December
2002
Attachment
1
South
Carolina
Early
Action
Compacts
Early
Action
Compacts
of
South
Carolina
Attachment
Early
Action
Compact
Name
Designations
1­
A
Appalachian
1­
B
Catawba
1­
C
Pee
Dee
1­
D
Waccamaw
1­
E
Santee
Lynches
1­
F
Berkeley­
Charleston­
Dorchester
1­
G
Low
Country
1­
H
Lower
Savannah
1­
I
Central
Midlands
1­
J
Upper
Savannah
Area
Map
of
South
Carolina
Attachment
2
Appalachian
Catawba
Waccamaw
Pee
Dee
Lower
Savannah
Central
Midlands
Upper
Savannah
Santee­
Lynches
Berkeley­

Charleston­

Dorchester
Low
Country
December
2002
Attachment
3
South
Carolina
Early
Action
SIP
Letters
of
Support
Attachment
1
­
F
Berkeley­
Charleston­
Dorchester
South
Carolina
Early
Action
Compacts
December
2002
1
SOUTH
CAROLINA'S
8­
HOUR
OZONE
EARLY
ACTION
COMPACT
Berkeley
County
The
United
States
Environmental
Protection
Agency
(
EPA)
has
provided
an
option
for
areas
currently
meeting
the
1­
hour
ozone
standard,
like
those
in
South
Carolina,
to
attain
the
8­
hour
ozone
standard
by
December
31,
2007,
and
obtain
cleaner
air
sooner
than
federally
mandated.
This
option
offers
a
more
expeditious
time
line
for
achieving
emissions
reductions
than
expected
under
the
EPA's
8­
hour
ozone
implementation
rulemaking,
while
providing
"
fail­
safe"
provisions
for
the
area
to
revert
to
the
traditional
State
Implementation
Plan
(
SIP)
process
if
specific
milestones
are
not
met.
Through
the
development
of
this
Early
Action
Compact
(
EAC),
local,
state,
and
EPA
officials
agree
to
work
together
to
develop
and
implement
local
and
state
early
action
plans.
The
plans
will
become
a
part
of
the
state
early
action
SIP
to
reduce
ground­
level
ozone
concentrations
to
comply
with
the
8­
hour
ozone
standard
by
December
31,
2007,
and
maintain
the
standard
beyond
that
date.
Failure
to
meet
the
obligations
outlined
in
this
EAC
will
result
in
immediate
reversion
to
the
traditional
non­
attainment
designation
process
as
required
in
the
Clean
Air
Act
(
CAA).

In
an
effort
to
provide
this
information
to
areas
within
South
Carolina,
the
South
Carolina
Department
of
Health
and
Environmental
Control
(
DHEC)
held
six
public
meetings
throughout
the
state.
The
locations
of
the
meetings
were
targeted
to
areas
that
could
potentially
be
designated
as
non­
attainment
for
the
8­
hour
ozone
standard.
The
meetings
were
held
in
Columbia,
Greenville,
Florence,
Rock
Hill,
Aiken
and
Charleston.
EPA
officials
participated
in
five
of
the
six
meetings.
The
general
public,
local
government
representatives,
industry
representatives,
and
environmental
interest
groups
attended
the
meetings.
Prior
to
the
meetings,
DHEC
issued
a
press
release
regarding
the
development
of
an
early
action
SIP.
Correspondence
including
a
fact
sheet
was
sent
to
all
county
administrators,
Councils
of
Governments,
Metropolitan
Planning
Organizations,
public
interest
groups,
industry
representatives,
other
state
agencies
and
others
determined
to
be
stakeholders
in
the
process.

The
Parties
to
this
EAC
are:
Berkeley
County,
South
Carolina
Department
of
Health
and
Environmental
Control
(
DHEC)
and
EPA.

I.
General
Provisions
A.
The
parties
commit
to
develop,
implement
and
maintain
the
early
action
SIP
(
which
includes
the
local
early
action
plans)
providing
EPA
defers
the
effective
date
of
the
non­
attainment
designation
and
related
requirements
as
long
as
all
conditions
of
the
EAC
and
key
milestones
are
met.

B.
If
the
potential
area
of
non­
attainment
does
not
meet
all
the
terms
of
the
EAC,
then
it
will
forfeit
its
participation
and
will
be
subject
to
the
full
planning
requirements
under
applicable
CAA
2
traditional
SIP
processes
including
requirements
defined
as
part
of
the
EPA's
8­
hour
ozone
implementation
rulemaking.

C.
If
the
area
has
had
the
effective
date
of
a
non­
attainment
designation
deferred
and
the
area
does
not
reach
attainment
of
the
standard
by
December
31,
2007,
then
the
non­
attainment
designation
will
be
effective.
If
the
EPA's
implementation
schedule
also
requires
a
traditional
SIP
from
areas
on
or
before
December
31,
2007,
then
a
traditional
SIP
revision
demonstrating
attainment
by
the
new
attainment
date
will
be
due
for
the
non­
attainment
area
no
later
than
December
31,
2008.

D.
Before
formal
adoption
into
the
early
action
SIP,
this
agreement
may
be
modified
or
terminated
by
mutual
consent
of
all
parties,
or
any
party
may
withdraw
from
the
agreement
by
notifying
other
parties
in
writing.
If
a
party's
withdrawal
from
the
agreement
prevents
remaining
signatories
from
satisfying
any
of
the
terms
and
milestones
of
the
original
agreement,
the
agreement
will
be
void,
any
deferred
effective
date
of
the
non­
attainment
designation
would
be
withdrawn
and
the
area's
non­
attainment
designation
would
become
effective
soon
after.
Upon
termination
or
withdrawal
from
the
EAC,
the
area
will
be
subject
to
the
full
planning
requirements
under
applicable
CAA
traditional
processes
including
requirements
defined
as
part
of
the
EPA's
8­
hour
ozone
implementation
rulemaking.
The
local
government
signatories
will
approve
the
local
early
action
plans
before
submittal
to
DHEC
for
inclusion
in
the
early
action
SIP.
Once
the
local
early
action
plan
is
incorporated
into
the
early
action
SIP,
any
modifications
will
be
treated
as
SIP
revisions.

E.
Execution
of
this
EAC
by
each
Party
shall
be
by
signature
of
each
Party's
authorized
representative.
This
agreement
remains
in
effect
until
December
31,
2007.

