14determining the appropriate inventory of nearby sources to include in the cumulative modeling
15analysis, including the potential influence of terrain characteristics on concentration gradients
16and the availability and adequacy of ambient monitoring data to account for background sources.
17In light of the March 1, 2011, guidance, the EPA cautions against the literal and uncritical
18application of very prescriptive procedures for identifying which nearby sources should be
19included in the modeled emission inventory for NAAQS compliance demonstrations, such as
20those described in Chapter C, Section IV.C.1 of the draft New Source Review Workshop Manual
21(U.S. EPA, 1990). This caution should not be taken to imply that the procedures outlined in the
22draft New Source Review Workshop Manual are flawed or inappropriate in themselves.
23Cumulative impact assessments based on following such procedures will generally be acceptable
as the basis for permitting decisions, contingent on an appropriate1 accounting for the monitored
2contribution. Our main concern is that following such procedures in a literal and uncritical
3manner may increase the likelihood of double counting modeled and monitored concentrations in
4many cases, resulting in cumulative impact assessments that are overly conservative and would
5unnecessarily complicate the permitting process in some cases. Such procedures might be
6characterized as being sufficient in most cases, but not always necessary to fulfill the
7requirements of a cumulative impact assessment.
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castellano: DISPER CUSTIC DESCAR RADIA italiano:
deutsch: DIS CUS DES RAD
castellano: DIS CUS DES RAD english: DIS CUS DES RAD
português: DIS CUS DES RAD italiano: DIS CUS DES RAD
français: DIS CUS DES RAD