the control measures in the AQMP. The economic impact of 5,000 to 10,000 jobs could be overwhelming. Possible health hazzards could be the only reason for imposing strict control. It could be unpolitical for any politician to be against such an economic boost to the area, barring any health hazzard problems. This illustration indicates that when all the dust settles, the AQMP may, in fact, become a political item. This is because the plan will have a major impact on a portion of the community's life that is extremely sensitive to political pressure: jobs and taxes. Chapter II of the document deals with nine possible administrative measures for controlling emissions. A short discussion follows on each. ------- Emission Allocation Procedure This procedure has possible appli- cation in the St. Louis AQMA because of the numerous governmental bodies in the area and because this measure is somewhat general. As noted in the chapter, however, the main problem with this measure is that it assumes that the assimilative capacity of the ambient air in the region is known. As of yet, operational techniques for determ- ining this capacity do not yet exist. Another problem with this procedure as applied to the St. Louis AQMA is that a major local data collection and planning effort would be required on a subcounty or submunicipality basis. Most of the existing detailed planning effort in St. Louis is being completed on a county or municipality basis. A third problem would be determining which agency in St. Louis should be charged with implementing the plan and whether or not this agency would have police power cross state boundaries. Regional Development Planning This measure implies that the AQMP be made part of the overall comprehensive planning process of an AQMA. This was discussed with the East-West Gateway Council staff in St. Louis. They agree completely with the concept since they are the only regional planning agency for St. Louis. Their main concern was that they had received no directives from the federal agencies that the AQMP should be included, nor had they received any guideance as to what was to be included in the plan or how to develop the plan. Most importantly, they were concerned about funding for the additional effort required to develop the AQMP. Once these items of concern are addressed the Council will be more than ready to include air quality planning in the overall comphrensive planning program for St. Louis. ------- Emission Density Zoning -- This type of zoning implies that emissions of a pollutant be limited to prescribed levels within a defined spatial area. This zoning would be administered by an air pollution control agency in conjunction with planners and zoning administrators. In applying this measure to the St. Louis AQMA, the major problem is the multiplicity of local communities that exist within each county. St. Louis County has 93 municipalities each with its own zoning ordinance. The County does not have the power to override local zoning. In addition the bi-state nature of the AQMA and the fact that many of the major pollutant sources are located along thestate boundary. This type of measure could only be applied at a municipal level in St. Louis and could not be applied on a regional scale. Zoning Appraisals and Other Indirect Regulatory Controls -- All of the measures indicated in this set of controls would again be implementable in St. Louis only on the local level. Regional implementation would be virtually impossible. Any regional controls would give the local citizens the feeling that a "super government" was taking over and they would be losing control of their own "destiny". As b-3rkground for this statement, the City of St.' Louis and St. Louis County were politically seperateJ in 1876. Since -;he 1920's five attempts at some type of consolidation have been made and all have failed at the polls by wide margins. Transportation Controls -- A transportation control plan is being developed for St. Louis at the present time.. It should be input to any AQMP developed for the area. However, it will not be workable until Fedruary, 1975. ------- Emission Charges -- This measure proposed placing a charge on the pol- luter as part of his cost of doina business or of consuming goods. It is also suggested that the rate charged could be on a graduated scale with the highest charge being in those areas with the worst pollution problem. Application of this concept to St. Louis or to any other AQMA could cause an adverse economic effect on the central city. The polluters could decide to relocate within the AQMA or could move out of the area with the highest pollutant levels and, abandon the central city. In St. Louis this is an especially acute problem because of the fixed boundaries of the central city and its inability to annex suburban areas to which these new industries may go. The charge could also provide an opportunity for an "island" of no or minimal charge to come into existence. This "island" could be within an AQMA or it could be an entire metropolitan area. The "island" would be able to siphon many large industries from other areas which have these charges. A national policy would be required to prevent this type of abuse of this