Guidance on the Use of Models and
Other Analyses in Attainment
Demonstrations for the 8-hour Ozone
NAAQS

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                                    EPA-454/R-05-002
                                       October 2005
 Guidance on the Use of Models and Other
Analyses in Attainment Demonstrations for
         the 8-hour Ozone NAAQS
         U.S. Environmental Protection Agency
       Office of Air Quality Planning and Standards
      Emissions, Monitoring, and Analysis Division
             Air Quality Modeling Group
        Research Triangle Park, North Carolina

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                           ACKNOWLEDGMENTS

      We would like to acknowledge contributions from members of an external review group,
the STAPPA/ALAPCO emissions/modeling committee and U.S. EPA Regional Office modeling
staffs in providing detailed comments and suggestions regarding the final version of this
guidance. In particular, we would like to thank staff members of the Lake Michigan Air
Directors Consortium (LADCO), Carolina Environmental Program (CEP),  South Coast Air
Quality Management District (SCAQMD), California Air Resources Board (CARB), Texas
Commission on Environmental Quality (TCEQ), North Carolina Division of Air Quality
(NCDAQ), New York State Department of Environmental Conservation (NYDEC) and
Computer Sciences Corporation (CSC) for testing our ideas for a modeled attainment test and
sharing the results with us.
                                         in

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TABLE OF CONTENTS

ACKNOWLEDGMENTS	iii

FOREWORD	ix

1.0    Introduction	1
      1.1    What Is The Purpose Of This Document?	2
      1.2     Does The Guidance In This Document Apply To Me?	2
      1.3    How Does The Perceived Nature Of Ozone Affect My Attainment
            Demonstration? 	2
      1.4    What Topics Are Covered In This Guidance?  	5

Part I.      How Do I Use Results Of Models And Other Analyses To Help
            Demonstrate Attainment?	7

2.0    What Is A Modeled Attainment Demonstration?—An Overview	8
      2.1    What Is The Recommended Modeled Attainment Test?--An Overview .... 8
      2.2    What Does A Recommended Supplemental Analysis/Weight Of Evidence
            Determination Consist Of?  —An Overview  	9
      2.3    Why Should A Model Be Used In A "Relative" Sense And Why May
            Corroboratory Analyses Be Used In A Weight Of Evidence Determination?10

3.0    What Is The Recommended Modeled Attainment Test?	12
      3.1    Calculating site-specific baseline concentrations	13
      3.2    Identifying surface grid cells near a monitoring site	15
      3.3    Choosing model predictions to calculate a relative reduction factor (RRF)j
            near a monitor	16
      3.4    Estimating design values at unmonitored locations: what is an unmonitored
            area analysis and why is it needed?  	18
            3.4.1  Why does the unmonitored area analysis need to use both ambient
                  data and model output?	18
            3.4.2  Implementation of Model Adjusted Spatial Fields	19
            3.4.3  Using the Results of the Unmonitored Area Analysis  	20
      3.5    Limiting modeled 8-hour daily maxima chosen to calculate RRF	21
      3.6    Which base year emissions inventory should be projected to the future for
            the purpose of calculating RRFs?  	24
      3.7    Choosing a year to project future emissions	25
      3.8    How Do I Apply The Recommended Modeled Attainment Test?	26

4.0    How Can Additional Analyses Can Be Used to Support the Attainment
      Demonstration? 	28
      4.1    What Types of Additional Analyses Should Be Completed as Part of the
                                       IV

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            Attainment Demonstration?	28
      4.2   If I Use A Weight Of Evidence Determination, What Does This Entail? ... 31

5.0  What Additional Analyses Can Be Completed to Assess Progress towards Attainment
       	34

6.0  What Documentation Do I Need To Support My Attainment   Demonstration?
       	36

Part II.     How Should I Apply Air Quality Models To Produce Results
            Needed To Help Demonstrate Attainment?  	41

7.0    How Do I Apply Air Quality Models?-- An Overview	42

8.0  How Do I Get Started?- A "Conceptual Description"	46
      8.1   What Is A "Conceptual Description"?	46
      8.2   What Types Of Analyses Might Be Useful For Developing And Refining A
            Conceptual Description?	49
            8.2.1. Is regional transport an important factor affecting the nonattainment
                   area?  	49
            8.2.2.  What types of meteorological episodes lead to high ozone?	49
            8.2.3.  Is ozone limited by availability of VOC, NOx or combinations of the
                   two?  Which  source categories may be most important?	50

9.0    What Does A Modeling/Analysis Protocol Do, And What Does Developing One
      Entail?	51
      9.1   What Is The Protocol's Function?	51
      9.2   What Subjects Should Be Addressed In  The Protocol?	51

10.0  What Should I Consider In Choosing An Air Quality Model?	53
      10.1  What Prerequisites Should An Air Quality Model Meet To Qualify For Use
            In An Attainment Demonstration?  	53
      10.2  What Factors Affect My Choice of A Model For A Specific Application?  . 54
      10.3  What Are Some Examples Of Air Quality Models Which May Be Considered?
             	55

11.0  How are the Meteorological Time Periods (Episodes) Selected?  	57
      11.1  What Are The Most Important Criteria For Choosing Episodes?	58
            11.1.1  Choose a mix of episodes which represents a variety of meteorological
                   conditions which frequently correspond with observed 8-hour daily
                   maxima exceeding 84 ppb	58
            11.1.2  Choose episodes having days with monitored 8-hour daily maxima
                   close to observed average 4th high daily maximum ozone

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                   concentrations	59
             11.1.3 Choose days with intensive data bases	60
             11.1.4 Choose a sufficient number of days to enable the monitored
                   attainment test to be based on multiple days at each monitoring site
                   violating the NAAQS	60
      11.2   What Additional, Secondary Criteria May Be Useful For Selecting Episode^

12.0  What Should Be Considered When Selecting The Size And Horizontal/Vertical
      Resolution Of The Modeling Domain?  	66
      12.1   How is the Size of the Modeling Domain Chosen?	66
      12.2   How are the Initial and Boundary Conditions Specified?	67
      12.3   What Horizontal Grid Cell Size Is Necessary?	68
      12.4   How Should the Vertical Layers Be Selected?  	70

13.0  How are the Meteorological Inputs Prepared for Air Quality Modeling?	72
      13.1   What Issues are Involved in the Generation and Acquisition of
             Meteorological Modeling Data?	72
      13.2   How Should the Meteorological Modeling Analysis be Configured?
              	73
      13.3   How Should the Performance of the Meteorological Modeling Be Evaluated^

14.0  How Are the Emission Inputs Developed?  	77
      14.1   Can The National Emission Inventory Be Used As a Starting Point?
              	77
      14.2   What Emission Inventory Data are Needed to Support Air Quality Models?78
      14.3   What Other Data are Needed to Support Emissions Modeling?	80
      14.4   How Are Inventory Data Converted Into Air Quality Model Input?
              	82
      14.5   Are there Other Emissions Modeling Issues?	84
      14.6   How Are Emissions Estimated for Future Years?	86

15.0  What are the Procedures for Evaluating Model Performance and What is the Role
      of Diagnostic Analyses?  	95
      15.1   What are the Procedures for Evaluating An Air Quality Model?  	95
      15.2   How Should the Operational Evaluation of Performance Be Completed?
              	96
      15.3   What Types of Analyses Can be Done to Evaluate the Accuracy of the Model
             Response: Diagnostic Evaluations?  	99
      15.4   How Should the Results of the Model Evaluation be Assessed?	100

REFERENCES	102

Glossary  	115
                                        VI

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APPENDIX A	116
LIST OF TABLES

Table 2.1    Guidelines For Weight of Evidence Determinations 	9
Table 3.1    Example Illustrating Calculation Of Baseline Design Values	15
Table 3.2.   Default Recommendations For Nearby Grid Cells Used To Calculate RRF's
             	16
Table 3.3    Mean RRFs and standard deviations as a function of various minimum
            thresholds	23
Table 3.4    Example Calculation of a Site-Specific Future Design Value (DVF)j	27
Table 6.1    Recommended Documentation for Demonstrating Attainment of the 8-hour
            NAAQS for Ozone	37
Table 10.1   Current Air Quality Models Used To Model Ozone 	56
Table 10.2   Other Air Quality Models Used to Model Ozone	56
Table 11.1   Number of Days Needed to Replicate the 25/50/100 Day Dataset Mean RRF
            to Within ±1% and ± 2% , With a 95% Confidence Interval	62
Table 11.2   Examples of the Recommended Hierarchy in Choosing the Number of Days
            in the Mean RRF Calculation vs. the Minimum Threshold 	63

LIST OF FIGURES

Figure 3.1   Daily Relative Reduction Factors as a Function of Daily Maximum Base
            Modeled Concentrations  for Monitors in the Baltimore Nonattainment
            Area	22
Figure 11.1  Mean RRF as a Function of the Subset of Days (3-25) for a Harford County,
            MD Ozone Monitoring Site	61
                                       vn

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                                    FOREWORD
       The purpose of this document is to provide guidance to EPA Regional, State, and Tribal
air quality management authorities and the general public, on how to prepare 8-hour ozone
attainment demonstrations using air quality models and other relevant technical analyses.  This
guidance is designed to implement national policy on these issues. This document does not
substitute for any Clean Air Act provision or EPA regulation, nor is it a regulation itself. Thus,
it does not impose binding, enforceable requirements on any party, nor does it assure that EPA
will approve all instances of its application. The guidance may not apply to a particular
situation, depending upon the circumstances.  The EPA and State decision makers retain the
discretion to adopt approaches on a case-by-case basis that differ from this guidance where
appropriate. Any decisions by EPA regarding a particular State Implementation Plan (SIP)
demonstration will only be made based on the statute and regulations, and will only be made
following notice and opportunity for public review and comment. Therefore, interested parties
will be able to raise questions and objections about the contents of this guidance and the
appropriateness of its application for any particular situation.

       This guidance is a living document and may be revised periodically. Updates, revisions,
and additional documentation will be provided at http://www.epa.gov/ttn/scram/. Any mention
of trade names or commercial products in this document is not intended to constitute
endorsement or recommendation for use. Users are cautioned not to regard statements
recommending the use of certain procedures or defaults as either precluding other procedures or
information, or providing guarantees that using these procedures or defaults will result in actions
that are fully approvable.  As noted above, EPA cannot assure that actions based upon this
guidance will be fully approvable in  all instances, and all final actions will only be taken
following notice and opportunity for public comment. The EPA welcomes public comments on
this document and will consider those comments in any future revisions of this guidance
document, providing such approaches comply with all applicable statutory and regulatory
requirements.
                                          Vlll

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1.0    Introduction

       This document recommends procedures for estimating whether a control strategy to
reduce emissions of ozone precursors will lead to attainment of the 8-hour national ambient air
quality standard (NAAQS) for ozone. The document also describes how to apply air quality
models to generate the predictions later used to see whether attainment is shown.  Guidance in
this document applies to nonattainment areas1 for which modeling is needed, or desired.

       The guidance consists of two major parts. Part I addresses the question, "how should I
use the results of models and other analyses to help demonstrate attainment?" It explains what
we mean by a modeled attainment demonstration, a modeled attainment test., and a weight of
evidence determination.  It also identifies additional data which, if available, can enhance the
credibility of model results. Part I concludes by identifying what documentation States/Tribes
should include as part of an attainment demonstration.

       Part II of the guidance describes how to apply air quality models.  The recommended
procedure for applying a model has nine steps. The results of this process are then used to apply
the modeled attainment test to support an attainment demonstration, as described in Part I of the
guidance.

       1. Develop  a conceptual description of the problem to be addressed.
       2. Develop  a modeling/analysis protocol.
       3. Select an appropriate model to support the demonstration.
       4. Select appropriate meteorological episodes, or time periods to model.
       5. Choose an appropriate area to model with appropriate horizontal/vertical resolution
       and establish the initial and boundary conditions that are suitable for the application.
       6. Generate meteorological inputs to the air quality model.
       7. Generate emissions inputs to the air quality model.
       8. Evaluate the performance of the air quality model and perform diagnostic tests to
       improve the model, as necessary.
       9. Perform future year modeling (including additional control strategies, if necessary) and
       apply  the attainment test.

       Model applications require a substantial effort.  States/Tribes should work closely with
the appropriate U.S. EPA Regional Office(s) in executing each step. This will increase the
likelihood of  approval of the demonstration at the end of the process.
             this guidance document is primarily directed at modeling applications in
nonattainment areas, it may also be useful as a guide for modeling in maintenance areas or to
support other rules or sections of the Clean Air Act.

                                            1

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     1.1     What Is The Purpose Of This Document?

     This document has two purposes.  The first is to explain how to interpret whether results of
modeling and other analyses support a conclusion that attainment of the national ambient air
quality standard (NAAQS) for 8-hour daily maximum ozone concentrations will occur by the
appropriate attainment date for an area. The second purpose is to describe how to apply an air
quality model to produce results needed to support an attainment demonstration.

     The guidance herein should be viewed as recommendations rather than requirements.
Although this guidance attempts to address issues that may arise in attainment demonstrations,
situations which we have failed to anticipate may occur. These should be resolved on a case by
case basis in concert with the appropriate U.S. EPA Regional Office.

     1.2      Does The Guidance In This Document Apply To Me?

     This guidance applies to  all locations required to submit a State Implementation Plan (SIP),
or Tribal Implementation Plan (TIP) revision with an attainment demonstration designed to
achieve attainment of the 8-hour ozone NAAQS.  Areas required to submit an attainment
demonstration are encouraged  to follow the procedures described in this document.  Details on
when a State is required to submit a modeled attainment demonstration can be found in the 8-
hour implementation rule and preamble2.

     Implementation plan revisions are due three years after an area is designated
"nonattainment" (e.g., June 15, 2007 for areas whose effective designation dates are June 15,
2004).  Attainment demonstrations supporting these revisions should be completed in time to
allow sufficient time to complete the rulemaking process by June 15, 2007, at the latest.

     1.3     How Does The Perceived Nature Of Ozone Affect My Attainment
             Demonstration?

     Guidance for performing attainment demonstrations needs to be consistent with the
perceived nature of ozone.  In this section, we identify several premises regarding this pollutant.
We then describe how the guidance accommodates each.

Premise 1. There is uncertainty accompanying model predictions. "Uncertainty" is the
notion that model  estimates will not perfectly predict observed air quality at any given location,
neither at the present time nor in the future.  Uncertainty arises for a variety of reasons, for
example, limitations in the model's formulation which may be due to an incomplete
representation in the model of physiochemical processes and/or meteorological and other input
data base limitations, and uncertainty in forecasting future levels of emissions.  States/Tribes
should recognize these limitations when preparing their modeled attainment demonstrations.
       2Ozone Implementation Rule- Phase 2

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     We recommend several qualitative means for recognizing model limitations and resulting
uncertainties when preparing an attainment demonstration. First, we recommend using models
in a relative sense in concert with observed air quality data (i.e., taking the ratio of future to
present predicted air quality and multiplying it times an "ambient" design value)3. As described
later, we believe this approach should reduce some of the uncertainty attendant with using
absolute model predictions alone.  Second, we recommend that a modeling analysis be preceded
by analyses of available air quality, meteorological, and emissions data to gain a qualitative
understanding of an area's nonattainment problem. Such a description should be used to help
guide a model application and may provide a reality check on the model's predictions.  Third, we
recommend that States/Tribes use several model outputs, as well as other supporting analyses, to
provide corroborative evidence concerning the adequacy of a proposed strategy for meeting the
NAAQS. Modeling results and other supporting analyses can be weighed to determine whether
or not the resulting evidence suggests a proposed control strategy is adequate to meet the
NAAQS. Finally, we identify several activities/analyses which States/Tribes could undertake, if
they so choose, to apply models and corroborative approaches in subsequent reviews and
analyses of a control strategy, such as mid-course reviews. These subsequent reviews are useful
for determining whether a SIP is achieving progress as expected.
Premise 2. For many areas, nested regional/urban model applications will be needed to
support the attainment demonstration.  Available air quality data suggest ozone
concentrations approach levels specified in the NAAQS throughout much of the eastern U.S. and
in large parts of California.  A number of analyses (EPA, 1998 and EPA, 2004) show that
regional ozone transport can impact areas several hundred miles or more downwind. The
regional extent of moderate to high ozone and transport patterns and distances in some areas will
likely necessitate nested regional model applications.

     This guidance identifies several modeling systems* with nesting capabilities to resolve
meteorological parameters, emissions, chemistry, and transport. We believe it is not beneficial
to identify any modeling system as the preferred, or "guideline model" for ozone.  States/Tribes
may use any appropriate modeling system provided that the requirements of 40 CFR 51.112 are
met. In this guidance, we provide  certain criteria to assist States/Tribes in justifying the use of
such modeling systems.  These criteria apply equally to U.S.EPA models and alternative air
quality model(s). The guidance also provides recommendations for developing meteorological,
air quality and emissions inputs used in nested regional model applications, and makes
       3  Ambient design values are based on observations made at monitor locations.

       4A modeling system includes a chemical model, an emissions model and a meteorological
model. Terms, such as this one, which are introduced using italics are defined more fully in a
glossary at the back of this guidance.  "Modeling system" and "air quality model" are used
interchangeably. "Air quality model" means "modeling system" in this guidance.

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suggestions for quality assuring inputs and evaluating performance of emissions, meteorological
and air quality models.

Premise 3. Resource intensive approaches may often be needed to support an adequate
attainment demonstration. This follows from the regional nature of ozone concentrations
approaching 0.08 ppm in large portions of the U.S.  While we believe that existing and future
regional reductions in NOx emissions will reduce ozone over much of the eastern U.S., regional
ozone concentrations approaching the level specified in the NAAQS will continue to affect local
strategies needed to attain the NAAQS in the remaining nonattainment areas.

      This guidance recommends using regional modeling domains.  Regional modeling
applications require coordination, quality assurance and management of data bases covering
large areas of the country. Resources used to run recommended models  for generating
meteorological and emissions inputs and the air quality model itself can  be substantial.
States/Tribes facing the need to develop an  attainment demonstration requiring resource
intensive techniques may wish to consider pooling resources in some manner.  Examples might
include delegating responsibilities for certain parts of the analyses to  a single State/Tribe which
can "specialize" in that kind of analysis. Another example might be formation of a regional
technical center to perform analyses as directed by its client group of States/Tribes (e.g., multi-
state and tribal organizations such as the Regional Planning Organizations (RPO) 5, LADCO,
and the Ozone Transport Commission (OTC)).

Premise 4. High concentrations of ozone, PM2 56 and regional haze often have a common
origin.  Ozone formation and formation of secondary particulates result  from several common
reactions and reactants. Secondary  particulates are a major part of PM25 Often similar sources
contribute precursors to both ozone and PM2 5.  In some regions of the U.S., high regional ozone
and secondary particulates are observed under common types of meteorological  conditions.
Reducing PM25 is the principal controllable means for improving regional haze.  U.S. EPA
policy is to encourage "integration" of programs to reduce ozone, PM25  and regional haze to
ensure they do not work at cross purposes and to foster maximum total air quality benefit for
lower costs.

     Integration of strategies to reduce ozone, PM2 5 and regional haze may be complicated by
the different dates by which SIP revisions may be due (e.g., 2007 for ozone, circa 2007-2008 for
PM2 5 and regional haze, etc.). This guidance identifies activities which  could yield useful
information for a subsequent review of the impact of ozone control strategies on PM2 5 and
regional haze.
       5EPA provides funding to five regional planning organizations to address regional haze
and related issues,  http://www.epa.gov/air/visibility/regional.html

       6PM25 are particles having aerodynamic diameters less than or equal to 2.5 micrometers.

                                           4

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     1.4      What Topics Are Covered In This Guidance?

     This guidance addresses two broad topics: Part I, "How do I use results of models and
other analyses to help demonstrate attainment?", and Part II, "How should I apply air quality
models to produce results needed to help demonstrate attainment?". Part I is divided into 5
sections (i.e., Sections 2-6). Part II consists of 9 sections (Sections 7-15).

     Part I ("How do I use results of models and other analyses to help demonstrate
attainment?") begins  in Section 2 with an overview of the procedure for using modeling results
to help demonstrate attainment of the 8-hour ozone NAAQS.

     Section 3 describes the recommended modeled attainment test in detail.  The section also
includes examples illustrating the use of the recommended tests.

     Section 4 describes how supporting analyses should be performed to complement the
attainment test, as well as how it should be used in a weight of evidence determination.

     Section 5 identifies several data gathering activities and analyses which States/Tribes could
undertake to enhance the credibility of the modeling and corroborative analyses to support
subsequent reviews on progress toward attainment (e.g. mid-course reviews).

     Section 6 identifies the documentation necessary to adequately describe the analyses used
to demonstrate attainment of the ozone NAAQS.
     Part II ("How should I apply air quality models to produce results needed to help
demonstrate attainment?") begins in Section 7 with an overview of the topics to be covered.

     Section 8 identifies a series of meteorological, emissions and air quality data analyses
which should be undertaken to develop a qualitative description of an area's nonattainment
problem prior to a model application.  As we describe, this qualitative description should be used
to guide the subsequent model application.

     Section 9 describes the purpose, function, and contents of a modeling protocol.

     Section 10 addresses what criteria should be considered in choosing a model to support the
attainment demonstration of the ozone NAAQS.  Several guidelines are identified for accepting
the use of a model for this purpose.

     Section 11 provides guidance  for selecting suitable episodes to model for an ozone
attainment demonstration.  Topics include a discussion of the form of the NAAQS and its
resulting implications for episode selection.

     Section 12 identifies factors which should be considered in choosing; a model domain, the

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horizontal and vertical resolution, and the initial/boundary conditions for an air quality modeling
application.

     Section 13 addresses how to develop and evaluate meteorological inputs for use in a
modeling exercise supporting an attainment demonstration.

     Section 14 discusses how to develop appropriate emissions estimates for use in the selected
air quality model.

     Section 15 outlines the structure of model performance evaluations and discusses the use of
diagnostic analyses.

     The guidance concludes with references and a glossary of important terms which may be
new to some readers.

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Part I.   How Do I Use Results Of Models And Other
        Analyses To Help Demonstrate Attainment?

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2.0  What Is A Modeled Attainment Demonstration?--An Overview

     A modeled attainment demonstration consists of (a) analyses which estimate whether
selected emissions reductions will result in ambient concentrations that meet the NAAQS, and
(b) an identified set of control measures which will result in the required emissions reductions.
As noted in Section 1, this guidance focuses on the first component of an attainment
demonstration, that is, completion and interpretation of analyses to estimate the amount of
emission reduction needed to attain the ozone NAAQS. Emission reduction strategies should be
simulated by reducing emissions from specific source categories rather than through broad
"across-the-board" reductions from all sources.

     States/Tribes should estimate the amount of emission reduction needed to demonstrate
attainment by using the modeled attainment test. In addition, a State/Tribe should consider a
broader set of model results, as well as perform a set of other corroboratory analyses to further
support whether a proposed emission reduction will lead to attainment of the NAAQS.

     2.1      What Is The Recommended Modeled  Attainment Test?~An Overview

     A modeled attainment test is an exercise in which an air quality model is used to simulate
current and future air quality. If future estimates of ozone concentrations are < 84 ppb, then this
element of the attainment test is satisfied7.  Our recommended test is one in which model
estimates are used in a "relative" rather than "absolute" sense.  That is, we take the ratio of the
model's future to current (baseline) predictions at ozone monitors. We call these ratios, relative
reduction factors.  Future ozone  concentrations are estimated at existing monitoring sites by
multiplying a modeled relative reduction factor at locations "near" each monitor by the
observation-based, monitor-specific, "baseline" ozone design value. The resulting predicted
"future concentrations" are compared to 84 ppb.

     The recommended modeled attainment test predicts whether or not all estimated future
design values will be less than or equal to the concentration level specified in the ozone NAAQS
under meteorological conditions  similar to those which have been simulated.  The monitor-based
test does not consider future ozone in areas that are not near a monitor. Therefore, we
recommend a supplemental unmonitored area analysis to identify other locations where passing
the attainment test may be problematic if monitoring data were available. Details of the
unmonitored area analysis are in Section 3.4.
       7As detailed in Section 4, additional corroborative analyses are still needed to supplement
the modeled attainment test, even when predicted ozone concentrations are < 84 ppb.

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     2.2     What Does A Recommended Supplemental Analysis/Weight Of Evidence
             Determination Consist Of? —An Overview
     As we describe in more detail in Section 4, States/Tribes should always perform
complementary analyses of air quality, emissions and meteorological data, and consider
modeling outputs other than the results of the attainment test.  Such analyses are instrumental in
guiding the conduct of an air quality modeling application. Sometimes, the results of
corroboratory analyses may be used in a weight of evidence determination to show that
attainment is likely despite modeled results which may be inconclusive.  The further the
attainment test is from being passed, the more compelling contrary evidence produced by
corroboratory analyses must be to draw a conclusion differing from that implied by the modeled
attainment test results. If a conclusion differs from the outcome of the modeled test, then the
need for subsequent review (several years hence) with more complete data bases is increased. If
the test is failed by a wide margin (e.g., future design values greater than or equal to 88 ppb at an
individual site or multiple sites/locations), it is far less likely that the  more qualitative arguments
made in a weight of evidence determination can be sufficiently convincing to conclude that the
NAAQS will be attained8. Table 2.1 contains guidelines for assessing when corroboratory
analyses and/or weight of evidence determinations may be appropriate.

     Table 2.1 Guidelines For Weight of Evidence Determinations	
      Results of Modeled Attainment
                   Test
       Future Design Value < 82 ppb,
             all monitor sites
      Future Design Value 82 - 87 ppb,
       at one or more sites/grid cells
      Future Design Value > 88 ppb,
       at one or more sites/grid cells
         Supplemental Analyses
   Basic supplemental analyses should be
 completed to confirm the outcome of the
         modeled attainment test
A weight of evidence demonstration should
  be conducted to determine if aggregate
supplemental analyses support the modeled
             attainment test
  More qualitative results are less likely to
  support a conclusion differing from the
  outcome of the modeled attainment test.
     In a weight of evidence (WOE) determination, States/Tribes should review results from
several diverse types of air quality analyses, including results from the modeled attainment test.
As a first step, States/Tribes should note whether or not the results from each of these analyses
support a conclusion that the proposed strategy will meet the air quality goal.  Secondly,
       8 Regional ozone modeling completed by EPA indicates that, on average, considerable
amounts of precursor control (e.g., 20-25 percent) will be needed to lower projected ozone
design values by 3 ppb or more.

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States/Tribes should weigh each type of analysis according to its credibility, as well as its ability
to address the question being posed (i.e., is the strategy adequate for meeting the ozone NAAQS
by a defined deadline?).  The conclusions derived in the two preceding steps are combined to
make an overall assessment of whether meeting the air quality goal is likely.  This last step is a
qualitative one. If it is concluded that a strategy is inadequate to demonstrate attainment, a new
strategy is selected for review, and the process is repeated.  States/Tribes should provide a
written rationale documenting how and why the conclusion is reached regarding the adequacy of
the final selected strategy. Results obtained with air quality models are an essential part of a
weight of evidence determination and should ordinarily be very influential in deciding whether
the NAAQS will be met.

   2.3        Why Should A Model Be Used In A "Relative" Sense And Why May
              Corroboratory Analyses Be Used In A Weight Of Evidence Determination?

   The procedure we recommend for estimating needed emission reductions differs from that in
past guidance (U.S. EPA, 1996c) for ozone in two major respects. First, we recommend a
modeled attainment test in which model predictions are used in  a relative rather than absolute
sense.  Second, the role of the weight of evidence determination, when used, has been expanded.
That is, these results can now be used as a rationale for concluding that a control strategy will
meet the NAAQS, even though the modeled attainment test alone may not be conclusive. There
are several reasons why we believe these changes are appropriate.

