The
EPA
anticipates
that
nonattainment
designations
for
the
8­
hour
ozone
national
ambient
air
quality
standards
(
NAAQS)
will
occur
in
2004,
and
the
designations
for
the
fine
particles
(
PM2.5)
NAAQS
will
occur
in
the
2004­
2005
time
frame.
Within
3­
4
years
after
designations
are
promulgated,
States
will
need
to
submit
new
attainment
demonstration
State
implementation
plans
(
SIPs)
for
the
new
NAAQS.
A
key
element
in
the
overall
SIP
planning
process
is
the
need
for
updated
statewide
emission
inventories.
This
memorandum
identifies
2002
as
the
anticipated
emission
inventory
(
EI)
base
year
for
the
SIP
planning
process
to
address
these
pollutants.
Identifying
the
base
year
at
this
time
gives
certainty
to
States,
and
the
selection
of
2002
harmonizes
dates
for
other
reporting
requirements,
e.
g.,
EPA's
Consolidated
Emissions
Reporting
Rule
(
CERR)
that
requires
submission
of
EI
every
three
years;
2002
is
one
of
the
required
years
for
such
updates.

The
Agency
encourages
States
to
take
early
action
to
reduce
emissions
of
pollutants
that
cause
violations
of
the
NAAQS
for
ozone
(
the
8­
hour
standard)
and
PM2.5,
and
that
cause
regional
haze.
States
will
be
able
to
take
credit
for
emission
reductions
that
occur
after
the
2002
base
year,
including
reductions
that
occur
before
the
deadlines
for
submission
of
these
SIPs.
As
a
matter
of
policy,
EPA
seeks
to
avoid
penalizing
States
for
moving
forward
early
to
address
these
problems.
Attached
is
additional
information.

The
EPA
is
aware
that
some
areas
have
already
begun
on
a
voluntary
basis
to
model
for
purposes
of
the
8­
hour
ozone
standard.
These
areas
may
continue
to
use
modeling
from
previous
base
years
for
each
set
of
meteorological
episode
conditions
for
use
in
their
SIP
submittals
if
these
studies
are
still
applicable
for
an
attainment
demonstration.
The
2002
EI,
however,
needs
1U.
S.
EPA,
(
1999),
"
Guidance
onthe
use
of
models
and
other
analyses
in
attainment
demonstrations
for
the
8­
hour
ozone
NAAQS,"
DRAFT,
May
1999,
Web
site:
http://
www.
epa.
gov/
tnn/
scram,
under
Guidance/
Support,
file
name:
O3TEST.
2
to
be
factored
into
this
analysis.
For
example,
the
2002
inventory
would
be
a
good
choice
for
use
in
modeling
"
current"
emissions.
As
described
in
the
modeling
guidance,
predictions
for
the
current
emissions
and
predictions
for
the
future
year
emissions
are
used
in
the
modeled
attainment
test1.
Furthermore,
for
reasonable
further
progress
(
RFP)
purposes,
the
2002
EI
needs
to
be
used
as
the
base
year.

Please
make
this
guidance
available
to
the
appropriate
contacts
in
your
State
and
local
air
agencies.
Questions
on
this
should
be
directed
to
(
for
ozone)
Annie
Nikbakht
at
919­
54l­
5246
or
(
for
PM2.5)
Rich
Damberg
at
919­
54l­
5592.

