1) A fully-evaluated, high-quality modeling analysis that projects future values that are

close to the NAAQS.

2) Multiple supplemental analyses in each of the three various categories discussed above

(modeling, air quality/emissions trends analyses, observational models).

3) A qualitative weighting for each separate analysis based on its ability to quantitatively

assess the ability of the proposed control measures to yield attainment.

4) A description of each of the individual supplemental analyses and their results.

Analyses that utilize well-established analytical procedures and are grounded with sufficient data

should be weighted accordingly higher.

5) Where applicable, a written description as to why the full set of evidence leads to a

conclusive determination regarding the future attainment status of the area that differs from the

results of the modeled attainment test alone.

7.3 What Role Should Weight Of Evidence Play In Visibility-Related Analyses?

We believe a weight of evidence analysis is an appropriate option for States to use when

examining visibility trends. Unlike the NAAQS, progress goals address trends in air quality

rather than some absolute level of air quality. Thus, the focus of weight of evidence analyses

differs from those performed in NAAQS attainment demonstrations. In this subsection, we note

some potential supplemental analyses that may be used to examine visibility trends. We then

identify several refinements to our recommended modeled test for uniform rate of progress

analyses if a State or regional planning organization believes these are warranted for a weight of

evidence determination. We conclude by noting some potential concerns about the ability of

models to address days with very good visibility.


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