This is a preliminary document prepared by a subgroup member 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. This document has not been reviewed by the work group and is subject to further work group discussions. The issues and options for this topic are still being developed by members of the subgroup. No effort has been made to develop recommendations.

Reasonable Further Progress

Strawman Customized Process

Date: March 27, 1997

Status: The attached strawman process has been discussed by the RFP Issue Paper Subgroup but the group has not achieved concensus on the process nor have the divergences been fully identified by stakeholder group. This process is being made available for information purposes only to give a sense of the discussion. One of the areas that has taken a great deal of discussion time is the situation where attainment of the NAAQS is deemed to be difficult with currently available, cost-effective control measures. We anticipate that a smaller group will be developing a process for addressing this situation.

Contact: Sarah Peirce-Sandner, Telephone 716-588-6477, FAX 716-722-3695

RFP GOALS	draft 3/26/97

Emissions

Air Quality

Administrative

DETERMINE CAUSE OF SUCCESS OF MEETING AIR QUALITY GOALS:

LINE SCENARIO NEXT STEPS GO TO DIAGRAM Emission reduction goals were-- (a)	-- Achieved because of implementation of controls Continue implementation. A (a)	-- Achieved due to economic downturn, decreasing emissions but area failed to implement control strategy. Penalty (Rewards and Sanctions paper to address). Continue implementation of current measures (catch up); implement next set of measures. If economic downturn permanent, may be able to avoid penalty. A, B (b)	-- Not achieved due to failure to implement control strategy but--	--Model overpredicted concentrations & emission reductions needed Penalty (Rewards and Sanctions paper to address). Continue implementation of current measures (catch up); implement next set of measures; reevaluate model & control strategy & revise if necessary A, B	--Favorable meteorology occurred Penalty (Rewards and Sanctions paper to address). Continue implementation of current measures (catch up); implement next set of measures. A (b)	-- Not achieved due to--	--Strategy was implemented but did not yield all anticipated reductions No penalty.* Continue implementation of current & next set of measures; reevaluate model & inputs & control strategy & revise if necessary A, B	--Strategy was implemented but growth increased emissions No penalty.* Continue implementation of current & next set of measures; reevaluate inputs & control strategy & revise if necessary A, B Administrative goals (a)	--Were achieved Continue implementation. A (b)	--Were not achieved Penalty (Rewards and Sanctions paper to address). Continue implementation of current measures (catch up); implement next set of measures A

DETERMINE CAUSE OF FAILURE TO MEET AIR QUALITY GOALS:

LINE SCENARIO NEXT STEPS GO TO DIAGRAM Emission reduction goals were-- (c)	-- Not achieved due to failure to implement control strategy

Penalty (Rewards and Sanctions paper to address). Catch up on implementation of current measures & implement next set of measures; implement continency measures A (c)	-- Not achieved due to--	-- Strategy was implemented but did not yield all anticipated reductions No penalty.* Continue implementation of current & next set of measures; do mid-course correction; reevaluate model & inputs & control strategy & revise if necessary; implement contingency measures A, B	-- Strategy was implemented but growth increased emissions No penalty.* Continue implementation of current & next set of measures; do mid-course correction; reevaluate inputs & control strategy & revise if necessary; implement contingency measures A, B (d)	-- Emission reduction goals achieved but--	--Model underpredicted concentrations & emission reductions needed No penalty.* Continue implementation of current & next set of measures; do mid-course correction; reevaluate model, inputs & control strategy & revise if necessary; implement contingency measures A, B	-- Unfavorable meteorology occurred No penalty. Continue implementation of current & next set of measures; do mid-course correction; reevaluate model, inputs & control strategy & revise if necessary; implement contingency measures

NOTE: If the Subgroup believes that this scenario--or some subscenario--should result in a complete exemption from futher action, then a change to EPA's Exceptional Events policy would be required. A, B	-- Economic downturn occurred, decreasing emissions Penalty (Rewards and Sanctions paper to address). Continue implementation of current measures (catch up); implement next set of measures. If economic downturn permanent, may be able to avoid penalty. A, B Administrative goals (d)	-- Were achieved Continue implementation, but do mid-course correction if failure to achieve an air quality goal were due to a final administrative goal. A, B (c)	-- Were not achieved Penalty (Rewards and Sanctions paper to address). Continue implementation of current measures (catch up); implement next set of measures A

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*Assuming good faith analytical processes were followed (i.e., no "gaming the system").