II.
Early
Action
Compact
Requirements
A.
Milestones
and
Reporting
DHEC
and
local
areas
will
assess
progress
towards
developing
and
implementing
the
early
action
SIP
and
make
a
report
available
to
EPA
and
the
public
every
six
months
beginning
in
June
2003.
As
per
EPA
guidance,
the
key
milestones
for
participation
in
the
EAC
are
identified
in
the
following
table.
3
Local
Plan
/
Early
Action
SIP
Milestones
DATE
MILESTONE
RESPONSIBILITY
December
31,
2002
EAC
signed
by
all
parties
and
submitted
to
EPA
Local/
State/
EPA
June
16,
2003
Discussion
of
control
measures
being
considered
to
EPA
Local/
State
March
31,
2004
Final
local
early
action
plan
submitted
to
DHEC;
copy
to
EPA
Local
December
31,
2004
Early
Action
State
Implementation
Plan
submitted
to
EPA
for
incorporation
into
SIP
State
April
1,
2005
Local/
State
control
strategies
implemented
no
later
than
this
date
Local/
State
September
30,
2005
EPA
takes
final
action
on
SIP
submitted
December
31,
2004
EPA
June
30,
2006
State
submits
progress
report
to
EPA
State
December
31,
2007
Attainment
of
the
8­
hour
ozone
standard
Local/
State
B.
Emissions
Inventories
1.
DHEC
will
be
responsible
for
developing
emissions
inventories.

2.
An
initial
modeling
emissions
inventory
will
be
completed
by
December
31,
2002.
This
inventory
includes:
a.
Emissions
modeling
data
for
a
1998
episode
that
is
representative
of
a
typical
ozone
season
exceedance
that
meets
the
EPA
episode
selection
guidance;
b.
MOBILE6
for
determining
on­
road
mobile
emissions;
c.
NONROAD
model
data;
and,
d.
Area
source
database
utilizing
population
data
allocated
statewide.

3.
A
2007
future
year
modeling
emissions
inventory
will
be
developed
by
March
31,
2004.
This
inventory
will
sufficiently
account
for
projected
future
growth
in
ozone
precursor
emissions
through
2007,
particularly
from
stationary,
non­
road
and
on­
road
mobile
sources.

4.
Additional
inventories
will
be
contingent
upon
legislative
appropriations
or
other
funding.
Selection
of
specific
episode
inventories
will
be
partially
determined
by
the
conceptual
model,
which
reflects
an
analysis
of
meteorological
conditions
typical
of
high
ozone
events.

5.
Emissions
inventories
will
be
compared
and
analyzed
for
trends
in
emission
sources
over
time.
The
emissions
inventory
comparison
and
analysis
will
be
completed
by
December
31,
2003.
4
C.
Modeling
1.
DHEC
will
be
responsible
for
conducting
the
meteorological
and
air
quality
modeling
analysis.
DHEC
will
conduct
the
modeling
analysis
based
on
the
"
Draft
Guidance
on
the
use
of
Models
and
Other
Analyses
in
Attainment
Demonstrations
for
the
8­
Hour
Ozone
NAAQS"
(
EPA­
454/
R­
99­
004,
May
1999).
The
modeling
will
follow
the
guidance
as
facilitated
by
the
EPA
Regional
Office.

2.
Base
case
modeling
will
be
completed
by
December
31,
2002.
Future
case
modeling
will
be
completed
by
October
31,
2003.
One
or
more
modeled
control
cases
will
be
completed
by
January
31,
2004,
with
final
revisions
completed
by
March
31,
2004.
All
modeling
will:
 
be
SIP
quality
and
perform
within
EPA's
accepted
margin
of
accuracy;
 
be
carefully
documented;
 
sufficiently
account
for
projected
future
growth
in
ozone
precursor
emissions;
 
be
accomplished
by
DHEC
and
reviewed
by
EPA;
and,
 
be
used
to
determine
the
effectiveness
of
NOx
and/
or
VOC
reductions.
The
control
case(
s)
will
be
used
to
determine
the
relative
effectiveness
of
different
emission
reduction
strategies
and
to
aid
in
the
selection
of
appropriate
emission
reduction
strategies.

D.
Control
Strategies
1.
All
adopted
Federal
and
State
control
strategies
that
have
been
or
will
be
implemented
by
the
December
31,
2007,
attainment
date
will
be
included
in
base,
future
and
control
case
modeling.

2.
Additional
local
and
state
control
strategies
under
consideration
will
be
identified
by
June
16,
2003.
The
local
and
state
control
strategies
selected
will
be
implemented
as
soon
as
practical,
but
no
later
than
April
1,
2005.

3.
Local
and
state
control
strategies
will
be
specific,
quantified,
permanent
and
enforceable.
The
strategies
will
also
include
specific
implementation
dates
and
detailed
documentation
and
reporting
processes.

4.
Voluntary
strategies
can
play
a
supporting
role
in
the
local
early
action
plan
and
the
early
action
SIP.
If
emission
reductions
from
voluntary
strategies
are
quantified
and
credit
is
taken
for
them
in
the
local
early
action
plan
or
the
early
action
SIP,
those
emission
reductions
will
be
enforceable.
Additional
strategies
must
be
implemented
to
meet
those
quantified
reduction
requirements
if
quantified
voluntary
strategies
fail.
This
is
true
for
all
quantified
emission
reductions.

5.
Local
and
state
control
strategies
will
be
designed
and
implemented
with
full
stakeholder
participation.
5
6.
Local
and
state
control
strategies
will
be
incorporated
by
DHEC
into
the
early
action
SIP.
In
the
event
that
the
local
area
desires
to
add,
delete
or
substitute
strategies
after
early
action
SIP
submittal,
the
local
area
will
request
a
modification.
Local
early
action
plan
modifications
will
be
treated
as
SIP
revisions
and
facilitated
by
DHEC.

