MEMORANDUM
SUBJECT:
Early
Action
Compacts
(
EACs):
The
June
16,
2003
Submission
and
Other
Clarifications
FROM:
Lydia
N.
Wegman,
Director
Air
Quality
Strategies
and
Standards
Division
TO:
Air
Directors,
Regions
III,
IV,
VI,
and
VIII
This
memorandum
responds
to
questions
from
States
and
local
EAC
areas
about
what
needs
to
be
included
in
the
milestone
submittals
and
semiannual
reports
due
June
and
December
2003.
As
we
have
stated
before,
completion
of
each
of
the
critical
milestones
and
schedules
as
described
in
the
"
Protocol
for
Early
Action
Compacts
Designed
to
Achieve
and
Maintain
the
8­
hour
Ozone
Standard"
("
Protocol"),
revised
November
2002,
and
the
November
14,
2002
memorandum
from
Jeffrey
Holmstead
to
EPA
Regional
Administrators
is
essential
if
areas
are
to
remain
eligible
for
participation
in
the
EAC
program.
To
ensure
that
the
2003
submissions
and
subsequent
milestones
will
be
met,
we
are
issuing
this
memorandum
(
1)
to
provide
State
and
local
air
pollution
control
agencies
some
general
guidelines
to
assist
them
in
completing
the
June
16,
2003
submission;
(
2)
to
clarify
what
should
be
included
in
the
semiannual
reports
due
in
June
and
December
2003;
and
(
3)
to
clarify
several
technical
requirements
of
the
program
to
ensure
that
the
attainment
demonstrations
being
developed
in
conjunction
with
the
local
air
quality
plans
are
representative
of
current
information
and
conditions.

1.
June
16,
2003
Submission
The
Protocol
and
the
November
14,
2002
Holmstead
memorandum
require
EAC
areas
to
identify
and
describe
the
local
control
measures
that
will
be
considered
during
the
local
planning
process.
This
June
16,
2003
milestone
must
be
met
to
maintain
eligibility
in
the
EAC
program.
This
submission
can
be
referenced
in
the
June
2003
progress
report,
as
described
in
the
Section
2
of
this
memorandum.

We
recommend
that
EAC
areas,
based
on
stakeholder
consultation,
submit
by
June
16,
2003
a
list
of
candidate
local
control
measures
that
is
sufficient
to
ensure
a
control
strategy
can
be
developed
to
achieve
attainment
of
the
8­
hour
ozone
standard
by
2007.
As
provided
in
the
Protocol,
areas
should
describe
each
of
the
local
control
measures
under
consideration.
2
As
EAC
areas
prepare
and
subsequently
analyze
the
June
2003
list
of
local
measures,
we
advise
the
participants
to
work
with
stakeholders
to
consider
carefully
each
of
the
following
components
needed
to
develop
an
attainment
strategy:

°
Local
control
measures
that
can
reasonably
be
implemented
in
each
area.
Among
the
factors
to
consider
are
the
resource
and
political
constraints
of
that
specific
area;

°
Realistic
implementation
dates
for
the
control
measures;

°
The
range
of
potential
emissions
reductions
that
will
result
from
each
control
measure
based
on
reasonably
available
information.
(
In
accordance
with
the
Protocol,
these
local
measures
must
be
specific,
quantified,
and
permanent,
and
that
if
approved
by
EPA,
will
be
federally
enforceable
SIP
revisions.)
A
list
of
resources
containing
emissions
reduction
estimates
for
specific
measures
can
be
found
in
the
attachment
to
this
memorandum;
and
°
The
geographic
area
to
which
control
measures
could
be
applied.

Any
public
comments
received
in
response
to
the
June
16,
2003
submissions
will
be
posted
on
EPA's
EAC
website
at:
http://
www.
epa.
gov/
ttn/
naaqs/
ozone/
eac/
.

2.
June
30,
2003
Progress
Report
The
Protocol
requires
local
areas
to
assess
and
report
every
6
months
their
progress
against
milestones
in
a
regular,
public
process.
At
a
minimum,
the
June
2003
progress
report
should
do
the
following:

°
Document
progress
in
developing
the
stakeholder
process,
including
the
roles
and
responsibilities
of
various
stakeholder
groups,
a
list
of
stakeholders,
and
a
brief
summary
of
stakeholder
meetings;

°
Report
progress
on
evaluating
and
selecting
emission
reduction
measures
for
the
local
control
strategy,
including
stakeholder
involvement
in
the
development
of
the
initial
list
of
control
measures
(
The
June
2003
progress
report
can
reference
the
June
16,
2003
submission
discussed
above.);