cc:
Lydia
Wegman
Peter
Tsirigotis
Rich
Ossias
Kevin
McLean
2The
EPA
is
still
working
on
the
implementation
guidance
that
will
address
the
extent
to
which
subparts
1
and
2
of
the
CAA
apply
for
purposes
of
the
8­
hour
ozone
NAAQS.
Subpart
1
provides
up
to
three
years
after
nonattainment
designation
for
States
to
submit
attainment
and
reasonable
further
progress
(
RFP)
SIPs,
while
subpart
2
provides
3
to
4
years,
depending
on
an
area's
classification,
for
States
to
submit
those
plans.
Attachment
Background
The
EPA
anticipates
that
designations
for
the
8­
hour
ozone
NAAQS
will
occur
in
2004,
and
the
designations
for
the
PM2.5
NAAQS
will
occur
in
the
2004­
2005
time
frame.
The
Clean
Air
Act
(
CAA)
requires
States
to
submit
attainment
demonstration
SIPs
for
the
8­
hour
ozone
standard
within
3
to
4
years
(
depending
on
classification),
and
within
3
years
for
the
PM2.5
standard.
Therefore,
EPA
anticipates
that
SIPs
will
be
due
in
2007
or
20082
for
both
NAAQS
programs.
For
regional
haze,
most
States
(
i.
e.,
those
participating
in
regional
planning
organizations)
will
have
SIPs
due
at
the
same
time
as
PM2.5
SIPs.
We
anticipate
that
technical
analyses
in
support
of
these
SIPs,
such
as
regional
scale
air
quality
modeling,
will
need
to
begin
no
later
than
the
2004
time
frame.
Updated
statewide
emissions
inventories
will
be
an
important
component
used
in
these
analyses.
In
addition,
for
many
of
the
required
SIPs,
emissions
in
upwind
States
will
also
be
an
important
input
to
necessary
technical
analyses.

For
the
8­
hour
ozone,
PM2.5,
and
regional
haze
program
areas,
there
are
statutory
and
regulatory
provisions
related
to
prospective
and/
or
retrospective
demonstrations
of
progress
in
reducing
emissions
and/
or
improving
air
quality,
although
the
exact
provisions
differ
somewhat
across
programs.
We
have
considered
the
statutory
and
regulatory
provisions
applicable
to
each
of
these
program
areas,
and
have
concluded
that
in
each
case
2002
is
an
appropriate
base
year
for
program
requirements
related
to
progress.
In
addition,
there
are
practical
reasons
for
choosing
2002,
as
explained
below.

Therefore,
even
though
EPA
has
not
developed
final
rules
or
guidance
for
implementation
of
either
the
8­
hour
ozone
NAAQS
or
the
PM2.5
NAAQS,
EPA
believes
that
2002
should
be
the
base
year
inventory
for
these
SIP
planning
efforts,
including
for
regional
haze
SIPs.
Using
the
2002
inventory
as
the
base
year
will
also
ensure
that
the
inventory
reflects
one
of
the
years
used
for
calculating
the
air
quality
design
values
on
which
designation
decisions
are
based,
as
well
as
one
of
the
years
in
the
2000­
2004
period
used
to
establish
baseline
visibility
levels
for
the
regional
haze
program.
Our
reasoning
is
explained
in
more
detail
below
for
each
program
area.

The
year
2002
is
also
suitable
as
the
principle
or
one
of
the
principle
years
used
for
air
quality
model
validation.

The
practical
reasons
for
choosing
2002
have
to
do
with
the
requirements
of
the
CERR
(
67
Federal
Register
39602),
which
was
finalized
on
June
10,
2002,
and
with
the
schedule
of
EPA's
own
work
on
the
National
Emissions
Inventory.
The
CERR
requires
States
to
submit
3
The
CAA
provides
that
nitrogen
oxides
(
NO
)
emission
reductions
may
be
substituted
for
VOC
emission
reductions
for
these
subsequent
three­
year
periods
under
prescribed
circumstances.
See
CAA
section
182(
c)(
2)(
C).