1. The form of the 8-hour NAAQS necessitates such an attainment test.  The 8-hour NAAQS
for ozone requires the fourth highest 8-hour daily maximum ozone concentration, averaged over
three consecutive years, to be < 0.08 ppm at each monitoring site9.  The feature of the  NAAQS
requiring averaging over three years presents difficulties using the resource-intensive Eulerian
models we believe are necessary to capture spatially differing, complex non-linearities between
ambient ozone and precursor emissions. That is, it is difficult to tell whether or not a modeled
exceedance obtained on one or more days selected from a limited sample of days is consistent
with meeting the NAAQS. To do so would require modeling many days and, perhaps, many
strategies. This problem is reduced by using the monitored design value, as an inherent part  of
the modeled attainment test.

2. Starting with an observed concentration as the base value reduces problems in
interpreting model results.  If a model under (or over) predicts an observed daily maximum
concentration,  the appropriate target prediction is not as clear as might be  desired.  For example,
if an 8-hour daily maximum ozone concentration of 120 ppb were observed and a model
predicted 100 ppb on that day, should the target for the day still be 84 ppb? In the relative
attainment test, observed data is used to define the target concentration. This has the effect of
       9See 40CFR Part 50.10, Appendix I, paragraph 2.3.  Because of the stipulations for
rounding significant figures, this equates to a modeling target of < 84 ppb.  Because non-
significant figures are truncated, a modeling estimate < 85 ppb is equivalent to < 84 ppb.

                                           10

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anchoring the future concentrations to a "real" ambient value.  Although good model
performance remains a prerequisite for use of a model in an attainment demonstration, problems
posed by less than ideal model performance on an individual day are reduced by the new
procedure.

3. Model results and projections will continue to have associated uncertainty. The
procedure we recommend recognizes this by including modeling plus other analyses to
determine whether all available evidence supports a conclusion that a proposed emission
reduction plan will suffice to meet the NAAQS. For applications in which the modeled
attainment test is not passed (i.e., the attainment test indicates that the strategy will not reduce
ozone to 84 ppb or less), a weight of evidence analysis may be used to support a determination
that attainment will be achieved, despite the results of the modeled attainment test. The weight
of evidence determination includes several modeling results which are more difficult to relate to
the form of the NAAQS. These results address relative changes in the frequency and intensity  of
high modeled ozone concentrations on the sample of days selected for modeling. If
corroboratory analyses produce strong evidence that a control strategy is unlikely to meet the
NAAQS, then the strategy may be inadequate, even if the modeled attainment test is passed.

4. Focusing the modeled attainment test only at monitoring sites could result in control
targets which are too low if the  monitoring network is limited or poorly designed.  We
recommend a test which includes a review of the  strategy's impact at locations without monitors.
This exercise provides a supplemental test to determine whether there is a need for further action
despite passing the modeled attainment test at all  monitoring sites.  Ultimately, the best way to
account for a limited or poorly designed monitoring network is to use the model results, or other
available analyses, to help determine locations where  additional monitors should be sited.
                                           11

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3.0    What Is The Recommended Modeled Attainment Test?

   In Section 2, we provided an overview of the recommended modeled attainment test.
However, there are several decisions which must be made before the recommended test can be
applied. In this section, we identify a series of issues regarding selection of inputs to the test,
and recommend solutions.  We also describe, in more detail, the unmonitored area analysis
procedure.  Finally, we describe how to apply the test and illustrate this with examples.

   Equation (3.1) describes the recommended modeled attainment test, applied near monitoring
site I.

   (DVF)I = (RRF)I(DVB)I                                                       (3.1)

   where

    (DVB)j = the baseline concentration monitored at site I, units in ppb;

    (RRF)j = the relative reduction factor, calculated near site I, unitless
    The relative reduction factor is the ratio of the future 8-hour daily
    maximum concentration predicted near a monitor (averaged over multiple days) to the
    baseline 8-hour daily  maximum concentration predicted near the monitor (averaged over the
    same days), and

    (DVF)j = the estimated future design value for the time attainment is required, ppb.

   Equation (3.1) looks simple enough.  However, several issues must be resolved before
applying it.

(1) How is a "site-specific" baseline design value ((DVB)j) calculated?

(2) In calculating the (RRF)i, what do we mean by "near" site I?

(3) Several surface grid cells may be "near" the monitor, which one(s) of these should be  used to
calculate the (KKF\ ?

(4) How do you calculate future design values in unmonitored areas?

(5) Should any days be excluded when computing a relative reduction factor?

(6) Which base year emissions inventory should be projected to the future for the purpose of
calculating RRFs?

(7) Which future year should emissions be projected to in order to assess attainment using the
modeled attainment test?

                                          12

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   3.1        Calculating site-specific baseline concentrations.

   The modeled attainment test is linked to the form of the 8-hour NAAQS for ozone through
use of monitored design values10. The baseline design values are projected to the future using
RRFs. In practice, the choice of the baseline design value can be critical to the determination of
the estimated future year design values. Therefore, careful consideration should be given to the
calculation of baseline values.  The baseline design values should have the following attributes:

1) Should be consistent with the form of the 8-hour ozone standard.
2) Should be easy to calculate.
3) Should represent the baseline inventory year.
4) Should take into account the year-to-year variability of meteorology.
5) Should take into account the year-to-year variability of emissions.

Several possible methodologies to calculate baseline design values are:

1) The designation design value period (i.e. 2001-2003).
2) The design value period that straddles the baseline inventory year (e.g., the 2001-2003 design
value period for a 2002 baseline inventory year).
3) The highest (of the three) design value periods which include the baseline inventory year (e.g.
the 2000-2002, 2001-2003, and 2002-2004 design value periods for a 2002 baseline inventory
year).
4) The average (of the three) design value periods which straddle the baseline inventory year.

   For the modeled attainment test we recommend using the average of the three design value
periods (choice number 4 from above) which include the baseline inventory year. Based on the
attributes listed above, the average of the three design value periods best represents the baseline
ozone concentrations, while taking into account the variability of the meteorology and emissions
(over a five year period).

   The three design values that are averaged in the calculation cover a five year period, but the
average design value is not a straight five year average. It is, in effect, a weighted average of the
annual averages. For example, given a baseline inventory year of 2002, the years used to
calculate the average design value range from 2000-2004. In the average of the 2000-2002,
2001-2003, and 2002-2004 periods, 2002 is "weighted" three times, 2001 and 2003 are weighted
twice, and 2000 and 2004 are weighted  once.  This has the desired effect of weighting the
projected ozone values towards the middle year of the five year period, which is the emissions
year (2002  in this example).  The average design value methodology is weighted towards the
       10Design values at each monitoring site are calculated in accordance with 40 CFR Part
50.10, Appendix I. The design value is calculated as the 3 year average of the fourth highest
monitored daily 8-hour maximum value at each monitoring site.

                                           13

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inventory year and also takes into account the emissions and meteorological variability that
occurs over the full five year period (although the emissions and meteorology from the other
years are weighted less than the middle year of the 5 year period). Because of this, the average
weighted design value is thought to be more representative of the baseline emissions and
meteorology period than other methodologies such as choosing the highest single design value
period.

   Additionally, the average design value will be more stable (less year to year variability) than
any single design value period. An analysis of recent ambient design value data at 471 ozone
monitors, over the period 1993-2004,  shows that the median standard deviation of design values
was 3.3 ppb whereas the standard deviation of the 5 year weighted average design values was 2.4
ppb (Timin, 2005a). Also, moving from the period ending in 2003 to the period ending in 2004,
the median change in the design values was 4.0 ppb. The median change in the 5 year weighted
average design values was only 0.8 ppb.  These analyses show that the average design values are
clearly more stable and will therefore provide a "best estimate" baseline year design value
(DVBj) for use in future year model projections.

   The recommended averaging technique assumes that at least five complete years of ozone
data is available at each monitor. In some cases there will less than five years of available data
(especially at relatively new monitoring sites).  In this case we recommend that data from the
monitor is used if there is at least three consecutive years of data. If there are three years of data
then the baseline design value will be based on a single design value.  If there are four years of
data then the baseline design value will be based on an average of two design value  periods.  If a
site has less than three years of data, then the site should not ordinarily be used in the attainment
test.

Calculating site-specific "baseline"  design values11 to use in the attainment test

Example 3.1

Given:

(1) The baseline inventory year is 2002 (i.e., 2002 emissions are being modeled).
(2) For purposes of illustration, suppose the area contains only three ozone monitors.

Find: The appropriate site-specific baseline design values to use in the modeled attainment test.

Solution: Since the inventory reflects 2002, we need to examine monitored design values for
overlapping 3-year periods that include 2002.  The three design values are then averaged for
       nThe "baseline design value" is an average of several design values and thus is
technically not a design value.  The guidance continues to refer to the average design values as
"design values" even though they are based on averages of observed design values.

                                           14

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each site.  These are the values for site-specific baseline design values (DVB) in the modeled
attainment test. The procedure is shown in Table 3.1.
          Table 3.1 Example Illustrating Calculation Of Baseline Design Values
Monitor
1
2
3
2000-2002
Design Value,
ppb
88
86
88
2001-2003
Design
Value, ppb
87
84
86
2002-2004
Design
Value, ppb
90
91
85
Baseline Design Value
(DVB) Used In The
Modeled Attainment
Test, ppb
88.312
87.0
86.3
   3.2
Identifying surface grid cells near a monitoring site.
   There are three reasons why we believe it is appropriate, in the modeled attainment test, to
consider cells "near" a monitor rather than just the cell containing the monitor. First, one
consequence of a control strategy may be "migration" of a predicted peak. If a State were to
confine its attention only to the cell containing a monitor, it might underestimate the RRF (i.e.,
overestimate the effects of a control strategy).  Second, we believe that uncertainty in the
formulation of the model and the model inputs is consistent with recognizing some leeway in the
precision of the predicted location of daily maximum ozone concentrations. Finally, standard
practice in defining a gridded modeling domain is to start in the southwest corner of the domain,
and determine grid cell location from there.  Considering several cells "near" a monitor rather
than the single cell containing the monitor diminishes the likelihood of inappropriate results
which may occur from the geometry of the superimposed grid system.

   Earlier guidance (U.S. EPA,1996a) has identified 15 km as being "near" a site.  This is also
consistent with the broad range of intended representativeness for urban scale ozone monitors
identified in 40CFR Part 58, Appendix D.
       12 The average design value should carry one significant figure to the right of the decimal
point. There are several calculations in the modeled attainment test which carry the tenths of a
ppb digit.  We have found that rounding and/or truncating ozone concentrations and RRFs can
lead to an overestimate or underestimate of the impact of emissions controls. In some cases, a
few tenths of a ppb change (or a few tenths of a percent reduction) can be meaningful. Rounding
or truncating can make the change appear to be equal to a full ppb (or 1%) or equal to zero
change. It is recommended to round to the tenths digit until the last step in the calculation when
the final future design value is truncated.
                                           15

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   For ease in computation, States/Tribes may assume that a monitor is at the center of the cell
in which it is located and that this cell is at the center of an array of "nearby" cells.  The number
of cells considered "nearby" (i.e., within about a 15 km radius of) a monitor is a function of the
size of the grid cells used in the modeling. Table 3.2 provides a set of default recommendations
for defining "nearby" cells for grid systems having cells of various sizes. Thus, if one were
using a grid with 4 km grid cells, "nearby" is defined by a 7 x 7 array of cells, with the monitor
located in the center cell.

   The use  of an array of grid cells near a monitor may have a large  impact on the RRFs in
"oxidant limited" areas (areas where NOx decreases may lead to ozone increases). The array
methodology could lead  to unrealistically small or large RRFs, depending on the specific case.
Care should be taken in identifying an appropriate array size for these areas. States/Tribes may
consider the presence of topographic features, demonstrated mesoscale flow patterns (e.g.,
land/sea, land/lake interfaces), the density of the monitoring network, and/or other factors to
deviate from our default definitions for the array of "nearby" grid cells, provided the justification
for doing so is documented.

  Table 3.2. Default Recommendations For Nearby Grid Cells Used To Calculate RRF's
Size of Individual Cell, km
4-513
>5-8
>8-15
>15
Size of the Array of Nearby
Cells, unitless
7x7
5x5
3x3
1x1
   3.3        Choosing model predictions to calculate a relative reduction factor (RRF)j
              near a monitor.

   Given that a model application produces a time series of estimated 1-hour ozone
concentrations (which can be used to calculate running 8-hour averages), what values should be
chosen from within the time series? We recommend choosing predicted 8-hour daily maximum
concentrations from each modeled day (excluding "ramp-up" days) for consideration in the
modeled attainment test. The 8-hour daily maxima should be used, because they are closest to
the form of concentration specified in the NAAQS.
       13The appropriate size of the array for horizontal grid cells < 4km should be discussed
with the appropriate U.S EPA Regional Office.

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   The second decision that needs to be made is, "which one(s) of the 8-hour daily maxima
predicted in cells near a monitor should we use to calculate the RRF?" We recommend choosing
the nearby grid cell with the highest predicted 8-hour daily maximum concentration with
baseline emissions for each day considered in the test, and the grid cell with the highest
predicted 8-hour daily maximum concentration with the future emissions for each day in the test.
Note that, on any given day, the grid cell chosen with the future emissions need not be the same
as the one chosen with baseline emissions.

   We believe selecting the maximum (i.e., peak) 8-hour daily maxima  on each day for
subsequently calculating the relative reduction factor (RRF) is preferable for several reasons.
First, it is likely to reflect any phenomenon which causes peak concentrations within a plume to
migrate as a result of implementing controls.  Second, it is likely to take  better advantage of data
produced by a finely resolved modeling analysis.

   The relative reduction factor (RRF) used in the modeled attainment test is computed by
taking  the ratio of the mean of the 8-hour daily maximum predictions in  the future to the mean of
the 8-hour daily maximum predictions  with baseline emissions, over all relevant days.  The
procedure is illustrated  in Example 3.2.

Example 3.2

Given: (1) Four primary days have been simulated using baseline and future emissions.

(2) The horizontal dimensions for each surface grid cell are 12 km x  12 km.

(3) In each of the 9 grid cells "near" a monitor site I, the maximum daily predicted future
concentrations are 87.2, 82.4, 77.5, and 81.1 ppb.

(4) In each of the 9 grid cells "near" a monitor site I, the maximum daily predicted baseline 8-
hour daily maximum ozone concentrations are 98.3, 100.2, 91.6, and 90.7 ppb.

Find: The site-specific  relative reduction factor for monitoring site I, (RRF)j

Solution:

(1) For each day and for both baseline and future emissions, identify  the 8-hour daily maximum
concentration predicted near the monitor. Since the grid cells are 12  km, a 3  x 3 array of cells is
considered "nearby" (see Table 3.2).

(2) Compute the mean 8-hour daily maximum concentration for (a) future and (b) baseline
emissions.

Using the information from above,
                                           17

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   (a) (Mean 8-hr daily max.)&ture = (87.2 + 82.4 + 77.5 + 81.1)/4 = 82.1 ppb
    and

   (b) (Mean 8-hr daily max.)baseline = (98.3 + 100.2 + 91.6 + 90.7)74 = 95.2 ppb

(3) The relative reduction factor for site I is

(RRF)j = (mean 8-hr daily max.)&ture/(mean 8-hr daily max.)baseline

      = 82.1/95.2 = 0.862
   3.4    Estimating design values at unmonitored locations: what is an unmonitored area
          analysis and why is it needed?
   An additional review is necessary, particularly in nonattainment areas where the ozone
monitoring network just meets or minimally exceeds the size of the network required to report
data to Air Quality System (AQS). This review is intended to ensure that a control strategy leads
to reductions in ozone at other locations which could have baseline (and future) design values
exceeding the NAAQS were a monitor deployed there.  The test is called an "unmonitored area
analysis". The purpose of the analysis is to use a combination of model output and ambient data
to identify areas that might exceed the NAAQS if monitors were located there.

   The unmonitored area analysis should identify areas (outside of the monitor arrays) where
future year design values are predicted to be greater than the NAAQS. The unmonitored area
analysis for a particular nonattainment area is intended to address potential problems within or
near that nonattainment area. The analysis should include, at a minimum, all nonattainment
counties and counties surrounding the nonattainment area (located within the State).  In large
States, it is possible that unmonitored area violations may appear in counties far upwind or
downwind of the local area of interest.  In those cases, the distance to the nonattainment area and
ability of the modeling to represent far downwind areas should be evaluated on a case by case
basis. In order to examine unmonitored areas in all portions of the domain, it is recommended to
use interpolated spatial fields of ambient ozone data combined with gridded modeled ozone
outputs.
   3.4.1  Why does the unmonitored area analysis need to use both ambient data and
          model output?

   Ambient ozone data can be interpolated to provide a set of spatial fields. The spatial fields
will provide an indication of ozone concentrations in monitored and unmonitored areas.  But a
simple interpolation of the ambient data cannot identify unmonitored areas with higher ozone
concentrations than those measured at monitors. The interpolated concentration between

                                           18

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monitors will generally be the same or lower than the measured concentration at the monitors
(assuming that more sophisticated statistical techniques are not used, such as adding a nugget
effect or a trend surface).  The interpolation technique does not account for emissions or
chemistry  information that is needed to identify potential unmonitored violations.

   The gridded model output (absolute) concentrations can also be used to examine
unmonitored area concentrations. The model provides an hourly concentration for every grid
cell.  The concentrations can be analyzed to determine unmonitored areas where the model
predicts high ozone values.  But the absolute predictions from the model may not be entirely
accurate. The model output is only as good as the emissions and meteorological input. But
unlike the  interpolated ambient data, the model output explicitly accounts for emissions,
chemistry, and meteorology over the entire domain.

   Both the interpolated ambient data and the model outputs have major weaknesses. But they
also both have strengths.  We can take advantage of the strengths of each dataset by combining
the two types of data.  The interpolated spatial fields of ambient data provide a strong basis for
estimating accurate ozone concentrations at monitors and near monitors. Given that information,
the model  outputs can be used to adjust the interpolated spatial fields (either up or down) so that
more accurate estimates can be derived in the unmonitored areas. The best way to use the model
to adjust the spatial fields is to use modeled gradients. It is preferable to assume that the model
is predicting areas of generally high or low ozone, as compared to assuming that the absolute
predictions from the model are correct.  For example, in areas where the model predicts relatively
high ozone concentrations, the spatial fields can be adjusted upward. In areas where the model
predicts relatively low ozone concentrations, the spatial fields can be adjusted downward.  In
this way, it may be possible to predict downwind unmonitored areas that may have high ozone
concentrations.  At the same time, ozone concentrations in rural areas, (which may be overly
influenced by high monitored ozone near urban areas), may be adjusted downward  The
combination of interpolated spatial fields and modeled output will be referred to as "model
adjusted spatial fields"

   3.4.2  Implementation of Model Adjusted  Spatial Fields

   Model adjusted spatial fields are first created for the base year.  Future year estimates can
then be created by applying  gridded RRFs to the model adjusted spatial fields. The basic steps
are as follows:

1) Interpolate ambient ozone design value  data to create a set of spatial fields.
2) Adjust the spatial fields using gridded model output gradients (base year values).
3) Apply gridded model RRFs to the model adjusted spatial fields.
4) Determine if any unmonitored areas are predicted to exceed the NAAQS in the future.

   The first step in the analysis is to interpolate ambient  data.  Ideally, design values should be
interpolated. The same 5  year weighted average design values that are used in the monitor based
model attainment test can be used in the development of ambient spatial fields.  Care should be

                                           19

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taken so that the interpolated fields are not unduly influenced by monitoring sites that do not
have complete data. Since the design values can vary significantly from year to year, it is
important to use a consistent set of data. In some cases, it may be preferable to interpolate
individual years of data or individual design values, and then average those up to get the 5 year
weighted average.  There is not a single recommended interpolation technique.  EPA has
provided example analyses in the past using the Kriging interpolation technique (U.S.EPA,
2004b). EPA's BenMAP software, which was used to create interpolated fields for the CAIR,
uses the Voronoi Neighbor Averaging (VNA) technique (Abt, 2003).

    The second step in the process involves the use of gridded model output to adjust the spatial
fields. The BenMAP software contains an example of this technique called eVNA. It uses
seasonal average model output data to adjust interpolated spatial fields. The eVNA technique
has been used in health benefits assessments (U.S. EPA, 2005a).

    The next step is to create future year fields by multiplying the base year model adjusted
spatial fields by model derived gridded RRFs.  The RRFs for the unmonitored area analysis are
calculated in the same way as the monitored based attainment test (except that the grid cell array
is not used in the spatial fields based analysis). The future year concentrations are equal to the
base year concentration times the RRF in each grid cell. The future year model adjusted spatial
fields are then  analyzed to determine if any grid cells are predicted to remain above the NAAQS.

    EPA intends to provide software (similar to BenMAP) which will be able to spatially
interpolate data (VNA), adjust the spatial fields based on model output (eVNA) and multiply the
fields by model calculated RRFs. States will be able to use the EPA-provided software or are
free to develop alternative techniques that may be appropriate for their areas or situations.

    3.4.3  Using the Results of the Unmonitored Area Analysis

    It should be stressed that due to the lack of measured data, the examination of ozone
concentrations as part of the unmonitored area analysis is more uncertain than the monitor based
attainment test. As a result, the unmonitored area analysis should be treated as a separate test
from the monitor based attainment test. While it is expected that additional emissions controls
are needed to eliminate predicted violations of the monitor based test, the same requirements
may not be appropriate in unmonitored areas. Due to the uncertainty of the analysis, at a
minimum, it is appropriate to commit to additional deployment of ozone monitors in areas where
the unmonitored area analysis predicts future violations14.  This monitoring would allow a better
assessment in the future of whether the NAAQS is being met at currently unmonitored locations.
   Violations of the unmonitored area analysis should be handled on a case by case basis. As
       14In most cases, States/Tribes can commit to additional emissions controls in lieu of
additional monitoring in unmonitored areas.

                                           20

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such, additional analyses and/or tracking requirements may be needed depending on the nature
of the problem and the uncertainty associated with the potential violation.

   3.5    Limiting modeled 8-hour daily maxima chosen to calculate RRF.

   On any given modeled day, meteorological conditions may not be similar to those leading to
high concentrations (i.e., values near the site-specific design value) at a particular monitor. If
ozone predicted near a monitor on a particular day is much less than the design value, the model
predictions for that day could be unresponsive to controls (e.g., the location could be upwind
from most of the emissions in the nonattainment area on that day). Using equation (3.1) could
then lead to an erroneously high projection of the future design value.

   In order to examine this issue, we analyzed modeled baseline and future emissions for 30
episode days during 1995 using a grid with 12 km x 12 km cells and 9 vertical layers15. We
examined modeled RRF's computed near each of 299 monitoring sites in the eastern half of the
United States (Timin, 2005b).  The study examined the day to day variability of (daily) RRFs at
each site. One purpose of the study was to assess the extent to which a relative reduction factor
(RRF) is  dependent on the magnitude of modeled current 8-hour  daily maxima.

   Figure 3.1 shows an example of the raw data from the analysis for all of the monitoring sites
in the Baltimore region.  The plot shows the daily RRFs vs. the base case daily maximum
modeled  concentrations for all days (above 60 ppb in this case).  In this example, it can be seen
that the model tends to respond more to emissions reductions (lower RRFs) at higher predicted
ozone concentrations.  There appears to be a general bias in the model results such that the
model predicts less benefit from emissions reductions at lower concentrations.  Since we are
generally interested in the model response on high ozone days, these results tend to suggest that
the RRF calculation should be limited to days when the model predicts high ozone
concentrations.

   The analysis examined daily RRFs, but in practice, the RRFs are not  calculated on a daily
basis. A  mean RRF is calculated based on the mean base case concentration (across model days)
divided by the mean future case concentration (across the same model days).  As such, we also
calculated mean RRFs using various minimum concentration thresholds.  The minimum
       15See http://www.epa.gov/cair/pdfs/finaltech02.pdf for documentation of the base case
and future year modeling.

                                          21

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60 65 70 75 80 85 90 95 100 105 110 115 120 125 130 135 140
2001 Base Model Value (ppb)
Figure 3.1 - Daily relative reduction factors as a function of daily maximum base modeled
concentrations for monitors in the Baltimore nonattainment area.

 concentration thresholds examined ranged from 70-85 ppb in 5 ppb increments16. The
 monitoring sites were screened to eliminate sites that had a limited number of "high" modeled
 ozone days. All sites that had less than 10 days with an 8-hour average maximum modeled
 concentration of 85 ppb were dropped from the analysis. This left 206 sites in the analysis17.

    Table 3.3 shows that the mean RRF (averaged across all sites) is sensitive to the minimum
 ozone threshold. As the threshold is raised from 70 ppb to 85 ppb, the RRFs become larger. On
 average, the model predicts a 0.2% greater ozone reduction for every 5 ppb increase in the
 minimum threshold. Additionally, the variability of the daily RRFs (as measured by the standard
        16It was clear from the plots that a minimum threshold value of less than 70 ppb would
 not be appropriate.  An upper threshold of 85 ppb was examined because it is equal to the
 NAAQS.  We are generally concerned about the model response on days that exceed the
 NAAQS. But at the same time, it is necessary to have a sufficient number of days in the mean
 RRF calculation to develop a robust estimate (this is addressed in more detail in section 3.6).

        17The same set of sites was used for each of the threshold concentrations (70-85 ppb).

                                           22

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deviation of the daily RRFs) is reduced as the threshold is increased. This is an important
finding because lower variability in day to day RRFs indicates lower uncertainty in the mean
RRFs, and hence the attainment test results.
Minimum Threshold
70ppb
75ppb
80 ppb
85ppb
MeanRRF
0.879
0.876
0.874
0.872
Mean Standard
Deviation
0.030
0.029
0.028
0.026
Table 3.3- Mean RRFs and standard deviations as a function of various minimum
thresholds.

   As a result of the apparent bias in model response at concentrations below the NAAQS,
combined with the increased variability of the RRFs at lower concentrations, we recommend
using a minimum concentration threshold of 85 ppb18. This will result in less bias and provide
for more robust RRFs and future design values.
Example 3.3

Example 3.3 illustrates how to apply the minimum concentration threshold.

Given: The same simulations as performed in Example 3.2 yield low predictions near site I with
baseline emissions on day 3, such that the 8-hour daily maximum ozone concentration predicted
for that day is 65.0 ppb (rather than the 91 ppb shown in Example 3.2).

Find: The relative reduction factor near site I ((RRF);).

Solution:  (1) Calculate the mean 8-hour daily maximum ozone concentration obtained near site
I for baseline and future emissions.  Exclude results for day 3 from the calculations. From
Example 3.2,

(a) (mean 8-hr daily max)&ture = (87.2 + 82.4 + 81.1)73 = 83.6 ppb

(b) (mean 8-hr daily max)baseline = (98.3 + 100.2 + 90.7)73 = 96.4 ppb.
       18The analysis suggests a threshold of greater than 85 ppb may be appropriate, but 85 ppb
was chosen as the upper end of the threshold because it is equal to the NAAQS. It should be
sufficient to judge the results based on modeled days that exceed the standard.
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(2) Compute the relative reduction factor by taking the ratio of future/baseline.

(RRF)! = 83.6/96.4 = 0.867

   3.6    Which base year emissions inventory should be projected to the future for the
          purpose of calculating RRFs?

   The modeled attainment test adjusts observed concentrations during a baseline period (e.g.,
2000-2004) to a future period (e.g., 2009) using model-derived "relative reduction factors". It is
important that emissions used in the attainment test correspond with the period reflected by the
chosen design value period (e.g., 2000-2004).  Deviations from this constraint will diminish the
credibility of the relative reduction factors. Therefore, it is important to choose an appropriate
baseline emissions year. There are potentially two different base year emissions inventories.
One is the base case inventory which represents the emissions for the meteorology that is being
modeled.  These are the emissions that are used for model performance evaluations. For
example, if a State is modeling a 1998 episode, "base case" emissions and meteorology would be
for 1998.  As described in  Section 15, it is essential to use base case emissions together with
meteorology occurring in the modeled episode(s) in order to evaluate model performance.

   Once the model has been shown to perform adequately, it is no longer necessary to model the
base case emissions.  It now becomes important to model emissions corresponding to the period
with a recent observed design value. The second potential base year inventory corresponds to
the middle year of the baseline average design value (e.g 2002 for a 2000-2004 average design
value).  This is called the baseline inventory. The baseline emissions inventory is the inventory
that is ultimately projected to a future year.