measure. Transfers of Emission Source Location -- This measure requires the optimium use of terrain, meteorology, and geography of an AQMA from an air pollution viewpoint. It is especially applicable to power plants. This measure is essentially being used at the present time in St. Louis due to the concern of the local citizenry about the location of the power plants and the requirement of the state air pollution agency for an EIS on power plant locations. ------- Indirect Source Review and Environmental Impact Statements -- These measures are relevant upon regulations stated in 40 CFR and on Section 102 (2) (C) of NEDDA of 1969. The principal question concerning these measures is not the measures themselves, but the realism of the standards. Whether the standards are realistic or not will not be determined until the absorption rates of the ambient air are determined. Chapter III of the document deals with explaining nine emission control measures. These are: e New Source Performance Standards e Revision of Existing SIP Control Measures e Phaseout or Prohibition of Emission Sources o Fuel Conservation o Energy Conservation and Utilization o Combination of Emission Sources e Special Operating Conditions e Stack Height Regulations e Control of Fugitive Dust Sources All of these measures appear to be applicable to the St. Louis AQMA and are only restricted by the state-of-the-art of the technology required for their implementation. Chapter IV merely presents a matrix of how the varying control measures assist each other, overlap each other, or act independently. The matrix gives some useful information to the state and local agencies as to the applicability of each measure and will help in making the decisions required for developing specific control measures for the AQMP. ------- On a "broad-brush" review it appears that Chapter V is adequate. However, the general nature of the discussion may be imcomplete with respect to some of the legal problems involved in implementing these meausres. The state-local relationships in terms of legal authority and air pollution control responsibilities should be emphasized. A more concise legal analysis, which brings in definitions of criteria of acceptability for implementation of each measure would enhance the usefulness of this chapter. Relation of Land Use and Transportation Plans to Air Quality This document is intended to provide a methodology for relating land use and air quality. The document presents a general review of land use planning and the 3-C Process and defines a general methodology for considering air quality in the overall planning process. Procedures are also suggested for utilizing existing land use and transportation plans to project and allocate emissions and air quality in AQMAs. Following are the comments on the document. 1. Although work on the St. Louis plan has not progressed to the diffusion modeling stage as yet, it is already apparent from discussion with the Source-Receptor Analysis Branch that the spatially distributed projected emissions data for 1975, 1980, and 1985 cannot be modeled with any of the simple models listed in the Task 1 to indicate the extent of the AQMA expected to exceed air quality standards. Available models which do provide the necessary spatial resolution, such as AQDM, require considerable effort in validation and calibration steps and generally need stack parameter and other data that cannot be obtained for projected new sources (and many existing sources in St. Louis). ------- 2. The expected integration of guidelines on modeling to be prepared by EPA with the guidelines relating land use and transportation plans to air quality is lacking. If input data are not presently available for the preferred models, especially under the proposed schedule, some backup methodology such as emission density calculations should be explained in the guidelines, so that the responsible agencies can make some estimates of the area where maintenance action are needed. 3. The "preferred" or available analysis approach described in the document assumes a detailed county projection methodology will be available as well as an EPA guideline on air quality models. There are then three documents which must be integrated to provide the complete analysis guideline. To date, these three documents have not been properly coordinated in their preparation and it appears that they may be inconsistent. It is recommended that EPA coordinate these efforts so that a detailed methodology can be prepared. 