9.0 What Documentation Do I Need To Support My Attainment

Demonstration?

States/Tribes should follow the guidance on reporting requirements for attainment

demonstrations provided in U.S. EPA (1994b). The first seven subjects in Table 9.1 are similar

to those in the 1994 guidance. The 1994 guidance envisions an air quality model as the sole

means for demonstrating attainment. However, the current guidance (i.e., this document)

identifies supplemental analyses as well as a possible weight of evidence determination as a

means for corroborating/refuting the modeled attainment test in an attainment demonstration. In

addition, feedback received since the earlier guidance has emphasized the need for technical

review of procedures used to identify a sufficient control strategy. Thus, we have added two

additional subject areas which should be included in the documentation accompanying an

attainment demonstration. These are a description of the supplemental analyses and/or weight of

evidence determination, and identification of reviews to which analyses used in the attainment

demonstration have been subject. In the end, the documentation submitted by the States/Tribes

as part of their attainment demonstration should contain a summary section which addresses the

issues shown in Table 9.1.

Table 9.1 Recommended Documentation for Modeled Attainment Demonstrations and

Regional Haze Analyses

10.0 How Do I Apply Air Quality Models?-- An Overview

In Part I of this guidance, we described how to estimate whether a proposed control

strategy will lead to attainment of the NAAQS or meet the uniform rate of progress goals within

a required time frame. We noted that air quality models play a major role in making this

determination. We assumed that modeling had been completed, and discussed how to use the

information produced. We now focus on how to apply models to generate the information used

in the modeled attainment demonstration. The procedure we recommend consists of nine steps:

1. Formulate a conceptual description of an area’s nonattainment problem;

2. Develop a modeling/analysis protocol;

3. Select an appropriate air quality model to use;

4. Select appropriate meteorological episodes to model;

5. Choose a modeling domain with appropriate horizontal and vertical resolution and

establish the initial and boundary conditions to be used;

6. Generate meteorological and air quality inputs to the air quality model;

7. Generate emissions inputs to the air quality model;

8. Evaluate performance of the air quality model and perform diagnostic tests, as necessary.

9. Perform future year modeling (including additional control strategies, if necessary) and

apply the attainment test

 

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