EPA Ozone/PM/Haze FACA Subcommittee

Science and Technical Support Work Group

Position on

Attainment Dates Issue Paper

Issue:	What dates or time frames should be established for attaining new NAAQS?

BPAP Work Group Recommendation:

RFP approach with no defined attainment data and with increasingly more stringent controls for each successive planning cycle. BPAP favors 10-yr planning cycles, establishing RFP increments and minimum emissions reduction targets, considering modeling, monitoring, episode analysis, and cost/benefit as well as allowances for impacts of natural events. Eligibility for successive cycles should be based on achieving minimum emissions reductions and more stringent controls. Incentives for early reductions are encouraged. Mid-cycle and end-of-cycle evaluations required.

STSWG Comments:

Measurements of RFP should be based on what is scientifically measurable in some reasonable manner. Measuring RFP is very difficult. Traditional methods focusing on RFP in terms of emissions reductions have not proven meaningful. Using a variety of environmental indicators to measure RFP may be preferable to just focusing on ambient air quality monitors or emissions reductions.

Incentives for early reductions could be an integral part of an attainment strategy, but must be based on scientific evidence showing that the resultant reductions are equivalent to those expected from the normal SIP process. Both short and long term effects should be considered as well as potential tradeoffs inherent in an integrated approach.

There is a basic difficulty in defining "attainment" given that areas can be in attainment one year and not in attainment in another year, due to a variety of influences.

There is support for allowing an adequate amount of time for a reasonable planning period (up to 10 years in some cases) to allow the proper collection of relevant data and its analysis and use in appropriate modeling. There is also support for the concept of using data analyses and modeling as feedback for successive planning cycles.

There is concern that it may not be feasible for some areas to attain the NAAQS in the foreseeable future.