In this section, we briefly describe each of these steps to better illustrate how they are

inter-related. Because many of these steps require considerable effort to execute, States/Tribes

should keep the appropriate U.S. EPA Regional Office(s) informed as they proceed. This will

increase the likelihood of having an approvable attainment demonstration when the work is

completed. The steps outlined in this section are described in greater depth in Sections 11 - 18.

1. Formulate a conceptual description of an area’s nonattainment problem. A State/Tribe

needs to have an understanding of the nature of an area’s nonattainment problem before it can

proceed with a modeled attainment demonstration. For example, it would be difficult to identify

appropriate stakeholders and develop a modeling protocol without knowing whether resolution

of the problem may require close coordination and cooperation with other nearby States.

The State/Tribe containing the designated nonattainment area or the RPO containing the

Class I area is expected to initially characterize the problem. This characterization provides a

starting point for addressing steps needed to generate required information by those

implementing the protocol. Several examples of issues addressed in the initial description of a

problem follow. Is it a regional or local problem? Are factors outside of the nonattainment area

likely to affect what needs to be done locally? Are monitoring sites observing violations located

in areas where meteorology is complex or where there are large emission gradients? How has

observed air quality responded to past efforts to reduce precursor emissions? Are there ambient

measurements suggesting which precursors and sources are important to further reduce ozone,

PM2.5, and/or regional haze? What information might be needed from potential stakeholders?

As many of the preceding questions imply, an initial conceptual description may be based


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