E.
Maintenance
for
Growth
1.
The
early
action
SIP
will
include
a
component
to
address
emissions
growth
at
least
five
years
beyond
December
31,
2007,
ensuring
that
the
areas
will
remain
in
attainment
of
the
8­
hour
ozone
standard
during
that
period.
Attainment
maintenance
analysis
will
be
completed
by
January
31,
2004,
with
final
revisions
completed
by
March
31,
2004.
The
analysis
will
employ
one
or
more
of
the
following
or
any
other
appropriate
techniques
necessary
to
make
such
a
demonstration:
a.
Modeling
analysis
showing
ozone
levels
below
the
8­
hour
ozone
standard
in
2012;
b.
An
annual
review
of
growth
(
especially
mobile
and
stationary
source)
to
ensure
control
measures
and
growth
assumptions
are
adequate;
c.
Identification
and
quantification
of
federal,
state,
and/
or
local
measures
indicating
sufficient
reductions
to
offset
growth
estimates;
or,
d.
Any
other
appropriate
techniques
necessary
to
make
such
a
determination.

2.
The
early
action
SIP
must
also
detail
a
continuing
planning
process
that
includes
modeling
updates
and
modeling
assumption
verification
(
particularly
growth
assumptions).
Modeling
updates
and
planning
processes
must
consider
and
evaluate
the
following:
a.
All
relevant
actual
new
point
sources;
b.
Impacts
from
potential
new
source
growth;
and,
c.
Future
transportation
patterns
and
their
impact
on
air
quality
in
a
manner
that
is
consistent
with
the
most
current
adopted
Long
Range
Transportation
Plan
and
most
current
trend
and
projections
of
local
motor
vehicle
emissions.

3.
If
the
review
of
emissions
growth
in
conjunction
with
the
continuing
planning
process
demonstrates
that
adopted
emission
reduction
strategies
are
inadequate
to
address
growth
in
emissions,
additional
measures
will
be
added
to
the
early
action
plan.
Local
planning
processes
should
prepare
for
this
possibility.

4.
In
the
event
that
the
continuing
planning
process
identifies
the
need
to
add,
delete,
or
substitute
control
strategies
after
the
local
early
action
plan
has
been
incorporated
into
the
early
action
SIP,
the
local
area
will
initiate,
and
DHEC
will
facilitate
a
SIP
revision
to
accommodate
changes.
6
F.
Public
Involvement
1.
Public
involvement
has
been
and
will
continue
to
be
strongly
encouraged
during
the
planning
and
implementation
process.

2.
Public
awareness
programs
will
be
used
to
provide
opportunities
for
involvement
in
the
planning
process,
implementation
of
control
strategies,
and
any
other
issues
important
to
the
area.

3.
Interested
stakeholders
(
i.
e.,
local,
state,
and
federal
government,
citizens,
public
interest
groups,
and
the
business
community)
will
continue
to
be
involved
in
the
planning
process
as
early
as
possible.
Planning
meetings
will
be
open
to
the
public,
with
posted
meeting
times
and
locations.
Early
action
SIP
drafts
will
be
publicly
available,
and
the
drafting
process
will
have
sufficient
opportunities
for
comment
from
all
interested
stakeholders.

4.
Opportunities
for
public
comment
on
the
proposed
early
action
SIP
will
be
provided
and
will
follow
the
traditional
SIP
revision
process
as
implemented
by
DHEC.

5.
Semi­
annual
reports
detailing,
at
a
minimum,
progress
toward
key
milestones,
will
be
made
available
to
the
public.

6.
DHEC
has
established
and
will
maintain
a
website
for
South
Carolina's
Early
Action
Plan
for
the
8­
hour
ozone
standard,
located
at
www.
scdhec.
net/
baq/
eap.
html.

III.
Local
Government
Responsibilities
The
local
governments
agree
to
develop
and
implement
a
local
early
action
plan
that
will
promote
the
area's
attainment
by
December
31,
2007,
of
the
8­
hour
ozone
standard
and
maintenance
until
at
least
2012.
The
local
governments
will
develop
this
plan
in
coordination
with
the
DHEC,
EPA,
stakeholders
and
the
public.
The
local
early
action
plan
will
include
a
process
to
evaluate
the
effectiveness
and
maintain
long­
term
compliance
with
the
standard.

After
all
adopted
Federal
and
State
controls
that
have
been
or
will
be
implemented
by
the
attainment
date
of
December
31,
2007,
are
accounted
for
in
the
modeling,
the
local
area
must
adopt
additional
local
controls,
as
necessary
to
demonstrate
attainment
of
the
8­
hour
ozone
standard
by
December
31,
2007.
Local
controls
under
consideration
must
be
identified
and
described
by
June
16,
2003.
These
measures
must
be
included
in
the
semi­
annual
report
made
available
to
the
public.

The
draft
local
early
action
plan
will
be
submitted
to
DHEC
by
August
31,
2003.
The
final
local
early
action
plan
will
be
submitted
to
DHEC,
with
a
copy
forwarded
to
EPA,
by
March
31,
2004.
The
adopted
local
early
action
plan
will
be
included
in
the
early
action
SIP
due
December
31,
2004.
7
In
the
event
a
development
or
issue
arises
that
may
impact
performance
or
progress
toward
key
milestones
(
including
if
a
key
milestone
will
be
or
has
been
missed
and/
or
if
a
termination
or
modification
has
been
requested),
the
responsible
party
will
notify
all
other
signatories
in
writing
as
soon
as
possible.

IV.
The
South
Carolina
Department
of
Health
and
Environmental
Control
DHEC
agrees
to
develop
and
implement
a
state
early
action
SIP
that
will
demonstrate
the
participating
area's
attainment
by
December
31,
2007,
of
the
8­
hour
ozone
standard
and
maintenance
until
at
least
2012.
DHEC
will
develop
this
plan
in
coordination
with
the
local
governments,
EPA,
stakeholders
and
the
public.
The
state
early
action
SIP
will
include
a
process
to
monitor
and
maintain
long­
term
compliance
with
the
standard.

It
is
the
responsibility
of
each
state
under
the
CAA
to
ensure
attainment
with
all
National
Ambient
Air
Quality
Standards.
At
any
such
time
that
an
area
is
deemed
non­
attainment,
the
state
will
be
required
to
develop
a
plan
to
return
the
area(
s)
to
attainment
in
accordance
with
the
CAA.
If
applicable,
South
Carolina
is
committed
to
working
with
adjacent
states
to
assure
mutual
attainment
of
national
standards.