   In section 14 we recommend using 2002 as the baseline inventory year for the current round
of ozone SIPs.  If States/Tribes use only episodes from 2002  (or the full 2002 ozone season) then
the base case and baseline  inventory years will be the same19.  But if States/Tribes model
episodes or full seasons from other years,  then the base case inventories should be projected (or
"backcasted") to 2002 to provide a common starting point for future year projections.

   Alternatively, the baseline emissions year could be earlier or later than 2002, but it should be
a relatively recent year (preferably within the 5 year design value window).  In order to gain
confidence in the model results, the emissions projection period should be as short as possible.
For example, projecting emissions from 2002 to 2009  (with a 2000-2004 baseline average design
value) should be less uncertain than projecting emissions from 1995 to 2009 (with a 1993-1997
baseline average design value).  Use of an older baseline average design value period is
       19 The year may be the same, but the emissions may still differ. The base case inventory
may include day specific information (e.g. wildfires, CEM data) that is not appropriate for using
in future year projections. Therefore the baseline inventory may need to replace the day specific
emissions with average or "typical" emissions (for certain types of sources).

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discouraged.

   It is desirable to model meteorological episodes occurring during the period reflected by the
baseline design value (e.g., 2000-2004). However, episodes need not be selected from the period
corresponding to the baseline design value, provided they are representative of meteorological
conditions which commonly occur when exceedances of the ozone standard occur.  The idea is
to use selected representative episodes to capture sensitivity of predicted ozone to changes in
emissions during commonly occurring conditions. There are at least three reasons why using
episodes outside the period with the baseline design value may be acceptable: (1) availability of
air quality and meteorological data from an intensive field study, (2) the desire to use
meteorological data which may be "more representative" of typical ozone conditions compared
to the baseline design value period and (3) availability of a past modeling analysis in which the
model performed well.
   3.7    Choosing a year to project future emissions.

   States/Tribes should project future emissions to the attainment year or time period, based on
the area's classification.  The "Final Rule to Implement the 8-Hour Ozone National Ambient Air
Quality Standard, Phase 1" provides a schedule for implementing emission reductions needed to
ensure attainment by the area's attainment date (40 CFR 51.908). Specifically, it states that
emission reductions needed for attainment must be implemented by the beginning of the ozone
season immediately preceding the area's attainment date. Attainment dates are expressed as "no
later than" three, five, six, or nine years after designation and nonattainment areas are required to
attain as expeditiously as practicable.  For example, moderate nonattainment areas that were
designated on June 15, 2004, have an attainment date of  no later than June 15, 2010, or as
expeditiously as practicable. States/Tribes are required to conduct a Reasonably Available
Control Measures (RACM) analysis to determine if they can advance their attainment date by at
least a year.  Requirements for the RACM analysis can be found in (U.S. EPA, 1999c).

    For areas with  an attainment date of no later than  June  15th 2010, the emission reductions
need to be implemented no later than the beginning of the 2009 ozone season. A determination
of attainment will likely be based on air quality monitoring data collected in 2007, 2008, and
2009. Therefore, the year to project future emissions should be no later than the last year of the
three year monitoring period; in this case 2009. Since areas are required to attain as
expeditiously as practicable and perform a RACM analysis, results of the analysis may indicate
attainment can be achieved earlier, (e.g., 2008). In this case, the timing of implementation of
control measures should be used to determine the appropriate projection year. For example, if
emission reductions (sufficient to show attainment) are implemented no later than the beginning
of the 2008 ozone season, then the future projection year should be no later than 2008. The
selection of the future year(s) to model should be discussed with the appropriate EPA Regional
Office as part of the modeling protocol development process.
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   3.8    How Do I Apply The Recommended Modeled Attainment Test?

   States/Tribes should apply the modeled attainment test at all monitors within the
nonattainment area plus other nearby counties within the State20. Inputs described in Section 3.1
are applied in Equation (3.1) to estimate a future design value at all monitor sites and grid cells
for which the modeled attainment test is applicable.  When determining compliance with the 8-
hour ozone NAAQS, the standard is met if, over three consecutive years, the average 4th highest
8-hour daily maximum ozone concentration observed at each monitor is < 0.08 ppm (i.e., < 84
ppb using rounding conventions)21.  Thus, if all resulting predicted future design values (DVF)
are < 84 ppb, the test is passed. The modeled attainment test is applied using 3 steps.

Step 1.  Compute baseline design values.  Compute site-specific baseline  design values
(DVBs) from observed data by using the average of the design value periods which include
the baseline inventory year.

   This is illustrated in Table 3.1 for  specific sites.  The values in the right hand column of
Table 3.1 are site-specific baseline design values.

Step 2.  Estimate relative reduction  factors. Use air quality modeling results to estimate a
relative reduction factor for each grid cell near a monitoring site.

   This step begins by computing the mean 8-hour daily maximum ozone concentrations for
future and baseline emissions. This has been illustrated in Examples 3.2 and 3.3. The  relative
reduction factor for site I is given by Equation 3.2.

(RRF)j = (mean 8-hr daily max)&ture/ (mean 8-hr daily max)baseline                         (3.2)

   Using Equation (3.2), the relative reduction factor is calculated as shown in the column (5) in
the last row of Table 3.3. Note that the RRF is calculated to three significant figures to the right
of the decimal place. The last significant figure is obtained by rounding, with values of "5" or
more rounded upward.  For the illustration shown in Table 3.3, we have assumed that the same
four days described previously in Example 3.3 have been simulated.  Note that on day 3,  model
baseline 8-hour daily maximum ozone concentration was < 85 ppb.  As discussed in Section 3.5,
predictions for this day are not included in calculating the mean values shown in the last row of
       20States are responsible for submitting SIPs for all areas of their State.  As such, the
monitored and unmonitored area attainment tests should be applied both within and outside of
the nonattainment area. In the modeling protocol, States should identify the appropriate areas to
apply the respective tests.  States should work with their EPA Regional Office to help determine
the appropriate areas.

       2140CFR Part 50.10, Appendix I, paragraph 2.3

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the table. We have also assumed that the monitored baseline design value (DVB) at site I is
102.0 ppb.

Step 3. Calculate future design values for all monitoring sites in the nonattainment area.
Multiply the observed baseline design values obtained in Step 1 times the relative reduction
factors obtained in Step 2.

   In Table 3.4, we see (column (2)) that the baseline observed design value at monitor site I is
102.0 ppb.  Using Equation (3.1), the predicted future design value for monitor site I  is,

   (DVF)! = (102.0 ppb) (0.867) = 88.4 ppb = 88 ppb

Note that the final future design value is truncated22 and in this example, the modeled attainment
test is not passed at monitor site I.
Day
1
2
3
4
Mean
Calculated
baseline design
value, (DVB),,
(ppb)




102.0
Baseline 8-hr daily
max. concentration
at monitor (ppb)
98.3
100.2
65.0
90.7
96.4
Future predicted
8-hr daily max.
concentration at
monitor (ppb)
87.2
82.4
Not Considered
81.1
83.6
Relative
reduction
factor(RRF),
-
-
-
-
0.867
(i.e.,
83.3/96.0)
Future design
value, (DVF)j,
(ppb)
-
-
-
-
88.4=
88 ppb
Table 3.4 Example Calculation of a Site-Specific Future Design Value (DVF)j
       22This effectively defines attainment in the modeled test as <= 84.9 ppb and
nonattainment as >= 85.0 ppb.
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4.0 How Can Additional Analyses Can Be Used to Support the
   Attainment Demonstration?

   By definition, models are simplistic approximations of complex phenomena. The modeling
analyses used to demonstrate that various emission reduction measures will bring an individual
area into attainment of the 8-hour ozone standard contain many elements that are uncertain (e.g.,
emission projections, meteorological inputs, model response). These uncertain aspects of the
analyses can sometimes prevent definitive assessments of future attainment status. The
confidence in the accuracy of the quantitative results from a modeled attainment test should be a
function of the degree to which the uncertainties in the analysis were minimized.  In general, by
following the recommendations contained within this guidance document, EPA expects that the
attainment demonstrations will mitigate the uncertainty as much as is possible given the current
state of modeling inputs, procedures, and science. However, while Eulerian air quality models
represent the best tools for integrating emissions and meteorological information with
atmospheric chemistry and no single additional analysis can replace that, EPA believes that all
attainment demonstrations will be strengthened by additional analyses that can help confirm that
the planned emissions reductions will result in attainment.

   Corroboratory evidence should accompany all model attainment demonstrations. Generally,
those modeling analyses that show that attainment will be reached in the future with some
margin of safety (e.g., less than 82 ppb in the attainment year) will need more limited supporting
material. For other attainment cases, in which the projected future design value is closer to 85
ppb, more  supporting analyses should be completed.  As noted earlier (see section 2.2), there
may be some  cases in which it is possible to either demonstrate attainment via a "weight of
evidence" demonstration despite failing the model attainment test, or conversely, demonstrate
that reaching attainment is not likely despite passing the model attainment test. This section of
the guidance will discuss some specific additional analyses that can be used to corroborate the
model projections, or refute them in the case of a weight of evidence determination. Additional
examples of possible weight of evidence determinations are provided in existing EPA guidance
(USEPA, 1996c).  Again, it should be noted that no single corroborating analysis can serve as an
adequate substitute for the air quality model, however, in aggregate, many such analyses can
help inform the process.

   4.1    What Types of Additional Analyses Should Be Completed as Part of the
          Attainment  Demonstration?

   Modeling: As discussed in Section 2, EPA has determined that the best approach to using
models to demonstrate attainment of the 8-hour ozone standard is to use the model in a relative
mode.  However, for some model applications there may be strong evidence from the
performance evaluation that the model is able to reproduce detailed observed data bases with
relatively little error or bias.  Particularly for cases such as these, some types of "absolute"
modeling results may be used to assess general progress towards attainment from the baseline
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inventory to the projected future inventory23.  There are several metrics that can be considered as
part of this type of additional analysis:

          percent change in total amount of ozone >= 85 within the nonattainment area
          percent change in grid cells >= 85 ppb within the nonattainment area
          percent change in grid cell-hours >= 85 ppb within the nonattainment area
    •      percent change in maximum modeled 8-hour ozone within the nonattainment area

    While these metrics can be used to estimate the magnitude, frequency, and relative amount of
eight-hour ozone reductions from any given future emissions scenario, there are no threshold
quantities of these metrics that can directly translate to an attainment determination.  Generally, a
large reduction in the frequency, magnitude, and relative amount of 8-hour ozone nonattainment
(i.e., >= 85 ppb) is consistent with a conclusion that a proposed strategy would meet the
NAAQS. In the context of a weight of evidence determination, these metrics could be used to
show that a particular location may be "stiff or relatively unresponsive to emissions controls,
while the rest of the modeling domain/nonattainment area is projected to experience widespread
reductions in 8-hour ozone.  If a sound technical argument can be made for why atypically high
RRFs at any particular location are not reasonable, then these types of supplemental  modeling
metrics may help provide confidence that attainment will be reached.

    In cases where attainment is demonstrated at all monitors,  the above metrics are useful in
showing the amount of expected reduction in other portions of the area where the unmonitored
area analysis was applied. The results of the unmonitored area analysis can also be examined to
indicate the magnitude and spatial extent of remaining nonattainment. If application of the
modeled test in all grid cells indicates that most or all of the unmonitored areas will be
attainment, then that information can support a modeled attainment demonstration and add
positive evidence to a weight of evidence determination.

    Uncertainty estimates associated with the spatial interpolation technique can also be
considered when reviewing and interpreting the results of an unmonitored area analysis. When
making a decision on whether attainment is likely to occur, areas with very high uncertainty
estimates for interpolated design values should be given less weight than areas with low
uncertainty estimates.  If model predicted future design values are close to or above the level of
the NAAQS, placing a monitor in the area, may be the only way to address this issue in the
future (absent of requiring additional emissions controls).

    There are various other ways to use modeling results as supplemental evidence that supports
       23 Care should be taken in interpreting absolute metrics if the model evaluation shows a
large underprediction or overprediction of 8-hour ozone concentrations. An underprediction of
observed ozone concentrations will make it artificially easy to show progress towards absolute
attainment levels and an overprediction of ozone will make it artificially difficult to show
progress towards attainment.

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(or questions) the modeled attainment test. These include, but are not limited to:

•  use of available regional modeling applications that are suitable24 for the local area,

•  use of other appropriate local modeling attainment demonstrations that include the
   nonattainment area of interest,

•  use of photochemical source apportionment and/or process analysis modeling tools to help
   explain why attainment is (or is not) demonstrated,

•  use of multiple air quality models / model input data sets (e.g., multiple meteorological data
   sets, alternative chemical mechanisms or emissions inventories, etc.).  For results to be most
   relevant to the way we recommend models be applied in attainment demonstrations, it is
   preferable that such procedures focus on the sensitivity of estimated relative reduction factors
   (RRF) and resulting projected design values to the variations in inputs or model
   formulations.

•  use of the same modeled attainment demonstration but with future design values that are
   calculated in an alternative manner than that recommended in Section 3 of this guidance.
   Any alternate  approaches for the calculation of the future design value should be
   accompanied with a technical justification as to why the approach is appropriate for the area
   in question and should be discussed with the appropriate EPA regional office.

   Trends in Ambient Air Quality and Emissions: Generally, air quality models are regarded
as the most appropriate tools for assessing the expected impacts of a change in emissions.
However, it may also be possible to extrapolate future trends in 8-hour ozone based on measured
historical trends of air quality and emissions. There are several elements to this analysis that are
difficult to quantify. First, the ambient data trends must be normalized to account for year-to-
year meteorological variations. Second, one must have an accurate accounting  of the year-to-
year changes in actual emissions (NOx and VOC) for the given area and any surrounding areas
whose emissions may  impact local ozone. Third, one must have a solid conceptual model of
how ozone is formed in the local area (e.g., NOx-limited, transport-influenced,  etc.). Assuming
all of these prerequisites can be met, then it may be possible to develop a curve that relates past
emissions changes to historical and current air quality.  Once the relationship between
past/present emissions and air quality is established, this "reduction factor" can be applied to the
expected emissions reductions from a particular control strategy.

   A simpler (and more uncertain) way to qualitatively assess progress toward attainment is to
       24 The resolution, emissions, meteorology, and other model inputs should be evaluated for
applicability to the local nonattainment area.  Additionally, model performance of the regional
modeling for the local nonattainment area should be examined before determining whether the
regional model results are suitable for use in the local attainment demonstration.

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examine recently observed air quality and emissions trends.  A downward trend in observed air
quality and a downward trend in emissions (past and projected) is consistent with progress
towards attainment.  Strength of the evidence produced by emissions and air quality trends is
increased if an extensive monitoring network exists and if there is a good correlation between
past emissions reductions and current trends in ozone. EPA recently prepared a report that
analyzed statistically significant trends in ozone (U.S. EPA, 2004c and U.S. EPA, 2005b) and
ozone precursor emissions as well as a report which examined the . This report is a good
template for States/Tribes considering similar analyses.

    Observational Modeling: In some cases ambient data can be used to corroborate the effects
of a control strategy (e.g., Blanchard et al, 1999; Croes et al, 2003; Koerber and Kenski, 2005).
There are numerous tools that can be used to determine whether ozone is sensitive to certain
types of precursors (i.e., VOC or NOx) or source sectors. Observational models can be used to
examine days which have not been modeled with an air quality model, as well as days which
have been modeled.  The resulting information may be useful for drawing conclusions about the
general representativeness of the responses simulated with the air quality model for a limited
sample of days. Additionally, receptor models, like chemical mass balance (CMB), positive
matrix factorization (PMF), and Unmix may be useful for confirming whether a strategy is
reducing the right sorts of sources (Maykut, 2003; Poirot et. al, 2001).

    Strength of the evidence produced by observational models is increased if an extensive
monitoring network exists and at least some of the monitors in the network are capable of
measuring pollutants to the degree of sensitivity required by the methods.  Evidence produced by
observational models is more compelling if several techniques are used which complement one
another and produce results for which plausible physical/chemical explanations can be
developed. Indications of a strong quality assurance analysis of collected data and
measurements that are made by a well trained staff also lend credence to the results.
   4.2    If I Use A Weight Of Evidence Determination, What Does This Entail?

   As discussed in Section 2, it may be possible through the use of supplemental analyses to
draw a conclusion differing from that implied by the modeled attainment test results. Past
modeling analyses have shown  that future design value uncertainties of 2-4 ppb can result from
use of alternate, yet equally appropriate, emissions inputs, chemical mechanisms, and
meteorological inputs (Jones, 2005; Sistla, 2004). Because of this uncertainty, EPA believes that
weight of evidence determinations can be used in some cases to demonstrate attainment
conclusions that differ from the conclusions of the model attainment test..

   As part of their recommendations to transform the SIP process into one that is more
performance-oriented, the Clean Air Act Advisory Committee (CAAAC) recommended
increased use of weight of evidence within State/Local attainment demonstrations (AQMWG,
2005). One of the workgroup's recommendations to EPA was that "EPA, in conjunction with
affected stakeholders, should modify its guidance to promote weight-of-evidence (WOE)

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demonstrations for both planning and implementation efforts. In particular, these demonstrations
should reduce reliance on modeling data as the centerpiece for SIP/TIP planning, and should
increase use of monitoring data and analyses of monitoring data, especially for tracking progress.
Enhanced tracking and ambient monitoring data is a better use of available resources than
intensive local modeling."

   A weight of evidence (WOE) determination examines results from a diverse set of additional
analyses, including the outcome of the attainment test, and attempts to summarize the results into
an aggregate conclusion with respect to whether a chosen set of control strategies will result in
an area attaining the NAAQS by the appropriate year. The supplemental analyses discussed
above are intended to be part of a WOE determination, although the level of detail required in a
WOE submittal will vary as a function of many elements of the model application (e.g., model
performance, degree of residual nonattainment in the modeled attainment test, amount of
uncertainty in the model and its inputs, etc.).  Each weight of evidence determination will be
subject to area-specific conditions and data availability.  Area-specific factors may also affect the
types of analyses which are feasible for a nonattainment area, as well as the significance of each.
Thus, decisions concerning which analyses to perform and how much credence to give each
needs to be done on a case by case basis by those implementing the modeling/analysis protocol.
States/Tribes are encouraged to consult with their EPA Regional office in advance of initiating a
WOE analysis to determine which additional analyses will be most appropriate for their
particular area.

   In a WOE determination, each type of analysis has an identified outcome that is consistent
with the hypothesis that a proposed control strategy is sufficient to meet the NAAQS within the
required time frame. Each analysis is weighed qualitatively, depending on: 1) the capacity  of the
analysis to address the adequacy of a strategy and 2) the technical credibility of the analysis. If
the overall weight of evidence produced by the various analyses supports the attainment
hypothesis, then  attainment of the NAAQS is demonstrated with the proposed strategy. The end
product of a weight of evidence determination is a document which describes analyses
performed, data bases used, key assumptions and outcomes of each analysis,  and why a
State/Tribe believes that the evidence, viewed as a whole, supports a conclusion that the area
will, or will not,  attain the NAAQS despite a model-predicted DVF concluding otherwise. In
conclusion, the basic criteria required for an attainment demonstration based  on weight of
evidence are as follows:

   1) A fully-evaluated, high-quality modeling analysis that projects future values that are  very
close to the NAAQS (e.g., 82 to 87 ppb).

   2) Multiple supplemental analyses in each of the three various categories discussed above
(modeling, ozone/emissions trends, observational models).

   3) A weighting for each separate analysis based on its ability to quantitatively assess the
ability of the proposed control measures to yield attainment.
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    4) A description of each of the individual supplemental analyses and their results.  Analyses
that utilize well-established analytical procedures and are grounded with sufficient data should
be weighted accordingly higher.

    5) A written description as to why the aggregate analyses leads to a conclusive determination
regarding the future attainment status of the area that differs from the modeled attainment test.
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5.0  What Additional Analyses Can Be Completed to Assess Progress
towards Attainment

   The purpose of an attainment demonstration is to provide a best estimate as to whether the
control measures included in a State Implementation Plan will result in attainment of the
NAAQS by a specific date in the future.  In most cases, it will be desirable to periodically track
the air quality improvements resulting from the SIP to ensure that the plan is going to result in
attainment by the appropriate dates. One possible tracking approach is a mid-course review
(MCR). In this section, we identify measurements and activities which will provide better
support for mid course reviews, future modeling exercises and other supplemental analyses
designed to determine the progress toward attainment of the NAAQS. Improved data bases will
increase the reliability of reviews and enable identification of reasons for attainment or non-
attainment of the NAAQS.

   Deploying additional air quality monitors. One type of additional monitoring which
should be  considered has already been mentioned in Section 3. Additional ozone monitors
should be  deployed in unmonitored locations where future design values are predicted to exceed
the NAAQS via the unmonitored area test. This would allow a better future assessment of
whether the NAAQS is being met at unmonitored locations.

   Measurement of "indicator species" is a potentially useful means for assessing which
precursor category (VOC or NOx) limits further production of ozone at a monitor's location at
various times of day and under various sets of meteorological  conditions. Sillman (1998, 2002)
and Blanchard, (1997, 1999, 2000, 2001) identify several sets of indicator species which can be
compared  to suggest whether ozone is limited by availability of VOC or NOx.  Comparisons are
done by looking at ratios of these species.  The following appear to be the most feasible for use
by a regulatory agency: O3/NOy, O3/(NOy - NOx) and O3/HNO3. Generally, high values for the
ratios suggest ozone is limited by availability of NOx emissions. Low values suggest
availability of organic radicals (e.g., attributable to VOC emissions) may be the limiting factor.
For these ratios to be most useful, instruments should be capable of measuring NOy, NOx, NO2
and/or HNO3 with high precision (i.e., greater than that often possible with frequently used
"routine" NOx measurements).  Thus,  realizing the potential of the "indicator species method" as
a tool for  model performance evaluation and for diagnosing why observed ozone concentrations
do or do not meet previous expectations may depend on deploying additional monitors and/or
measurements. States/Tribes should consult the Sillman (1998, 2002) and Blanchard, (1997,
1999, 2000, 2001) references for further details on measurement requirements and interpretation
of observed indicator ratios.

   Making measurements aloft.  Almost all  measured ambient air quality and meteorological
data are collected within 20 meters of the earth's surface. However, the modeling domain
extends many kilometers above the surface. Further, during certain times of day  (e.g., at night)
surface measurements are not always representative of air quality or meteorological conditions
aloft.  Concentrations aloft can have marked effects when they are mixed with ground-level
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emissions during daytime.  Thus, the weight given to modeling results can be increased if good
agreement is shown with air quality measurements aloft. The most important of these
measurements are ozone, NOy, NO, NO2, as well as several relatively stable species like CO and
selected VOC species. Measurements of SO2 may also be helpful for identifying presence of
plumes from large combustion sources.

   Measurements of altitude, temperature, water vapor, winds and pressure are also useful.
Continuous wind measurements, made aloft in several  locations, are especially important.  They
provide additional data to "nudge" meteorological model fields, but more importantly also allow
for construction of more detailed conceptual models of local ozone formation (Stehr, 2004).
This provides greater assurance that the air quality model correctly reflects the configuration of
sources contributing to ozone formation.

   Collecting locally applicable speciated emissions data. While the U.S. EPA maintains a
library of default VOC emissions species profiles (U.S. EPA, 1993), some of these may be dated
or may not properly reflect local sources. Use of speciated emissions data is a critical input to
air quality models.  For example, the accurate representation of the VOC speciation of current
and future gasoline emissions may have an important impact on future ozone concentrations.
Efforts to improve speciation profiles for local sources should enhance credibility of the
modeling as well as several of the procedures recommended for use in supplemental analyses
and the weight of evidence determinations.

   Projecting emission estimates and comparing these to subsequent emission estimates.
States/Tribes addressing traditional nonattainment areas with lengthy attainment dates may find
it worthwhile to project emissions to multiple future years and retain the resulting data files for
use in subsequent reviews.  Intermediate projections could be useful during a mid-course review
to help diagnose reasons for subsequent observed ozone trends which are inconsistent with
earlier expectations obtained with the air quality model. Retention of projected emission data
bases would enable States/Tribes to compare the projected inventory  estimates with an inventory
which is subsequently updated. These checks would be possible after the inventory updates for
2005 or 2008 become available.

   Future diagnostic analyses using air quality models. To facilitate a subsequent, mid-
course review, States/Tribes should retain all meteorological input data as well as current (e.g.,
2002) and projected (e.g., 2009) emission input files developed to support the needed SIP
revisions. When a model is applied with updated emissions estimates (e.g., 2009 projections
from the later versions of national inventories) and/or with updated meteorological inputs
indicative of more recent episodes, several useful comparisons are possible if the old files are
retained. A State/Tribe would be better able to determine whether differences in observed and
past-predicted air quality are explained by revised emission estimates, differences in
meteorological episodes, or by changes which have occurred in the model formulation during the
intervening years. Insights from such comparisons should help a State/Tribe explain why
changes in the strategy reflected in its MCR SIP revision may or may not be necessary.
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6.0  What Documentation Do I Need To Support My Attainment
   Demonstration?

   States/Tribes should follow the guidance on reporting requirements for attainment
demonstrations provided in U.S. EPA (1994b).  The first seven subjects in Table 6.1 are similar
to those in the 1994 guidance.  The 1994 guidance envisions an air quality model as the sole
means for demonstrating attainment. However, the current guidance (i.e., this document)
identifies supplemental analyses as well as a possible weight of evidence determination as a
means for corroborating/refuting the modeled attainment test in an attainment demonstration.  In
addition, feedback received since the earlier guidance has emphasized the need for technical
review of procedures used to identify a sufficient control strategy. Thus, we have added two
additional subject areas which should be included in the documentation accompanying an
attainment demonstration.  These are a description of the supplemental analyses and/or weight of
evidence  determination, and identification of reviews to which analyses used in the attainment
demonstration have been subject. In the end, the documentation  submitted by the States/Tribes
as part of their attainment demonstration should contain a summary section which addresses the
issues shown in Table 6.1.
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  Table 6.1 Recommended Documentation for Demonstrating Attainment of the 8-hour
            NAAQS for Ozone
       Subject Area
 Purpose of Documentation
       Issues Included
Conceptual Description
Characterization (qualitative and
quantitative) of the area's
nonattainment problem; used to
guide the development of the
modeling analysis.
Emissions and air quality
assessment;

Processes, conditions, and
influences for ozone formation.
Modeling/Analysis Protocol
Communicate scope of the
analysis and document
stakeholder involvement.
Names of stakeholders
participating in preparing and
implementing the protocol;

Types of analyses performed;
Steps followed in each type of
analyses;

Rational for choice of the
modeling system and model
configurations.
Emissions Preparations and
Results
Assurance of valid, consistent
emissions data base. Appropriate
procedures are used to derive
emission estimates needed for air
quality modeling.
Data base used and quality
assurance methods applied;

Data processing used to convert
data base to model-compatible
inputs;

Deviations from existing
guidance and underlying
rationale;

VOC, NOx, CO emissions by
State/County for major source
categories.

Quality assurance/quality control
procedures
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  Table 6.1  Recommended Documentation for Demonstrating Attainment of the 8-hour
             NAAQS for Ozone (continued)
        Subject Area
 Purpose of Documentation
       Issues Included
Air Quality/Meteorology
Preparations and Results
Assurance that representative air
quality and meteorological
inputs are used in analyses
Description of data base and
procedures used to derive and
quality assure inputs for
modeling;

Departures from guidance and
their underlying rationale.

