If the State cannot demonstrate that the SIP shows attainment with the revised MOBILE6

inventories as described in question 5 of EPA’s guidance on use of MOBILE6, the State can submit an

enforceable commitment to do one of the following in its mid-course review: 1) submit additional

measures needed to fill any emission reduction shortfall in the SIP at the time of the submission of the

mid-course review; or 2) document that there is no emission reduction shortfall as demonstrated

through the mid-course review. Such a commitment would be submitted as part of the MOBILE6 SIP

revision, and this commitment is necessary for EPA to find the revised MOBILE6-based motor vehicle

emission budgets adequate for conformity purposes.

If the time between the submission of the MOBILE6 revision and the submission of the mid-course

review is not sufficient for adoption of the additional measures needed as a result of the MOBILE6

revision, the State may submit the additional measures pursuant to these commitments as a separate

SIP revision as expeditiously as practicable after the submission of the mid-course review, but no later

than 12/31/04. Also, some areas may have committed to perform the MOBILE6 revision at the same

time as the MCR; these areas would be given a sufficient amount of time to adopt any measures needed

as a result of their MOBILE6 revision, but no later than 12/31/04.


The EPA believes that a mid-course review is an important element of the SIP planningimplementation-

assessment-revision process. It is particularly important for cases where the attainment

demonstration relies on a weight of evidence demonstration.

The Regional Offices should provide this guidance to the appropriate State air pollution control


Air Program Managers, RO 1-10, Regional Meteorologists, RO 1-10, Tom Helms, Joe

Tikvart, John Silvasi, Sharon Reinders, Denise Gerth, Ellen Baldridge, Jan Tierney, Sara

Schneeberg, Kevin McLean, Meg Patulski

EPA:OAR:OAQPS:AQSSD:OPSG:JSILVASI\LLassiter:N. Campus C545E\1-5526\C-539-02

File Name: I:\SEC\SILVASI\POLICYMEM33D.WPD March 21, 2002



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