°
Describe
public
outreach
activities
(
press
coverage,
public
presentations,
websites,
etc.);
and
°
Provide
an
update
on
modeling/
technical
planning
activities.
3
3.
December
31,
2003
Progress
Report
As
part
of
the
December
2003
progress
report,
EAC
areas
should
address
in
detail
each
of
the
bulleted
components
discussed
in
section
1
above.
This
progress
report
will
be
an
important
element
in
EPA's
consideration
of
whether
or
not
to
grant
a
deferral
of
the
effective
date
of
the
nonattainment
designation
at
the
time
of
final
designations
in
April
2004.
More
specifically,
the
progress
report
should
address:

°
A
list
of
control
measures
still
under
consideration
for
adoption
by
the
local
area
as
part
of
the
March
2004
submission;

°
Likely
implementation
dates
for
the
local
control
measures
that
are
under
consideration;

°
Current
assessment
of
the
amount
of
emissions
reductions
expected
to
be
achieved
through
implementation
of
the
local
control
measures;
and
°
The
geographical
area
in
which
each
control
measure
is
anticipated
to
apply.

4.
Attainment
Demonstration
As
State
and
local
agencies
move
forward
to
develop
the
modeling
and
other
technical
analyses
in
support
of
attainment
demonstrations
for
EAC
areas,
they
have
asked
EPA
for
clarification
of
the
modeling
guidance
and
its
application
to
EAC
areas.
As
modeling
demonstrations
will
become
part
of
the
enforceable
SIP,
State
and
local
agencies
should
do
the
following:

°
Follow
the
most
recent
OAQPS
modeling
guidance
("
Draft
Guidance
on
the
Use
of
Models
and
Other
Analyses
in
Attainment
Demonstrations
for
the
8­
hour
Ozone
NAAQS,"
May
1999,
EPA­
454/
R­
99­
004);
see:
http://
www.
epa.
gov/
scram001/
guidance/
guide/
drafto3.
pdf
;

°
Model
most
current
emissions
inventory,
preferably
2002;
however,
if
2002
is
not
available,
use
of
a
1999
or
later
inventory
for
EAC
modeling
is
acceptable;

°
Base
2007
projections
on
1999
emissions
inventory
or
later;

°
Use
MOBILE6
in
both
the
current
and
future
inventories;

°
Select
episodes
that
are
representative
of
the
area's
ozone
problem;

°
Use
appropriate
assumptions
and
emissions
analysis
techniques
in
quantifying
emissions
reductions.
4
Please
advise
your
States
that
any
deviations
from
the
above
guidance
need
to
be
reviewed
by
and
coordinated
with
the
EPA
Regional
Office.
For
additional
clarification
of
these
and
other
technical
requirements,
State
and
local
agencies
should
refer
to
questions
and
answers
related
to
EAC
modeling
issues
at:
http://
www.
epa.
gov/
scram001/
guidance/
guide/
eac­
ozone.
pdf
.
This
document,
which
will
be
updated
periodically
with
additional
questions
as
necessary,
provides
clarification
of
the
current
modeling
guidance
and
its
application
to
EAC
areas.

I
hope
this
information
will
be
helpful
to
you
and
EAC
areas
as
they
move
forward
to
meet
the
swiftly­
approaching
milestone
and
semiannual
reports
for
this
year.

Any
questions
related
to
EAC
policy
issues
should
be
directed
to
David
Cole
at
919/
541­
5565,
while
questions
related
to
EAC
modeling
and
attainment
demonstration
issues
should
be
directed
to
Ellen
Baldridge
at
919/
541­
5684.

cc:
Air
Directors,
Regions
I,
II,
V,
VII,
IX,
X
Margo
Oge,
OTAQ
Steve
Page,
OAQPS
Peter
Tsirigotis,
OAQPS
Joe
Tikvart,
OAQPS
G.
T.
Helms,
OAQPS
Jan
Tierney,
OGC
1
ATTACHMENT
Resources
for
Identification
of
Control
Strategies,
Emission
Reduction
Estimates
and
Emission
Inventories
URL
Downloadable
Document(
s)
and
Websites
www.
epa.
gov/
otaq/
transp/
costemis.
pdf
"
Summary
Review
of
Costs
and
Emission
Reductions
for
24
CMAQ
Projects"
(
September
1999)

www.
epa.
gov/
otaq/
transp/
publicat/
pub_
volu.
htm
"
Quantification
of
Episodic
Control
Programs"
(
EPA420­
R­
97­
0061,

April
1997)

www.
epa.
gov
/
oms/
transp/
comchoic/
sipguide.
pdf
"
Index
of
Transportation
Measure
Quantification
Efforts:
Methodology
Matrix"
(
EPA420­
R­
98­
018,
September
1998)

www.
epa.
gov/
oms/
transp/
comchoic/
sipguide.
pdf
"
State
Implementation
Plan
Development
Guidance:
Using
Emission
Reductions
from
Commuter
Choice
Programs
to
Meet
Clean
Air
Act
Requirements"
(
EPA420­
R­
98­
007,
December
1998)

www.
epa.
gov/
otaq/
transp/
publicat/
pub_
tcms.
htm
"
Benefit
Estimates
for
selected
TCM
Programs"
(
EPA420­
R­
98­
002,
July
1999)

www.
epa.
gov/
otaq/
transp/
publicat/
pub_
tech.
htm
Transportation
and
Air
Quality
ACM
Technical
Overviews.
These
documents
provide
overviews
of
individual
TCMs,
discussing
their
advantages,
disadvantages,
and
issues
involved
in
their
implementation.

