John
Silvasi/
RTP/
USEPA/
US
07/
19/
2005
10:
52
AM
T
o
Amy
Flynn,
Art
Fraas
c
c
Tom
Helms,
Doug
Grano,
Dave
Sanders,
Jan
Tierney/
DC/
USEPA/
US@
EP
A,
Sara
Schneeberg,
Lydia
Wegman/
RTP/
USEPA/
US@
EPA,
Robert
Meyers/
DC/
USEPA/
US@
EP
A,
Jim
Ketcham­
Colwill
S
u
b
j
e
c
t
Material
on
2004
alternative
baseline
year
for
RFP
Hi,
Art
&
Amy,

Several
of
us
discussed
your
idea
of
allowing
2004
as
an
option
to
States
as
a
baseline
year
for
RFP.
We
do
not
believe
this
is
a
viable
alternative.

Here
are
some
reasons:

2002
VS.
2004
BASELINE
YEAR
INVENTORY
FOR
RFP
See
pdf
file
showing
that
there
is
not
much
in
the
way
of
benefit
for
States
using
a
2004
inventory.
OTHER
PROBLEMS:

 
All
emission
reductions
occurring
after
the
baseline
year
are
creditable
(
with
the
CAA
exceptions
 
pre­
1990
required
reductions
and
the
4
specified
categories).
Therefore
a
later
baseline
year
would
eliminate
opportunity
for
credit
toward
15%
requirement.
Notable
affected
areas
include
the
OTR
States
(
particularly
NYC,
which
invested
in
low
emitting
diesel
construction
equipment
after
the
Sept.
11
2001
attack),
and
TX,
which
implemented
its
regional
NOx
strategy.
 
A
later
baseline
gives
areas
less
time
to
make
the
emission
reductions.
In
fact,
since
reductions
for
attainment
must
be
made
in
spring
2009,
that
would
be
the
controlling
timing,
not
2010
(
6
years
after
2004).
 
EPA's
emission
inventory
regulations
(
40
CFR
51,
subpart
A)
requires
triennial
inventories
in
2002
and
2005;
2004
would
be
off
the
cycle
and
require
a
lot
of
additional
work.
 
Indicating
2004
is
an
appropriate
baseline
(
even
as
an
option)
could
make
the
2002
year
more
vulnerable
to
litigation;
furthermore,
we
did
not
propose
2004
as
a
baseline
year
and
in
fact
argued
against
years
other
than
2002.
 
A
2004
inventory
would
impair
States'
abilities
to
meet
a
2007
submittal;
States
really
could
not
develop
an
adequate
inventory
for
2004
in
time
to
meet
a
2007
submittal
date.

John
J.
Silvasi
Environmental
Engineer
Ozone
Policy
and
Strategies
Group
(
C539­
02)
Office
of
Air
Quality
Planning
and
Standards
U.
S.
Environmental
Protection
Agency
Research
Triangle
Park,
NC
27711
919­
541­
5666
(
v);
919­
541­
0824
(
fax)
silvasi.
john@
epa.
gov
