Reasonable Further Progress Issue Paper

Table of Contents

Section	Page

Introduction	1

Background	2

Links to Other Issue Papers	3

SIP-Phase Issue -- How Should RFP be Defined?	4

Issue 1	Should RFP emission reduction requirements (i.e., type and quantity of reductions predicted necessary to achieve attainment) be standardized nationwide or customized at the AOI/AOV level?	4

Issue 2	What is the range of options for the RFP metric?	6

Issue 3	How frequently should Reasonable Further Progress be demonstrated?	8

Issue 4	What is the base year for RFP?	9

Issue 5	What would be the rate of RFP -- that is, what is the nature of the line or curve describing the path from nonattainment to attainment for an AOI/AOV?	12

Issue 6	How should end-loaded strategies be handled in RFP? Specifically, how much emission reductions required for attainment may be end-loaded strategies?	14

Issue 7	What is the corrective mechanism to get an area back on-track when the area has failed an RFP milestone?	15

Issue 8	Can emission reduction measures that are not fully enforceable, quantifiable or permanent be credited towards the RFP emission reduction metric?	15

Issue 9	What parts of the RFP requirements for ozone and PM should be integrated with the reasonable progress (RP) requirements for Regional Haze?	17

Issue 10	Under what circumstances, if any should an area be allowed to avoid demonstrating attainment, and if so what will constitute RFP?	18

Issue 11	Who is responsible for performing next steps in the iterative RFP process when an interjurisdictional area fails an RFP metric?	20

Issue 12	Should RFP be specified for each source sector (mobile/area/major stationary sources)?	21

Issue 13	Should RFP be measured as seasonal or annual? (Should control measures be required on a seasonal, annual, or episodic basis?)	22

Issue 14	Can RFP include mandatory measures outside of Title I (e.g., national programs such as Titles II, III, and IV)?	23

Issue 15	Should there be specific procedures to determine if RFP has been achieved (David Baron, FACA)?	23

Issue 16	How does RFP relate to the secondary standards?	24

APPENDIX A	25

Attachment 1. Table 1. Summary of RFP Issues	26

Attachment 2. Table 2.	28

Attachment 3. Discussions and Principles for Issue 8	29

APPENDIX B	32

Attachment 1. Guidance Documents for RFP Requirements	33

Attachment 2. Underlying Principles/Assumptions of the Customized RFP Process	34

Attachment 3. Initial RFP Development Process	37

Attachment 4. Original list of options listed and discussed by the RFP work group for Issue 1	38

Attachment 5. Discussion for Issue 2 by the Subgroup	40

Attachment 6. Information Provided to the Science and Technical Support Work Group Related to the RFP Metric Issue	42

Attachment 7. Additional Discussion Material for Issue 10 Developed by One Industrial Stakeholder and One State Agency Stakeholder	48

Attachment 8. Background Information, Options, and a List of Principles for Issue 11	50

Attachment 9. Initial Options Discussed by Subgroup for Issue 13	53