In
the
event
a
development
or
issue
arises
that
may
impact
performance
or
progress
toward
key
milestones
(
including
if
a
key
milestone
will
be
or
has
been
missed
and/
or
if
a
termination
or
modification
has
been
requested),
DHEC
will
notify
all
other
signatories
in
writing
as
soon
as
possible.

DHEC
will
provide
support
to
areas
throughout
the
planning
and
implementation
process
by:

1
Developing
emission
inventories,
modeling,
trend
analysis,
and
quantification
and
comparison
of
control
measures.

2.
Providing
necessary
information
on
all
federal
and
state
adopted
emission
reduction
measures,
which
affect
the
area.

3.
Providing
technical
and
strategic
assistance,
as
appropriate,
in
the
selection
and
implementation
of
control
strategies.

4.
Providing
technical
and
planning
assistance
in
developing
and
implementing
processes
to
address
the
impact
of
emissions
growth
beyond
the
attainment
date.

5.
Maintaining
monitors
and
reporting
and
analysis
of
monitoring
data.

6.
Promoting
public
awareness
efforts.

7.
Coordinating
communication
between
local
areas
and
the
EPA
to
facilitate
continuing
the
EPA
review
of
local
work.

8.
Ensuring
expeditious
review
of
local
early
action
plan(
s),
and
if
deemed
adequate,
proposing
modification
of
the
early
action
SIP
to
adopt
the
early
action
plan.
8
9.
Adopting
control
measures
into
the
early
action
SIP
as
expeditiously
as
possible.
The
final
complete
early
action
SIP
revision
must
be
completed,
adopted,
and
submitted
by
the
state
to
the
EPA
by
December
31,
2004.

10.
Tracking
progress.
If
any
milestone
is
missed
and
EPA
withdraws
the
deferred
effective
date,
thereby
triggering
a
non­
attainment
designation
and
applicable
statutory
requirements,
the
state
will
strive
to
submit
a
traditional
non­
attainment
SIP
within
one
year.
However,
due
to
the
South
Carolina
legislative
review
process,
it
may
take
at
least
eighteen
months.

11.
Working
concurrently
with
areas
not
electing
to
participate
in
the
early
action
SIP
process
in
preparing
the
traditional
SIP
submittal
as
required
by
the
CAA.

V.
The
Environmental
Protection
Agency
The
EPA
will
participate
by:

1.
Recognizing
the
local
area's
and
state's
commitment
to
voluntarily
adopt
an
early,
substantive,
enforceable,
and
scientifically­
based
attainment
plan
with
early
implementation
of
control
measures
by
becoming
a
party
to
the
EAC
developed
in
conformance
with
South
Carolina's
Protocol
for
Early
Action
Compacts.

2.
Providing
technical
assistance
to
the
state(
s)
and
local
area(
s)
in
the
development
of
the
early
action
plan.

3.
Reviewing
and
approving
the
completed
early
action
SIP
by
no
later
than
September
30,
2005.

4.
Deferring
the
effective
date
of
non­
attainment
designation
and
related
requirements
for
participating
areas
that
fail
to
meet
the
8­
hour
ozone
standard
as
long
as
all
terms
and
key
milestones
of
the
EAC
are
being
met,
including
submission
of
the
early
action
SIP
revision
by
December
31,
2004.

5.
Designating
the
area
expeditiously
as
attainment
and
imposing
no
additional
requirements,
provided
that
the
monitors
in
the
area
reflect
attainment
by
December
31,
2007.

6.
Taking
action
to
withdraw
the
deferred
effective
date
if
the
area
violates
the
standard
as
of
December
31,
2007,
and
the
area
has
had
the
effective
date
of
its
non­
attainment
designation
deferred.
The
area's
non­
attainment
designation
will
become
effective
soon
after.

7.
Ensuring
appropriate
credit
in
the
traditional
SIP
process
for
all
emissions
reductions
from
measures
implemented
in
the
early
action
SIP
if
the
area
does
not
meet
all
the
terms
of
the
EAC;
including
meeting
agreed­
upon
key
milestones
and
is
designated
(
or
redesignated
if
necessary)
according
to
the
EPA's
8­
hour
ozone
implementation
guidelines.
The
EPA
will
offer
such
an
area
no
delays,
exemptions,
or
other
favorable
treatment
because
of
its
participation
in
the
EAC.
1
SOUTH
CAROLINA'S
8­
HOUR
OZONE
EARLY
ACTION
COMPACT
Charleston
County
The
United
States
Environmental
Protection
Agency
(
EPA)
has
provided
an
option
for
areas
currently
meeting
the
1­
hour
ozone
standard,
like
those
in
South
Carolina,
to
attain
the
8­
hour
ozone
standard
by
December
31,
2007,
and
obtain
cleaner
air
sooner
than
federally
mandated.
This
option
offers
a
more
expeditious
time
line
for
achieving
emissions
reductions
than
expected
under
the
EPA's
8­
hour
ozone
implementation
rulemaking,
while
providing
"
fail­
safe"
provisions
for
the
area
to
revert
to
the
traditional
State
Implementation
Plan
(
SIP)
process
if
specific
milestones
are
not
met.
Through
the
development
of
this
Early
Action
Compact
(
EAC),
local,
state,
and
EPA
officials
agree
to
work
together
to
develop
and
implement
local
and
state
early
action
plans.
The
plans
will
become
a
part
of
the
state
early
action
SIP
to
reduce
ground­
level
ozone
concentrations
to
comply
with
the
8­
hour
ozone
standard
by
December
31,
2007,
and
maintain
the
standard
beyond
that
date.
Failure
to
meet
the
obligations
outlined
in
this
EAC
will
result
in
immediate
reversion
to
the
traditional
non­
attainment
designation
process
as
required
in
the
Clean
Air
Act
(
CAA).

In
an
effort
to
provide
this
information
to
areas
within
South
Carolina,
the
South
Carolina
Department
of
Health
and
Environmental
Control
(
DHEC)
held
six
public
meetings
throughout
the
state.
The
locations
of
the
meetings
were
targeted
to
areas
that
could
potentially
be
designated
as
non­
attainment
for
the
8­
hour
ozone
standard.
The
meetings
were
held
in
Columbia,
Greenville,
Florence,
Rock
Hill,
Aiken
and
Charleston.
EPA
officials
participated
in
five
of
the
six
meetings.
The
general
public,
local
government
representatives,
industry
representatives,
and
environmental
interest
groups
attended
the
meetings.
Prior
to
the
meetings,
DHEC
issued
a
press
release
regarding
the
development
of
an
early
action
SIP.
Correspondence
including
a
fact
sheet
was
sent
to
all
county
administrators,
Councils
of
Governments,
Metropolitan
Planning
Organizations,
public
interest
groups,
industry
representatives,
other
state
agencies
and
others
determined
to
be
stakeholders
in
the
process.