4. The "preferred" analysis approach described in the document is a sequential approach resulting in a description of air quality. The emissions projection methodology implies that consideration will be given to emission controls and control plans already in existence as well as the source of growth rate in the determination of projected emissions. However, the impact of SIP's and Transportation Control Plans (TCP's) on land use and transportation has not been adequately defined to date. Indeed, the majority of proposed TCP measures have not been implemented and are not defined in sufficient detail to perform an air quality impact analysis. Therefore, the growth rates used in the projections may be in considerable error. ------- Many regional transportation plans are under study or revision at this time. For example, in St. Louis the existing transportation plan calls for rapid rail transit. However, a new study is about to begin to determine the feasibility of alternative approaches, This study will not be completed until mid or late 1975. Therefore, 1980 or 1985 transportation network cannot be evaluated at this time. It seems apparent that a one time sequential analysis will not be sufficient to support an air quality maintenance strategy. It is therefore recommended that the air quality analysis be a continuing and interative process responsive to the changes in policy which affect both the sources and their control. This would require a large scale effort to quantify the effect of policy changes, etc., on both sources and resultant air quality. The states should be given some guidance in establishing a mechanism to incorporate these changes as they occur. 5. The analysis approach begins with a controlled 1975 emissions inventory (which was a required step in the techniques for designating the AQMA) assuming that an accurate, complete, and "controlled" emissions inventory can be compiled for 1975. In attempting to compile such an inventory for St. Louis, the following problems were noted and specific examples are given. However, these problems are probably not unique to St. Louis. It is, therefore, recommended that a major upgrading of the emissions inventory be performed as an integral part of the maintenance plan implementation. This upgrading will require significant resurveying as opposed to reformating of data and should consider a means of continuous update when significant fuel use or other energy related or control related changes occur. ------- (a) Projection techniques are based on multiplying existing emissions by a growth factor. This assumes that the data base is reasonably accurate. Since the industrial growth rates are small (less than 3 percent per year), the major source of error in projected total emissions will be the baseline. For example, in St. Louis, one point source was listed as emitting 100,000 TONS/year of S02 . The State of Missouri has determined that in actuality this source emits more than 400,000 TONS/year. If fuels are varied during the next few years, the annual emission rate for this source may vary significantly. It appears that S02 is still a significant point source control problem and that maintenance measures directed at any other sources (i.e., area source fuel combustion) may not be justified due to the significant error in the data base of major sources. (b) Specific formulation of growth and control factors on a subcounty basis is time consuming and costly. If backup growth factors and control factors such as those used in the guidelines for designation document are employed, the error in the projected emissions can be greater than the control potential of pro- posed AQMA control measures. (c) In the counties outside of the urbanized portion of the SMSA, fugitive dust may be a significant impact on TSP ambient monitor readings. Projections of TSP emissions will contain no growth factor for these sources although the ambient monitors will continue to record values exceeding the standards. This implies that a sensitivity analysis should be performed to determine the significant sources influencing each monitor before the monitor data base is used as a criterion for AQMP development. ------- (d) Power plants are frequently the most significant sources of S(L and TSP. The range of error in control or fuel use assumptions for a power plant may be greater than the total emissions from all other sources. Annual average or annual total emissions are not sufficient to show the fluctuations in emissions from these sources which may be influencing an ambient monitor. This data must be updated continuously and should include results of source testing. This level of detail is beyond the simplified sequential approach for AQMA analysis and AQMP development. (e) CO is now and will become more so in the future a "hot-spot" problem. Existing inventory data for mobile sources is totally inadequate to project "hot-spots". Backup methodologies for projecting VMT all have one thing in commonthey aggregate the VMT data spatially and temporally in order to avoid error. Backup, or short cut approaches to mobile source emissions projection is not appropriate for AQMP development. Some guidance should be prepared on how to estimate the location of probable "hot-spots". (f) Photochemical oxidants are inadequately treated in any available analysis approach. Current efforts to model these pollutants will not be available within the proposed time frame. Some guidance should be given to the states on how to proceed. ------- C. SUGGESTED ADDITIONS TO GUIDELINES DOCUMENTS It is recommended that the following additions and deletions of material from draft reports be made in the final guidelines document distributed to the States. 1. As part of the requirements for contents of the maintenance plans, some preferred or suggested formats for data presenta- tions should be added. This would assist the agencies and also make EPA evaluation of the plans easier. 