2
emissions
inventories
for
all
criteria
pollutants
and
their
precursors
every
three
years,
on
a
schedule
that
includes
the
emissions
year
2002.
The
due
date
for
the
2002
emission
inventory
is
established
in
the
CERR
as
June
2004.
Therefore,
each
State
should
have
information
available
some
time
before
this
date
to
develop
the
in­
state
emissions
inventory
needed
for
technical
analyses
during
2004.
In
addition,
EPA
plans
to
make
its
initial
version
of
the
2002
National
Emission
Inventory
(
NEI)
available
to
the
states
by
December
2003,
based
on
2002
data
on
emissions
from
electric
generating
units,
preliminary
2002
vehicle
miles
traveled
information
from
the
Federal
Highway
Administration,
and
growth
and
control
projections
starting
with
the
1999
NEI
for
other
source
types.
This
preliminary
2002
NEI
can
be
used
in
2004
by
each
State
needing
emission
estimates
for
upwind
States.
The
EPA's
final
2002
NEI,
which
will
merge
and
augment
the
state­
by­
state
inventories
received
in
2004,
will
be
ready
by
the
summer
of
2005.
Depending
on
where
they
are
in
their
work,
States
may
wish
to
switch
to
the
newer
estimates
of
upwind­
states'
emissions,
and
certainly
should
at
least
consider
how
the
emission
estimates
for
upwind
States
have
changed.

Alternatively,
some
regional
groupings
of
States
may
exchange
and
merge
their
2002
inventories
directly,
prior
to
completion
of
EPA's
final
2002
NEI.
We
will
be
consulting
with
multi­
state
organizations
about
the
2002
inventory
process
so
that
work
is
not
duplicated
unnecessarily.

8­
hour
Ozone
NAAQS
Under
the
8­
hour
ozone
standard,
EPA
anticipates
that
many
areas
designated
nonattainment
for
the
8­
hour
ozone
NAAQS
will
need
to
comply
with
the
rate
of
progress
(
ROP)
requirement
in
Subpart
2
of
the
CAA,
which
applies
to
areas
classified
moderate
or
above.
Any
area
not
subject
to
the
subpart
2
ROP
requirement
would
be
subject
to
the
more
general
requirement
under
subpart
1
to
make
RFP.
Both
ROP
and
RFP
consider
progress
made
from
a
baseline
inventory.
As
enacted
in
1990,
Subpart
2
provided
that
the
base­
year
inventory
would
be
1990.
See,
CAA
section
182(
b)(
1)(
B).
Thus,
for
1­
hour
ozone
nonattainment
areas
classified
moderate
or
higher,
ROP
reductions
for
the
target
of
1996
were
considered
to
be
a
15
percent
reduction
of
volatile
organic
compound
(
VOC)
emissions
from
the
1990
baseline
year.
Similarly,
for
each
three­
year
period
following
1996
up
to
its
attainment
date,
a
serious
or
above
nonattainment
area
was
required
to
achieve
an
additional
9
percent
reduction
in
VOC
emissions.
3
Under
the
8­
hour
ozone
standard,
EPA
anticipates
that,
consistent
with
the
above
discussion,
a
2002
base
year
emission
inventory
would
be
used
as
the
baseline
from
which
future
target
levels
of
emissions
would
be
calculated.
Therefore,
any
emission
reductions
that
the
State
initiates
after
2002
would
be
creditable
toward
the
ROP
or
RFP
requirements.
3
For
areas
subject
to
the
subpart
2
ROP
requirement,
section
182(
b)(
1)(
D)
places
constraints
on
the
use
of
emission
reduction
credits
from
certain
pre­
1990
programs
even
though
those
programs
might
achieve
additional
reductions
in
the
years
following
1990,
i.
e.,
the
federal
motor
vehicle
emission
control
program,
Reid
Vapor
Pressure
programs,
corrections
required
to
pre­
existing
reasonably
available
control
technology
(
RACT)
rules,
and
inspection
and
maintenance
(
I/
M)
program
corrections.
While
these
limitations
would
still
apply
for
purposes
of
credit
for
SIPs
designed
to
meet
the
8­
hour
ozone
NAAQS,
EPA
does
not
believe
it
is
legally
required
and
does
not
plan
to
expand
the
list
of
programs
for
which
credit
is
precluded.
Subpart
1
does
not
establish
any
limits
on
the
creditability
of
measures
for
purposes
of
RFP
and
EPA
does
not
anticipate
establishing
any
regulatory
limits
on
the
creditability
of
emission
reductions.
Thus,
EPA
does
not
anticipate
establishing
any
additional
constraints
on
crediting
emission
reductions
achieved
in
years
following
the
2002
base
year.
Therefore,
apart
from
those
programs
listed
in
the
CAA,
we
believe
that
States
can
take
credit
for
other
emission
reductions
that
occur
after
the
2002
base
year.