The
Parties
to
this
(
EAC)
are:
Charleston
County,
South
Carolina
Department
of
Health
and
Environmental
Control
(
DHEC)
and
EPA.

I.
General
Provisions
A.
The
parties
commit
to
develop,
implement
and
maintain
the
early
action
SIP
(
which
includes
the
local
early
action
plans)
providing
EPA
defers
the
effective
date
of
the
non­
attainment
designation
and
related
requirements
as
long
as
all
conditions
of
the
EAC
and
key
milestones
are
met.

B.
If
the
potential
area
of
non­
attainment
does
not
meet
all
the
terms
of
the
EAC,
then
it
will
forfeit
its
participation
and
will
be
subject
to
the
full
planning
requirements
under
applicable
CAA
2
traditional
SIP
processes
including
requirements
defined
as
part
of
the
EPA's
8­
hour
ozone
implementation
rulemaking.

C.
If
the
area
has
had
the
effective
date
of
a
non­
attainment
designation
deferred
and
the
area
does
not
reach
attainment
of
the
standard
by
December
31,
2007,
then
the
non­
attainment
designation
will
be
effective.
If
the
EPA's
implementation
schedule
also
requires
a
traditional
SIP
from
areas
on
or
before
December
31,
2007,
then
a
traditional
SIP
revision
demonstrating
attainment
by
the
new
attainment
date
will
be
due
for
the
non­
attainment
area
no
later
than
December
31,
2008.

D.
Before
formal
adoption
into
the
early
action
SIP,
this
agreement
may
be
modified
or
terminated
by
mutual
consent
of
all
parties,
or
any
party
may
withdraw
from
the
agreement
by
notifying
other
parties
in
writing.
If
a
party's
withdrawal
from
the
agreement
prevents
remaining
signatories
from
satisfying
any
of
the
terms
and
milestones
of
the
original
agreement,
the
agreement
will
be
void,
any
deferred
effective
date
of
the
non­
attainment
designation
would
be
withdrawn
and
the
area's
non­
attainment
designation
would
become
effective
soon
after.
Upon
termination
or
withdrawal
from
the
EAC,
the
area
will
be
subject
to
the
full
planning
requirements
under
applicable
CAA
traditional
processes
including
requirements
defined
as
part
of
the
EPA's
8­
hour
ozone
implementation
rulemaking.
The
local
government
signatories
will
approve
the
local
early
action
plans
before
submittal
to
DHEC
for
inclusion
in
the
early
action
SIP.
Once
the
local
early
action
plan
is
incorporated
into
the
early
action
SIP,
any
modifications
will
be
treated
as
SIP
revisions.

E.
Execution
of
this
EAC
by
each
Party
shall
be
by
signature
of
each
Party's
authorized
representative.
This
agreement
remains
in
effect
until
December
31,
2007.

II.
Early
Action
Compact
Requirements
A.
Milestones
and
Reporting
DHEC
and
local
areas
will
assess
progress
towards
developing
and
implementing
the
early
action
SIP
and
make
a
report
available
to
EPA
and
the
public
every
six
months
beginning
in
June
2003.
As
per
EPA
guidance,
the
key
milestones
for
participation
in
the
EAC
are
identified
in
the
following
table.
3
Local
Plan
/
Early
Action
SIP
Milestones
DATE
MILESTONE
RESPONSIBILITY
December
31,
2002
EAC
signed
by
all
parties
and
submitted
to
EPA
Local/
State/
EPA
June
16,
2003
Discussion
of
control
measures
being
considered
to
EPA
Local/
State
March
31,
2004
Final
local
early
action
plan
submitted
to
DHEC;
copy
to
EPA
Local
December
31,
2004
Early
Action
State
Implementation
Plan
submitted
to
EPA
for
incorporation
into
SIP
State
April
1,
2005
Local/
State
control
strategies
implemented
no
later
than
this
date
Local/
State
September
30,
2005
EPA
takes
final
action
on
SIP
submitted
December
31,
2004
EPA
June
30,
2006
State
submits
progress
report
to
EPA
State
December
31,
2007
Attainment
of
the
8­
hour
ozone
standard
Local/
State
B.
Emissions
Inventories
1.
DHEC
will
be
responsible
for
developing
emissions
inventories.

2.
An
initial
modeling
emissions
inventory
will
be
completed
by
December
31,
2002.
This
inventory
includes:
a.
Emissions
modeling
data
for
a
1998
episode
that
is
representative
of
a
typical
ozone
season
exceedance
that
meets
the
EPA
episode
selection
guidance;
b.
MOBILE6
for
determining
on­
road
mobile
emissions;
c.
NONROAD
model
data;
and,
d.
Area
source
database
utilizing
population
data
allocated
statewide.

3.
A
2007
future
year
modeling
emissions
inventory
will
be
developed
by
March
31,
2004.
This
inventory
will
sufficiently
account
for
projected
future
growth
in
ozone
precursor
emissions
through
2007,
particularly
from
stationary,
non­
road
and
on­
road
mobile
sources.

4.
Additional
inventories
will
be
contingent
upon
legislative
appropriations
or
other
funding.
Selection
of
specific
episode
inventories
will
be
partially
determined
by
the
conceptual
model,
which
reflects
an
analysis
of
meteorological
conditions
typical
of
high
ozone
events.

5.
Emissions
inventories
will
be
compared
and
analyzed
for
trends
in
emission
sources
over
time.
The
emissions
inventory
comparison
and
analysis
will
be
completed
by
December
31,
2003.
4
C.
Modeling
1.
DHEC
will
be
responsible
for
conducting
the
meteorological
and
air
quality
modeling
analysis.
DHEC
will
conduct
the
modeling
analysis
based
on
the
"
Draft
Guidance
on
the
use
of
Models
and
Other
Analyses
in
Attainment
Demonstrations
for
the
8­
Hour
Ozone
NAAQS"
(
EPA­
454/
R­
99­
004,
May
1999).
The
modeling
will
follow
the
guidance
as
facilitated
by
the
EPA
Regional
Office.