Performance of meteorological
model used to generate
meteorological inputs to the air
quality model.
Performance Evaluation for Air
Quality Model (and Other
Analyses)
Show decision makers and the
public how well the model (or
other analyses) reproduced
observations on the days selected
for analysis for each
nonattainment area and
appropriate sub-regions.
Summary of observational data
base available for comparison;

Identification of performance
tests used and their results;

Ability to reproduce observed
temporal and spatial patterns;

Overall assessment of what the
performance evaluation implies.
Diagnostic Tests
Ensure rationale used to adjust
model inputs or to discount
certain results is physically
justified and the remaining
results make sense.
Results from application prior to
adjustments;

Consistency with scientific
understanding and expectations;

Tests performed, changes made
and accompanying justification;

Short summary of final
predictions.
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  Table 6.1  Recommended Documentation for Demonstrating Attainment of the 8-hour
             NAAQS for Ozone (continued)
        Subject Area
 Purpose of Documentation
       Issues Included
Description of the Strategy
Demonstrating Attainment
Provide the EPA and the public
an overview of the plan selected
in the attainment demonstration.
Qualitative description of the
attainment strategy;

Reductions in VOC, NOx, and/or
CO emissions from each major
source category for each
State/county/Tribal land from
current (identify) emission levels;

Clean Air Act mandated
reductions and other reductions;

Show predicted 8-hour future
design values for the selected
control scenario and identify any
location(s) which fails the
unmonitored area test described
in Section 3;

Identification of authority for
implementing emission
reductions in the attainment
strategy.

Evidence that emissions remain
at or below projected levels
throughout the 3-year period
used to determine future
attainment.
Data Access
Enable the EPA or other
interested parties to replicate
model performance and
attainment simulation results, as
well as results obtained with
other analyses.
Assurance that data files are
archived and that provision has
been made to maintain them;

Technical procedures for
accessing input and output files;

Identify computer on which files
were generated and can be read,
as well as software necessary to
process model outputs;

Identification of contact person,
means for  downloading files and
administrative procedures which
need to be  satisfied to access the
files.
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  Table 6.1  Recommended Documentation for Demonstrating Attainment of the 8-hour
             NAAQS for Ozone (concluded)
        Subject Area
 Purpose of Documentation
       Issues Included
Weight of Evidence
Determination
Assure the EPA and the public
that the strategy meets applicable
attainment tests and is likely to
produce attainment of the
NAAQS by the required time.
Description of the modeled
attainment test and observational
data base used;

Identification of air quality model
used;

Identification of other analyses
performed;

Outcome of each analysis,
including the modeled attainment
test;

Assessment of the credibility
associated with each type of
analysis in this application;

Narrative describing process
used to conclude the overall
weight of available evidence
supports a hypothesis that the
selected strategy is adequate to
attain the NAAQS.
Review Procedures Used
Provide assurance to the EPA
and the public that analyses
performed in the attainment
demonstration reflect sound
practice
Scope of technical review
performed by those
implementing the protocol;

Assurance that methods used for
analysis were peer reviewed by
outside experts;

Conclusions reached in the
reviews and the response.	
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Part II.  How Should I Apply Air Quality Models To
        Produce Results Needed To Help Demonstrate
        Attainment?
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7.0     How Do I Apply Air Quality Models?-- An Overview

   In Part I of this guidance, we described how to estimate whether a proposed control strategy
will lead to attainment of the ozone NAAQS within a required time frame. We noted that air
quality models play a major role in making this determination. We assumed that modeling had
been completed, and discussed how to use the information produced. We now focus on how to
apply models to generate the information used in the modeled attainment demonstration. The
procedure we recommend consists of nine steps:

    1. Formulate a conceptual description of an area's nonattainment problem;
    2. Develop a modeling/analysis protocol;
    3. Select an appropriate air quality model to use;
    4. Select appropriate meteorological episodes to model;
    5. Choose a modeling domain with appropriate horizontal and vertical resolution and
    establish the initial and boundary conditions to be used;
    6. Generate meteorological and air quality inputs to the air quality model;
    7. Generate emissions inputs to the air quality model;
    8. Evaluate performance of the air  quality model and perform diagnostic tests, as necessary.
    9. Perform future year modeling (including additional control strategies,  if necessary) and
    apply the attainment test

   In this section, we briefly describe each of these steps to better illustrate how they are inter-
related.  Because many of these steps require considerable effort to execute, States/Tribes should
keep the appropriate U.S. EPA Regional Office(s) informed as they proceed.  This will increase
the likelihood of having an approvable  attainment demonstration when the work is completed.
The steps outlined in this section are described in greater depth in Sections 8-15.

1. Formulate a conceptual description of an area's nonattainment problem. A State/Tribe
needs to have an understanding of the nature of an area's nonattainment problem before it can
proceed with a modeled attainment demonstration.  For example, it would be difficult to identify
appropriate stakeholders and develop a modeling protocol without knowing whether resolution
of the problem may require close coordination and cooperation with other nearby States.

   The State/Tribe containing the designated nonattainment area is expected to initially
characterize the problem. This characterization provides a starting point for addressing steps
needed to generate required information by those implementing the protocol. Several examples
of issues addressed in the initial description of a problem follow. Is it a regional or local
problem? Are factors outside of the nonattainment area likely to affect what needs to be done
locally? Are monitoring sites observing violations located in areas where meteorology is
complex or where there are large emission gradients? How has  observed air quality responded
to past efforts to reduce precursor emissions? Are there ambient measurements suggesting
which precursors and sources are important to further reduce ozone?  What information might be
needed from potential stakeholders? As many of the preceding questions imply, an initial

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conceptual description may be based largely on a review of ambient air quality data. Sometimes,
methods described in Sections 4 and 5 (e.g., trend analysis, observational models) may be used.
Other times, these types of analyses may be deferred until after a team is in place to develop and
implement steps following a modeling/analysis protocol. The initial conceptual picture may be
based on less resource-intensive analyses of available data.

2. Develop a modeling/analysis protocol.  A protocol describes how modeling will be
performed to support a particular attainment demonstration. The content of the protocol and
identification of participating stakeholders are influenced by the previously developed
conceptual description of the problem.  The protocol outlines methods and procedures which will
be used to perform the subsequent six steps needed to generate the modeling results and then
apply the modeled attainment and screening tests as well as other corroborating analyses. This is
accomplished by:  a) identifying those responsible for implementing the modeling, b) outlining
the specific steps needed to complete the attainment demonstration, c) identifying those who will
review each  step as it occurs, and d) identifying procedures to be used to consider
input/suggestions  from those potentially affected by the outcome (i.e., "stakeholders"). In short,
the protocol  defines the "game plan" and the "rules of the game".

3. Select an appropriate model for use.   This step includes reviewing non-proprietary, grid-
based photochemical models to select the model that is most appropriate for the application in
terms of (a)  state-of-the science algorithms  to represent the chemical and physical processes
associated with ozone formation, transport,  and removal during high ozone episodes, (b) peer
review, (c) model  performance in prior applications, and (d) ease of use.  Identifying the air
quality model to be used is an early step in the  process, since it may affect how emissions and
meteorological information are input to the  model.  It could also affect size of the area modeled
and choice of the horizontal/vertical resolution considered.

4. Select appropriate meteorological time periods to model.  Like the preceding step, this
step requires review of available air quality and meteorological data.  It also requires a thorough
understanding of the form of the national ambient air quality standard and of the modeled
attainment test described in Section 3. Finally, it requires a review of meteorological conditions
which have been observed to accompany monitored exceedances of the 8-hour ozone NAAQS.
The object of these reviews is to select time periods which: a) include days with observed
concentrations close to site-specific design values and b) reflect a variety of meteorological
conditions which have been commonly observed to accompany monitored exceedances. This
latter objective is desirable, because it adds confidence that a proposed strategy will work under
a variety of conditions.

   Due to increased computer speeds, it is now prudent to recommend modeling relatively long
time periods. At a minimum, modeling episodes which cover full synoptic cycles is desirable.
Depending on the area and the time of year, a synoptic cycle may be anywhere from 5-15 days.
Modeling even longer time periods of up to a full ozone season may simplify the episode
selection process and provide a rich database with which to apply the modeled attainment test.

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5. Choose a modeling domain with appropriate horizontal and vertical resolution and
establish the initial and boundary conditions. Nested grid models will typically be used to
support the modeled attainment test. In order to provide reasonable boundary conditions for the
local nonattainment area, in many cases it is important to model a large regional domain with
relatively coarse resolution, and a smaller sub-regional domain with relatively fine horizontal
resolution.  Meteorological and air quality (i.e., ozone) data corresponding to the time periods
that will be modeled need to be reviewed prior to choosing size of the area modeled. The
presence of topographical features or mesoscale meteorological features (e.g., land/sea breeze)
near or in the nonattainment area of principal interest are factors to consider in choosing size of
individual grid cells and the number of required vertical  layers for that portion of the modeling
grid. Another factor affecting the choice of grid cell size is the available spatial detail in the
emissions data used as input to an emissions model. Finally, factors which cannot be ignored in
choosing size of a domain  and its grid cells include the feasibility of managing large data bases
and the resources needed to estimate meteorological inputs and air quality in many grid cells.

6. Generate meteorological inputs to the air  quality simulation model. Prognostic
meteorological models will ordinarily be used to generate the meteorological inputs used in the
attainment demonstration modeling.  The application of meteorological models and the choice of
model grid resolution in the preceding step are closely related.  Meteorological  conditions near
the area which is the focus of an attainment demonstration may dictate the required spatial
resolution.  On the other hand,  cost and data management difficulties increase greatly for finely
resolved grids.  Thus, those implementing the protocol will likely be faced with a tradeoff
between cost/feasibility of running air quality and meteorological models and resolution at which
it might be most desirable to treat dispersion of nearby emissions.

7. Generate emissions inputs to the air quality simulation model.  Emissions are the central
focus in a modeled attainment demonstration because they are the only input which is altered
between the present and future case scenarios and represent the model input to which control
strategies are applied.  Emissions inputs to an air quality model are generated using an emissions
model. Applying such a model is as complicated as the air quality model itself, and demands at
least as much attention. In current emissions models, emissions from some of the major source
categories of ozone precursors  are affected by meteorological conditions.  This  requires an
interface between meteorological inputs and emissions.  The development of emissions data
must also take into account the horizontal/vertical model resolution of the model configuration
and the size of the area to be modeled. In short, treatment of emissions is a central and complex
one which, itself, involves  several steps.  These include deriving  emission inventories, quality
assuring results, applying results in an emission model(s), and (again) quality assuring results.
Emission inputs may be needed for number of scenarios including; (1) a base case
corresponding to that of the selected episodes, (2) a baseline corresponding to that represented
by the current monitored design value, (3) a future base case when attainment of the NAAQS
needs to be demonstrated, and (4) control scenarios in which emissions controls are applied to
emissions in the future base case.

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8. Evaluate performance of the air quality simulation model and perform diagnostic tests.
The credibility of a modeled attainment test and other model outputs is affected by how well the
model replicates observed air quality in a historical case.  Evaluating model performance and
conducting diagnostic tests depend on the prior definition of the modeling exercise and
specification of model inputs.  Hence, this is generally the last step prior to using the model to
support an attainment demonstration. In the past, the performance evaluation has relied almost
exclusively on numerical tests comparing predicted and observed ozone, or visual inspection of
predictions and observations.  These are still important tools. However, photochemical grid
models have many inputs, and it is possible to get similar predicted ozone concentrations with
different combinations of these inputs. There is no guarantee that ozone will respond the same
way to controls with these different combinations of inputs. Thus, we place greater emphasis on
additional kinds of tests than was the case in past guidance. These include use of precursor
observations, indicator species, and corroborative analyses with observational models.
Diagnostic tests are separate simulations which are performed to determine the sensitivity of a
model's ozone predictions to various inputs to the model. This can be done for a variety of
purposes, including selection of effective control strategies, prioritizing inputs needing greatest
quality assurance and assessing uncertainty associated with model predictions. In performing
such tests, States/Tribes  should remember how model results are used in the modeled attainment
test recommended in Section 3. Model results are used in a relative rather than absolute sense.
Thus, diagnostic tests should be used to consider how relative, as well as absolute ozone
predictions, are affected  by changes to model inputs.

9. Perform future year modeling (including additional control strategies, if necessary) and
apply the attainment test.  The base case model runs for performance evaluations should
contain emissions inventories on a highly resolved basis which can best simulate the ozone
concentrations that were measured. For some sources, it may not be appropriate to project day
specific emissions to the future because they may not be representative of typical base case
ozone days.  This is commonly the case for wildfire and continuous emissions monitor (CEM)
based utility emissions.  If needed, a separate baseline model run  should be completed for the
purpose of calculating relative reduction factors.

   The next step is to run the future year base case model run. The inventory should contain all
known emissions controls expected to be in place in the future year, as well as projected growth
of emissions to the future. The attainment test should be performed using the future base case
and the base year baseline. If attainment cannot be shown, then additional model runs which
contain control measures are needed. Multiple future year control strategy runs may need to be
completed until the attainment test is passed.
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8.0  How Do I Get Started?- A "Conceptual Description"

   A State/Tribe should start developing information to support a modeled attainment
demonstration by assembling and reviewing available air quality, emissions and meteorological
data.  Baseline design values should be calculated at each ozone monitoring site, as described in
Section 3. If past modeling has been performed, the emission scenarios examined and air quality
predictions may also be useful. Readily available information should be used by a State/Tribe to
develop an initial conceptual description of the nonattainment problem in the area which is the
focus of a modeled attainment demonstration. A conceptual description is instrumental for
identifying potential stakeholders and for developing a modeling/analysis protocol. It may also
influence a State's choice of air quality model, modeling domain, grid cell size, priorities for
quality assuring and refining emissions estimates, and the choice of initial diagnostic tests to
identify potentially effective control strategies.  In general, a conceptual description is useful for
helping a State/Tribe identify priorities and allocate resources in performing a modeled
attainment demonstration.

   In this Section, we identify key parts of a conceptual description. We then present examples
of analyses which could be used to describe each of these parts.  We note that initial analyses
may be complemented later by additional efforts performed by those implementing the protocol.

   8.1  What Is A "Conceptual Description"?

   A "conceptual description" is a qualitative way of characterizing the nature of an area's
nonattainment problem.  It is best described by identifying key components of a description.
Examples are listed below.  The examples are not necessarily comprehensive. There could be
other features of an area's problem which are important in particular cases. For purposes of
illustration later in the discussion, we have answered each of the questions posed below.  Our
responses appear in parentheses.

    1. Is the nonattainment problem primarily a local one, or are regional factors important?

    (Surface measurements suggest transport of ozone close to  84 ppb is likely. There
    are some other nonattainment areas not too far distant.)

    2. Are ozone and/or precursor concentrations aloft also high?

    (There are no such measurements.)

    3. Do violations of the NAAQS occur at several monitoring sites throughout the
    nonattainment area, or are they confined to one or a small number of sites in proximity to
    one another?

    (Violations occur at a limited number of sites, located throughout the area.)

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4. Do observed 8-hour daily maximum ozone concentrations exceed 84 ppb frequently  or
just on a few occasions?

(This varies among the monitors from 4 times up to 12 times per year.)

5. When 8-hour daily maxima in excess of 84 ppb occur, is there an accompanying
characteristic spatial pattern, or is there a variety of spatial patterns?

(A variety of patterns is seen.)

6. Do monitored violations occur at locations subject to mesoscale wind patterns (e.g., at a
coastline) which may differ from the general wind flow?

(No.)

7. Have there been any recent major changes in emissions of VOC or NOx in or near the
nonattainment area? If so, what changes have occurred?

(Yes, several local measures  [include a list] believed to result in major reductions in VOC
[quantify in tons per summer day] have been implemented in the last five years.
Additionally, the area is expected to benefit from the regional NOx reductions from the
NOx SIP call.)

8. Are there discernible trends in design values or other air quality indicators which have
accompanied a change in emissions?

(Yes, design values have decreased by about 10% at four sites over the past [x] years.
Smaller or no reductions are seen at three other sites.)

9. Is there any apparent spatial pattern to the trends in design values?

(No.)

10. Have ambient precursor concentrations or measured VOC species profiles changed?

(There are no measurements.)

11. What past modeling has been performed and what do the results suggest?

(A regional modeling analysis has been performed. Two emission scenarios were modeled:
current emissions and a substantial reduction in NOx emissions throughout the regional
domain. Reduced NOx emissions led to substantial predicted reductions in 8-hour daily
maximum ozone in most locations, but changes near the most populated area in the

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    nonattainment area in question were small or nonexistent.)

    12. Are there any distinctive meteorological measurements at the surface or aloft which
    appear to coincide with occasions with 8-hour daily maxima greater than 84 ppb?

    (Other than routine soundings taken twice per day, there are no measurements aloft.  There
    is no obvious correspondence with meteorological measurements other than daily maximum
    temperatures are always > 85 F on these days.)

   Using responses to the preceding questions in this example, it is possible to construct an
initial conceptual description of the nonattainment area's ozone problem. First, responses to
questions 1 and 11 suggest there is a significant regional component to the area's nonattainment
problem. Second, responses to questions 3, 4, 7, 8, and 11 indicate there is an important local
component to the area's nonattainment problem. The responses to questions 4, 5 and 12 indicate
that high ozone concentrations may be observed under several sets of meteorological conditions.
The responses to questions 7, 8, and 11 suggest that ozone in and near the nonattainment area
may be responsive to both VOC and NOx controls and that the extent of this response may vary
spatially. The response to question 6 suggests that it may be appropriate to develop a strategy
using a model with 12 km grid cells.

   The preceding conceptual description implies that the State/Tribe containing the
nonattainment area in this example will need to involve stakeholders from other, nearby
States/Tribes to develop and implement  a modeling/analysis protocol. It also suggests that a
nested  regional modeling  analysis  will be needed to address the problem. Further, it may be
necessary to model at least several distinctive types of episodes and additional analyses will be
needed to select episodes. Finally, sensitivity (i.e., diagnostic) tests, or other modeling probing
tools, will be needed to assess the effects of reducing VOC and NOx emissions separately and at
the same time.

   It should be clear from the preceding example that the initial conceptual description of an
area's nonattainment problem may draw on readily available information and need not be
detailed.  It is intended to  help launch development and implementation of a modeling/analysis
protocol in  a productive direction.  It will likely be supplemented by subsequent, more extensive
modeling and ambient analyses performed by or for those implementing the modeling/analysis
protocol discussed in Section 9.
   8.2  What Types Of Analyses Might Be Useful For Developing And Refining A
        Conceptual Description?

   Questions like those posed in Section 8.1 can be addressed using a variety of analyses
ranging in complexity from an inspection of air quality data to sophisticated mathematical
analyses. We anticipate the simpler analyses will often be used to develop the initial conceptual

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description.  These will be followed by more complex approaches or by approaches requiring
more extensive data bases as the need later becomes apparent.  In the following paragraphs, we
revisit key parts of the conceptual description identified in Section 8.1.  We note analyses which
may help to develop a description of each part. The list serves as an illustration. It is not
necessarily exhaustive.

    8.2.1. Is regional transport an important factor affecting the nonattainment area?

- Are there other nonattainment areas within a day's transport of the nonattainment area?

- Do "upwind" 8-hour daily maximum ozone concentrations approach or exceed 84 ppb on some
or all of the days with observed 8-hour daily maxima > 84 ppb in the nonattainment area?

- Are there major sources of emissions upwind?

- What is the size of the downwind/upwind gradient in 8-hour daily maximum ozone
concentrations compared to the upwind values?

- Do ozone concentrations aloft but within the planetary boundary layer approach or exceed 84
ppb at night or in the  morning hours prior to breakup of the nocturnal surface inversion?

- Is there a significant positive correlation between observed 8-hour daily maximum ozone
concentrations at most monitoring  sites within or near the nonattainment area?

- Is the timing of high observed ozone consistent with impacts estimated from upwind areas
using trajectory models?

- Do available regional modeling simulations suggest that 8-hour daily maximum ozone
concentrations within the nonattainment area respond to regional control measures?

- Does source apportionment modeling indicate significant contributions to local ozone from
upwind emissions?

    8.2.2.     What  types of meteorological episodes lead to high ozone?

- Examine the spatial patterns of 8-hour daily maxima occurring on days where the ozone is > 84
ppb and try to identify a limited number of distinctive patterns.

- Review synoptic weather charts for days having observed concentrations > 84 ppb to identify
classes of synoptic scale features corresponding to high observed ozone.

- Perform statistical analyses between 8-hour daily maximum ozone and meteorological
measurements at the surface and aloft to identify distinctive classes of days corresponding with

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observed daily maxima > 84 ppb.

   8.2.3.      Is ozone limited by availability of VOC, NOx or combinations of the two?
              Which source categories may be most important?

- What are the major source categories of VOC and NOx and what is their relative importance in
the most recent inventory?

- Review results from past modeling analyses to assess the likelihood that ozone in the
nonattainment area will be more responsive to VOC or NOx controls. Do conclusions vary for
different locations?

- Apply modeling probing tools (e.g., source  apportionment modeling) to determine which
source sectors appear to contribute most to local ozone formation.

- Apply indicator species methods such as those described by Sillman (1998, 2002) and
Blanchard (1999, 2000, 2001) at sites with appropriate measurements on days with 8-hour daily
maximum ozone exceedances. Identify classes of days where further ozone formation appears
limited by available NOx versus classes of days where further ozone formation appears limited
by available VOC.  Do the conclusions differ for different days?  Do the results differ on
weekdays versus weekends?

- Apply receptor modeling approaches such as those described by Watson (1997, 2001), Henry
(1994) and Henry (1997a, 1997b, 1997c) to identify source categories contributing to ambient
VOC on days with high observed ozone.  Do the conclusions differ on days when measured
ozone is not high?

   Additional analyses may be identified as issues arise in implementing a modeling/analysis
protocol. These analyses are intended to channel resources available to  support modeled
attainment demonstrations onto the most productive paths possible. They will also provide other
pieces of information which can be used to reinforce conclusions reached with an air quality
model, or cause a reassessment of assumptions made previously in applying the model. As noted
in Section 4, corroboratory analyses should be used to help assess whether a simulated control
strategy is sufficient to meet the NAAQS.
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9.0     What Does A Modeling/Analysis Protocol Do, And What Does
        Developing One Entail?

   Developing and implementing a modeling/analysis protocol is a very important part of an
acceptable modeled attainment demonstration. The protocol should detail and formalize the
procedures for conducting all phases of the modeling study, such as describing the background
and objectives for the study, creating a schedule and organizational structure for the study,
developing the input data, conducting model performance evaluations, interpreting modeling
results, describing procedures for using the model to demonstrate whether proposed strategies
are sufficient to attain the ozone NAAQS, and producing documentation to be submitted for EPA
Regional Office review and approval. Much of the information in U.S. EPA (199 la) regarding
modeling protocols remains applicable. States/Tribes should review the 1991 guidance on
protocols.  In this document, we have revised the name of the protocol to "Modeling/Analysis
Protocol" to emphasize that the protocol needs to address modeling  as well as other
supplemental analyses.

   9.1  What Is The Protocol's Function?

   As noted above, the most important function of a protocol is to serve as a means for planning
and communicating up front how a modeled attainment demonstration will be performed.  The
protocol is the means by which States/Tribes, U.S. EPA, and other stakeholders can assess the
applicability of default recommendations and develop alternatives. A good protocol should lead
to extensive participation by stakeholders in developing the demonstration. It should also
reduce the risk of spending time and resources on efforts which are unproductive or inconsistent
with EPA policy.

   The protocol  also serves several important, more specific functions. First, it should identify
who will help the State/Tribe or local air quality agency (generally the lead agency) undertake
and evaluate the analyses needed to support a defensible demonstration (i.e., the stakeholders).
Second, it should identify how communication will occur among States/Tribes and stakeholders
to develop consensus on various issues. Third, the protocol should describe the review process
applied to key  steps in the demonstration. Finally, it should also describe how changes in
methods and procedures or in the protocol itself will be agreed upon and communicated with
stakeholders and the appropriate U.S. EPA Regional Office(s).  Major steps to implement the
protocol should be discussed with the appropriate U.S. EPA Regional Office(s) as they are being
decided. States/Tribes may choose to update the protocol as major decisions are made
concerning forthcoming analyses.
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   9.2  What Subjects Should Be Addressed In The Protocol?

   At a minimum, States/Tribes should address the following topics in their modeling/analysis
protocol:

1. Overview of Modeling/Analysis Project
   a. Management structure
   b. Technical committees or other communication procedures to be used
   c. Participating organizations
   d. Schedule for completion of attainment demonstration analyses
   e. Description of the conceptual model for the nonattainment area

2. Model and Modeling Inputs
   a. Rationale for the selection of air quality, meteorological, and emissions models
   b. Modeling domain
   c. Horizontal and vertical resolution
   d. Specification of initial and boundary conditions
   e. Episode  selection
   f. Geographic area identified for application of the attainment test(s)
   g. Methods used to quality assure emissions, meteorological, and other model inputs

3. Model Performance Evaluation
   a. Describe ambient data base
   b. List evaluation procedures
   c. Identify possible diagnostic testing that could be used to improve model performance

4. Supplemental Analyses
   a. List additional analyses to be completed to corroborate the model attainment test
   b. Outline plans for conducting a weight of evidence determination, should it be necessary

5. Procedural Requirements
   a. Identify how modeling and other analyses will be archived and documented
   b. Identify  specific deliverables to EPA Regional Office
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10.0   What Should I Consider In Choosing An Air Quality Model?

   Photochemical grid models are, in reality, modeling systems in which an emissions model, a
meteorological model and an air chemistry/deposition model are applied. In this guidance, we
use the term "air quality model" to mean a gridded photochemical modeling system. Some
modeling systems are modular, at least in theory.  This means that it is possible to substitute
alternative emissions or meteorological models within the modeling system. Often however, the
choice of an emissions or meteorological model or their features is heavily influenced by the
chosen air quality model  (i.e., an effort is needed to develop software to interface combinations
of components differing from the modeling system's default combination). Thus, choosing an
appropriate air quality model is among the earliest decisions to be made by those implementing
the protocol. In this section, we identify a set of general requirements which an air quality
model should meet in order to qualify for use in an attainment demonstration for the 8-hour
ozone NAAQS. We then identify several factors which will help in choosing among qualifying
air quality models for a specific application. We conclude this section by identifying several air
quality models which are available for use in attainment demonstrations. Meteorological and
emissions models are discussed in Sections 13  and 14, respectively.

   10.1      What Prerequisites Should An Air Quality Model Meet To Qualify For Use
             In An Attainment Demonstration?

   A model should meet several general criteria for it to be a candidate for consideration in an
attainment demonstration. These general criteria are consistent with requirements in 40 CFR
51.112_and 40 CFR part 51, Appendix W (U.S. EPA, 2003).  Note that, unlike in previous
guidance (U.S. EPA, 199la), we are not recommending a specific model for use in the
attainment demonstration for the 8-hour NAAQS for ozone. At present, there is no  single model
which has been extensively tested and shown to be clearly superior than its alternatives. Thus,
40CFR Part 51 Appendix W does not identify a "preferred model" for use in attainment
demonstrations of the 8-hour NAAQS for ozone.  Based on the language in 40CFR Part 51
Appendix W, States/Tribes should consider nested regional air quality models or urban scale air
quality models as "applicable models" for ozone.

   States/Tribes should use a non-proprietary  model which is a model whose source code is
available for free (or for a "reasonable" cost).  Furthermore, the user must be able to revise the
code25 to perform diagnostic analyses and/or to improve  the model's ability to describe
observations in a credible manner. Several additional prerequisites should be met for a model to
be used to support an ozone attainment demonstration.
       25 Air quality models are generally identified by a version number. The version of the
model that is used in SIP applications should be identified. Code revisions to standard versions
of models should be noted and documented.

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    (1) It should have received and been revised in response to a scientific peer review.

    (2) It should be appropriate for the specific application on a theoretical basis.

    (3) It should be used with a data base which is adequate to support its application.

    (4) It should be shown to have performed well in past ozone modeling applications.  (If the
    application is the first for a particular model, then the State should note why it believes the
    new model is expected to perform sufficiently.)

    (5) It should be applied consistently with a protocol on methods and procedures.

