This document contains a list of issues developed in cooperation with members of the Base Programs Analyses and Policies FACA Work Group on which EPA solicits their advice and recommendations when implementing potential new NAAQS for ozone and particulate matter. It not intended to encompass every issue and will be updated periodically.

Base Programs Analyses and Policies

April 16, 1996

Revised Preliminary Prioritized Issues List

If the Environmental Protection Agency (EPA) proposes to revise current national ambient air quality standards (NAAQS) or promulgate new NAAQS for ozone and particulate matter and regulations for regional haze, the following characterize the most important classes of implementation issues in priority order that should be considered. In order to accommodate the two phases of implementation development within the FACA process, issues 1-4 will be addressed in phase I and issues 5-8 will be addressed in phase II.

1.	Designations for New NAAQS and Regional Haze Planning Areas

Areas are to be designated as attainment, nonattainment, or unclassifiable for a new or revised NAAQS after promulgation of such new or revised NAAQS. This requirement raises questions such as the following.

(a) What information should be used as a basis for designating areas and establishing regional haze planning areas?

(b) Will information be available within the time allowed? If not, would the unclassifiable designation be the appropriate designation?

(c) What sources of pollutants and precursors to fine particulate matter (PM-fine), ozone and regional haze formation should 1) be linked to sites with NAAQS violations and held responsible; and, 2) be included within the boundaries of nonattainment or control areas and regional haze planning areas? Can this be accomplished in the existing regulatory scheme? If not, what alternative approach could be developed and recommended while the monitoring data are developed to designate areas, e.g., the approach in Title IV?

(d) To what extent should the boundaries of NAAQS nonattainment areas and regional haze planning areas coincide? What approach could be used when the sources contributing to the problem are from broad areas that cannot be effectively identified? Can the nonattainment area approach be used in these circumstances?

(e) How can we create incentives to monitor air quality in order to gain a better scientific understanding of the pollutants and avoid the disincentives when NAAQS violations are measured? How can we create incentives for private sectors to form monitoring partnerships with EPA and States?

2.	Integration of NAAQS Implementation Programs

(a) Where does it make sense to follow the same criteria and policies when implementing the ozone, PM-fine and regional haze programs?

(b) Where and when does it not make sense to develop integrated ozone, PM-fine and regional haze programs?

3.	New Source Review

(a) What should be required of major new or modified sources that would contribute to violations of the new NAAQS or visibility impairment in Class I areas?

(b) Do existing requirements for new source review (NSR) need to be revisited under new NAAQS?

4.	Attainment Dates for New NAAQS

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

5.	Classifications

(a) Should classifications based on the severity of air quality above the NAAQS be used in conjunction with designations? If so, how should the classification system be modified?

(b) Will the current concept of attainment and nonattainment designations and classifications be workable under a regional scale approach? If not, what new approach can be used?

6.	Control Requirements

(a) What are the roles of mandatory versus voluntary control programs such as those found in the Clean Air Act for areas designated or contributing to nonattainment?

(b) What is the appropriate balance between local and regional responsibilities for providing emission reductions? How should the local emission reduction responsibility be established?

7.	Economic Incentives

What local programs or policies could provide economic incentives to reduce emissions of precursors to the formation of PM-fine, ozone and regional haze to benefit the broad regional problem?

8.	State Implementation Plan Requirements

(a) What should be required with respect to timing and the contents of emission inventories and budgets, control strategy attainment demonstrations, measures and rates of progress, contingency measures, pollution transport and treatment of areas affected by natural events?

(b) Does a regional concept render individual SIPs inappropriate or unnecessary, i.e., will all or part of the SIPs be replaced by regional plans?

(c) What is the response to local or regional SIP or progress failures such as failures to adopt and implement SIP measures or meet progress milestones? What is the role of SIP calls, sanctions, and Federal implementation plans?