2.
Base
case
modeling
will
be
completed
by
December
31,
2002.
Future
case
modeling
will
be
completed
by
October
31,
2003.
One
or
more
modeled
control
cases
will
be
completed
by
January
31,
2004,
with
final
revisions
completed
by
March
31,
2004.
All
modeling
will:
 
be
SIP
quality
and
perform
within
EPA's
accepted
margin
of
accuracy;
 
be
carefully
documented;
 
sufficiently
account
for
projected
future
growth
in
ozone
precursor
emissions;
 
be
accomplished
by
DHEC
and
reviewed
by
EPA;
and,
 
be
used
to
determine
the
effectiveness
of
NOx
and/
or
VOC
reductions.
The
control
case(
s)
will
be
used
to
determine
the
relative
effectiveness
of
different
emission
reduction
strategies
and
to
aid
in
the
selection
of
appropriate
emission
reduction
strategies.

D.
Control
Strategies
1.
All
adopted
Federal
and
State
control
strategies
that
have
been
or
will
be
implemented
by
the
December
31,
2007,
attainment
date
will
be
included
in
base,
future
and
control
case
modeling.

2.
Additional
local
and
state
control
strategies
under
consideration
will
be
identified
by
June
16,
2003.
The
local
and
state
control
strategies
selected
will
be
implemented
as
soon
as
practical,
but
no
later
than
April
1,
2005.

3.
Local
and
state
control
strategies
will
be
specific,
quantified,
permanent
and
enforceable.
The
strategies
will
also
include
specific
implementation
dates
and
detailed
documentation
and
reporting
processes.

4.
Voluntary
strategies
can
play
a
supporting
role
in
the
local
early
action
plan
and
the
early
action
SIP.
If
emission
reductions
from
voluntary
strategies
are
quantified
and
credit
is
taken
for
them
in
the
local
early
action
plan
or
the
early
action
SIP,
those
emission
reductions
will
be
enforceable.
Additional
strategies
must
be
implemented
to
meet
those
quantified
reduction
requirements
if
quantified
voluntary
strategies
fail.
This
is
true
for
all
quantified
emission
reductions.

5.
Local
and
state
control
strategies
will
be
designed
and
implemented
with
full
stakeholder
participation.
5
6.
Local
and
state
control
strategies
will
be
incorporated
by
DHEC
into
the
early
action
SIP.
In
the
event
that
the
local
area
desires
to
add,
delete
or
substitute
strategies
after
early
action
SIP
submittal,
the
local
area
will
request
a
modification.
Local
early
action
plan
modifications
will
be
treated
as
SIP
revisions
and
facilitated
by
DHEC.

E.
Maintenance
for
Growth
1.
The
early
action
SIP
will
include
a
component
to
address
emissions
growth
at
least
five
years
beyond
December
31,
2007,
ensuring
that
the
areas
will
remain
in
attainment
of
the
8­
hour
ozone
standard
during
that
period.
Attainment
maintenance
analysis
will
be
completed
by
January
31,
2004,
with
final
revisions
completed
by
March
31,
2004.
The
analysis
will
employ
one
or
more
of
the
following
or
any
other
appropriate
techniques
necessary
to
make
such
a
demonstration:
a.
Modeling
analysis
showing
ozone
levels
below
the
8­
hour
ozone
standard
in
2012;
b.
An
annual
review
of
growth
(
especially
mobile
and
stationary
source)
to
ensure
control
measures
and
growth
assumptions
are
adequate;
c.
Identification
and
quantification
of
federal,
state,
and/
or
local
measures
indicating
sufficient
reductions
to
offset
growth
estimates;
or,
d.
Any
other
appropriate
techniques
necessary
to
make
such
a
determination.

2.
The
early
action
SIP
must
also
detail
a
continuing
planning
process
that
includes
modeling
updates
and
modeling
assumption
verification
(
particularly
growth
assumptions).
Modeling
updates
and
planning
processes
must
consider
and
evaluate
the
following:
a.
All
relevant
actual
new
point
sources;
b.
Impacts
from
potential
new
source
growth;
and,
c.
Future
transportation
patterns
and
their
impact
on
air
quality
in
a
manner
that
is
consistent
with
the
most
current
adopted
Long
Range
Transportation
Plan
and
most
current
trend
and
projections
of
local
motor
vehicle
emissions.

3.
If
the
review
of
emissions
growth
in
conjunction
with
the
continuing
planning
process
demonstrates
that
adopted
emission
reduction
strategies
are
inadequate
to
address
growth
in
emissions,
additional
measures
will
be
added
to
the
early
action
plan.
Local
planning
processes
should
prepare
for
this
possibility.

4.
In
the
event
that
the
continuing
planning
process
identifies
the
need
to
add,
delete,
or
substitute
control
strategies
after
the
local
early
action
plan
has
been
incorporated
into
the
early
action
SIP,
the
local
area
will
initiate,
and
DHEC
will
facilitate
a
SIP
revision
to
accommodate
changes.
6
F.
Public
Involvement
1.
Public
involvement
has
been
and
will
continue
to
be
strongly
encouraged
during
the
planning
and
implementation
process.

2.
Public
awareness
programs
will
be
used
to
provide
opportunities
for
involvement
in
the
planning
process,
implementation
of
control
strategies,
and
any
other
issues
important
to
the
area.

3.
Interested
stakeholders
(
i.
e.,
local,
state,
and
federal
government,
citizens,
public
interest
groups,
and
the
business
community)
will
continue
to
be
involved
in
the
planning
process
as
early
as
possible.
Planning
meetings
will
be
open
to
the
public,
with
posted
meeting
times
and
locations.
Early
action
SIP
drafts
will
be
publicly
available,
and
the
drafting
process
will
have
sufficient
opportunities
for
comment
from
all
interested
stakeholders.

4.
Opportunities
for
public
comment
on
the
proposed
early
action
SIP
will
be
provided
and
will
follow
the
traditional
SIP
revision
process
as
implemented
by
DHEC.