   An air quality model may be considered to have undergone "scientific peer review" if each of
the major components of the modeling system (i.e., air chemistry/deposition, meteorological and
emissions models) has been described and tested, and the results have been documented and
reviewed by one or more disinterested third parties.  We believe that it should be the
responsibility of the model developer or group which is applying an air quality model on behalf
of a State/Tribe to document that a "scientific peer review" has occurred.  States/Tribes should
then reference this documentation to gain acceptance of an air quality model for use in a
modeled attainment demonstration.


   10.2       What Factors Affect My Choice of A Model For A Specific Application?

   States/Tribes should consider several factors as criteria for choosing a qualifying air quality
model to support an attainment demonstration for the 8-hour ozone NAAQS.  These factors are:
(1) documentation and past track record of candidate models in similar applications; (2)
advanced science and technical features (e.g., probing tools) available in the model and/or
modeling system; (3) experience of staff and available contractors;  (4) required time and
resources versus available time and resources; and (5) in the case of regional applications,
consistency with regional models applied in adjacent regions. Finally, before the results of a
selected model can be used in an attainment demonstration, the model should be  shown to
perform satisfactorily using the data base available for the specific application.

   Documentation and Past Track Record of Candidate Models.  For a model to be used in
an attainment demonstration, evidence should be presented that it has been found acceptable for
estimating hourly and eight-hourly ozone concentrations. Preference should be given to models
exhibiting satisfactory past performance under a variety of conditions.  Finally, a user's guide
(including a benchmark example and outputs) and technical description of the model should be
available.

   Advanced Technical Features. Models are often differentiated by their available advanced
science features and tools. For example, some models include advanced probing tools that allow

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tracking of downwind ozone impacts from upwind emissions sources. Availability of probing
tools and/or science algorithms is a legitimate reason to choose one equally capable model over
another.

   Experience of Staff and Available Contractors.  This is a legitimate criterion for choosing
among several otherwise acceptable alternatives. The past experience might be with the air
quality model itself, or with a meteorological or emissions model which can be more readily
linked with one candidate air quality model than another.

   Required vs. Available Time and Resources.  This is a legitimate criterion provided the
first two criteria are met.

   Consistency of a Proposed Model with Models Used in Adjacent Regions. This criterion
is applicable for regional model applications.  If candidate models meet the other criteria, this
criterion should be considered in choosing a model for use in a regional or nested regional
modeling application.

   Demonstration that an "Alternative Model" is Appropriate for the Specific Application.
If an air quality model meets the prerequisites identified in Section 10.1, a  State/Tribe may use
the factors described in this section (Section 10.2) to show that it is appropriate for use in a
specific application. Choosing an "alternative model"  needs to be reviewed and approved by the
appropriate U.S. EPA Regional Office.

   Satisfactory Model Performance in the Specific Application. Prior to use of a selected
model's results in an attainment demonstration, the model should be shown to perform
adequately for the specific application. The approach for evaluating model performance are
discussed in Section 15.
    10.3    What Are Some Examples Of Air Quality Models Which May Be Considered?

    Air quality models continue to evolve and have their own strengths and weaknesses
(Russell, 2000).  Table 10.1 lists several current generation air quality models which have been
used to simulate ambient ozone concentrations.  Table 10.2 lists several air quality models which
have been used for various ozone applications over the past decade, but are not widely used at
this time.  The list is not intended to be comprehensive. Exclusion of a model from the list does
not necessarily imply that it cannot be used to support a modeled attainment demonstration for
the ozone NAAQS. In the same way, inclusion on the list does not necessarily  imply that a
model may be  used for a particular application.  States/Tribes should follow the guidance in
Sections 10.1 and 10.2 in selecting an air quality model for a specific application.
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Table 10.1   Current Air Quality Models Used To Model Ozone
Air Quality Model
CAMx
CMAQ
UAM-V
References
Environ (2004)
U.S. EPA (1998a)
Systems Applications
International (1996)
   Table 10.2  Other Air Quality Models Used to Model Ozone
Air Quality Model
CALGRID
MAQSIP
SAQM
URM
References
Scire. et al. (1989)
'
MCNC (1999)
Odman. et al. (1996)
'
Chans, et al.. (1997)
CARB (1996)
Kumar, et al.. (1996)
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11.0   How are the Meteorological Time Periods (Episodes) Selected?

   Historically, ozone attainment demonstrations have been based on a limited number of
episodes consisting of several days each. In the past, the number of days modeled has been
limited by the speed of computers and the ability to store the model output files.  With the
advancement in computer technology over the past decade, computer speed and storage issues
are no longer an impediment to modeling long time periods. In fact, several groups have
recently modeled entire summers or even full years (Baker, 2004).

   Additionally, recent research has shown that model performance evaluations and the
response to emissions controls need to consider modeling results from long time periods, in
particular full synoptic cycles or even full ozone seasons (Hogrefe, 2000). In order to examine
the response to ozone control strategies, it may not be necessary to model a full ozone season (or
seasons), but we recommend modeling "longer" episodes that encompass full synoptic cycles.
Time periods which include a ramp-up to a high ozone period and a ramp-down to cleaner
conditions allow for a more complete evaluation of model performance under a variety of
meteorological conditions.  The following sections contain further recommendations for
choosing appropriate time periods to model for attainment demonstrations.

   At a minimum, four criteria should be used to select episodes26 which are appropriate to
model:

   1) Choose a mix of episodes reflecting a variety of meteorological conditions which
   frequently correspond with observed 8-hour daily maxima > 84 ppb at multiple monitoring
   sites.

   2) Model periods in which observed 8-hour daily maximum concentrations are close to the
   average 4th high 8-hour daily maximum ozone concentrations.

   3) Model periods for which extensive air quality/meteorological data bases exist.

   4) Model a sufficient number of days so that the modeled attainment test applied at each
   monitor violating the NAAQS is based on multiple days (see section 11.1.4).

   These four criteria may often conflict with one another. For example, there may only be a
limited number of days with intensive data bases,  and these may not cover all of the
meteorological conditions which correspond with monitored ozone concentrations close to site-
specific design values during the base period.  Thus, tradeoffs among the four primary criteria
may  be necessary in specific applications.
       26If modeling a full ozone season or year, the ambient ozone data and meteorology should
be evaluated to determine if the suggested criteria are met.

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   Those implementing the modeling/analysis protocol may use secondary episode selection
criteria on a case by case basis. For example, prior experience modeling an episode, may result
in its being chosen over an alternative.  Another consideration should be to choose episodes
occurring during the 5-year period which serves as the basis for the baseline average design
value (DVB). If observed 8-hour daily maxima >  84 ppb occur on weekends, weekend days
should be included within some of the selected episodes. If it has been determined that there is a
need to model several nonattainment areas simultaneously (e.g., with a nested regional scale
model application), a fourth secondary  criterion is to choose episodes containing days of
common interest to different nonattainment areas.

   In this section, we first discuss each of the four identified primary criteria for choosing
meteorological episodes to model. We then discuss the secondary criteria, which may be
important in specific applications.
    11.1 What Are The Most Important Criteria For Choosing Episodes?

        11.1.1   Choose a mix of episodes which represents a variety of meteorological
                 conditions which frequently correspond with observed 8-hour daily
                 maxima exceeding 84 ppb.

    This criterion is important, because we want to be assured that a control strategy will be
effective under a variety of conditions leading to elevated ozone concentrations. Those
implementing the modeling/analysis protocol should describe the rationale for distinguishing
among episodes which are modeled.  The selection may reflect a number of area-specific
considerations. Qualitative procedures such as reviewing surface  and aloft weather maps, and
observed or modeled wind patterns may suffice for distinguishing episodes with distinctively
different meteorological conditions.  More quantitative procedures, such as a Classification and
Regression Tree (CART) analysis or a principal component analysis (PCA), to identify
distinctive groupings of meteorological/air quality parameters corresponding with high 8-hour
daily maxima for ozone, may sometimes be desirable. An example of a CART analysis applied
to select episodes is described by Deuel (1998). LADCO used CART to rank historical years for
Midwestern cities by their conduciveness to ozone formation (Kenski, 2004).  A PCA may also
be used to characterize predominant meteorological conditions and relate those conditions to
ozone concentrations (Battelle, 2004).  This information can be used to quantify the relative
"ozone forming potential" of different days, regimes, and years.

    The interpretation of results of a wind rose analysis or a statistical analysis such as PCA or
CART should focus on  episodic time periods, rather than individual days. The winds may
blowing from different directions on consecutive days, but that does not necessarily mean that
those days represent different meteorological regimes.  Preference should be given to modeling
episodic cycles.
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   Additionally, statistical analyses such as PCA normally limit the number of identified
meteorological regimes to a relatively small number of generalized patterns. The analysis may
indicate that only one or two of these patterns are responsible for most or all of the ozone
exceedance days in an area. But no two days and no two episodes are exactly the same.  Further
analysis should be performed on potential episode periods to differentiate subtle, but often
important, differences between episodes. For this reason, it may be beneficial to model more
than one episode from the most frequently occurring meteorological regimes which lead to ozone
exceedances. Modeling a continuous time period which encompasses several ozone episodes or
a full ozone season will make it easier to adequately account for all of the potential
meteorological conditions which correspond to high measured ozone.

        11.1.2   Choose episodes having days with monitored 8-hour daily maxima close
                 to observed average 4th high daily maximum ozone concentrations.

   We want to use episodes whose severity is comparable to that implied by the form of the
NAAQS (i.e., an episode whose severity is  exceeded, on average, about 3 times/year at the time
of the selected episode). Note that we said, "at the time of the selected episode" (i.e., the "base
case period") rather than "current or baseline period" in the preceding sentence. The objective is
to choose episodes with days which are approximately as severe as the average 4th high 8-hour
daily maximum concentration specified in the NAAQS.

   Air quality measurements recorded during the baseline/current period can also be used to
characterize episode severity. This is done by  selecting a 5-year period which "straddles" a
modeled episode. For example, if an episode from 2002 were modeled, we recommend looking
at measured 8-hour daily maxima at each site in the nonattainment area during 2000-2004.
Using this information it should be possible to assess the relative severity of the days chosen for
modeling at each site.  Limiting this characterization to the five years  straddling an episode
avoids problems posed by long term trends in emissions in assessing episode severity.  However,
it leaves unanswered the question of whether the 5-year period selected to assess severity of a
modeled day is typical or atypical. If there is an underlying long term trend in ambient ozone
attributable to meteorological cycles or other causes, it may not be appropriate to compare
different periods with one another using air quality observations.  Thus, if one uses a 10-year old
episode with an exceptional data base, there is greater uncertainty in ranking its severity relative
to the current period of interest than if the episode were drawn from the current period.

   Note that if the episode is drawn from a recent time period (especially the three years upon
which the nonattainment designation is based), days which are chosen are likely to have
monitored observations very close to the baseline design value. In the absence of such
information, we suggest "+ 10 ppb" as a default recommendation for  purposes of prioritizing
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choice of episodes27.  If the base and baseline/current periods do not coincide, "close to" is
within +10 ppb of the design value during the base period straddling the episode. If it is not
feasible to meet this default criterion for all monitoring sites, meeting it at sites with
baseline/current design values > 85 ppb should receive greatest priority.

        11.1.3   Choose days with intensive data bases.

   Preference should be given to days with measurements aloft, available measurements of
indicator species (see Section 15) and/or precursor measurements. These preferences result from
a desire to incorporate a rigorous model performance evaluation as a part of the attainment
demonstration.  This reduces the likelihood of "getting the right answer for the wrong reason".
Thus, the likelihood of mischaracterizing ozone/precursor sensitivity is reduced.

        11.1.4   Choose a sufficient  number of days to enable the monitored attainment
                 test to be based on multiple days at each monitoring site violating the
                 NAAQS.

   Figure 3.2 indicates that the relative reduction factor computed at any given site appears to
be affected by the minimum threshold value.  Based on an analysis of modeled data, the
recommended minimum  (baseline) threshold value is 85 ppb. The minimum threshold value
analysis (detailed in section 3.5) was also used to examine how the number of days contained in
the mean RRF calculation influences the mean RRF. It was found that, on average, a minimum
number of 10 modeled days (in the mean RRF calculation) produces mean RRFs that are
relatively robust.

   The analysis cited earlier in the guidance (Timin, 2005b) was used to help determine the
minimum number of days to use in a mean RRF calculation.  The dataset consisted of 206
monitoring sites which had at least 10 days with predicted 8-hour daily baseline maximum ozone
concentrations > 85 ppb. In the analysis we assumed that a mean RRF calculated from  a "large"
set of days is more stable than an RRF calculated from a small  set of days. Using information on
the variability of the model response on individual days, we are able to measure the variability of
the mean RRF on any subset of days. The analysis used datasets of 25, 50, and 100 days28.  The
       27The analysis in section 3.5 showed that low ozone predictions can introduce a bias in
the relative results from the model. Therefore, ambient (and modeled) concentrations that are
more than 10 ppb above the design value are preferable to episodes with ambient concentrations
that are more than 10 ppb below the design value.

       28The 25, 50, and 100 day datasets were created by calculating the standard deviation of
the daily RRFs for the monitoring sites with at least 10 days > 85 ppb.  The distribution of the
RRF was calculated from the standard deviation. The original dataset had an actual maximum
number of 30 days.

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standard deviation of the daily RRFs was used to create the datasets and measure the variability
oftheRRFs.

   Figure 11.1 shows an example of the variability of the mean RRF as a function of the number
of days in the mean RRF calculation. The example plot is for a monitoring site in Harford
County, MD. The mean RRF for a 50 day sample size is 0.90 (10% ozone reduction). The
standard deviation of the daily RRFs was 0.034 (3.4%)29.  The plot shows the range of the mean
RRFs calculated using a sample size ranging from 3 to 25 days (a subset of the 50 days). Each
subset (3  days, 4 days, 5 days, etc.) was sampled 1000 times.  As can be seen in the plot, the
range of mean RRFs varies widely for a small sample size (3 days) and is relatively stable for a
large sample size (25 days). As the number of days increases, the variability of the mean RRF
decreases. A similar conclusion was reached in a different study (Hogrefe, 2000) which found
      rv
      CC
                345678 910111213141516171819202122232425

                                        No samples

  Figure 11.1- Mean RRF as a function of the subset of days (3-25 days) for a Harford
  County, MD ozone monitoring site. The full dataset was 50 days.

that the RRF is more variable when based on a small number of days.
   The ability to accurately capture a mean RRF with a small number of days is dependent on
the variability of the daily RRFs (as measure by the standard deviation).  Sites with a small
standard deviation of the daily RRFs will be able to replicate the large dataset mean RRF with
relatively few days.
       29The standard deviation is in "RRF units".  For example, an RRF of 0.90 is equal to
alO% ozone reduction. A standard deviation of 3.4% is a measure of the variability such that +-
3.4% is equal to a range in mean RRF of 0.866-0.934.
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   Using the available information, we were able to calculate, for each monitoring site, the
number of days needed to provide a mean RRF calculation that is within ±1% and ±2% of the
"large dataset" mean, with a 95% confidence interval.  The number of days needed to produce a
robust mean RRF is dependent on the variability of the daily RRFs (as measured by the standard
deviation).  Therefore, more days are needed to produce a stable RRF if the standard deviation of
the daily RRFs is high.

   Table 11.1  summarizes the results for the 25th, 50th (median) and 75th percentile of the
standard deviation for the 206 monitoring sites.  The table presents results for a range of standard
deviations, a range of large datasets (25, 50,  and 100 days), and both ±1% and ±2% accuracy.
The table shows that for the median standard deviation of the monitoring sites (2.4%), a
minimum number of 10-16 days is needed to replicate the mean RRF to within ±1% (95% of the
time) and a minimum number of 5-6 days is needed to replicate the mean RRF to within ±2%
(95% of the time). The table also  shows that a smaller standard deviation requires fewer days
and a larger standard deviation requires more days.
Value (206 sites)
25th Percentile
Median
75th Percentile
Standard
Deviation
1.9%
2.4%
3.1%
±1% (25/50/1 00 days)
9/10/12
10/13/16
12/17/23
± 2% (25/50/100 days)
3/4/4
5/5/6
6/8/9
Table 11.1- Number of days needed to replicate the 25/50/100 day dataset mean RRF to
within ±1% and ±2%, with a 95% confidence interval.
   Based on these results, we recommend a minimum number of 10 days to be included in the
mean RRF calculation for each monitoring site. This will ensure a relatively robust mean RRF
value that is within ±1% (on average) of the large dataset mean. If relatively few ozone days are
being modeled or certain monitors have relatively few exceedances (above 85 ppb), then we
recommend using an absolute minimum number of 5 days in the calculation.

    The minimum number of days recommendations can be combined with the minimum
threshold recommendation to create a hierarchy of number of days/threshold combinations that
can address any situation. The recommended minimum concentration threshold identified in
section 3.5 is 85 ppb.  But similar to the minimum number of days, there may be situations
where there are relatively few "high" modeled ozone days at certain monitors.  Therefore, when
possible, we recommend using the 85 ppb threshold, but it is acceptable to use a threshold as low
as 70 ppb.
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   Therefore, the following criteria should be applied to determine the number of days and the
minimum threshold at each ozone monitor:

•  If there are 10 or more days with daily maximum 8-hour average baseline modeled ozone >
   85 ppb then use an 85 ppb threshold.
•  If there are less than 10 days with daily maximum 8-hour average baseline modeled ozone >
   85 ppb then reduce the threshold down to as low as 70 ppb until there are 10 days in the
   mean RRF  calculation.
•  If there are less than 10 days with daily maximum 8-hour average modeled ozone > 70 ppb
   then use all days > 70 ppb.
•  Don't calculate an RRF for sites with less than 5 days > 70 ppb30.

The following table illustrates several examples of the recommended hierarchy of choosing the
number of days vs. the minimum threshold.
Number of Days
> 70 ppb
50
20
12
11
9
6
O
Number of Days
> 85 ppb
15
12
7
3
6
1
0
Number of Days in
Mean RRF
15
12
10
10
9
6
N/A
Theshold < 85 ppb?
No
No
Yes
Yes
Yes
Yes
N/A
Table 11.2- Examples of the recommended hierarchy in choosing the number of days in the
mean RRF calculation vs. the minimum threshold. The "number of days" refers to the
number of days (at each monitor) when the daily modeled 8-hour ozone maximum is > 70
or 85 ppb.

   In summary, States should try to model enough episode days so that the mean RRF
calculation at each monitor contains a minimum of 10 days with a modeled concentration > 85
ppb.  If there are less than 10 days > 85 ppb, then the threshold should be lowered until 10 days
       30Any situation where there are less than 5 days available for RRF calculations at
monitoring sites with relatively high concentrations, (above the NAAQS and/or close to the area-
wide design value) should be discussed with the appropriate U.S. EPA Regional office(s).
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are included in the calculation.  The threshold should not go below 70 ppb and the number of
days should always be at least 5. In trying to meet these recommendations, the greatest priority
should be given to identifying episode days with appropriate ozone concentrations at the
monitoring sites with the highest design values.  Sites with design values below the NAAQS
should be given a low priority.
    11.2      What Additional, Secondary Criteria May Be Useful For Selecting Episodes?

    In Section 11.1, we noted that there may often be conflicts among the four primary criteria
recommended as the basis for choosing episodes to model.  Several additional, secondary
selection criteria may be helpful for resolving these conflicts.

    Choose episodes which have already been modeled. That is, of course, provided that past
model performance evaluation for such an episode was successful in showing that the model
worked well in replicating observations. Given that the four primary criteria are met
approximately as well by such episodes as they are by other candidate episodes, a State/Tribe
could likely save a substantial amount of work in evaluating model performance. However, it
should be noted that large changes in ozone precursor levels or ratios may make the use of older
episodes undesirable.

    Choose episodes which are drawn from the period upon which the baseline design value
is based.  As we note in Section 3, fewer emission estimates and fewer air quality model
simulations may be needed if the base case period used to evaluate model performance, and the
baseline period used in the recommended modeled attainment test are the same. Following this
criterion could also make the second primary criterion more straightforward.

    Choose episodes having observed concentrations "close to" the NAAQS on as many
days and at as many sites as possible.  This criterion is related to the modeled attainment test
and to the fourth primary criterion for episode selection.  The more days and sites for which it is
reasonable to apply the test, the greater the confidence possible in the modeled attainment test.

    It is desirable to include weekend days among those chosen, especially if concentrations
greater than 84 ppb are observed on weekends. Weekend days often reflect a different mix of
emissions than occurs on weekdays31.  This could also lead to different spatial patterns of 8-hour
daily maxima in excess of 84 ppb. Thus, for increased confidence that a control strategy is
effective it needs to be tested on weekends as well as on weekdays. If emissions and spatial
patterns of high ozone do differ on weekends versus weekdays, including weekend days in the
choice of episodes will provide a mechanism for evaluating the accuracy of a model's response
to changes in emissions.

    If it has been determined that there is a need to model several nonattainment areas
       31 http://www.arb.ca.gov/aqd/weekendeffect/weekendeffect.htm

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simultaneously, choose episodes which meet the primary and secondary criteria in as many
of these nonattainment areas as possible.  As discussed in Section 10, a State/Tribe or group of
States/Tribes may decide to apply a model on a regional or a nested regional scale to
demonstrate attainment in several nonattainment areas at once. Time and resources needed for
this effort could be reduced by choosing episodes which meet the primary and secondary criteria
in several nonattainment areas which are modeled.
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12.0   What Should Be Considered When Selecting The Size And
        Horizontal/Vertical Resolution Of The Modeling Domain?

   A modeling domain identifies the geographical bounds of the area to be modeled. The
appropriate domain size depends on the nature of the strategies believed necessary to meet the
air quality goal. This, in turn, depends on the degree to which air quality observations suggest
that a significant part of an observed exceedance is attributable to regional concentrations which
approach or exceed levels specified in the NAAQS.  The choice of domain size is also affected
by data base management considerations.  Generally, these are less demanding for smaller
domains.

   Horizontal resolution is the geographic size of individual grid cells within the modeling
domain. Vertical resolution is the number of grid cells (i.e., layers) considered in the vertical
direction.  The choice of suitable horizontal and vertical resolution depends on spatial variability
in emissions, spatial precision of available emissions data, temporal and spatial variation in
mixing heights, the likelihood that mesoscale or smaller scale meteorological phenomena will
have a pronounced effect on precursor/ozone relationships, data base management constraints,
and any computer/cost constraints.

   We begin this section by discussing factors States/Tribes should consider in choosing domain
size. Next, we address the selection of horizontal grid cell  size and the number of vertical layers.
We conclude by discussing factors affecting the decision on the size and resolution of coarse
scale and fine scale grids within a nested model.

   12.1       How is the Size of the Modeling Domain Chosen?

   Historically (until -1995), ozone attainment demonstrations used urban scale modeling
domains which were typically several hundred kilometers (or less)  on a side.  With the advent of
nested grid models, most model applications began to use either relatively fine regional grids, or
urban-scale inner grids nested within  relatively coarse regional-scale outer grids.  We expect that
most 8-hour ozone attainment demonstrations will utilize a regional nested grid modeling
approach.

   The principal determinants of model domain size are the nature of the ozone problem and the
scale of the emissions which impact the nonattainment area. Isolated nonattainment areas that
are not impacted by regional ozone and ozone precursors may be able to use a relatively small
domain. Some areas of the western U.S. may fall into this category.  Most nonattainment areas
in the eastern U.S. have been shown to be impacted by transported  ozone and ozone precursors
from hundreds of miles or more upwind of the receptor area (U.S EPA,  1998b).  The modeling
domain should be designed so that all major upwind source areas that influence the downwind
nonattainment area are included in the modeling domain. The influence of boundary conditions
should be minimized to the extent possible.  In most cases,  the modeling domain should be large
enough to allow the use of clean or relatively clean boundary conditions.

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   The inner domain of a nested model application should include the nonattainment area and
surrounding counties and/or States. The size of the inner domain depends on several factors.
Among them are:

1) The size of the nonattainment area.

2) Proximity to other large source areas and/or nonattainment areas.
   -Relatively isolated areas may be able to use a smaller fine grid domain.
   -Nearby source areas should be included in the fine grid.

3) Proximity of topographical features which appear to affect observed air quality.

4) Whether the model application is intended to cover multiple nonattainment areas.

5) Typical wind speeds and re-circulation patterns during ozone episodes.
   -Very light wind speeds and re-circulation patterns may obviate the need for a large fine grid
   domain.

6) Whether the photochemical model utilizes one-way or two-way nested grids.
   -The fine grid domain of a model with one-way nested grids may need to be larger
   (compared to a model with two-way nested grids) due to the fact that air that leaves the fine
   grid never returns.  The grid needs to be large enough to capture re-circulation due to shifting
   wind directions. A two-way nested grid model allows for continuous feedback from the fine
   grid to the coarse grid and vice versa.

7) Computer and time resource issues.
    12.2       How are the Initial and Boundary Conditions Specified?

    Air quality models require specification of initial conditions for model species in each grid
cell in the model domain (in all layers) and boundary conditions for all grid cells along each of
the boundaries (in all layers).  Generation of initial and boundary conditions for individual model
species include gas-phase mechanism species, aerosols, non-reactive species and tracer species.
There is no satisfactory way to specify initial conditions in every grid cell. Thus, we recommend
using a "ramp-up" period by beginning a simulation at least 2-3 days prior to a period of interest
to diminish the importance of initial conditions32.  In this way, relatively clean static initial
       32Sensitivity simulations can be completed to determine the necessary length of the ramp-
up period. A longer ramp-up period may be needed for very large domains where the
characterization of long range transport is important.

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conditions can be used to initialize the model. For nested model applications, initial conditions
can be specified using model predictions from the outer grid if the nested grids are started a
couple of days after the beginning of the simulation for the outer grid.

   Boundary conditions can be specified in several ways.  One option is to nest the area of
interest within a much larger domain using nested regional models, as described previously.  As
noted above in Section 12.1, use of a large regional domain acts to diminish the importance of
boundary conditions. Alternatively, initial  and boundary conditions can be derived from another
regional nested modeling application or from a global model33.  Another option is to use default
initial and boundary concentration profiles  representing relatively clean conditions which have
been formulated from available measurements and results obtained from prior modeling studies,
e.g. prescribing 35 ppb for annual ozone. Another approach to consider is  using the model's
simulated pollutant values (generated for emissions) averaged over one or more of the upper
layers to specify a value for the lateral and top boundary conditions. This approach allows for
better representation of spatial  and temporal variation of boundary conditions (i.e.,
diurnal/seasonal/vertical profiles). This method also avoids arbitrarily guessing at the future-
year boundary conditions.

   If there is no larger regional model application available, then it is recommended that
background boundary conditions be used to specify initial  and boundary concentrations for the
attainment demonstration modeling. However, concentration fields derived from a larger
domain regional or global chemistry model (i.e. nesting approach) is considered more credible
than the assumption of static concentrations, since the pollutant concentration fields reflect
simulated atmospheric chemical and physical processes driven by assimilated meteorological
observations.

   Diagnostic testing which indicates a large impact on the model results from initial or
boundary conditions may indicate that the domain is not large enough or the ramp-up period is
too short. In either case, it should generally be assumed that initial and boundary conditions do
not change in the future.  The use of lowered initial or boundary conditions in the future year
should be documented and justified.

    12.3       What Horizontal Grid Cell Size Is Necessary?

   As we discuss in Section 13, most applications will use a prognostic meteorological model to
provide meteorological inputs needed to make air quality estimates. Typically, these models are
       33One atmosphere model applications for ozone and PM may commonly use global
models to specify boundary conditions. This is especially important for PM species due to their
long lifetimes. A number of recent studies show that long-range, intercontinental transport of
pollutants is important for simulating seasonal/annual ozone and particulate matter (Jacob, et al..
1999; Jaffe, et al.. 2003; Fiore, et al.. 2003).

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set up to produce meteorological fields for nested grids with a 3:1 ratio. In past ozone modeling
applications, the most commonly used grid cell sizes have been 108, 36, 12 and 4 km cells. In
this section we provide recommendations for choosing the grid size to use as an upper limit for
regional and urban scale models or for fine portions of nested regional grids.