Topics:
Accelerated
Retirement
of
Vehicles,
Bicycle
and
Pedestrian
Programs,
Commute
Alternative
Incentives,
Congestion
Pricing,

Guaranteed
Ride
Home,
High
Occupancy
Vehicle
Lanes,
Intelligent
Transportation
Systems,
Parking
Management,
Parking
Pricing,

Improved
Public
Transit,
Telecommuting,
Traffic
Flow
Improvements,

Trip
Reduction
Ordinances,
Work
Schedule
Changes
2
www.
epa.
gov/
otaq/
transp/
publicat/
pub_
mrkt.
htm
"
Opportunities
to
Improve
Air
Quality
Through
Transportation
Pricing
Programs"
(
EPA420­
R­
97­
004,
July
1997)

www.
epa.
gov/
otaq/
transp/
publicat/
pub_
pedo.
htm
"
TDM
Case
Studies
and
Commuter
Testimonials"
(
August,
1997)

Successful
transportation
demand
management
programs
are
described
in
19
case
studies.

www.
epa.
gov/
dced/
pdf/
comparing_
methodologies.
pdf
"
Comparing
Methodologies
to
Assess
Transportation
and
Air
Quality
Impacts
of
Brownfields
and
Infill
Development"
(
EPA­
231­
R­
01­
001,

August
2001)

PDF
file
will
be
made
available
on
EAC
website
at:
www.
epa.
gov/
ttn/
naaqs/
ozone/
eac/
"
Methodologies
for
Estimating
Emission
and
Travel
Activity
Effects
of
TCMs"
(
EPA­
420­
R­
94­
002,
July
1994)

www.
epa.
gov/
ttn/
chief/
Clearinghouse
for
Inventories
and
Emission
Factors,
including
a
new
draft
of
an
update
to
the
1999
National
Emission
Inventory
(
March
11,

2003)

PDF
file
will
be
made
available
on
EAC
website
at:
www.
epa.
gov/
ttn/
naaqs/
ozone/
eac/
"
Meeting
the
15­
Percent
Rate­
of­
Progress
Requirement
Under
the
Clean
Air
Act:
A
Menu
of
Options,"
STAPPA/
ALAPCO,
September
1993.

PDF
file
will
be
made
available
on
EAC
website
at:
www.
epa.
gov/
ttn/
naaqs/
ozone/
eac/
"
Controlling
Nitrogen
Oxides
Under
the
Clean
Air
Act:
A
Menu
of
Options,"
STAPPA/
ALAPCO,
July
1994.

PDF
file
will
be
made
available
on
EAC
website
at:
www.
epa.
gov/
ttn/
naaqs/
ozone/
eac/
"
Serious
and
Severe
Ozone
Nonattainment
Areas:
Information
on
Emissions,
Control
Measures
Adopted
or
Planned
and
Other
Available
Control
Measures,"
November
24,
1999.

www.
epa.
gov/
otaq/
voluntary.
htm
EPA
Website:
Transportation
and
Air
Quality
Voluntary
Programs,

including
Green
Vehicle
Guide,
Voluntary
Diesel
Retrofit
Program,
and
Commuter
Choice
Leadership
Initiative,
U.
S.
EPA
(
updated
January
10,

2003)
3
www.
epa.
gov/
otaq/
transp/
traqdata.
htm
EPA
Website:
Transportation
and
Air
Quality
Planning,
Clearinghouse
and
Databases.
Includes
Survey
of
Episodic
Control
Programs,
Market
Incentives
Resource
Center
for
Air
Quality
Programs,
Smart
Travel
Resource
Center,
Transportation­
related
Grants
Database,
and
Transportation
Control
Measures
Program
Information
Directory
(
updated
June
28,
2002)

www.
epa.
gov/
otaq/
transp/
landguid.
htm
"
Improving
Air
Quality
Through
Land
Use
Activities."
Report
(
EPA420­
R­
01­
001,
January
2001)

www.
epa.
gov/
otaq/
transp/
traqtcms.
htm
EPA
Website
on
Transportation
Control
Measures:
On­
line
Database;

Methodologies
for
Estimating
Emission
and
Travel
Activity
Effects
of
TCMs
­
(
EPA420­
R­
97­
004,
July
1997)

www.
trb.
org
Transportation
Research
Board
Website:
Quantifying
Air­
quality
and
Other
Benefits
and
Costs
of
Transportation
Control
Measures