5.
Semi­
annual
reports
detailing,
at
a
minimum,
progress
toward
key
milestones,
will
be
made
available
to
the
public.

6.
DHEC
has
established
and
will
maintain
a
website
for
South
Carolina's
Early
Action
Plan
for
the
8­
hour
ozone
standard,
located
at
www.
scdhec.
net/
baq/
eap.
html.

III.
Local
Government
Responsibilities
The
local
governments
agree
to
develop
and
implement
a
local
early
action
plan
that
will
promote
the
area's
attainment
by
December
31,
2007,
of
the
8­
hour
ozone
standard
and
maintenance
until
at
least
2012.
The
local
governments
will
develop
this
plan
in
coordination
with
the
DHEC,
EPA,
stakeholders
and
the
public.
The
local
early
action
plan
will
include
a
process
to
evaluate
the
effectiveness
and
maintain
long­
term
compliance
with
the
standard.

After
all
adopted
Federal
and
State
controls
that
have
been
or
will
be
implemented
by
the
attainment
date
of
December
31,
2007,
are
accounted
for
in
the
modeling,
the
local
area
must
adopt
additional
local
controls,
as
necessary
to
demonstrate
attainment
of
the
8­
hour
ozone
standard
by
December
31,
2007.
Local
controls
under
consideration
must
be
identified
and
described
by
June
16,
2003.
These
measures
must
be
included
in
the
semi­
annual
report
made
available
to
the
public.

The
draft
local
early
action
plan
will
be
submitted
to
DHEC
by
August
31,
2003.
The
final
local
early
action
plan
will
be
submitted
to
DHEC,
with
a
copy
forwarded
to
EPA,
by
March
31,
2004.
The
adopted
local
early
action
plan
will
be
included
in
the
early
action
SIP
due
December
31,
2004.
7
In
the
event
a
development
or
issue
arises
that
may
impact
performance
or
progress
toward
key
milestones
(
including
if
a
key
milestone
will
be
or
has
been
missed
and/
or
if
a
termination
or
modification
has
been
requested),
the
responsible
party
will
notify
all
other
signatories
in
writing
as
soon
as
possible.

IV.
The
South
Carolina
Department
of
Health
and
Environmental
Control
DHEC
agrees
to
develop
and
implement
a
state
early
action
SIP
that
will
demonstrate
the
participating
area's
attainment
by
December
31,
2007,
of
the
8­
hour
ozone
standard
and
maintenance
until
at
least
2012.
DHEC
will
develop
this
plan
in
coordination
with
the
local
governments,
EPA,
stakeholders
and
the
public.
The
state
early
action
SIP
will
include
a
process
to
monitor
and
maintain
long­
term
compliance
with
the
standard.

It
is
the
responsibility
of
each
state
under
the
CAA
to
ensure
attainment
with
all
National
Ambient
Air
Quality
Standards.
At
any
such
time
that
an
area
is
deemed
non­
attainment,
the
state
will
be
required
to
develop
a
plan
to
return
the
area(
s)
to
attainment
in
accordance
with
the
CAA.
If
applicable,
South
Carolina
is
committed
to
working
with
adjacent
states
to
assure
mutual
attainment
of
national
standards.

In
the
event
a
development
or
issue
arises
that
may
impact
performance
or
progress
toward
key
milestones
(
including
if
a
key
milestone
will
be
or
has
been
missed
and/
or
if
a
termination
or
modification
has
been
requested),
DHEC
will
notify
all
other
signatories
in
writing
as
soon
as
possible.

DHEC
will
provide
support
to
areas
throughout
the
planning
and
implementation
process
by:

1
Developing
emission
inventories,
modeling,
trend
analysis,
and
quantification
and
comparison
of
control
measures.

2.
Providing
necessary
information
on
all
federal
and
state
adopted
emission
reduction
measures,
which
affect
the
area.

3.
Providing
technical
and
strategic
assistance,
as
appropriate,
in
the
selection
and
implementation
of
control
strategies.

4.
Providing
technical
and
planning
assistance
in
developing
and
implementing
processes
to
address
the
impact
of
emissions
growth
beyond
the
attainment
date.

5.
Maintaining
monitors
and
reporting
and
analysis
of
monitoring
data.

6.
Promoting
public
awareness
efforts.

7.
Coordinating
communication
between
local
areas
and
the
EPA
to
facilitate
continuing
the
EPA
review
of
local
work.

8.
Ensuring
expeditious
review
of
local
early
action
plan(
s),
and
if
deemed
adequate,
proposing
modification
of
the
early
action
SIP
to
adopt
the
early
action
plan.
8
9.
Adopting
control
measures
into
the
early
action
SIP
as
expeditiously
as
possible.
The
final
complete
early
action
SIP
revision
must
be
completed,
adopted,
and
submitted
by
the
state
to
the
EPA
by
December
31,
2004.

10.
Tracking
progress.
If
any
milestone
is
missed
and
EPA
withdraws
the
deferred
effective
date,
thereby
triggering
a
non­
attainment
designation
and
applicable
statutory
requirements,
the
state
will
strive
to
submit
a
traditional
non­
attainment
SIP
within
one
year.
However,
due
to
the
South
Carolina
legislative
review
process,
it
may
take
at
least
eighteen
months.

11.
Working
concurrently
with
areas
not
electing
to
participate
in
the
early
action
SIP
process
in
preparing
the
traditional
SIP
submittal
as
required
by
the
CAA.

V.
The
Environmental
Protection
Agency
The
EPA
will
participate
by:

1.
Recognizing
the
local
area's
and
state's
commitment
to
voluntarily
adopt
an
early,
substantive,
enforceable,
and
scientifically­
based
attainment
plan
with
early
implementation
of
control
measures
by
becoming
a
party
to
the
EAC
developed
in
conformance
with
South
Carolina's
Protocol
for
Early
Action
Compacts.

2.
Providing
technical
assistance
to
the
state(
s)
and
local
area(
s)
in
the
development
of
the
early
action
plan.

3.
Reviewing
and
approving
the
completed
early
action
SIP
by
no
later
than
September
30,
2005.

4.
Deferring
the
effective
date
of
non­
attainment
designation
and
related
requirements
for
participating
areas
that
fail
to
meet
the
8­
hour
ozone
standard
as
long
as
all
terms
and
key
milestones
of
the
EAC
are
being
met,
including
submission
of
the
early
action
SIP
revision
by
December
31,
2004.