   In past guidance, we have recommended using horizontal grid cell sizes of 2-5 km in urban
scale modeling analyses (U.S. EPA, 1991a). Sensitivity tests performed by Kumar (1994) in the
South Coast Air Basin compared hourly base case predictions obtained with 5 km versus 10 km
versus 20 km grid cells. Results indicate that use of finer grid cells tends to accentuate higher
hourly ozone predictions and increase localized effects of NOx titration during any given hour.
However, statistical comparisons with observed hourly ozone data in this heavily monitored area
appear comparable with the 5 and 20 km grid cells in this study.  Comparisons between hourly
ozone predictions obtained with 4 km vs. 12 km grid cells have also been made  in an Atlanta
study (Haney, 1996). As in Los Angeles, the use of smaller (i.e., 4 km) grid cells again leads to
higher domain wide maximum hourly ozone concentrations.  However, when reviewing
concentrations at specific sites, Haney (1996) found that for some hours concentrations obtained
with the 12 km grid cells were higher than those obtained with the 4 km cells. Other studies
have shown that model performance does not necessarily improve with finer resolution
modeling. In several studies, the model performance at 12 km resolution was equal to or better
than performance at 4 km resolution (Irwin, 2005).

   Another important aspect in choosing the horizontal grid cell size is the relative response of
the model at various grid cell resolutions.  Recent sensitivity tests comparing relative reduction
factors in predicted 8-hour daily maxima near sites in the eastern United States indicate
relatively small unbiased differences (< .04, in 95% of the comparisons) using a grid with 12 km
vs. 4 km grid cells (LADCO, 1999; Arunachalam, 2004). The largest differences in the relative
response of models at varying resolution is likely to occur in oxidant limited areas.  The
horizontal resolution may have a large impact on the spatial distribution and magnitude of NOx
"disbenefits" (i.e., ozone increases in oxidant limited areas when NOx emissions are reduced).
Therefore, emissions density is an  important factor in considering grid resolution.  Additionally,
terrain features (mountains, water) should be considered when choosing grid cell size.

   Intuitively, one would expect to get more accurate results in urban applications  with smaller
grid cells (e.g., 4 km) provided the spatial details in the emissions and meteorological inputs
support making such predictions. Thus, using 4 km grid cells for urban or fine portions of nested
regional grids and 12 km cells in coarse portions of regional grids are desirable goals.  However,
extensive use of urban grids with 4 vs. 12 km grid cells and regional grids with  12 vs. 36 km grid
cells greatly increases computer costs, run times and data base management needs.  Further,
elsewhere in this guidance we identify needs to model large domains, many days, and several
emission control scenarios.  We also identify a number of diagnostic tests which would be
desirable and suggest using more vertical layers than has commonly been done in the past.  Also,
there may be ways of dealing with potential problems posed by using larger than desired grid
cells.  For example, use of plume-in-grid algorithms for large point sources of NOx should be

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considered as an alternative with coarser than desired grid cells.

   The relative importance of using a domain with grid cells as small as 4 km should be
weighed on a case by case basis by those implementing the modeling/analysis protocol.  Thus, in
this guidance, we identify upper limits for horizontal grid cell size which may be larger than
desired for some applications. This is intended to provide flexibility for considering competing
factors (e.g., number of modeled days versus grid cell size) in performing a modeling analysis
within the limits of time and resources.

   For coarse portions of regional grids, we recommend a grid cell size of 12 km if feasible, but
not larger than 36 km. For urban and fine scale portions of nested regional grids, it may be
desirable to use grid cells about 4 km, but not larger than 12 km. States/Tribes should examine
past model applications and data analyses for their area when choosing the fine grid resolution.
Past model applications and data analyses may help determine whether  a grid cell size as  small
as 4 km (or smaller) is necessary for a particular area. Model performance and the relative
response to emissions controls should be considered in the decision. States/Tribes should
consider diagnostic tests to assess the difference in model performance and response from
varying model grid resolution, particularly in oxidant-limited areas.

   All ozone monitor locations within a nonattainment area  should ordinarily be placed within
the fine scale portion of a nested regional grid if nested models are used. States/Tribes choosing
an urban grid or fine portion of a nested grid with cells  12 km or larger should ordinarily  apply
plume-in-grid algorithms to major point sources  of NOx. The use of plume-in-grid should be
discussed with the appropriate EPA Regional Office.
    12.4       How Should the Vertical Layers Be Selected?

    As described in Section 13, the preferred approach for generating meteorological data fields
for input to air quality simulation models is to use a prognostic meteorological model with four
dimensional data assimilation (FDDA). Such models normally use more than 30 vertical layers.
To minimize a number of assumptions needed to interface meteorological and air quality models,
it is better to use identical vertical resolution in the air quality and meteorological models.
However,  application of air quality models with as many as 30 vertical layers may not be
feasible or cost effective. In this section we identify factors to consider in choosing the number
of vertical layers chosen for the air quality model applications.

    In the past, short ozone episodes of only several days usually encompassed periods of mostly
clear skies with very  little precipitation. As  such, ozone models often did not explicitly model
clouds or precipitation. However, we are recommending modeling longer episodes  (or even a
full ozone season) with a "one atmosphere" model which accounts for cloud processes and a full
range of precipitation types. In order to adequately parameterize these processes, the top of the
modeling domain should typically be set at thelOO millibar level  (-16,000 meters).  In turn, this

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means that many more vertical layers will be needed to capture the meteorological processes
both below and above the boundary layer, up to the top of the model.

   The accuracy of predicted base case ozone concentrations will be affected by how well the
model is able to characterize dilution of precursors and ozone. This, in turn, depends in part on
how precisely the model can estimate maximum afternoon mixing heights (i.e., the PEL).  The
precision of mixing height estimates is affected by the thickness of the model's vertical layers
aloft which are near the anticipated mixing height (Dolwick, 1999). Because maximum mixing
heights may vary on different days and it is necessary to simulate numerous days and locations,
model predictions can be influenced by the number of vertical layers considered by the model.

   Placement of vertical layers within the planetary boundary layer is also an important issue.
For practical reasons, it is best to have an air quality model's vertical layers align with the
interface between layers in the meteorological model.  In view of the importance of carefully
specifying the temporal variation in mixing height, we recommend high precision below and
near the anticipated maximum afternoon mixing height. In addition, specifying the vertical
extent of mixing overnight during stable conditions is also an important consideration in
determining the vertical layer structure. In this regard, we recommend that the lowest layer in
the air quality model be no more than 50 meters thick. In general, layers below the daytime
mixing height should not be too thick, or large unrealistic step increases in mixing may occur.
Layers above the boundary layer are important for characterizing clouds and precipitation, but
are less important to the daily mixing processes of ozone precursors on high ozone days.
Therefore, vertical  resolution above the boundary layer is typically much coarser.

   There  is no correct minimum number of vertical layers needed in an ozone attainment
demonstration.  The vertical resolution will vary depending on the application. Recent
applications of one atmosphere models (with model tops at 100mb) have used anywhere from 12
to 21 vertical  layers with 8-15 layers approximately within the boundary layer (below 2500m)
and 4-6 layers above the PEL (Baker, 2004b), (Hu et. al, 2004).

   There  are also ozone model applications which may not need to consider the full  set of
meteorological data through the tropopause.  These applications typically use vertical domains
which extend up to 4 or 5 km. These applications are most appropriate for short ozone episodes
that occur under high pressure conditions (little cloud cover or precipitation).  In these cases,
fewer vertical layers are needed to represent the atmosphere up to the top of the domain (4-5
km).  However, where appropriate, EPA encourages the use of full-scale one-atmosphere models
which account for all atmospheric processes up to -100 mb.
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13.0   How are the Meteorological Inputs Prepared for Air Quality
        Modeling?

   In order to solve for the change in pollutant concentrations over time and space, air quality
models require certain meteorological inputs that, in part, determine the formation, transport, and
removal of pollutant material. The required meteorological inputs can vary by air quality model,
but consistently involve parameters such as wind, vertical mixing, temperature, moisture, and
solar radiation. While model inputs can be derived strictly from ambient measurements, a more
credible technical approach is to use meteorological grid models to provide the necessary inputs.
When these models are applied retrospectively (i.e., for historical episodes) they are able to
blend ambient data with model predictions via four-dimensional data assimilation (FDDA),
thereby yielding temporally and spatially complete data sets that are grounded by actual
observations.

   This section provides recommendations for generating, or otherwise acquiring,
meteorological data  sets sufficient for air quality modeling purposes. Additional suggestions are
provided to assist in the configuration of the meteorological modeling analysis. The last section
outlines procedures for evaluating whether the meteorological input is of sufficient quality for
input into the air quality model. It is recommended that States/Tribes spend considerable effort
in accurately characterizing the meteorological fields in view of several sensitivity runs which
show that relatively  small differences in meteorological inputs can have large impacts on
resultant air quality modeling results (Dolwick, 2002).

   13.1       What Issues are Involved in the Generation and Acquisition of
              Meteorological Modeling Data?

   The recommended approach for generating the meteorological data needed to conduct the
attainment  demonstration is to apply dynamic meteorological models with FDDA.  These models
use the fundamental equations of momentum, thermodynamics, and moisture to determine the
evolution of specific meteorological variables from a given initial state. When modeling past
events, the  use of data assimilation, helps to steer (i.e., "nudge") solutions  so that they do not
diverge greatly from the actual observed meteorological fields.  A major benefit of using
dynamic meteorological models is that they provide a way of consistently characterizing
meteorological conditions at times and locations where observations do not exist. Examples of
frequently used meteorological models include, but are not limited to, MM5 (Grell et al., 1994)
and RAMS (Pielke et al., 1992). Recent advances in relatively low-cost computational power
have resulted in widespread use of MM5 and RAMS for air pollution applications over the past
decade (Olerud et al., 2000; Doty et al., 2001; Johnson, 2003, Baker, 2004) and EPA expects that
all future attainment demonstration analyses will be based on data from these types of prognostic
meteorological models. Over the next several years, EPA further expects that more
meteorological input data sets will be developed from archived National Weather Service (NWS)
model simulations. It is possible that data from the Eta, Rapid Update Cycle (RUC), and/or the
Weather Research Forecast (WRF) model could be used to feed air quality  simulations.  Some  of

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these prognostic meteorological models are already being used to drive real-time air quality
forecasts (McQueen et al., 2004).
    13.2       How Should the Meteorological Modeling Analysis be Configured?

    As with other parts of the air quality modeling system,  determining how to configure the
meteorological modeling can affect the quality and suitability of the air quality model
predictions.  Decisions regarding the configuration of complex prognostic meteorological
models can be particularly  challenging because of the amount of flexibility  available to the user.
The following are recommendations on how to configure a meteorological model for air quality
analyses.

    Selecting a Model Domain: As noted in Section 12, it is expected that most attainment
demonstrations will cover large areas and use nested grids. The outermost grid should capture
all upwind areas that can reasonably be expected to influence ozone locally. In terms of
selecting a meteorological modeling domain, one should extend the grid 3-6 cells beyond the
bounds of each air quality modeling grid to avoid boundary effects. For example, if 4 km grid
cells are to be used in the fine portion of a nested regional air quality model, then the
meteorological fields at this detail would need to extend 12-24 km beyond the bounds of the 4
km grid used for air quality predictions.   In terms of grid resolution, EPA recommends that the
meteorological models use the same grid resolution as desired for the air quality model
applications.  In some cases, however, this may not be feasible. One possible reason for
modeling with meteorology using a different grid resolution is in the case of unacceptable model
performance from the  meteorological model at the desired grid resolution.  In other instances,
the need for finer resolution may be emissions-driven more than meteorologically-driven and the
costs do not warrant the generation  of additional resolution in the meteorological data. In these
situations it is recommended that the model application use available results from meteorological
models on the next coarser scale (i.e., 36 km for a desired 12 km estimate, 12 km for a desired 4
km estimate) to interpolate more finely resolved meteorological fields for air quality modeling.

    Selecting Physics  Options: Most meteorological models have a suite of "physics options"
that allow users to select how a given feature will be simulated. For example, there may be
several options for specifying the planetary boundary layer scheme or the cumulus
paramaterization. In many situations, the "optimal"configuration cannot be determined without
performing a series of up front sensitivity tests which consider various combinations of physics
options over specific time periods and regions. While these tests may not ultimately conclude
that one configuration is clearly superior at all times and in all areas, it is recommended that
sensitivity tests be completed as they should lead to a modeling analysis that is suited for the
domain and period being simulated. Examples of sensitivity analyses can be found in (Olerud,
2003) and (McNally, 2002).  Typically, the model configuration which yields predictions that
provide the best statistical match with observed data over the most cases (episodes, regions, etc.)
is the one that should be chosen, although other more qualitative information can also be

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considered.

   Use of Data Assimilation: As noted above, the use of FDD A helps to keep the model
predictions from widely diverging from what was actually observed to occur at a particular point
in time/space.  However, if used improperly, FDD A can significantly degrade overall model
performance and introduce computational artifacts (Tesche and McNally, 2001). Inappropriately
strong nudging coefficients can distort the magnitude of the physical terms in the underlying
atmospheric thermodynamic equations and result in "patchwork" meteorological fields with
strong gradients between near-site grid cells and the remainder of the grid.  Additionally, if
specific meteorological features  are expected to be important for predicting the location and
amount of ozone formed, based on  an area's conceptual model, then the meteorological
modeling should be set up to ensure that FDDA does not prevent the model from forming these
features (e.g.  nocturnal low-level wind jets). In general, analysis nudging  strengths should be
no greater than 1.0 x 10"4 for winds  and temperatures and 1.0 x 10"5 for humidity. In the case of
observation nudging (i.e., FDDA based on individual  observations as opposed to analysis fields),
it is recommended that the resultant meteorological fields be examined to ensure that the results
over the entire domain are still consistent. Further, based on past experience, we recommend
against using FDDA below the boundary layer for thermodynamic variables like temperature and
humidity because of the potential for spurious convection.

   Conversion of Meteorological  Outputs to Air Quality Model Inputs: Even before
determining how the meteorological model  is configured, careful thought should be given to the
compatibility between candidate meteorological models and the air quality model(s) chosen for
use.  A variety of post-processors exist to convert the  outputs from the meteorological models
into the input formats of the air quality models. Some examples include: the Meteorology
Chemistry Interface Processor (MCIP) (Otte, 2004), MMSCAMx (Environ, 2005), and
RAMSCAMx  (Environ, 2005).  These meteorological preprocessors provide a complete set of
meteorological data needed for the air quality simulation by accounting for issues related to: 1)
data format translation, 2) conversion of parameter units, 3) extraction of data for appropriate
window domains, 4) reconstruction of the meteorological data on different grid and layer
structures, and 5) calculation of missing yet needed variables.

   13.3       How Should the  Performance  of the  Meteorological Modeling Be Evaluated?

   While the air quality models  used in attainment demonstrations have consistently been
subjected to a rigorous performance assessment, in many cases the meteorological inputs to these
models are accepted as is, even though this component of the modeling is arguably more
complex and contains a higher quantity of potential errors  that could affect the results of the
analysis (Tesche, 2002).  EPA recommends that States/Tribes devote appropriate effort to the
process of evaluating the meteorological inputs to the air quality model as we believe good
meteorological model performance  will yield more confidence in predictions from the air quality
model. One of the objectives of this evaluation should be to determine if the meteorological
model output fields represent a reasonable approximation of the actual meteorology that

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occurred during the modeling period.  Further, because it will never be possible to exactly
simulate the actual meteorological fields at all points in space/time, a second objective of the
evaluation should be to identify and quantify the existing biases and errors in the meteorological
predictions in order to allow for an downstream assessment of how the air quality modeling
results are affected by issues associated with the meteorological data.  To address both
objectives, it will be necessary to complete both an operational evaluation (i.e., quantitative
statistical and graphical comparisons) as well as a more phenomenological assessment (i.e.,
generally qualitative comparisons of observed features vs. their depiction in the model data).

   Operational Evaluation: The operational evaluation results should focus on the values and
distributions of specific meteorological parameters34 as compared to observed data. Typical
statistical comparisons of the key meteorological parameters  will include: comparisons of the
means, mean bias, mean normalized bias, mean absolute error, mean absolute normalized error,
root mean square error (systematic and unsystematic), and an index of agreement. For modeling
exercises over large domains and entire ozone seasons, it is recommended that the operational
evaluation be broken down into individual segments such as geographic subregions to allow for
a more comprehensive assessment of the meteorological strengths and weaknesses. Other useful
ways of examining model performance include: aloft, surface, individual episodes (e.g., high
ozone days), diurnal cycle, as a function of synoptic regimes, or combinations of the above. It is
recommended that the ambient data used in these statistical comparisons be quality checked by
doing standard range check and buddy analyses. To the extent that modelers can set aside a
portion of the ambient data strictly for evaluation purposes (i.e., data not used in the FDD A), that
is also encouraged.

   It may be helpful  when calculating domainwide and/or regional summary statistics to
compare the results against previously accomplished meteorological model performance
"benchmarks" (Emery et al., 2001). However, because of concerns about potentially misleading
comparisons of model performance findings across different  analyses  with differing model
configurations and FDDA strengths, EPA does not recommend using these benchmarks in a
"pass/fail" mode, but only as a means of assessing general confidence in the meteorological
model data.  Statistical results that are outside the range of the compiled benchmarks may
indicate an issue that should be given  further examination. In most cases the performance
evaluation will be completed on the raw meteorological fields; however it is also important to
compare the results before and after the meteorological post-processing to ensure that the
meteorological fields going into the air quality model have not been adversely affected.
       34 It is difficult to say which meteorological parameters will most affect any particular
modeling exercise. However, in general, it is expected that following key variables should be
most closely evaluated: temperature, water vapor mixing ratio, wind speed, wind direction,
clouds/radiation, precipitation, and the depth and evolution of vertical mixing over the modeling
periods.

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   Phenomenological Evaluation: As discussed in Chapter 8, it is recommended that a
conceptual description of the area's ozone problem be developed prior to the initiation of any air
quality modeling study.  Within the conceptual description of a particular modeling exercise, it is
recommended that the specific meteorological parameters that influence air quality be identified
and qualitatively ranked in importance. When evaluating meteorological models or any other
source of meteorological data, the focus of the phenomenological evaluation should be on those
specific meteorological phenomena35 that are thought to strongly affect air pollution formation
and transport within the scope of a specific analysis.  It is expected that this event-oriented
evaluation will need to summarize model performance in terms of statistical metrics such as
probability of detection and false alarm rate.  As an example of a phenomenological analysis,
many regional air quality modeling exercises attempt to assess the effects of transport of
emissions from one area to a downwind area with an intent to establish source-receptor
relationships. For these types of modeling analyses, accurate transport wind trajectories are
needed to properly establish these source-receptor linkages.  In this type of model application, a
useful event-based meteorological evaluation would be to compare model-derived trajectories
versus those based on ambient data to determine what error distance can be associated with the
model fields.
       35 Possible examples include: lake/sea breezes, low-level jets, amount of convection on a
given day.

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14.0   How Are the Emission Inputs Developed?

   Air quality modeling for 8-hour ozone requires emission inputs for base case, baseline, and
future modeling years. As explained in the EPA Emission Inventory Guidance (U.S. EPA,
2005c), 2002 is designated as a new base year for 8-hour ozone and PM2 5 SIPs and regional haze
plans; therefore, wherever possible, 2002 should be used for baseline modeling for the 8-hour
ozone standard36.  The future-year depends on the nonattainment classification of the individual
State or Tribe, as described in Section 3.  Note that emissions data should be consistent with the
data used in the modeled attainment test,  described in Section 3.

   Preparation of emissions data for air quality models for the base and future years requires
several steps. First, States/Tribes need to compile base-year inventories for their modeling
region (e.g., the States and Tribes in the modeling grid). For ozone  model applications, emission
inventories must include a complete accounting of anthropogenic and biogenic VOC, NOx, and
CO.  Second, modelers must collect "ancillary data" associated with the inventories, which
prescribes the spatial, temporal, and chemical speciation information about the emission
inventory.  Third,  modelers use the  ancillary data for "emissions modeling".  Emissions models
spatially, temporally, chemically, and vertically allocate emission inventories to the resolution
needed by AQMs.  Fourth, modelers must collect data on growth rates and existing control
programs for use in projecting the base year emission inventories to the future year, and then use
an emissions  model to prepare that future year inventory data for input to the air quality model.
Fifth, emissions inventories that reflect the emissions reductions needed for attainment will have
to be prepared for air quality modeling.

   Sections 14.1 and 14.2 summarize the issues for  preparing emission inventories.  Section
14.3 describes the needs for ancillary data.  Section  14.4 summarizes the emissions modeling
steps. Section 14.5 and Section 14.6 summarizes the issues associated with modeling of future
year emissions data.

   14.1       Can The National Emission Inventory Be Used As a Starting Point?

   It is recommended that States/Tribes start with available inventories suitable for air quality
modeling of the modeling episode(s). If no such inventory is available, States/Tribes may derive
an inventory suitable for use with models starting from the National Emission inventory (NEI),
available from http://www.epa.gov/ttn/chief/net/.  The 2002 NEI can be used as a starting for
       36 2002 is the recommended inventory year for the baseline modeling (the starting point
for future year projections). Other years may be modeled for the base case modeling (for
performance evalaution) if episodes are chosen from years other than 2002.

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inventory development37.  However, the detail on emissions in the NEI  may not be sufficient for
use in attainment demonstration modeling. Thus, States/Tribes should review the contents of the
NEI for accuracy and completeness for regional and local scale modeling and amend the data
where it is insufficient to meet the needs of the local air quality model application. While some
benefits can be realized for states using the same inventory (such as the NEI) as a starting point
for their work, the more important goal for SIP inventory development is to ensure that the data
are representative and accurate enough for making good control strategy decisions.
    14.2      What Emission Inventory Data are Needed to Support Air Quality Models?

    Emission inventory data from five categories are needed to support air quality modeling:
stationary point-source emissions, stationary area-source emissions (also called non-point),
mobile emissions for on-road sources, mobile emissions for nonroad sources, and
biogenic/geogenic emissions.  The emission inventory development and emissions modeling
steps can be different for each of these categories.

Point Sources- Point source inventories for modeling should be compiled at a minimum by
country, State/Tribe, county, facility, stack, and source category code (SCC) but often are further
subdivided by "point"  and "segment"(see references below to point-source inventory
development).  The point source data must include information on the location of sources (e.g.,
latitude/longitude coordinates); stack parameters (stack diameter and  height, exit gas temperature
and velocity); and operating schedules (e.g., monthly, day-of-week, and diurnal).

Stationary Area Sources- Stationary-area source emissions data should be compiled by
country, State/Tribe, county, and SCC.

On-Road Mobile- On-road mobile source emissions should be  estimated using the most current
version of the U.S. EPA MOBILE model ( http://www.epa.gov/omswww/m6.htm), and for
California, the most current version of EMFAC
(http: //www. arb. ca. gov/m sei/on-road/1 atest_ver si on. htm) in concert with vehicle miles traveled
(VMT) data representative of the time periods modeled. The MOBILE model allows modelers
to override default settings to obtain a local-specific on-road inventory, and modelers should
consider using these options to improve their inventories.  On-road emissions and VMT should
be compiled at least at the country, State/Tribe, county, and SCC level, though modelers may
optionally compile and use data for individual road segments (called "links").  The link
approaches requires starting and ending coordinates for each road link. As noted in Section 14.3,
link-based emissions can be based on Travel Demand Models (TDMs).
       37The final 2002 NEI is expected to be available at the end of 2005. Until the final NEI is
available, the final 1999 (version 3) NEI or the draft 2002 NEI can be used as a source of
national inventory data.

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Nonroad Mobile- For nonroad mobile sources, the emissions should be compiled as country,
state/tribe, county and SCC totals using the most current version of EPA's NONROAD model
(http://www.epa.gov/oms/nonrdmdl.htm) or alternative model.

Biogenic Emissions - Biogenic emissions from plants and soil contribute VOC and NOx
emissions and are best calculated as part of the emissions modeling step, as described in Section
14.4.  These emissions require land use data, which is described as an ancillary dataset in Section
14.3.  Geogenic emissions (such as volcanic emissions) are often not relevant for many areas, but
if geogenic sources in the modeling domain are expected to contribute in a significant way to air
quality problems, they should be included.

Other Considerations - For all sectors, emissions data must be compiled at a minimum as an
annual total for the base modeling year. Emissions can also be compiled as monthly total
emissions or an average-summer-day inventory. In any case, the temporal allocation step during
emissions modeling (see Sections 14.3 and 14.4) must adjust the inventory resolution for the
modeling time period. Additionally, we encourage the use of more temporally specific data
where it is available and can be expected to improve model performance. For example, hour-
specific Continuous Emissions Monitoring (CEM) data may be used as a source for hour-specific
NOx emissions and exit gas flow rates38.

   Inventories should be built using the most current, accurate, and practical  methods available.
Several references are available for guidance on building emission inventories. The first is the
"Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter NAAQS
and Regional Haze Regulations" (U.S. EPA, 2005c). Additionally, modelers  may want to
consider EPA's approaches used for developing the 2002 NEI. Available NEI documentation
may be used to help guide the development of the modeling inventory
(http://www.epa.gov/ttn/chief/net/2002inventory.html).  Lastly, seven documents have been
issued by the Emission Inventory Improvement Program (EIIP) for use in inventory
development:

   •    Volume I:                Introduction and Use of EIIP Guidance for Emissions
                                 Inventory Development (U.S. EPA, 1997a)
       38Day specific emissions data, such as CEM data or wildfire data may be useful in the
base case modeling to improve model performance. But in some cases, it may not be appropriate
to project day-specific data to the future. For example, if a large power plant was shutdown for
maintenance during the base case period, it would not be logical to project zero emissions for
that source in the future (if it is assumed that the plant will be operating in the future year).
Therefore, certain day specific inventory information should be removed and replaced with
average data in the baseline inventory, before projecting the baseline to the future. This issue is
not a concern for day-specific mobile source or biogenic emissions data which may be dependent
on day specific (or even hourly) meteorological data for the time periods modeled.

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   •    Volume II:                Point Sources Preferred and Alternative Methods (U.S.
                                  EPA, 1997b)

   •    Volume III:               Area Sources Preferred and Alternative Methods (U.S.
                                  EPA, 1997c)

   •    Volume IV:               Mobile Sources preferred and Alternative Methods (U.S.
                                  EPA, 1997d)

   •    Volume V:                Biogenics Sources Preferred and Alternative Methods (U.S.
                                  EPA, 1997e)

        Volume VI:               Quality Assurance Procedures (U.S. EPA, 1997f)

        Volume VII:              Data Management Procedures (U.S. EPA, 1997g)

   The EIIP documents are available electronically through the EPA website at
http://www.epa.gov/ttn/chief/eiip/techreport/. The quality assurance procedures contain
essential steps for inventory preparation, which help assure that the emission inventory is
appropriate for SIP air quality modeling.

   14.3      What Other Data are Needed to Support Emissions Modeling?

    The emission inventories must be converted (through emissions modeling) from their
original resolution (e.g., database records) to input files for air quality models.  These input files
generally require emissions to be specified by model grid cell, hour, and model chemical species.
 This section describes the ancillary data that modelers should collect that allow emissions
models to convert the emission inventory data.

   Ancillary data for temporal allocation are necessary for stationary point, stationary area, and
all mobile sources.  To facilitate temporal allocation of the emissions, factors (called profiles)
must be created to convert annual emissions to specific months (monthly profiles), average-day
emissions to a specific day of the week (weekly profiles), and daily emissions to hours of the day
(hourly profiles). Additionally, a cross-reference file is needed to assign the temporal profiles to
the inventory records by SCC, facility, or some other inventory characteristics.  Where available,
the operating information that may be available from the point-source inventory should be used
to create inventory-specific temporal factors.  EPA provides a starting point for the temporal
profiles and cross-reference files, available at: http://www.epa.gov/ttn/chief/emch/temporal/.