PM
2.5
NAAQS
The
EPA
anticipates
that
States
will
be
required
to
implement
the
PM2.5
NAAQS
under
Subpart
1
since
the
more
specific
provisions
in
Subpart
4
that
address
particulate
matter
expressly
apply
only
to
PM10.
As
provided
above,
Subpart
1
does
not
place
limits
on
the
types
of
controls
that
are
creditable
for
purposes
of
the
RFP
requirement.
As
with
the
8­
hour
ozone
NAAQS,
EPA
does
not
anticipate
establishing
any
regulatory
constraints
limiting
creditability
of
emission
controls.
Subpart
1
generally
calls
for
States
to
submit
plans
including
emission
reduction
measures
designed
to
attain
the
NAAQS
within
3
years
after
a
nonattainment
designation.
It
also
includes
a
reasonable
further
progress
(
RFP)
requirement,
but
does
not
have
a
specific
percent
reduction
requirement
as
there
is
in
the
ROP
requirement
of
Subpart
2.
The
exact
form
of
the
RFP
requirement
for
PM2.5
has
yet
to
be
established,
but
it
is
expected
that
any
emission
reductions
that
occur
after
the
base
year
of
2002
would
be
credited
toward
the
emission
reductions
needed
by
the
State
under
its
attainment
demonstration
and
toward
the
reductions
needed
to
meet
the
RFP
requirement.

Regional
Haze
Program
The
regional
haze
program
calls
for
States
participating
in
regional
planning
organizations
to
submit
SIPs
in
2007­
8
that
contain
progress
goals
for
every
class
I
area
and
emission
reductions
strategies
needed
to
meet
these
goals.
Progress
in
improving
visibility
is
tracked
from
baseline
conditions
(
established
using
air
quality
monitoring
for
the
2000­
2004
period).
If
2002
is
used
as
the
base
year
for
planning
purposes,
then
States
can
take
credit
for
emission
reductions
that
are
achieved
before
the
2007­
2008
SIP
due
date.
4
Credits
in
General
It
should
be
noted
that
EPA
cannot
provide
"
double
credit"
for
an
emission
reduction
for
purposes
of
RFP
or
ROP.
For
instance,
if
a
program
or
rule
results
in
emission
reductions
prior
to
or
in
the
base
year,
those
reductions
would
be
considered
in
calculating
the
base
year
emissions
inventory
and
thus
could
not
be
counted
as
emission
reductions
from
the
base­
year
level.
Such
reductions
would
likely
lower
ambient
pollutant
concentrations,
however,
and
would
be
important
in
terms
of
determining
an
area's
designation
and,
if
designated
nonattainment,
could
affect
the
area's
classification
and
thus
its
planning
obligations.
For
example,
emission
reductions
in
NOx
or
VOC
achieved
prior
to
or
during
2002
could
have
already
resulted
in
the
area
having
a
lower
ozone
design
value,
which
is
the
measure
of
whether
the
area
is
violating
the
8­
hour
ozone
standard
and,
if
so,
by
how
much.
Reductions
from
such
measures
in
years
beyond
the
base
year
would
be
creditable
towards
ROP
SIPs.
These
concepts
of
credit
were
discussed
in
the
January
29,
2001,
memorandum
from
John
Seitz
entitled
"
Near­
Term
Discretionary
Emission
Reductions
for
Ozone
NAAQS
 
Clarification,"
which
addressed
the
1­
hour
ozone
standard,
but
which
are
also
conceptually
applicable
to
implementation
of
the
8­
hour
ozone
standard.

However,
post­
2002
emission
reductions
that
benefit
ozone,
PM2.5
and
regional
haze
can
be
credited
toward
the
RFP
requirements
for
each
of
these
programs.
