John
Silvasi/
RTP/
USEPA/
US
08/
30/
2005
09:
53
AM
T
o
Art
Fraas,
Amy
Flynn
c
c
Robert
Meyers/
DC/
USEPA/
US@
E
PA,
Jim
Ketcham­
Colwill,
Tom
Helms,
Lydia
Wegman/
RTP/
USEPA/
US
@
EPA,
Jan
Tierney/
DC/
USEPA/
US@
E
PA,
Kevin
Mclean,
Denise
Gerth
S
u
b
j
e
c
t
Revised
RACT
section
(
8­
hr
O3
NAAQS
implementation
rule/
phase
2)
&
RFP
section
revision
Hi,
Art
&
Amy,

Attached
is
the
revised
RACT
section
for
the
8­
hr
O3
rule,
in
redline/
strikeout
compared
to
the
8/
24
version
we
sent
to
you
last.

The
following
italicized
change
was
also
made
in
the
RFP
per
discussions
with
Amy:

The
requirements
for
RFP
under
subparts
1
and
2,
as
described
above,
are
the
minimum
required
for
an
area.
More
reductions
may
be
necessary
for
attainment
within
the
nonattainment
area.
Moreover,
an
upwind
area
that
contributes
to
nonattainment
in
a
downwind
area
in
the
same
State
may
need
reductions
in
order
for
the
downwind
area
to
reach
attainment
by
its
required
attainment
date.
As
we
noted
above
in
section
IV.
D.
8.,
we
recognize
that
some
areas
classified
under
subpart
2
may
need
additional
time
beyond
the
statutory
attainment
date
for
their
area
to
attain
as
expeditiously
as
practicable.
In
the
event
an
area
cannot
practicably
attain
by
the
maximum
date
for
its
classification,
the
CAA
provides
the
opportunity
for
more
time.
An
area
regulated
under
subpart
2
can
receive
a
later
maximum
attainment
date
through
a
State
request
to
bump­
up
to
a
higher
classification
(
e.
g.
from
moderate
to
serious).
There
may
not
be
additional
mandatory
control
measures
required
because
the
area
may
already
have
such
measures
in
place.
However,
an
area
that
needs
more
time
to
attain
may
also
need
additional
emissions
reductions
to
reach
attainment.
These
reductions
may
be
achieved
through
implementation
of
measures
that
are
necessary
to
demonstrate
RFP
requirements
or
additional
reductions
beyond
RFP
may
be
needed.
Preliminary
analyses
indicate
that
already
required
control
measures
(
e.
g.,
motor
vehicle
and
nonroad­
engine
rules,
CAIR,
etc.)
may
largely
or
fully
fulfill
RFP
requirements
for
many
areas
and
that
they
will
provide
substantial
progress
toward
attainment
for
most
areas.

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
