B. Where Failure to Make Progress Is Due to Transport
Section 2.2 of the MCR technical guidance provides a tool for assessing the relative importance of
transported emissions compared to local emissions. The analysis may show that an area’s failure to
make adequate progress toward attainment may be largely due to transported ozone and precursors.
The State should identify this situation in its MCR and recommend or propose ways of addressing
control, including filing a petition with EPA under section 126 to require control of upwind sources
contributing to the continuing nonattainment. To the extent that EPA determines that the lack of
adequate progress is due to transport from across State lines, EPA will use its authority under the Clean
Air Act to address the contributing emission sources. To the extent that the lack of progress is due to
local emissions, EPA will address that situation through an appropriate remedy (e.g., a call for a SIP
revision if additional control is needed or a finding of failure to implement and/or federal enforcement if
existing controls requirements are not being enforced).
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
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
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