2. At several points throughout the draft guidelines, the im- portance of indirect source review, NSPS, new source perfor- mance standards, permit systems for new sources, and environ- mental impact statements as elements of the maintenance plan are mentioned. Also, analyses of the air quality impacts of the first three of these programs are required in the AQMP. Yet, the administrative coordination between the separate agencies responsible for these different elements is not discussed in the Task 2 report and no indication is given that the agency and personnel responsible for implementing the AQMP must be continually apprised of all actions taken under these four programs in order for any maintenance strategy to function properly. Possibly, the establishment of some notification procedure should be required in each plan within the section entitled Intergovernmental Cooperation. ------- 3. The sequence of activities for air quality maintenance planning shows a step (number 7) entitled "Refine AQMA Boundaries." This particular step does not seem appropriate, and it is recommended that it be deleted. The States have supposedly considered factors other than growth potential, e.g., boundaries of regional planning areas, in their original recommendations and the Administrator has officially designated these specific areas as AQMA's. There are no obvious advantages in refining the boundaries within six months of their designation, since the maintenance plan does not necessarily have to specify controls for the entire AQMA. Low-growth counties (or other subareas) simply would not have any maintenance effort during the initial 10- year planning period. Including fringe counties in the AQMA permits greater latitude in developing a regional plan that can accommodate growth and maintain air quality standards. Although the guidelines for designation of AQMA's are not specific on this point, revising the boundaries would probably require public hearing and approval of the Administrator. 4. The situation of a regional planning agency with no enforcement powers, preparing the AQMP and local air pollution control agencies, with enforcement powers, being responsible for implementation in their own jurisdictions may be a common division of responsibilities. At present, this is the most probable alternative in the St. Louis AQMA. Since there are some inherent problems with this arrangement, it should be discussed in detail in the guidelines. The statement that the ------- any plan. If it is not accepted there, then the federal or state government will be forced to use the "carrot and stick" approach to ensure implementation and compliance of the plan. 7. In conjunction with number 6 above, it is assumed that the guidelines discussion will include the results, based on the experience of the contractors developing plans in the four sample cities. These results would be very helpful to the agencies in other AQMAs in the development of their AQMP. 8. Analysis guidelines are uncoordinated and inadequately detailed. It is recommended that after the sample plan projects are complete and after EPA has determined final policy on possible alternative approaches to AQMP development and submittal, a concise, coordinated analysis document, as prepared with some guidance on expected availability of required or recommended techniques. This document should be updated periodically as new techniques become available. EPA should evaluate and critique the new techniques for specific applicability to AQMA analysis and plan development or revision, and circulate a brief description of the technique and the critique of its applicability to those responsible for AQMA implementation. The level of effort and expected cost to utilize the techniques should be included. D. SUGGESTIONS FOR SIMILAR DOCUMENTS IN FIVE YEARS Within the next five year period, the AQMPs that are presently required will be produced. Possibly the most useful document that could be produced would be one that would summarize all the general and specific ------- problems that the states and local agencies encountered in their develop- ment and implementation of the AQMP. This document would also summarize the methods that these agencies used to solve the problems that arose. These results could be a seperate document or they could be used to update the present guideline documents. The latter could be extremely time consuming and may not be an effective as the summation document. In addition, EPA could develop over the five-year period, an information and data clearinghouse for the states and local agencies. Presently, these agencies do not have the staff to accomplish this, yet the need is definitely present as shown by the data problems being experienced in St. Louis. This clearinghouse would not only include emission data . base, but also would include information on new control technology and analysis techniques and applicability of this technology based on its use in the field. This type of information would be extremely valuable to the implementing agency in suggesting proven methods of control. This information in the clearinghouse should be automated for easy retrieval by the states and local agencies. Using this updated and more detailed data base and