   The emissions models also need information about the chemical species of the VOC
emissions for stationary point, stationary area, and all mobile sources. These data are used to
disaggregate the total VOC emissions to the chemical species expected by the air quality model

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and are called speciation "factors" or "profiles". EPA provides a starting point for the VOC
speciation data, which are available at: http://www.epa.gov/ttn/chief/emch/speciation/. For large
or critical VOC sources in the modeling domain, modelers should consider determining the
individual chemical compounds contributing to the total VOC.  If collected, this information
should then be used to compile improved speciation profiles for the critical facilities or source
categories.  These speciation profiles should be assigned to the inventory by a speciation cross-
reference file, which also needs to be created or updated from the available defaults. The cross-
reference files typically assign speciation profiles based on SCC code, though facility-specific
assignments for point source code is also possible if plant-specific data are available.

   For all source sectors that are compiled at a county resolution, the emissions models also
need information about allocating the countywide emissions to individual grid cells that intersect
the county.  Such sectors include stationary  area, nonroad mobile, and non-link on-road mobile
sources.  The spatial allocation process assigns fractions of county-total emissions to the model's
grid cells intersecting the county based on a "surrogate" data type (e.g., population or housing
data).  The  appropriate types of surrogate data to use for each SCC in the inventories should be
identified for this processing step. Spatial surrogates can be created using Geographic
Information Systems (GISs) and the MIMS  Spatial Allocator
(http://www.cep.unc.edu/empd/projects/mims/spatial/), which calculate the fraction of
countywide emissions to allocate  to each grid cell based on the surrogate type. Additionally, all
SCCs needing spatial surrogates should be assigned a surrogate in a cross-reference file.  Point
sources do not need spatial  surrogates, since the emissions models assign the grid location based
on the latitude and longitude of the point sources.  Additionally, EPA provides spatial surrogates
and cross-references for a limited set of modeling grids and surrogate types at:
http://www.epa.gov/ttn/chief/emch/spatial/.  Finally, for future-year modeling, emissions
developers  can choose to change their spatial surrogate data based on predicted changes in land
use patterns, population growth, and demographics, however, the impact  and utility of such
approaches is not well characterized39.

   For biogenic emissions  modeling, the Biogenic Emission Inventory System, version 3
(BEIS3)  (http://www.epa.gov/asmdnerl/biogen.html) model comes with all needed ancillary
data, except the gridded land-use data and meteorology data for a specific air quality modeling
domain and grid. Land use and meteorology data that are compatible with BEIS3 are needed for
the specific grid and grid-cell resolution that is being used.  For BEIS3, land use data can be
created with the MIMS Spatial Allocator (http://www.cep.unc.edu/empd/projects/mims/spatial/),
using raw Biogenic Emissions Landcover Data (BELD), version 3
(http://www.epa.gov/ttn/chief/emch/biogenic/). For future-year modeling, emissions developers
can choose to change their land cover data based on predicted changes in land use patterns,
however, the impact and utility of such approaches is not well characterized4.
       39At the time this document was written, tools to readily predict future-year land use
patterns are not readily available in a form for use in emissions modeling.

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   On-road emissions for fine-scale model grids (e.g., 4-km grid cells or smaller) may be based
on a link-based mentioned in Section 14.2. The VMT and speed data needed for a link-based
approach can be provided using a Travel Demand Model (TDM).  These models require their
own sets of inputs, which depend on the specific TDM used. Details on using TDMs for link-
based on-road mobile emissions are available from the EIIP document "Use of Locality-Specific
Transportation Data for the Development of Source Emission Inventories"
(http://www.epa.gov/ttn/chief/eiip/techreport/volume04/iv02.pdf).

   Emissions models have other input files that must be created. For example, criteria may be
needed for selecting elevated from non-elevated point sources.  Each model has a large number
of files and settings which work together in fairly complex ways; therefore, care must be taken to
determine the files needed for the emissions model, and to prepare all needed input files in a way
that will support using the emissions model for the specific air quality modeling episode.
    14.4      How Are Inventory Data Converted Into Air Quality Model Input?

    Emissions models are used to convert inventory data to inputs for air quality modeling. As
described in Section 14.3, additional ancillary data is needed to complete the process.  The
emissions data from each of the five emissions sectors are temporally allocated, chemically
speciated, and spatially allocated. The resulting hourly, gridded, and speciated emissions from
all sectors are then combined before being used by an air quality model. In this section, we will
provide information on several emissions models and summarize some additional issues that are
key for emissions modeling.

Emissions models Several emissions models are available for use in SIPs. While no single
model has been  specifically created for all situations of SIP development, each model is
generally capable of performing the temporal, chemical, and spatial allocation steps as well as
various other steps. Users of these models are responsible for ensuring that the  emissions
processing steps are transforming the emission inventories as intended and are not changing the
emissions in any unexpected way.  The models each have different capabilities, limitations, and
nuances.  Therefore, when choosing an emissions model, it is worthwhile to discuss the choice
with the developers of these systems and/or with EPA to  establish which model is best for the
specific application.

    Currently there are three main emissions models being used to process emissions for input
into photochemical grid models and a fourth model that is under construction at the time that this
document was written. They  are: Sparse Matrix Operator Kernel Emissions (SMOKE);
Emissions Modeling System (EMS-2001); and Emissions Preprocessor System  - Version 2.5
(EPS 2.5). The  Consolidated Community Emissions Processing Tool (CONCEPT) is under
development by the Regional Planning Organizations.

    The Sparse Matrix Operator Kernel Emissions (SMOKE), software and User's Guide are

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available through the University of North Carolina, Carolina Environmental Program
(http://www.cep.unc.edu/empd/products/smoke). SMOKE supports processing of criteria,
mercury, and toxics inventories for stationary point, stationary area, mobile, and biogenic
emissions.  It can create input files for the CMAQ, CAMX, UAM-V, and REMSAD air quality
models. SMOKE was the basis for development of the BEIS3 system, so BEIS3 in its original
form can be used easily with SMOKE.  Applications of SMOKE have been presented at several
of the International Emissions Inventory Workshops (Houyoux et al., 2000; Strum et al., 2003).
SMOKE is available for UNIX and Linux operating systems and is not recommended for use on
a PC. It does not require third party software. It does not include utilities for creating speciation
profiles, biogenic land use, or spatial surrogates, though the latter two datasets can be built using
the Multimedia Integrated Modeling System (MIMS) Spatial Allocator Tool
(http://www.cep.unc.edu/empd/projects/mims/spatial/).  Support for the SMOKE system is
available through the Community Modeling and Analysis System (CMAS) help desk
(http ://www. cmascenter.org/html/help .html).

   The Emissions Modeling System, (EMS 2001, http://www.ladco.org/tech/emis/ems_2001/) is
a later version of EMS-95, which was used in the modeling underlying the U.S. EPA NOx SIP
call rule to reduce regional NOx emissions (U.S. EPA 1997h), as well as in other applications of
nested regional air quality models. It can create inputs for the CAMX and UAM-V models.  It
includes the BIOME3 model, which provides access to similar calculations of biogenic
emissions as are  available in the BEIS3 system.  EMS-2001 can be run on either Linux or
Windows NT, and users must purchase a license for the SAS® software to use it. It includes
utilities for creating speciation profiles, biogenic land use, and spatial surrogates. An updated
version has new  spatial processors which limit the need for GIS software.

   The Emissions Preprocessor System - Version 2.5 (EPS-2.5), software and User's Guide are
available through Systems Applications International/ICF Consulting (www.uamv.com). EPS-
2.5 is a comprehensive emissions processing system that supports processing of stationary point,
stationary area, and mobile emissions for the development of base and future-year modeling
inventories for input to the CAMX, UAM-V, and REMSAD models. EPS-2.5 consists of a set of
stand-alone FORTRAN programs that do not require third-party  software.  The system is capable
of preparing local, regional, and continental-scale emission inventories for ozone, particulate
matter, mercury,  and air toxics modeling applications.  EPS 2.5 is available for UNIX and Linux
operating systems.  It includes utilities for creating source-specific temporal and chemical
speciation profiles based on locally provided detailed information for episode specific emission
inventories.  It also includes utilities for preparing spatial surrogates. In addition, EPS-2.5  has
the capability of  creating modeling inventories required for the application of source
apportionment techniques such as UAM-V's Ozone and Precursor Tagging Methodology
(OPTM).

   The Consolidated Community Emissions Processing Tool (CONCEPT) is an open source
model written primarily in PostgreSQL. Users are encouraged to make additions and
enhancements to the model The database structure of the model makes the system easy to

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 understand, and the modeling codes themselves are documented to encourage user participation
 in customizing the system for specific modeling requirements.  The CONCEPT model structure
 and implementation allows for multiple levels of QA analysis during every step of the emissions
 calculation process.  Using the database structures, an emissions modeler can easily trace a
 process or facility and review the calculation procedures and assumptions for any emissions
 value. CONCEPT includes modules for the major emissions source categories: area source,
 point source, on-road motor vehicles, non-road motor vehicles and biogenic emissions, as well as
 a number of supporting modules, including spatial allocation factor development, speciation
 profile development, growth and control for point and area sources, and CEM point source
 emissions handling.  Additional work by the emissions modeling community has begun
 development of CEM preprocessing software, graphical QA tools, and an interface to the traffic
 demand models for on-road motor vehicle emissions  estimation.

 Biogenic emissions  Estimates for biogenic emissions can be made using the BEIS emissions
 model (Geron, et al., 1994). The BEIS3 model estimates CO, NOx, and VOC emissions from
 vegetation and soils in the gridded, hourly, and model-species forms needed for air quality
 modeling. Guenther, et al., (2000) contains the technical development and review of BEIS3.
 Vukovich, et al., (2002) summarizes new input data and algorithms as implemented within
 SMOKE. Arunachalam,  et al., (2002) presents the impact of BEIS3 emissions on ozone. For
 more detailed local estimates, a State or Tribe should review the biogenic emissions on a county
 basis and update as needed the spatial patterns of land use data.

    Other models for biogenic emissions include the BIOME model that is a part of EMS-2001
 and the Global Biosphere Emissions and Interactions System (GloBEIS). The latter estimates
 emissions from natural (biogenic) sources and is designed for use in combination with
 photochemical modeling systems, such  as CAMx (http://www.globeis.com/).

    All of the biogenic models require a mix of land uses to be specified for each county or grid
 cell, as well as hourly temperature and in some cases other meteorological data. If a State or
 Tribe believes the average land use mix characterized for a county is inappropriate for certain
 gridded locations within a county, this may be overridden for the grid cells in question on a case
 by case basis.

    14.5      Are there Other Emissions Modeling Issues?

   In addition to the general emissions modeling steps and the biogenic emissions modeling,
there are several other issues of which the air quality modeler should be aware.  These are:

•  Elevated point sources
•  Advanced approaches for mobile source modeling
   Quality assurance

In the remainder of this section, we briefly address each of these issues.


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Elevated Point Sources Point sources need to be assigned to an appropriate model layer40 (the
vertical modeling dimension). Depending on the air quality model that is being used, different
emissions modeling steps can be taken. Models such as UAM-V and CAMX, expect input
emissions files separately for layer-1 emissions and elevated point-source emissions.
Additionally, elevated point sources may be flagged for treatment with a plume-in-grid (PinG)
approach. For these models, emissions modelers must supply a criteria for specifying which point
sources will be treated as elevated and as PinG sources.  In this case, the air quality model
calculates the plume rise of the point source emissions when the model is run.

   Models such as CMAQ expect (1) a 3-D emissions input file, for which the elevated plume
rise has already been calculated and (2) a separate optional PinG emissions file. Emissions
modelers may optionally specify which sources to treat as elevated and PinG.  Since the
emissions model must calculate plume rise in advance, it must use meteorological data such as
temperature, pressure and wind speeds. For the sake of consistency, the meteorological data that
is used in calculating plume rise is usually the same as what is used by the air quality model.

Mobile Source Modeling  Mobile source emissions modeling takes two primary approaches.
The first approach is to compute emissions from VMT and emission factors from the MOBILE
model prior to use by an emissions model. The second approach is to allow an emissions model,
such as SMOKE, to drive the MOBILE model using gridded meteorology data. Many more
assumptions must be made about using average temperatures in the first approach, since
emissions are calculated on an annual total, monthly, or average-day basis and therefore do not
include the day-to-day temperature variability that the second approach includes. It is widely
assumed that the second approach is more robust for local-scale modeling, though we do not
recommend one approach over the other.  States/Tribes are encouraged to choose an approach
that gives sufficient model performance for their attainment demonstration modeling.

Quality Assurance The third additional emissions modeling topic we have summarized here  is
emissions modeling quality assurance (QA).  A brief synopsis of appropriate quality assurance
(QA) approaches for emissions modeling is available in Section 2.19 of the SMOKE manual
(http://cf.unc.edU/cep/empd/products/smoke/version2.l/html/ch02sl9.html). The purpose of QA
for emissions modeling is to ensure that the inventories are correctly processed using the
information the modeler intended.  (It is assumed here that the inventory itself has already been
QA'd through inventory QA procedures, as referenced in Section 14.3.) Emissions modeling QA
includes such activities as reviewing log files for errors and warnings and addressing problems;
comparing emissions between each of the processing stages (e.g., data import, speciation,
temporal  allocation) to ensure mass is conserved; checking that the correct speciation, temporal
        40Point sources generally comprise most of the elevated emissions (above layer 1),
 although other area sources, such as fires and aircraft, may also have emissions assigned to
 elevated layers.

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allocation, and spatial allocation factors were applied; ensuring that emissions going into the air
quality model are consistent with expected results; and checking modeling-specific parameters
such as stack parameters.
    14.6       How Are Emissions Estimated for Future Years?

    Emissions estimates for future years are called "emissions projections". These projections
include both emissions growth (due to increased or decreased activities) and emissions controls
(due to regulations that reduce emissions in specific ways in the future). The goal in making
projections is to obtain a reasonable estimate of future-year emissions that accounts for the key
variables that will affect future emissions.  Each State/Tribe is encouraged to incorporate in its
analysis the variables that have historically been shown to drive its economy and emissions, as
well as the changes in growth patterns and regulations that are expected to take place over the
next five to twenty years. For details on which future year(s) should be modeled for attainment
demonstrations, refer to Section 3.

    A report entitled "Procedures For Preparing Emissions Projections" describes emissions
projections issues and approaches (U.S. EPA, 1991b; also available at
www.epa.gov/ttn/chief/eiip/techreport/volumelO/x01.pdf).  It is currently the most
comprehensive resource available about emissions projections.  In this  section, we will address an
overall approach for tackling emissions projection issues that incorporates use of this document
and points out where other approaches or new data are available to amend the information
included in that report.

Developers of projection-year emissions are advised to take the steps in the bulleted list below.
Each of these steps corresponds to a subsequent subsection.

•   Identify sectors of the inventory that require projections and sectors for which projections are
    not advisable, and prioritize these sectors based on their expected impact on the modeling
    region (Section 14.6.1).

•   Collect the available data and models that can be used to project emissions for each of the
    sectors (Section 14.6.2).

•   For key sectors, determine what information will impact the projection results the most, and
    ensure that the data values reflect conditions or expectations of the modeling region (Section
    14.6.3)

•   Create inputs needed for emissions models, create future-year inventories, quality assure
    them, and create air quality model inputs from them (Section 14.6.4)

The remainder of this section provides additional details about these steps.

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         14.6.1   Identify and prioritize key sectors for projections

Emissions modelers should evaluate their inventories for those sectors that are most critical to
their modeling results.  The purpose of identifying these key sectors is to direct more resources
and efforts to estimating future-year emissions for these sectors in the subsequent steps.

   Sectors can be subsets of the larger groups of stationary area, on-road mobile, nonroad
mobile, and point sources. For modeling regions that are NOx-limited, sectors with higher NOX
emissions will be more important for ensuring correct projections, and for VOC-limited regions,
sectors with higher VOC emissions will be more important.  Mobile sources are typically large
contributors to both VOC and NOX and are therefore usually a priority in estimation of future-
year emissions, particularly for urban areas.

   In some cases, there are sectors that are very difficult or highly uncertain to project into the
future. Wildfire  emissions is a common example of such a sector, since models are not readily
available that estimate the magnitude and location of future-year emissions. In this cases, it may
be advisable to either leave such emissions out of the modeling or create an "average year"
inventory and temporal distribution of the emissions.

         14.6.2   Collect available data and models for each sector needing projections

   The EIIP projections document (referenced previously) provides a starting point for this step.
The EIIP document provides the majority of information about sources of data on growth and
controls. This section supplements that document.

   For each sector needing projections (and in particular for the priority sectors), emissions
modelers should collect and review  growth and control information.  As noted in the EIIP
document, the sources of such information depend upon the sector of interest.  New data and
approaches beyond those in the EIIP document are available and provided here; likewise, new
data  and approaches will become available subsequent to the publication of this document.  The
information provided here is  a snapshot of information that will grow and adapt over time, and
emissions modelers should seek out such new information as part of this step.

   In addition to the sources of control information about non-EGU point and stationary area
sources listed in  the EIIP projection document, EPA has provides control assumptions with its
modeling data used for promulgating air quality rules. For example, emissions growth and
control assumptions were provided with the Clean Air Interstate Rule (See
http://www.epa.gov/air/interstateairquality/pdfs/fmaltech01.pdffor additional information on
obtaining actual  data files) More current information is usually available than what is available
from EPA, which is best obtained by working with state and local regulatory officials for the SIP
modeling region. The remainder of this section focuses on sources of growth information.
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Point sources.
    Section 2 of the EIIP projections document gives details about projection of point-source
emissions.  There are two major subsets of point sources: electric generating utilities (EGUs) and
non-EGUs.  The Clean Air Markets Division (CAMD) of the U.S. EPA uses the Integrated
Planning Model (IPM) to model emissions trading programs that now dominate the prediction of
future-year emissions from EGUs. More information on IPM is available at
(http://www.epa.gov/airmarkt/epa-ipm/). Additionally, IPM-based emissions are posted by
CAMD on EPA's website (http://www.epa.gov/airmarkets/epa-ipm/iaqr.html). Other trading
models may exist and could be used for estimation of future-year emissions.

    To prevent double-counting of emissions sources, emissions modelers who use IPM should be
careful to match the sources of emissions from IPM  with the base year emissions sources.  This
helps to ensure that the EGU part of their point source inventory is separated from the non-EGU
part based on the facilities included in IPM.  The facilities included in IPM are defined using the
National Electric Energy Database System (NEEDS). The NEEDS dataset should be compared to
the point inventory using the Office of Regulatory Information  Systems (ORIS) Plant ID field
from both.  In some cases (e.g., co-generation facilities), only some of the units at these facilities
are included in IPM; therefore, the separation of EGUs from non-EGUs should be done by unit
and not by facility.

    Since base-year emissions of EGU point sources can be based on hour-specific emissions
from the CEM program, emissions modelers must choose a temporal allocation approach for
estimated future-year emissions.  This issue was also noted in footnote 3 in Section 14.2.
Emissions modelers should choose an approach that is representative of future expected behavior
and not limited to any single year's closures and maintenance schedule.  Ideally, types of EGUs
that are run during high demand conditions would have temporal allocation approaches that
reflected those peaks, and units that are run continuously would be temporally allocated in a more
uniform way. Analysis of several years of CEM data could be helpful to determine these unit-by-
unit trends and develop profiles accordingly.

    Additional considerations for projecting point source emissions without the IPM model are
provided in the EIIP projection document. However, several of the references in that document
are now out of date, as follows.

•   The latest SCC codes  are available at http://www.epa.gov/ttn/chief/codes/ and not the website
    provided in the document.
•   The AP-42 emission factor website is now http://www.epa.gov/ttn/chief/ap42/index.html.
•   The website with further information about point source inventories is
    http://www.epa.gov/ttn/chief/eiip/techreport/
•   The references in Table 2.1-1 web link is no longer applicable. Instead, the following
    information can be used to help provide similar information:
             - Energy consumption by industry report, 2002:
                 http://www.eia.doe.gov/oiaf/analvsispaper/industry/consumption.html

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              - Annual Energy outlook report, 2005:
                 http://www.eia. doe. gov/oiaf//aeo/pdf/03 83 (lOOSYpdf

The references in Table 2.1-2 are also out of date and should be updated as follows:
          - US EPA Emissions trends reports. These reports can be used to provide the historical
              trends of emissions sectors based on the National Emission Inventory:
              http://www.epa.gov/air/airtrends/
          - Integrated Planning Model:
              http://www.epa.gov/airmarkt/epa-ipm/
          - Multiple Projections System - is no longer in use
          - California Emission Forecasting System:
              http ://www. arb. ca. gov/html/databases.htm

The tools and data sources described in the "Additional resources" section below should also be
evaluated for use for projection of point source emissions.

Stationary area sources.
   Section 3 of the EIIP projections document provides details about projecting area-source
(a.k.a nonpoint emissions).  However, several of the references or statements in that document are
now out of date,  as follows.

•  The web sites for SCCs, AP-42 emission factors, and more information about area-source
   inventories are out of date.  These should be updated to the same sites as were listed in the
   point sources section above.

•  The ASEM model mentioned in Section 3.2 of the EIIP projection document was not
   completed and is not available.

•  The references in Table  3.1-2 are out of date and should be updated as follows:
          - US EPA Emissions trends reports. These reports can be used to provide the historical
              trends of emissions sectors based on the National Emission Inventory:
              http ://www.epa. gov/air/airtrends/
          - Multiple Projections System - is no longer in use
          - California Emission Forecasting System:
              http ://www. arb. ca.gov/html/databases.htm

The tools and data sources described in the "Additional resources" section below should also be
evaluated for use for projection of point source emissions.

On-road mobile sources.
   Section 3 of the EIIP projections document provides details about projecting on-road mobile-
sources. It is still a very relevant snapshot of on-road mobile projection approaches; however,
several of the references or statements in that document are now out of date, as follows.

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Additionally, several new capabilities are available, which also are included in the list below.

•  The newer versions of the MOBILE model support 28 vehicle types instead of the 8 types
   listed in this document,  however, the NEI and other inventories often group these 28 types to
   the same 8 described in the document.
•  The web sites for SCCs, AP-42 emission factors, and more information about area-source
   inventories are out of date. These should be updated to the same sites as were listed in the
   point sources section above.
•  The EPA Office of Mobile Sources is now called the Office of Transportation and Air Quality
   (OTAQ). Its website is http://www.epa.gov/otaq/index.htm.
•  The new website for the MOBILE model is http://www.epa.gov/otaq/mobile.htm.
•  The PARTS model is no longer used, because it has been superceded by the MOBILE model,
   starting with version 6 (MOBILE6).
•  The increased popularity of sport utility vehicles has continued, but may be affecting more
   than only the percentage of light duty gasoline vehicles.  Additionally, since MOBILE6
   includes  28 vehicle types, the increases in larger and heavier vehicles  can be more carefully
   accounted for using MOBILE6 than the EIIP projection document mentions.
•  Updates to the SMOKE model and other emissions models permit the temperature
   information used in MOBILE6 to come from the prognostic meteorological models (e.g.,
   MM5 and MCIP) that are used to prepare inputs to air quality models.
•  OTAQ has created the National Mobile Inventory Model, which drives both the MOBILE6
   model and the NONROAD model to create base-year and future-year  inventories.  Additional
   information on this tool is available at: http://www.epa.gov/otaq/nmim.htm.
•  The references in Table 4.1-1 are out of date and should be updated as follows:
         - MOBILE6 - is an operational model and can be used
             See http://www.epa.gov/otaq/mobile.htm
         - The PARTS model is no longer needed because MOBILE6 replaces it
         - The California mobile sources emissions page is now:
             http ://www. arb. ca. gov/msei/msei .htm
         - The EIIP mobile source document is now available at:
             http://www.epa.gov/ttn/chief/eiip/techreport/volume04/index.html
         - Emission Inventory Guidance documentation is now available at:
             http://www.epa.gov/ttn/chief/eidocs/eiguid/index.html

Additionally, the Economic Growth Analysis System (EGAS) contains VMT growth information
and can be used to grow VMT by SCC. This system is further described in the "Additional
resources" section below.

Nonroad mobile sources.
   Section 4 of the EIIP projections document provides details about projecting nonroad mobile
sources.  Several of the references or statements in that document are now out of date, as follows.
Additionally, several new capabilities are available, which also are included in the list below.
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•  As noted above for on-road sources, the Office of Mobile Sources has changed to the Office
   of Transportation and Air Quality and has a different web site.
•  The EPA's NONROAD model has been completed and has been used in a variety of ways by
   EPA, states, and local agencies.  The website for the NONRO AD model is:
        http://www.epa. gov/otaq/nonrdmdl .htm
•  California's OFFROAD model website is now:
        http://www.arb.ca.gov/msei/off-road/updates.htm
•  OTAQ has created the National Mobile Inventory Model, which drives both the MOBILE6
   model and the NONRO AD model to create base-year and future-year inventories. Additional
   information on this tool is available at: http://www.epa.gov/otaq/nmim.htm.

Additional resources.
   In addition to sector-specific resources, there are other sources of information that can be used
for more than a single sector as information to help determine the most applicable growth rates
for the modeling region.  These include the Economic Growth Analysis System (EGAS), Bureau
of Economic Analysis data, Bureau of Labor Statistics "Employment Outlook", Census Bureau
data, Trade Organizations and individual facilities, and the Chemical Economics Handbook. The
following paragraphs provide a brief description and additional references for each of the sources
of data just listed.  Section 14.6.3 provides information about how to choose the best information
for a given  sector.

   Multiple sources of information can be used to better inform emissions modelers.  For
example, if a state and/or industry has show steady decreases in gross product over the past five
years, that information could temper (or be used in place of) a projected 30% growth predicted
from EGAS over the next 10 years.  Such a discrepancy would  simply highlight the fact that all
models, including REMI or those used by DOE can produce results that are not consistent with
other expectations. While this guidance does not provide a prescriptive approach for combining
such information, the authors recognize that predicting the future of emissions is not an exact
science and therefore multiple sources of information should be used to develop an informed
approach.

EGAS. The latest EGAS model at this time is version 5 (http://www.epa.gov/ttn/ecas/egas5.htm)
The default version of EGAS relies primarily on three sources of data: (1) state-specific economic
data from the Regional Economic Model, Inc. (REMI) Policy Insight ® model (version 5.5) that
includes population growth estimates, (2) Region-specific fuel-use projections from the U.S.
Department of Energy (DOE) Annual Energy Outlook 2004, and (3) VMT projections included in
the MOBILE6.0 model.  EGAS outputs growth factors that do not include control information for
a user-define base year and multiple future years through 2035. EGAS uses default cross-walks
from these data sources to SIC, SCC and MACT codes. The DOE data are used to compute
growth factors  assigned by default to stationary source fuel combustion sectors, the VMT
projections are used for on-road mobile, and the REMI data are used for the remaining sectors.
Additionally, EGAS5 supports emissions modelers adding new data sources, changing
assignments of data sources to SICs, SCCs, and MACT codes, and creating custom  configurations

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of data that best represent the growth expected in their modeling region. The additional sources
of information listed below can be input into EGAS to develop such custom scenarios. It should
be noted that these sources have very little, if any, projection information.  Instead, they provide
historical data that could be extrapolated to produce projections or to derive projections using
other methods.

   EGAS results should be assigned to the inventory to give the best mapping of the raw data to
the inventory.  Generally, SIC is the preferred cross-walk for point sources and SCC is the
preferred cross-walk for non-point sources.  However, the DOE-based fuel consumption forecasts
(assigned by SCC) can also be useful for some sectors that use fuel combustion.

Bureau of Economic Analysis. The Bureau of Economic Analysis (BEA) provides historical
data about macroeconomic factors at the state level such as gross state product, personal income
by industry, employment by industry, wages and earnings by industry, and population by state.
The website to obtain state and/or state-industry data is
http://www.bea.doc.gov/bea/regional/gsp/. Such information may be used to verify emissions
growth forecasts in EGAS by comparing available historical BEA data (1997-2004) with the
REMI economic activity data driving emissions in EGAS for the  same set of years. A good use
of the gross state product data is to verify growth in sectors/codes that use REMI output and
value-added data.  Additionally, employment and population statistics can be compared with
sectors/codes using REMI employment and population data.  The BEA also provides industry-
specific national information at http://www.bea.doc.gov/bea/dn2/home/annual_industry.htm.
However, since these data are at the national level, the use of the  data should be limited to
comparisons with national simulations in EGAS.

