Staff from some of the northeast Ozone Transport Commission (OTC) States have recommended

that the issue of transport be addressed in a more comprehensive manner and have provided EPA with

some ideas for the format of such an activity. OAQPS intends to follow up with the affected States on

their ideas.


C. Special Schedule for Serious Areas with Proposed Attainment Dates of 2004 or Earlier

The December 1999 notices of proposed rulemaking (NPRs) on the 1-hour O3 SIPs for these

areas (Atlanta and Western Massachusetts) acknowledged that in order to approve the attainment

demonstration SIP for the serious areas requesting an attainment date extension to a year prior to 2005,

a review that occurs at a midpoint prior to the attainment date would be impractical in terms of timing.

Therefore, for these areas, EPA requested the State’s commitment to an MCR be a commitment to

perform an early attainment assessment to be submitted by the end of the attainment year. Such an

early attainment assessment should follow the MCR technical guidance noted above. This early

attainment assessment will help guide the State and EPA in determining what further action might be

required if the area does not attain by its attainment date.

D. New Attainment Demonstration and Modeling as Part of MCR

Some States may wish to perform new modeling and develop a new attainment demonstration as

part of the their MCR. This approach is actually preferable to a mid-course assessment without new

modeling, since it will result in a more timely assessment of the magnitude of the problem that exists at a

point in time prior to the attainment date. More importantly, it will address any problems (i.e., identify

and plan for additional emission reductions that might be needed to ensure attainment) much sooner

than any SIP revision that EPA would require subsequent to submission of a mid-course review.

New attainment demonstration and modeling should make use of the most up-to-date guidance

(e.g., EPA 1996 modeling guidance), analytical techniques, and models such as MOBILE6, BEIS3

and/or NONROAD. In many cases this will require an assessment


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