methodologies, the AQMP process should be included in the overall comprehensive planning process for the AQMA. By so doing, a much more thorough AQMP can be developed. This plan will become part of the overall comprehensive plan for the AQMA. ------- IF IF CHAPTER III CRITIQUE OF EPA APPROACH TO AIR QUALITY MAINTENANCE A. OVERVIEW The framework for evaluation of the guidelines is necesssarily limited by the short time in which they could be applied in the field, compli- cated by the fact that the plan development process was proceeding simultaneously. Also, it has not been possible to fully evaluate some of the guidelines in the practice of plan development; for example, no effort has been directed toward strategy development (Task 3). Neverthe- less, the guidelines have been reviewed with an understanding of essential application and the findings are summarized below. In general, it may be concluded that although there is a need to develop maintenance plans for air quality, there is a lag in the state-of-the- art which has a potential to be costly and may not prove to be effective. Theoretically, the procedures described by the guidelines should be applicable in most AQMAs; however, as has been demonstrated in St. Louis, the emissions and air quality data bases and land use plan develop- ment have not progressed to a point where they are compatible or are in a format that can be used in the development of the AQMP. In other areas, especially where the land use plan has been quantified, it may be more practicable to apply the techniques specified in the guidelines. Similar problems are apparent in the jurisdictional and institutional constraints present in St. Louis which will hinder plan development and implementation. Again, it is not unlikely that similar problems will be encountered elsewhere, especially within AQMAs. ------- Another concern is the fact that the air quality implementation plans are to be developed, based on tenuous data, within less than a year, while the land use and transportation planning processes, in which the AQMP is so intimately involved, have been in practice for at least a decade. Admittedly, these latter processes have generally excluded the air and water quality aspects of the urban activity, but many areas are proceeding to incorporate these elements into the process. It will be useful to observe the results of this in Fairfax County, Virginia, and the Northeastern Illinois Planning Commission where air quality and land use will be quantified on a subarea basis and incorporated into the overall process. Thus, one recommendation is that the air quality maintenance plan development be delayed at least 12-18 months until a comprehensive approach can be implemented in the AQMA. This should result in a cost-effective approach and would ensure a more valid basis on which to evaluate maintenance strategies. There is also the question. of whether most areas will actually attain air quality standards by 1975, and if not what the impact of maintenance strategies will be. Furthermore, it must be recognized that planning agencies will not have the funds to actively participate in AQMP development in the next 12 months and it would be inappropriate for air pollution control agencies to prepare such plans without this participation. B. UNRESOLVED ISSUES General Issues Perhaps the greatest barrier to the level of intergovernmental cooperation envisioned in the draft guidelines documents is agency funding. Air pollution control agencies have traditionally been receptive to under- ------- taking new projects requested by EPA because a part of their funding comes from EPA. The impact of eliminating agency grants has yet to be determined. Planning and other local agencies, on the other hand, do not receive funding from EPA and have program commitments related to their sources of funding. Two different levels of involvement by these agencies can be anticipated. First, the agencies might be asked to send representatives to meetings and voice their agencies' viewpoints on the acceptability of plan development procedures and proposed maintenance measures. In general, this amount of assistance and cooperation may be expected. The other level of involvement would be to request the agency to generate data, such as regional VMT by highway link for the two projection years, or to simulate and evaluate the effects of a proposed maintenance measure. In most cases, this type of participation will not be forthcoming unless the agency receives some additional funding. The draft guidelines do not discuss the possibility that an important local agency may not accept the responsibility of participating in plan development. Demographic, economic, and transportation projection data necessary for plan development are generally not available for both of the projection years (1980 and 1985). Linear interpolation between available projection years may not be accurate. A regional planning agency may be able to generate the required data, but it will require the use of sophisticated activity models that may be beyond the resource availability of the planning agency or may take more time than is allotted to definition of the growth problem. Ideally, planning for air quality maintenance