12.1 What Is The Protocol’s Function?

As noted above, the most important function of a protocol is to serve as a means for

planning and communicating up front how a modeled attainment demonstration will be

performed. The protocol is the means by which States/Tribes, U.S. EPA, and other stakeholders

can assess the applicability of default recommendations and develop alternatives. A good

protocol should lead to extensive participation by stakeholders in developing the demonstration.

It should also reduce the risk of spending time and resources on efforts which are unproductive

or inconsistent with EPA policy.

The protocol also serves several important, more specific functions. First, it should

identify who will help the State/Tribe or local air quality agency (generally the lead agency)

undertake and evaluate the analyses needed to support a defensible demonstration (i.e., the

stakeholders). Second, it should identify how communication will occur among States/Tribes

and stakeholders to develop consensus on various issues. Third, the protocol should describe the

review process applied to key steps in the demonstration. Finally, it should also describe how

changes in methods and procedures or in the protocol itself will be agreed upon and

communicated with stakeholders and the appropriate U.S. EPA Regional Office(s). Major steps

to implement the protocol should be discussed with the appropriate U.S. EPA Regional Office(s)

as they are being decided. States/Tribes may choose to update the protocol as major decisions

are made concerning forthcoming analyses.


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