Bureau of Labor Statistics.  The Bureau of Labor Statistics (BLS) provides historical state-
specific and national employment data. The BLS database is fairly large and provides more detail
than needed for verifying the growth factors generated in EGAS using REMI employment data.
However, BLS employment data is likely to be as accurate if not more accurate than employee
data provided by BEA and US Census. The data are available at
http://www.bls.gov/sae/home.htm.

Census Bureau. The US Census Bureau provides data on total employees, total payroll, number
of establishments, and value of shipments by NAICS code (2 digit - 6 digit) for 1997 and 2002.
This database is ideal for examining changes in the number of establishments from 1997 - 2002.
However, it does not provide data from 1998-2001 so its trend information is limited to two
"snapshots".  Therefore, this data is useful primarily to evaluate the state/SCC and state/SIC
combinations from EGAS that show zero emissions growth, which indicates an assumption by
EGAS or its input data that those processes or industries do not exist in the state or region of
interest. The census data are available at
http://www.census.gOv/http://www.census.gov/econ/census02/guide/geosumm.htm.
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Trade Organizations and individual facilities.  Trade organizations can also be a helpful
resource because they often have projections for future-year growth of their industry and may be
aware of pending facility closures or new facility construction. This resources is most relevant
for large industrial sources that usually are included in point source inventories.  In addition,
emissions modelers should consider contacting large sources of emissions in their modeling
region for their expectations of emissions growth or reduction. In many cases, large industries
may be willing to provide such information when presented with what will be used if no
additional information can be provided. For these types of data sources, emissions modelers
should be aware of possible conflicts of interest, ie. industry groups or facilities may feel an
incentive to under-represent future-year emissions in hopes of avoiding additional requirements
for reducing emissions; however, many industrial representations have been valuable stakeholders
who are interested  in providing accurate information.

Chemical Economics Handbook. The Chemical Economics Handbook, produced by Access
International, Inc.,  is a series of reports on prices, production and consumption of hundreds of
chemical industry products and commodities. Past and current information on chemical products
and commodities is available, and projections of future prices, production and consumption are
often  available. Reports on specific industries are also available. Reports at an industry level can
often  be used to verify the efficacy of future industry modeling results.  Each report is updated
every 3 years. Projections, some up to 5 years from the current day, are often prepared using
proprietary methods. Reports are available by subscription, and can be  obtained as hard copy,
CD, or through the Internet at http://www.sriconsulting.com/CEH/Public/index.html.

         14.6.3   Evaluate and refine data for projections in modeling region

   For key sectors, emissions modelers should determine what information will impact the
projection results the most, and ensure that the data values reflect conditions or expectations  of
the modeling region. The key information is identified based on a combination of base-year
emissions data and growth and control rates. An iterative process is helpful to complete this  step,
as follows:

•  Estimate future-year emissions by combining the base-year emissions with the projection
   information.

•  Review future-year emissions data to identify large sectors of key pollutants (e.g. NOx and
   VOC). Emissions summaries by state/SCC or state/SIC can be helpful for this step to
   consolidate the data to review.

•  For the largest future-year emissions sectors, review the growth and control assumptions,
   compare among all available data sources, and/or collect additional information to refine the
   assumptions. A representative growth rate should be identified from the available data
   sources and all information known about the sources and sectors. Stakeholder review of the
   data can be helpful during this step;  for example, an industrial facility with large projected

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   emissions may be able to review the data and provide additional information for a more
   informed future-year emissions estimate.

•  Additionally, emission modelers should also compare the future-year emissions to base-year
   emissions to identify overall growth rates for industrial sectors and reconsider excessively
   high growth rates, especially when associated with significant emissions.

•   Using the new information, repeat step 1 and continue these steps until a satisfactory future-
   year projection across the entire inventory has been completed.

   Emissions models (e.g., SMOKE, MOBILE6, NONROAD, etc.) provide the capability to
create future-year inventories using base year inventories and projection information. Emissions
modelers will need to convert the projection data into specific formats for input to these models.
Prior to starting this step, emissions modelers should determine which emissions model will be
used to perform the calculations and make sure that the type of information needed by the model
is being collected.

         14.6.4  Create future-year inventories and air quality model inputs

   Using the final projection data determined in the previous step, create the final inputs to
emissions models being used. Then, use the emissions model to create the future-year inventory.
Other inputs to  emissions models, such as spatial surrogates, speciation profiles, or temporal
allocation factors may also be adjusted to reflect conditions expected in the future.

   Once a future-year inventory and other data have been created, it must undergo the same steps
as for the base-year modeling, such as temporal allocation, speciation, spatial allocation, elevated
source selection, special on-road mobile processing, and quality assurance. Every attempt should
be made to use  consistent approaches between the future year and the base year for all of these
modeling steps. Inconsistencies in approaches between the future-year modeling and the base-
year modeling can lead to artificial differences in air quality modeling results that can affect
conclusions.  Therefore, it is critical to avoid such differences whenever possible.
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15.0   What are the Procedures for Evaluating Model Performance and
        What is the Role of Diagnostic Analyses?

   The results of a model performance evaluation should be considered prior to using modeling
to support an attainment demonstration.  The performance of an air quality model can be
evaluated in two ways: (1) how well is the model able to replicate observed concentrations of
ozone and/or precursors (surface and aloft), and (2) how accurate is the model in characterizing
sensitivity of ozone to changes in emissions?  The first type of evaluation can be broadly
classified as an "operational evaluation" while the second type of evaluation can be classified as a
"diagnostic evaluation".  The modeled attainment test recommended in Section 3 uses models to
predict the response of ozone to controls and then applies the resulting relative reduction factors
to observed (rather than modeled) ozone. Thus, while historically, most of the effort has focused
on the operational evaluation, the relative attainment test makes the diagnostic evaluation even
more important.

   In addition to the  model performance evaluation, diagnostic analyses are potentially useful to
better understand whether or not the predictions are plausible.  Diagnostic analyses may also be
able  to provide: (1) information which helps prioritize efforts to improve and refine model inputs,
(2) insight into which control strategies may be the most effective for meeting the ozone NAAQS,
and (3) an indication  of the  "robustness" of a control strategy.  That is, diagnostic tests may help
determine whether the same conclusions would be reached regarding the adequacy of a strategy if
alternative, plausible, assumptions were made in applying the model for the attainment test.

   In this section, we first identify and discuss methods which may be useful for evaluating
model performance. It is recommended that performance be assessed by considering a variety of
methods. The section concludes by identifying several potentially useful diagnostic tests which
States/Tribes should consider at various stages of the modeling analysis to increase the
confidence in the model predictions of future ozone levels.

   15.1      What  are the Procedures for Evaluating An Air Quality Model?

   As noted above, model performance can be assessed in one of two broad ways: how
accurately does the model predict observed  concentrations for specific cases, and how accurately
does the model predict responses of predicted air quality to changes in inputs (e.g. relative
reduction factors)? Given existing data bases, nearly all analyses have addressed the first type of
performance evaluation. The underlying rationale is that if we are able to correctly characterize
changes in concentrations accompanying a variety of meteorological conditions, this gives us
some confidence that we can correctly characterize future concentrations under similar
conditions. Typically, this type of operational evaluation is comprised principally of statistical
assessments of model versus observed pairs. Operational evaluations are generally accompanied
by graphical and other qualitative descriptions of the model's ability to replicate historical air
quality patterns. The robustness of an operational evaluation is directly proportional to the
amount and quality of the ambient data available  for comparison. For the 8-hour ozone modeling,

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States/Tribes should compare all 1-hour observations and predictions (above a certain threshold),
as well as all observed and predicted 8-hour daily maxima.  Generally, if model performance is
acceptable for the hourly pairs, one would expect the 8-hour performance to be acceptable as
well.

   The second type of model performance assessment, a diagnostic evaluation, can be made in
several ways. One way to evaluate the response of the model is to examine predicted and
observed ratios of "indicator species".  If ratios of observed indicator species are very high or
very low, they  provide a sense of whether further ozone production at the monitored location is
likely to be limited by availability of NOx or VOC (Sillman, 1995).  Agreement between paired
observed and predicted high (low) ratios suggests a model may correctly predict sensitivity of
ozone at the monitored locations to emission control strategies.  Thus, the use of indicator species
has the potential to evaluate models in a way which is most closely related to how they  will be
used in attainment demonstrations. A second way for assessing a model's performance in
predicting sensitivity of ozone to changes in emissions is to compare model projections after the
fact with observed trends. Retrospective  analyses provide potentially useful means for
diagnosing why a strategy did or did not work as expected.  They also provide an important
opportunity to  evaluate model performance in a way which is closely related to how models are
used to support an attainment demonstration. More types of diagnostic analyses are provided in
Section 15.3. We recommend that diagnostic analyses be performed during the initial phase of
the model application and during any mid-course review.

   15.2       How Should the Operational Evaluation of Performance Be Completed?

   This section describes the recommended statistical measures and other analytical techniques
which should be considered as part of an operational evaluation of ozone model performance.
Note that model predictions from the ramp-up days should be excluded from the analysis of
model performance.  It is recommended that, at a minimum, the following three statistical
measures be calculated for hourly ozone and 8-hourly maxima over the episode days in an
attainment demonstration.

•  Mean Normalized Bias (MNB): This performance statistic averages the model/observation
   residual, paired in time, normalized by observation, over all  monitor times/locations. A value
   of zero would indicate that the model  over predictions and model under predictions exactly
   cancel each other out.  The calculation of this measure is shown in Equation 15.1.

•  Mean Normalized Gross Error (MNGE):  This performance statistic averages the absolute
   value of the model/observation residual, paired in time, normalized by observation,  over all
   monitor times/locations. A value of zero would indicate that the model exactly matches the
   observed values at all  points in space/time.  The calculation  of this measure is shown in
   Equation 15.2.

•  Average Peak Prediction Bias and Error:  These are measures of model performance that

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   assesses only the ability of the model to predict daily peak 1-hour and 8-hour ozone.  They are
   calculated essentially the same as the mean normalized bias and error (Equation 15.1 and
   15.2), except that they only consider daily maxima data (predicted versus observed) at each
   monitoring location. In the attainment test, models are used to calculate relative reduction
   factors near monitoring sites by taking the ratio of the average 8-hour daily maximum
   concentrations calculated for the future and current cases.  Thus, the model's ability to predict
   observed mean 8-hour daily maxima is an important indicator of model performance.

Equation 15.1

  MNB   =   iU(Model-Obs)Vloo%
                   i\       Obs       /
Equation 15.2
   MNGE   =   ;yf^^i].ioo%
                     71      Obs

   EPA recommends that the three metrics above be calculated two ways: 1) for pairs in which
the 1-hour or 8-hour observed concentrations are greater than 60 ppb41, and 2) for all pairs (no
threshold)42.  This will help to focus the evaluation on the models ability to predict NAAQS-
relevant ozone and minimize the effects of the normalization. In terms of pairing  model
predictions with monitored observations, EPA recommends that the grid cell value in which the
monitor resides be used for the calculations. It would also be acceptable to consider bi-linear
interpolation of model predictions to specific monitoring locations43.  States/Tribes should
       41 Past ozone modeling applications have used a minimum cutoff of either 40 ppb or 60
 ppb.  Due to the interest in predicted ozone concentrations at or above the 8-hour standard (85
 ppb), the higher cut off (60 ppb) is recommended.

       42 The use of a 0 ppb threshold can add valuable information about the ability of the
 model to simulate a wide range of conditions. Because of the tendency of the MNB and MNGE
 metrics to inflate the importance of biases at the lowest observed values (which are in the
 denominator), it is recommended that the alternate metrics of normalized mean bias (NMB) and
 normalized mean gross error (NMGE) be used as substitutes for evaluations with no minimum
 threshold.

       43In certain instances, States/Tribes may also want to conduct performance evaluations
 using the "near the monitor" grid cell arrays. A "near the monitor" analysis may be useful when

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recognize that, even in the case of perfect model performance, model-observed residuals are
unlikely to result in exact matches due to differences between the model predictions which are
volume averages and the observations which are point values.

   The statistics should initially be calculated for individual days (averaged over all sites) and
individual sites (averaged over all days). As appropriate, States/Tribes should then aggregate the
raw statistical results into meaningful groups of subregions or subperiods.

   Other statistics such as normalized mean bias, normalized mean gross error, fractional bias,
fractional error, root mean square error, and correlation coefficients should also be calculated to
the extent that they provide meaningful information (see Appendix A for definitions). Wherever
possible, these types of performance measures should also be calculated for ozone precursors and
related gas-phase oxidants (NOx, NOy, CO, HNO3, H2O2, VOCs and VOC species, etc.) and
ozone (and precursors) aloft.

   Along with the statistical measures, EPA recommends that the following four sets of graphical
displays be prepared and included as part of the performance analysis.

•  Time series plots of model and predicted hourly ozone for each monitoring location in the
   nonattainment area, as well as key sites outside of the nonattainment area.  These plots can
   indicate if there are particular times of day or days of the week when the model  performs
   especially poorly.

•  Scatter plots of predicted and observed ozone at each site within the nonattainment area
   (and/or an appropriate subregion). These plots should be completed using:  a) all hours within
   the modeling period for hourly ozone, and b) all 8-hour daily maxima within the modeling
   period.  It may also be useful to develop separate plots for individual time periods or key
   subregions. These plots are useful for indicating if there is a particular part of the distribution
   of observations that is poorly represented by the model44.

•  Daily tile plots of predicted ozone across the modeling domain with the  actual observations  as
   an overlay.  Plots should be completed for both daily  1-hour maxima and daily 8-hour
   maxima. These plots can reveal locations where the model performs poorly.  Superimposing
 strong ozone gradients are observed, such as in the presence of a sea breeze or in strongly
 oxidant limited conditions.  Furthermore, a "near the monitor" performance evaluation is
 consistant with the RRF methodology.

        44Quantile-quantile (Q-Q) plots may also provide additional information with regards to
 the distribution of the observations vs. predictions. But due to the fact that Q-Q  plots are not
 paired in time, they may not always provide useful information.  Care should be taken in
 interpreting the results.

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   observed hourly or daily maximum concentrations on the predicted isopleths reveals useful
   information on the spatial alignment of predicted and observed plumes.

   Animations of predicted hourly ozone concentrations for all episode days or for certain
   periods of interest. Animations are useful for examining the timing and location of ozone
   formation. Animations may also reveal transport patterns (especially when looking at ozone
   aloft).
    15.3       What Types of Analyses Can be Done to Evaluate the Accuracy of the Model
              Response: Diagnostic Evaluations?

    This section lists possible analyses that could be performed to investigate the ability of the
model to accurately forecast changes in ozone resulting from changes in ozone precursor
emissions.  States/Tribes are encouraged to complete as many of these types of analyses as
possible, in order to increase confidence in the modeled attainment projections.

    Observational models: In Section 5 it was noted that measurements of certain "indicator
species ratios" are a potentially useful way to assess whether local ozone formation is VOC- or
NOx-limited at any particular point in space  and time.  A performance evaluation which includes
comparisons between modeled and observed ratios of indicator species (e.g., O3/NOy, O3/HNO3)
can help reveal whether the model is correctly predicting the sensitivity of ozone to VOC and/or
NOx controls (Sillman, 1995 and 1998)  and  (Sillman,  1997 and 2002).  If a model accurately
predicts observed ratios of indicator species, then one can conclude with additional confidence
that the predicted change in ozone may be accurate. One precaution with respect to the use of
indicator species is that there may be a range of observed ratios for which the preferred direction
of control is not clear. When this occurs, agreement between predictions and observations does
not necessarily imply that the response to controls, as predicted by the model is correct. A second
precaution is that application of this method  often requires more measurements than are
commonly made. Despite these precautions, comparing  predicted and observed ratios of indicator
species provides a means of assessing a model's ability to accurately characterize the sensitivity
of predicted ozone to changes  in precursors.

    Other observational methodologies exist and can be used in a similar manner. The Smog
Production (SP) algorithm is another means by which ambient data can be used to assess areas
that are NOx or VOC-limited (Blanchard et al., 1999). Additionally, it has been postulated that
differences in weekend-weekday  ozone patterns may also provide real-world information on
which precursors are most responsible for ozone formation in any given area (Heuss et al., 2003).
In areas where there are large differences between average weekend and weekday ambient ozone
concentrations over the span of several seasons, it would be useful to compare statistical model

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performance for weekends versus weekdays.  This would allow one to assess whether the model
is capturing the effect of the emissions differences which are presumably driving the real-world
concentration differences.  This technique is not recommended if: 1) the number of days modeled
is too few to result in an appropriate sample size of days, 2) there is no clear difference between
ozone observations on the weekend versus weekdays, and/or 3) it is not possible to attribute
differences in weekend/weekday differences to emissions differences. Despite these reservations
associated with all of the various observational modeling approaches, these techniques allow one
to evaluate the ability of the model to accurately predict changes in ozone concentrations.
States/Tribes should include these comparisons in their efforts to evaluate model performance,
whenever feasible.

   Probing Tools:  Recently, techniques have been developed to embed procedures within the
code of an air quality model which enable users to assess the contributions of specific source
categories or of specific geographic regions to predicted  ozone at specified  sites (Zhang et al.,
2003). Various techniques have been implemented into various air quality models, but three of
the most commonly used probing tools are photochemical source apportionment (Environ, 2004),
the direct decoupled method (DDM) (Dunker, 1980 and  1981), (Environ, 2004) and process
analysis (Jeffries, 1994 and 1997); (Jeffries, 1996); (Jang, 1995); (Lo, 1997). In the context of
model performance evaluation, these attribution procedures are useful in that they allow one to
"track" the importance of various emissions categories or phenomena contributing to predicted
ozone at a given location. This can provide valuable insight into whether the model is adequately
representing the conceptual description of ozone patterns in the nonattainment area. In the cases
where model performance is subpar, these analyses can be useful for indicating where model
input or model algorithm improvements are most needed.

   Retrospective Analyses: A retrospective analysis is intended to examine the ability of the
model to respond to emissions changes by comparing recent trends in observed ozone
concentrations to the model-predicted trend over the same time period. As part of this analysis
the model is run for current episodes and episodes in one or more historical time periods using the
emissions and meteorological inputs appropriate for each time period modeled.  While
retrospective analyses may be useful, it may be difficult to obtain meteorological and emissions
inputs for the historical time period(s) that are calculated using techniques and assumptions which
are consistent with the calculation of these same inputs for the current time  period. Using
inconsistent inputs will confound the interpretation of the predicted trend. In Section 5, we noted
that a retrospective analysis can be a useful tool for diagnosing why an areas has not attained the
NAAQS. To that end, it is recommended that States/Tribes archive all modeling files and
document assumptions and procedures used for calculating model inputs in order to facilitate
replications of the modeled analyses at future dates.

   Alternative Base Cases: In some cases it may be useful to evaluate how the response of the
model to emissions reductions varies as a function of alternative model inputs or model
algorithms. These types of tests can be used to assess the robustness of a control strategy.  As an
example, States/Tribes could consider the effects of assumed boundary conditions on predicted

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effectiveness of a control strategy.  If the model response does not differ greatly over a variety of
alternative plausible configurations, this increases confidence in the model results. The
parameters for  sensitivity tests can include, but are not limited to:  different chemical
mechanisms, finer or coarser grid resolution, meteorological inputs from alternative, credible
meteorological  model(s), different initial/boundary conditions, and multiple sets of reasonable
emission projections.  Sensitivity tests can and should be applied throughout the modeling
process, not just when model performance is being evaluated. In cases where the operational
model performance is considered to be poor, these tests may help indicate where base case
input/algorithm changes are warranted.
    15.4       How Should the Results of the Model Evaluation be Assessed?

    In EPA guidance for the 1-hour ozone attainment demonstrations (U.S. EPA, 199la), several
statistical goals were identified for operational model performance.  These goals were identified
by assessing past modeling applications of ozone models and determining common ranges of
bias, error, and accuracy (Tesche et al., 1990).  The 1-hour guidance noted that because of
differences in the quality of the applications considered, it was inappropriate to establish "rigid
criterion for model acceptance or rejection" (i.e., no pass/fail test).  It was recommended that
these ranges should be used in conjunction with the additional qualitative procedures to assess
overall model performance.45

    With the additional experience of another decade of photochemical modeling, it is clear that
there is no single definitive test for evaluating model performance. All of the tests identified in
Sections 15.2 and 15.3 have strengths and weaknesses. Further, even within a single performance
test, it is not appropriate to assign "bright line" criteria that distinguish between adequate and
inadequate model performance.  In this regard, EPA recommends that a "weight of evidence"
approach (like that described in Section 4) be used to determine whether a particular modeling
application is valid for assessing the future attainment status of an area. EPA recommends that
States/Tribes undertake a variety of performance tests and weigh them qualitatively to assess
model performance.  Provided suitable data bases are available, greater weight should be given to
those tests which assess the model capabilities most closely related to how the model is used in
the modeled attainment test.  Generally, additional confidence should be attributed to model base
case applications in which a variety of the tests described above are applied and the results
indicate that the model is performing well.  From an operational standpoint, EPA recommends
that States/Tribes compare their evaluation results against similar modeling exercises to ensure
that the model performance approximates the quality of other applications.
        45 In practice, however, most 1-hour ozone modeling applications using the 1991
 guidance tended to focus almost entirely on meeting the three statistical "goals" for bias, error,
 and accuracy at the expense of more diagnostic evaluation.

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U.S. EPA, (1994a), Office of Transportation and Air Quality (OTAQ),
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U.S. EPA, (1994b), "Guidance on Urban Airshed Model (UAM) Reporting Requirements for
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U.S. EPA, (1996c), "Guidance on Use of Modeled Results to Demonstrate Attainment of the
   Ozone NAAQS",   http://www.epa.gov/ttn/scram/guidance_sip.htm, EPA-454/B-95-007.

U.S. EPA, (1997), "EIIP Volume I, Introduction and Use of EIIP Guidance for Emission
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U.S. EPA, (1998a), "EPA Third-Generation Air Quality Modeling System, Models-3 Volume 9b
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U.S EPA, (1998b)"Finding of Significant Contribution and Rulemaking for Certain States in the
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   of Ozone; Final Rule," 63 FR 57,356 (October 27, 1998).
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U.S. EPA, (1998c), "Implementation Plan PM25 Monitoring Program",
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U.S. EPA, (1999a), "Draft Guidance on the Use of Models and Other Analyses in Attainment
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U.S. EPA, (1999c), "Guidance on the Reasonably Available Control Measures (RACM)
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U.S. EPA, (2005c), "Emission Inventory Guidance For Implementation Of Ozone And Particulate
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Glossary

Modeled attainment demonstration - A modeled attainment demonstration consists of two
parts: an analysis estimating emission levels consistent with attainment of the NAAQS, and a list
of measures that will lead to the desired emission levels once growth is accounted for. The first
(analysis) part consists of a modeled attainment test. It may also include an additional screening
analysis and a review of a diverse set of model outputs and emissions, air quality and
meteorological data for consideration in a weight of evidence determination to assess whether
attainment of the NAAQS is likely with the proposed control strategy.

Modeled attainment test - This test takes the ratio of mean predicted future and current 8-hour
daily maximum ozone concentrations averaged over several days and multiplies this ratio times
the site-specific monitored design value at each monitoring location.  If the product is < 84 ppb
near all monitoring sites, the test is passed.

Modeling system - This is a group of models used to predict ambient ozone concentrations.
The group includes an emissions model which converts countywide emission information into
gridded speciated emissions which vary diurnally and reflect environmental conditions. It also
includes a meteorological model which provides gridded meteorological  outputs and an air
chemistry/deposition model which takes information provided by the emissions and
meteorological models and uses it to develop gridded predictions of hourly pollutant
concentrations.

Relative reduction factor (RRF)  - The ratio of predicted 8-hour daily maximum ozone
averaged over multiple days near a monitoring site with future emissions to corresponding
predictions obtained with current emissions.

Unmonitored Area Analysis - An analysis used to ensure that a proposed control strategy will
be effective in reducing ozone at locations without air quality monitors so that attainment is
shown throughout a nonattainment area. The purpose of the analysis is to use a combination of
model output and ambient data to identify areas that might exceed the NAAQS if monitors were
located there.

Weight of evidence determination (WOE) - This is a set of diverse analyses used to judge
whether attainment of the NAAQS is likely. The credibility of each analysis is assessed and an
outcome consistent with an hypothesis that the NAAQS will be met is identified beforehand. If
the set of outcomes, on balance, is consistent with attainment, then the WOE can be used to
show attainment. A weight of evidence determination includes results from the modeled
attainment test, the unmonitored area analysis, other model outputs and several recommended
analyses of air quality, emissions and meteorological data.
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APPENDIX A

Below are the definitions of model performance statistics suggested as part of this ozone
modeling guidance.

Mean Observation: The time-average mean observed value (in ppb)

               N
               y
            •» -r  £^
           N i=
   OBS  =  —    Obs'
            • -
Mean Prediction: The time-average mean predicted value (in ppb) paired in time and space
with the observations.

            1   N
  PRED  =  —  y Pred'
            f. Y  £-t     X. I
           N t=i
Ratio of the Means: Ratio of the predicted over the observed values. A ratio of greater than 1
indicates on overprediction and a ratio of less than 1 indicates an underprediction.

            1  N  Pred'
   RATIO= — y  	^~
           Nit-i
Mean Bias (ppb):  This performance statistic averages the difference (model - observed) over
all pairs in which the observed values were greater than zero. A mean bias of zero indicates that
the model over predictions and model under predictions exactly cancel each other out. Note that
the model bias is defined such that positive values indicate that the model prediction exceeds the
observation, whereas negative values indicate an underestimate of observations by the model.
This model performance estimate is used to make statements about the absolute or unnormalized
bias in the model simulation.
   BIAS=
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Normalized Mean Bias (percent): This statistic averages the difference (model - observed)
over the sum of observed values.  Normalized mean bias is a useful model performance indicator
because it avoids over inflating the observed range of values.

   NMB =  — -  * 1

                 E
Mean Fractional Bias (percent): Normalized bias can become very large when a minimum
threshold is not used. Fractional bias is used as a substitute. The fractional bias for cases with
factors of 2 under- and over-prediction are -67 and + 67 percent, respectively (as opposed to -50
and +100 percent, when using normalized bias). Fractional bias is a useful indicator because it
has the advantage of equally weighting positive and negative bias estimates. The single largest
disadvantage is that the predicted concentration is found in both the numerator and denominator.

              2   N  (Predlxt -
   FBIAS =  —  y	—
             N f-i
Mean Error (ppb): This performance statistic averages the absolute value of the difference
(model - observed) over all pairs in which the observed values are greater than zero.  It is similar
to mean bias except that the absolute value of the difference is used so that the error is always
positive.

            l^i
   ERR =  —  \- Predlt -  Obs't
           N £
Normalized Mean Error (percent):  This performance statistic is used to normalize the mean
error relative to the observations. This statistic averages the difference (model - observed) over
the sum of observed values. Normalized mean error is a useful model performance indicator
because it avoids over inflating the observed range of values.
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   NME =
                \Predlt  -
                 E
Mean Fractional Error (percent):  Normalized error can become very large when a minimum
threshold is not used. Therefore fractional error is used as a substitute. It is similar to the
fractional bias except the absolute value of the difference is used so that the error is always
positive.
                   N
   FERROR  =  —  E
               N ••= i   Pm/^ +  Ofe^
Correlation Coefficient (R2):  This performance statistic measures the degree to which two
variables are linearly related. A correlation coefficient of 1 indicates a perfect linear
relationship; whereas a correlation coefficient of 0 means that there is no linear relationship
between the variables.
                         N
                         E (Predi
   CORRCOEFF =
                         i=\
                       N
                     \
                       E  (fredi -  P
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United States                              Office of Air Quality Planning and Standards                        Publication No. EPA-454/R-05-002
Environmental Protection                    Emissions, Monitoring and Analysis Division                       October 2005
Agency                                   Research Triangle Park, NC
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