could best be accommodated by integration into other ongoing planning efforts. For example, an ------- 18-month study of alternative rapid transit and mass transit systems for the St. Louis area, sponsored by the East-West Gateway Coordinating Council, is scheduled to begin in June or July. Although improved mass transit has strong potential as a maintenance measure in St. Louis, the results and recommendations of this comprehensive study will not be available in time to be input into the plan. The immense air quality and emissions data base that would be provided by RAPS in St. Louis likewise will not be available for use in preparing the maintenance plan. The impending RAPS projects also make the local agencies understandably reluctant to update or upgrade their existing emissions data to the extent necessary to provide an adequate basis for plan preparation. In general, large-scale regional planning studies that may provide input to AQMP development cannot be rescheduled to meet the AQMP deadline. Therefore, to assure the best possible maintenance plans, the schedules for submittal should be more flexible. As noted in the proposed California plan prepared by Livingston and Blayney, an analysis that can determine whether air quality standards will be maintained throughout every part of an urban area requires a more detailed emissions inventory (especially spatial resolution of area sources) than the NEDS format or the 40 CFR Appendix D format used in the SIPs. In most cases, the additional data needed would necessitate an extensive field survey rather than just compilation or updating of information from permit forms and compliance schedules. This information is to be obtained for the St. Louis area during the next year as part of the RAPS program. However, it will not be available by September or October 1974, the completion date shown in the draft guidelines. For other AQMAs, the need for such an inventory should be emphasized. ------- During 1974, there have been significant shifts from historical trends in usage of all major fuel types, and therefore changes in emissions from fuel combustion operations. If the emissions projection procedure utilizes a data base of 1972 or 1973 rather than current data for 1974 or estimates for 1975, it will probably ignore these changes. For example, higher gasoline prices have reduced urban travel by 3-15 percent compared with year earlier values, while the normal occurrence is a 2-10 percent annual increase in VMT. Thus, VMT projections from 1973 data might overestimate any future values by an average of 15 percent. Industrial and domestic energy conservation programs instituted in 1974 might cause similar overpredictions, but switches to lower grade fuels due to non-availability and price increases would result in some signi- ficant underestimates of emissions rates per unit of fuel consumed. If a current data base cannot be developed, some method of correcting for the recent changes should be established and/or required because their impacts may be as great or greater than many of the maintenance measures. Demonstration that short-term air quality standards will be maintained requires that some analysis be made of maximum short-term emissions rates. Emissions are normally calculated on an annual basis. Therefore, some standardized methodology should be provided for converting annual emissions rates into equivalent maximum short-term rates. Unless such a standard method is prescribed, divergent assumptions made in conversions for different AQMAs may create problems of consistency in evaluating the plans. The St. Louis AQMA has one scheduling problem which is atypical--the initial transportation control plan will not be submitted until Febru- ary 1975. Until the contents of that plan are known, it is impossible to determine what additional measures, if any, will be needed to maintain ------- standards for carbon monoxide and oxidants through 1985. In fact, control measures that would be considered for inclusion in the two plans would probably be identical. Due to this peculiar overlapping in plan preparations, it is recommended (for the St. Louis AQMA only) that maintenance provisions of a regulatory nature be included in the trans- portation control plan, and that the maintenance plan for these two pollutants contain only the required demonstration of adequacy. Data Projection Issues This section present some of the more specific problems that have been encountered in attempting to develop baseline data and to project this data to 1975, 1980, and 1985. The emissions were divided into four categories: point sources exlusive of power plants, power plants, stationary area sources, and mobile sources. POINT SOURCE EMISSIONS Estimation for 1975, 1980, and 1985 The main data sources used were the 1972 NEDS emissions inventory for individual point sources for all counties involved as shown in Appendix B of Attainment of National Air Quality Standards for Carbon Monoxide and Oxidants in the St. Louis AQCR by PEDCo-Environmental Specialists, Inc., and individual information on major point source emissions for 1972 and 1975 for the Illinois Counties in the AQMA provided by the Illinois Environmental Protection Agency (IEPA). (Emissions