(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 of the impact changing from one

analytical technique or model to another will have on the original SIP analysis results.

E. Pilot Demonstration of MCR Guidance

Several State agency representatives have recommended that EPA perform a pilot application of

the MCR technical guidance. At this time, EPA plans to perform such an effort.

F. Documentation

A State should include the following documentation for its mid-course review:

- the administrative review;

- descriptions of the data bases used to support each analysis;

- identification of models and analytical techniques used to perform the analysis;

- the outcome of each analysis and whether or not it is consistent with a conclusion that the SIP is

on track;

- a narrative describing the rationale used to conclude that the weight of evidence does or does not

suggest that the SIP is on track toward timely attainment.

G. Relationship to SIP Revisions Needed as a Result of MOBILE6 Model


8Memorandum of January 18, 2002, from John S. Seitz and Margo Tsirigotis Oge to EPA

Regional Air Division Directors re: “Policy Guidance on the Use of MOBILE6 for SIP Development

and Transportation Conformity.”

The EPA recognizes that for some areas, States are required to submit revisions to their SIP to

account for the new MOBILE6 mobile source emissions model on a schedule earlier than that required

for the mid-course review. SIP revisions that revise interim MOBILE5 Tier 2 estimates with

MOBILE6 are not intended to duplicate any technical analyses completed for mid-course reviews in

those areas. The MOBILE6 SIP and budget revisions are primarily intended to revise the motor

vehicle emissions inventories with the new model. Although the overall SIP must continue to

demonstrate attainment or maintenance with these revised MOBILE6 inventories as described in

question 5 of the guidance memorandum, “Policy Guidance on the use of MOBILE6 for SIP

Development and Transportation Conformity,”8 for areas completing mid-course reviews, EPA

believes that new attainment modeling or additional control measures to ensure attainment may be

delayed until the mid-course reviews. EPA will work with these States on a case-by-case basis to

decide what additional documentation is necessary to show that the MOBILE6 SIP revision

demonstrates attainment.



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