This says that, on average, an area’s observed maximum design value for a given year varies

by about 4.6% from a best fit design value based on a review of 10 years’ data. So as not to

connote greater precision than warranted, we recommend rounding this variability upward to

the next whole integer. Thus, in this example, so long as the most recent observed design

value is not more than 5% above a pre-determined air quality target for the year of the midcourse

review (2004 in this example), this factor would support a conclusion that the SIP is on


Deciding whether ozone is sensitive to reductions in VOC, NOx or both. This step is

needed in order to judge whether to pay most attention to changes in VOC emissions, NOx

emissions or changes in emissions for both precursors to make a judgment about whether an

observed (adjusted) trend in ozone is likely to continue at a sufficient pace to meet the

NAAQS within prescribed times. Since ozone’s sensitivity to changes in VOC, NOx, or both

emissions may vary from one location to another, and from one date and time to another, the

approach selected must consider a composite of results from several days and locations

throughout the area.

There are at least two approaches which may be used to judge whether an estimated

change in emissions of VOC, NOx or changes in both should be tracked when interpreting

normalized trends in ambient ozone concentrations. A State may use another approach if it

presents sufficient justification for doing so to the appropriate U.S. EPA Regional Office. If it

is not clear whether an ozone problem is limited by available VOC or NOx emissions, a State

should estimate changes in emissions for both precursors.



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