4.0 Summary

States should first do an administrative review to determine whether the scheduled

number of measures called for in the SIP have been implemented and that

legal/administrative prerequisites are in place to implement the remaining measures identified

in the SIP revision. If these targets are not met, there is cause for concern that the SIP is not

on track toward attainment.

States should also perform a series of analyses to ascertain trends in ozone and

precursors, emission trends, relative importance of transport vs. local emissions and to review

modeling efforts to identify ozone-limiting precursors and the role of transport.

A weight of evidence determination may be performed to assess the likelihood that a SIP

is on track toward attainment. Two example analytical methods are provided and are

recommended for use as part of the weight of evidence determination to see if observed air

quality at the time of the mid-course review meets a target considered to be consistent with

meeting the NAAQS in a timely manner. The first and preferred approach is to use modeled

results to establish a target at the time of a mid-course review which is consistent with

ultimate attainment of the NAAQS. The second approach is to use proportional

extrapolations based on past observed correspondence between air quality and emissions and


anticipated future changes in emissions. Other factors that may be considered in the weight

of evidence analysis include consideration of the assumptions and methods underlying the two

analytical approaches or other analytical approach used and use of refinements which appear

more appropriate based on data and analyses performed for a specific area.

For a mid-course review to be acceptable, a State should include the following


- results of the administrative review;


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