This is a preliminary document prepared by a subgroup of members of the National and Regional Strategies Work Group as part of the Federal Advisory Committee Act (FACA) Subcommittee process. It is not an EPA document. Interested people should forward their comments to a member of the National and Regional Strategies Work Group.

Regional Air Management Partnerships and Areas Of Influence

Date:	February 13, 1997

Contact:	Don Theiler, Wisconsin @ (608) 266-0603

Status:	Draft #9; Last discussed by N&RS work group on February 6, 1997.

Note: This paper is intended to supplement the Designation Issues for New NAAQS (7/25/96), the Institutional Mechanism for Development and Implementation of Regional Strategies (2/13/97), the How Should AOIs be Determined? (9/19/96), and the Update on the Area of Violation (AOV)/Area of Influence (AOI) Concepts (11/12/96) issue papers. Readers are encouraged to refer to these papers for National and Regional Strategies work group recommendations and more in-depth discussion concerning AOIs, AOVs, Regionally Integrated Plans (RIPs), and Regional Air Management Partnerships (RAMPs). A list of current acronyms is given in Attachment 1. The determination of AOVs will be discussed in another issue paper.

Introduction

A five-step planning process, which builds on concepts in the 2/13/97 Institutional Mechanism for Development and Implementation of Regional Strategies and the various AOI issue papers, was presented to the National and Regional Strategies and Base Programs Analyses and Policies work groups at January 31, 1997 meetings in Durham, North Carolina. Both work groups generally agreed on the terminology and the conceptual framework.

The five-step process for establishing RAMPs, identifying AOIs, and developing plans follows:

Step 1 - RAMP Formation

RAMPs will be identified and formed as soon as possible.

The formation of RAMPs will be undertaken by combining technical and political considerations in the identification of areas which have common air quality characteristics and share common air quality concerns. Technical considerations may include anticipated air quality and haze problems, meteorology, emission density, etc. Political considerations may include the existing institutional structures (e.g., WESTAR, LADCO, OTC) and the desires of individual states and tribes.

The Science and Technical Support work group is requested to work with EPA to identify the appropriate technical considerations and, utilizing these technical considerations, prepare some alternative RAMP configurations to initiate the process of RAMP identification.

Every state (tribe) (except Hawaii and Alaska) will be placed in a RAMP.

If a state (tribe) requests, it may be placed in more than one RAMP. No state (tribe) will be required to be in more than one RAMP.

The placement of a state or tribe in a RAMP does not require that state to participate in the activities of the RAMP. However, the RAMP will include all of the area within the RAMP in the work which it undertakes, and it may make recommendations and establish policies and procedures which affect the nonparticipating state or tribe.

Step 2 - Initial RAMP Activities

The reader should refer to the Institutional Mechanism for Development and Implementation of Regional Strategies issue paper for a detailed discussion of the RAMP activities and the pros and cons of the RAMP activities. The RAMP should begin operation as soon as possible.

The RAMP should undertake all activities which it deems is appropriate to:

a. identify Preliminary AOIs and

b. assist the states and tribes involved in the process of developing RIPs.

As examples these activities may include:

a. identification of possible AOVs and associated AOIs,

b. development of procedures for identifying the appropriate emission inventories,

c. identification of acceptable modeling protocols,

d. development of a system for establishing emission reduction credits, and

e. initiation of discussions concerning potential market based control systems within the RAMP.

Step 3 - Identification of Preliminary AOIs

Upon the designation of an AOV within the boundaries of the RAMP, that RAMP will have a short, predetermined period to identify a Preliminary AOI.

The identification of the Preliminary AOI will be undertaken following guidance provided by EPA. The guidance will include the technical procedures to be used in the identification process. The Science and Technical Support work group is requested to work with EPA to prepare this guidance document.

The RAMP may identify states or tribes outside of its area as a part of an AOI using the technical procedures identified with the guidance document.

A state or tribe within a RAMP may indicate that it will take sole responsibility for RIP development for one or more AOVs. In this instance the RAMP would have no further responsibility for AOI identification for these AOVs. This would devolve to the state or tribe. In this instance the RIP and SIP/TIP development would be consolidated into a single step.

If a RAMP fails to make a preliminary AOI identification within the prescribed time period, EPA must make this identification within weeks of the deadline.

Preliminary AOI identifications will be reviewed, approved, and/or modified by EPA.

There may be a need for complex Preliminary AOIs to be identified when the AOIs for different AOVs substantially overlap. The process for establishing complex Preliminary AOIs is yet to be developed. For example, a RAMP might choose to identify the entire RAMP area as the Preliminary AOI for Class I area regional haze planning.

Step 4 - Preparation of the RIP and SIP/TIP calls

The states and tribes identified in the Preliminary AOI will be responsible for the preparation of the RIP.

The RIP provides the basic information needed for EPA to issue a SIP/TIP call to the appropriate States and Tribes involved in the preparation of the RIP. The minimum elements of the RIP are identified in the attached list of term definitions.