and compliance status information for major point sources in Missouri is forthcoming from the Missouri Air Conservation Commission (MACC), but was not available for usage in developing these preliminary emission estimates.) ------- The primary problem is the necessity of using NEDS data which is not considered total accurate. Incorrect site locations and plant closings were corrected where known. The lack of compliance projections necessitated using the average reduction factors given in the EPA guidelines for designating AQMA's. These average factors probably introduced a consid- erable amount of error into the 1975 and consequently '80 and '85 esti- mates because (1) they are national average figures which may not apply to the St. Louis area, (2) they are based on allowable emissions and not actual compliance, and (3) they probably are weighted more heavily towards large point sources than small point sources, thus giving a greater reduction than is likely for small point sources. This problem will be partially remedied by utilizing the forthcoming Missouri Air Conservation Commission's emissions and compliance information. Another problem was the lack of consistent countywide growth projections. This necessitated the use of SMSA level growth projections. Thus, the 1980 and 1985 emissions projections probably overpredict growth in emissions for slower growing, but heavily industrialized central city areas and underpredict growth in emissions for faster growing, but less industrialized suburban areas. POWER PLANT EMISSIONS Estimation for 1975, 1980, and 1985 Power plant emissions were provided for both 1972 and 1975 by the Illinois Environmental Protection Agency. However, these figures were not disaggregated according to consumption of fuel by fuel type. Missouri power plant emissions are not available as yet, but will be provided by the Missouri Air Conservation Commission. The information provided in the State Implementation Plan and in NEDS was not considered reliable. ------- Forecasts of 1980 and 1985 emissions from power plants by county will be based upon data already gathered on expected operation of existing power plants and new plants to be opened in the future. The area source emmisions were divided into three basic categories for forecasting purposes. These are: residential, industrial, and commer- cial/institutional. Each of these categories was further subdivided by fuel type to bituminous coal, anthracite coal, distillate oil, and natural gas. To project these values, the BEA statistics for the St. Louis SMSA were determined to be the only obtainable data source which covered the years of interest. The growth in residential area sources was forecast using the BEA estimates of population growth, industrial source pollutants were forecast using the estimated increase in total manufacturing earnings, and commercial/institutional was projected using wholesale and retail trade earning estimates. The projection of residential source emissions using base year totals was deemed unrealistic since coal usage is on the decline in the St. Louis area. To compensate for this, a fuel balance based on expected BTU requirements was performed. The assumption made was that by 1980, the percent of total BTU's required contributed by coal would decrease by 50 percent, and by 80 percent in 1985. Thus if in a given area 10 percent of the required BTU's were derived from coal in 1972, only 5 percent would be derived from coal in 1980, and only 2 percent in 1985. It was assumed that distillate oil and natural gas would contribute the necessary extra BTU's in proportion to their 1972 use. The fuel require- ments thus determined were converted to the respective pollutants using the appropriate emission factors. ------- These procedures resulted in county totals by type of pollutant and source for each of the forecast periods. These totals were then modified by the appropriate reduction factors required to comply with the 1975 emission standards. The results obtained by this technique should not be considered accurate. The BEA growth rates reflect areawide growth for the entire SMSA of St. Louis. Thus areas with high growth potential are significantly under- estimated, while current high density areas are overestimated. The basic problem encountered in the area source projections was the varying levels of refinement of the input data. The original or base pollutants were at the county level while the forecasting variables were based on regional growth. Ultimately the result is to be disaggregated to a one kilometer square grid system. To justify any result from such a procedure and substantiate the accuracy is extremely difficult. MOBILE SOURCE EMISSIONS Estimates for 1975, 1980, and 1985 -- Mobile source emission estimation for light and heavy duty vehicles for 1975 and 1980 will be based primarily on Appendix A of Pedco's Attainment of National Air Quality Standards for Carbon Monoxide and Oxidants in the St. Louis AQCR. This appendix gives VMT projections for 1975 and 1980 by county by class of road, average speeds by class of road, and weighted emission factors for 1975 and 1980 based on the expected vehicle model year distributions in those years. In order to estimate