This is a preliminary document prepared by a subgroup of the National and Regional Strategies (N&RS) work groups 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 work group.

Control Strategies

Date:	March 31, 1997

Contact:	Dan Johnson representing the NRSWG, 360/407-6872; fax: 360/407-6802

Status:	Preliminary Draft. Framing of issues from joint work group meeting (March 13 and 14, 1997), BPAP conference call (March 19, 1997), and NRS conference call (March 27, 1997).

Mission Statement

This paper will recommend a process to be used by the responsible air quality planning authority for allocation of control responsibilities among national, prescribed, and discretionary required measures. This issue paper will also attempt to produce a list of suggested national measures, and will attempt to produce a list of suggested prescribed measures, which the FACA Subcommittee should consider and potentially recommend to EPA.

Definitions

For the purpose of this issue paper the Control Strategies Subgroup will use the following definitions. It should be noted that both command and control programs and where appropriate incentive based programs shall be considered.

National Measures = Air quality improvement measures, Federally required nationwide, and applied without regard to air quality status.

Prescribed Measures = Air quality improvement measures, Federally required in a subnational area and applied with regard to air quality status.

Discretionary Measures = Federally enforceable air quality improvement measures, selected by the air quality regulatory authority, to be added to applicable National and Prescribed measures in a plan to achieve the air quality objectives.

Mandatory Reductions = The total Federally enforceable control program necessary in an area to achieve the air quality objectives.

Area(s) for Control = an area(s) within which emission source(s) will share, appropriately, in the responsibility to achieve an air quality objective (e.g., NAAQS, reasonable progress objective).

[Note: the control strategies subgroup used this more general definition for the concept of Area(s) for Control until they have had sufficient opportunity to discuss this issue with the other related issue paper subgroups. Resolution of the definition at this stage is not critical to the framing of this issue paper.]

Background [This section to be added later]

Principles and Working Assumptions [see following pages]

Questions that will be addressed by this issue paper:

1)	Should there be additional national measures or changes to the mix of those measures? If so, which measures should be adopted, and on what basis will the measures be determined (science, cost-effectiveness, achievability, public health, equity, input from the public, etc.)?

2)	Should there be minimum requirements imposed as additional prescribed measures common to some or all Area(s) for Control (e.g. final AOI, preliminary AOI, AOV, other subnational domains, or other domains)? If so, which measures should be adopted, where should they be applied, and on what basis will the measures be determined (science, cost-effectiveness, achievability, public health, equity, input from the public, etc.)?

3)	How should the order of implementation be determined?

4)	How should the situation be handled where national measures are not implemented, or are not timely? What is the consequence to the regulatory agency (e.g. sanctions)?

5)	For interstate, or State/tribal Area(s) for Control, what (if any) guidelines should be used by the responsible air quality planning authority in assessing the mix of controls?

6)	After answering each of the above questions, what implications are there for, or from, other issue papers?

Key Principles	[3/28/97 version]

This issue paper was prepared in accord with the "content related principles" adopted by the FACA Subcommittee. Principles that are key to the preparation of this issue paper include:

•	Progress toward attainment ... in an expeditious manner; no backsliding; early actions to improvement ... should be encouraged. [CRP #1, #5]

•	Control strategies should be effective in achieving air quality objectives, should be designed to accommodate flexible response methods by emission sources, and should encourage continuing improvements in air quality. To this end, the advantages, disadvantages, and available information on cost effectiveness of a full range of control methods should be presented, including technology-based performance standards, market-based approaches, and other traditional and nontraditional approaches. [CRP # 6]

•	All options/recommendations should provide for the use of best available, scientifically-based explanations to be used in planning requirements and control strategy development. Such options/recommendations should include methods to identify the role of nonlocal transport processes and mechanisms designed to address such processes. [CRP #7]

•	Opportunities for integration of planning and implementation for ozone, PM and haze that achieve better environmental results and lower cost should be fully pursued. [CRP #8]

•	Planning and implementation ... should include early and continued involvement of potentially affected interests ... must have a timeline for completion ... and must have the legal authority issues resolved ...[CRP #9, #3, #4]

•	A Federal back stop ... for failure to plan, participate or implement. [CRP #2]

Working Assumptions	[version 3/28/97]

In addition to the above key principles, this issue paper uses some critical working assumptions about the final implementation process. These are based on the recommendations and current understanding of Phase 1 issue papers, although final decisions have not yet been made. Changes in these working assumptions could require reconsideration of the questions addressed in this paper. The following key working assumptions are used in the current issue paper:

1. Areas violating the revised ozone and/or particulate matter standard will be considered Areas of Violation in advance of or perhaps in lieu of nonattainment areas.

2. Class I areas with impairment will be treated as Areas of Violation

3. In response to an Area of Violation, states, tribes, or multijurisdictional organizations (whichever is appropriate) will identify an Area(s) for Control.

4. When the Area(s) for Control is multijurisdictional, there will be an institutional mechanism that will, at a minimum, recommend to EPA the appropriate allocation of emission reduction responsibility between states and tribes in a document called a Regionally Integrated Plan (RIP).

5. New source review requirements will be addressed in a separate issue paper.

6. Integration ..* .. this is a placeholder for a working assumption on Integrated Implementation.