In the absence of an approved RIP at the required deadline, EPA will move ahead to issue SIP/TIP calls based on the best information it has available at the time.

The RIP will identify the control region which, when finally approved by EPA, will constitute the Final AOI.

Step 5 - SIP/TIP Preparation

States and tribes prepare SIP/TIP to bring AOVs into attainment of standard by dates established in the regulations.

Time Table Assuming Promulgation of Standards in June 1997

Step 1 - RAMP Formations - by June 1998 or sooner (pending final rulemaking)

Step 2 - Initial RAMP Activities - by June 1998 - June 1999 (or upon formation of the RAMP)

Step 3 - Identification of Preliminary AOIs - by September 1999 (assuming AOV designation in June 1999)

Step 4 - RIP and Final AOI - by June 2001

Step 5 - SIP/TIP - by June 2003

Preliminary List of Issues to be Developed

1. Timing and Legal Authority for RAMPs/AOIs

2. Decision Making Process for RAMP's and AOI's

3. Process for identifying complex AOIs

4. NSR and RFP during period of RIP preparation and after Final AOI has been identified.

5. Timing of rebuttal presumption for AOV being part of AOI's

6. How will maintenance of the standard relate to AOIs and reasonable progress toward the national visibility goals.

7. How nonattainment provisions of the current clean air act will integrate into the RAMP/AOI/AOV process

8. Coordination on technical tools and databases (guidance to be developed by the Science and Technical Support work group).

9. Legal status of RIP

Attachment 1

DEFINITION OF TERMS

Area of Influence (AOI) - An AOI is a geographical area containing anthropogenic and natural sources which contribute to Areas of Violation (AOV). The identification of AOIs is divided into two phases:

Phase 1 - Preliminary AOI - The Preliminary AOI is the area which contains an adequate array of sources to prepare a Regionally Integrated Plan (RIP). Inclusion within a Preliminary AOI does not mean that a location will necessarily be subject to regulation.

Phase 2 - Final AOI - The Final AOI is the area in which regulatory control of emissions will be needed to bring an AOV back into attainment and ensure maintenance of the standards. The Final AOI is synonymous with a control region.

Area of Violation (AOV) - The AOV is the area which is determined to be violating the NAAQS. Class I areas will be treated in the same manner as AOV's for the purposes of defining AOI's and developing plans. Contrary to the current nonattainment designation process, an AOV is not necessarily assumed to be responsible for the observed violation. Thus, designation of an AOV does not carry with it automatic control requirements for the designated area, as is currently the case for a nonattainment area. However, the initial presumption is that the AOV will be a part of the preliminary AOI and final AOI. This presumption can be rebutted only upon a clear and convincing demonstration that anthropogenic sources in the AOV are not contributing to the violations being experienced. (Process for making the demonstration to be defined later).

Control Region - A control region (CR) is an area within an AOI for which emission reductions of PM, its precursors and/or precursors of ozone are deemed necessary to meet the NAAQS/RH Rule. Controls are not necessarily applied uniformly across the CR. (A CR may be associated with one or more proximate areas of violation and Class I areas included with the AOI.) The control region is synonymous with the final AOI's.

Control Target - A control target is the amount of reduction and/or the emissions budget estimated as necessary in a control region to be consistent with an identified cohesive strategy for meeting PM and ozone NAAQS in areas of violation. The target can be a reduction relative to an agreed upon base level of emissions or it can be in the form of an emissions cap.

Regional Air Management Partnerships (RAMP) - Contiguous multi-state areas which have common air quality characteristics and share common air quality concerns. The RAMP will have the responsibility to undertake appropriate air quality analysis needed to identify the Preliminary Area of Influence. There are numerous options for the number and size of the RAMPs.

Regionally Integrated Plan (RIP) - This has been referred to as a "spatially integrated plan (SPIP)" in earlier versions of the FACA Regional Partnerships/AOI issue paper. A RIP is prepared for a preliminary AOI. A RIP will define:

•	the Final AOI/control region,

•	in general terms, what level of control should be applied in the various portions of the AOI,

•	where transportation conformity should apply,

•	the structure and type of market-based incentives programs (where appropriate)

•	New Source control recommendations, and

•	other elements as appropriate.

The RIP is a set of recommendations to EPA and is to serve as the basis upon which EPA can develop SIP and TIP calls to the individual states and tribes. The RIP is not enforceable on its face. The RIP may also contain recommendations to EPA for action at the national or subnational level.

State Implementation Plan (SIP) - A State implementation plan is a plan submitted by individual States to reduce emissions consistently with the regionally integrated plan. It contains specific measures and identifies mechanisms by which the measures are enforceable by that State.

Tribal Implementation Plan (TIP) - A tribal implementation plan is a plan submitted by individual tribes to reduce emissions consistently with the regionally integrated plan. It contains specific measures and identifies mechanisms by which the measures are enforceable by that tribe.