emissions for 1985, it will be necessary to project 1985 VMT by county by class of road. This will be done by extrapolation ------- of 1980 PEDCo figures in accordance with 1995 projection totals estimated by the East-West Gateway Coordinating Council. It will also be necessary to calculate weighted emission factors for 1985 based on the expected vehicle model year distribution in that year and revised average speed estimates by class of road. These techniques are again primarily directed toward obtaining a data base to test the procedures for Maintenance Strategy Development. This level of aggregation of data and interpolation of networks is considered inadequate to define the carbon monoxide maintenance problem. D) 3ft f ------- C. RECOMMENDATIONS FOR RESOLUTIONS AND ALTERNATIVE APPROACHES Following is a list of recommendations for resolution of some of the noted problems and some possible alternative approaches. 1. A comprehensive effort is needed to upgrade, update, and expand the emissions inventory for AQMAs. This task should begin after all alternative approaches to AQMP development are defined so that the data base can be compiled in a form suitable for analysis. 2. Efforts should be expended to determine the interactive effects of all existing environmental programs before any new program is initiated. For example, the 208 water programs are to be integrated with AQMA programs. However, under the proposed time constraints, little effort can be expended to coordinate these programs. 3. A means of providing incentive and direction for coordination of all Federally funded local activities is required. For example, DOT could provide direction and assistance to the 3-C planning agency to allow them to take part in the AQMP development. 4. Energy planning in urban areas must be coordinated with environmental programs. 5. Alternative approaches. The June 1975 submittal should consist of: (a) A detailed description and schedule of the states selected approach to AQMP development, implementation, and enforcement. (b) A detailed description of the agency or agencies responsible for each element of the proposed approach to AQMP development. (c) A detailed description of the coordination procedures to be employed during plan development to ensure that all available resources are applied and adequate review by all concerned organizations is provided. ------- (d) A description of a public awareness program to be initiated to which will an avenue for public participation and review. (e) A detailed description of available resources for plan develo- pment including staff and budget requirements and a listing of areas where resources are inadequate and funding or technical support is required. (f) A description of the coordination of AQMP development and implementation with other environmental programs; i.e., 208 water planning, indirect source procedures, transportation control plan implementation, etc. (g) A description of the means of coordinating AQMP development with other community planning programs, i.e., comprehensive planning, 3-C transportation planning, energy planning, etc. (h) An interim plan including: o a review of the progress of existing SIP and TCPs o proposed changes to SIPs or TCPs including new regulations o interim measures (i) A description of activities initiated to: o upgrade the emissions inventors o resolve legal issues o Obtain the staff and funds required (j) A legal authority analysis including: o a detailed description of existing state and local authority relevant to possible maintenance measures and approaches. o a description of deficiencies in existing authority ------- CHAPTER IV SUMMARY The comments contained in this critique are based on the first six weeks and attempt to apply the guideline documents to the situation in the St. Louis AQMA. Because of the many problems noted with the emissions and planning data base and because of the multitude of political juris- dictions, the application of the guidelines was necessarily limited. Though limited, the critique comments present some of the problems that have developed as the guidelines were applied to the St. Louis AQMA. The results are valuable in that they point out major stumbling blocks that presently exist and that will have a very real effect on the development of the AQMP for St. Louis. It is also likely that some if not all of these problems will surface in other AQMAs especially those that are interstate in nature. As the remaining portion of the Task Order and the sample plan development progresses, additional problems may occur that will alter or supplement the opinions already made in this critique. Because of this, it is anticipated that the final version of this critique, due on June 21, 1974, will not only incorporate the comments from EPA, but will also incorporate additional critique comments resulting from the development of the AQMP. This critique points to the need for submission of our AQMP work program that ties into the local area and is integrated with the local planning process. The work program should be submitted annually and be the basis for multiagency funds in the next year. The annual work program should be accompanied by a larger (5-year) program. ------- |