5.
Designating
the
area
expeditiously
as
attainment
and
imposing
no
additional
requirements,
provided
that
the
monitors
in
the
area
reflect
attainment
by
December
31,
2007.

6.
Taking
action
to
withdraw
the
deferred
effective
date
if
the
area
violates
the
standard
as
of
December
31,
2007,
and
the
area
has
had
the
effective
date
of
its
non­
attainment
designation
deferred.
The
area's
non­
attainment
designation
will
become
effective
soon
after.

7.
Ensuring
appropriate
credit
in
the
traditional
SIP
process
for
all
emissions
reductions
from
measures
implemented
in
the
early
action
SIP
if
the
area
does
not
meet
all
the
terms
of
the
EAC;
including
meeting
agreed­
upon
key
milestones
and
is
designated
(
or
redesignated
if
necessary)
according
to
the
EPA's
8­
hour
ozone
implementation
guidelines.
The
EPA
will
offer
such
an
area
no
delays,
exemptions,
or
other
favorable
treatment
because
of
its
participation
in
the
EAC.
1
SOUTH
CAROLINA'S
8­
HOUR
OZONE
EARLY
ACTION
COMPACT
Dorchester
County
The
United
States
Environmental
Protection
Agency
(
EPA)
has
provided
an
option
for
areas
currently
meeting
the
1­
hour
ozone
standard,
like
those
in
South
Carolina,
to
attain
the
8­
hour
ozone
standard
by
December
31,
2007,
and
obtain
cleaner
air
sooner
than
federally
mandated.
This
option
offers
a
more
expeditious
time
line
for
achieving
emissions
reductions
than
expected
under
the
EPA's
8­
hour
ozone
implementation
rulemaking,
while
providing
"
fail­
safe"
provisions
for
the
area
to
revert
to
the
traditional
State
Implementation
Plan
(
SIP)
process
if
specific
milestones
are
not
met.
Through
the
development
of
this
Early
Action
Compact
(
EAC),
local,
state,
and
EPA
officials
agree
to
work
together
to
develop
and
implement
local
and
state
early
action
plans.
The
plans
will
become
a
part
of
the
state
early
action
SIP
to
reduce
ground­
level
ozone
concentrations
to
comply
with
the
8­
hour
ozone
standard
by
December
31,
2007,
and
maintain
the
standard
beyond
that
date.
Failure
to
meet
the
obligations
outlined
in
this
EAC
will
result
in
immediate
reversion
to
the
traditional
non­
attainment
designation
process
as
required
in
the
Clean
Air
Act
(
CAA).

In
an
effort
to
provide
this
information
to
areas
within
South
Carolina,
the
South
Carolina
Department
of
Health
and
Environmental
Control
(
DHEC)
held
six
public
meetings
throughout
the
state.
The
locations
of
the
meetings
were
targeted
to
areas
that
could
potentially
be
designated
as
non­
attainment
for
the
8­
hour
ozone
standard.
The
meetings
were
held
in
Columbia,
Greenville,
Florence,
Rock
Hill,
Aiken
and
Charleston.
EPA
officials
participated
in
five
of
the
six
meetings.
The
general
public,
local
government
representatives,
industry
representatives,
and
environmental
interest
groups
attended
the
meetings.
Prior
to
the
meetings,
DHEC
issued
a
press
release
regarding
the
development
of
an
early
action
SIP.
Correspondence
including
a
fact
sheet
was
sent
to
all
county
administrators,
Councils
of
Governments,
Metropolitan
Planning
Organizations,
public
interest
groups,
industry
representatives,
other
state
agencies
and
others
determined
to
be
stakeholders
in
the
process.

The
Parties
to
this
EAC
are:
Dorchester
County,
South
Carolina
Department
of
Health
and
Environmental
Control
(
DHEC)
and
EPA.

I.
General
Provisions
A.
The
parties
commit
to
develop,
implement
and
maintain
the
early
action
SIP
(
which
includes
the
local
early
action
plans)
providing
EPA
defers
the
effective
date
of
the
non­
attainment
designation
and
related
requirements
as
long
as
all
conditions
of
the
EAC
and
key
milestones
are
met.

B.
If
the
potential
area
of
non­
attainment
does
not
meet
all
the
terms
of
the
EAC,
then
it
will
forfeit
its
participation
and
will
be
subject
to
the
full
planning
requirements
under
applicable
CAA
2
traditional
SIP
processes
including
requirements
defined
as
part
of
the
EPA's
8­
hour
ozone
implementation
rulemaking.

C.
If
the
area
has
had
the
effective
date
of
a
non­
attainment
designation
deferred
and
the
area
does
not
reach
attainment
of
the
standard
by
December
31,
2007,
then
the
non­
attainment
designation
will
be
effective.
If
the
EPA's
implementation
schedule
also
requires
a
traditional
SIP
from
areas
on
or
before
December
31,
2007,
then
a
traditional
SIP
revision
demonstrating
attainment
by
the
new
attainment
date
will
be
due
for
the
non­
attainment
area
no
later
than
December
31,
2008.

D.
Before
formal
adoption
into
the
early
action
SIP,
this
agreement
may
be
modified
or
terminated
by
mutual
consent
of
all
parties,
or
any
party
may
withdraw
from
the
agreement
by
notifying
other
parties
in
writing.
If
a
party's
withdrawal
from
the
agreement
prevents
remaining
signatories
from
satisfying
any
of
the
terms
and
milestones
of
the
original
agreement,
the
agreement
will
be
void,
any
deferred
effective
date
of
the
non­
attainment
designation
would
be
withdrawn
and
the
area's
non­
attainment
designation
would
become
effective
soon
after.
Upon
termination
or
withdrawal
from
the
EAC,
the
area
will
be
subject
to
the
full
planning
requirements
under
applicable
CAA
traditional
processes
including
requirements
defined
as
part
of
the
EPA's
8­
hour
ozone
implementation
rulemaking.
The
local
government
signatories
will
approve
the
local
early
action
plans
before
submittal
to
DHEC
for
inclusion
in
the
early
action
SIP.
Once
the
local
early
action
plan
is
incorporated
into
the
early
action
SIP,
any
modifications
will
be
treated
as
SIP
revisions.

E.
Execution
of
this
EAC
by
each
Party
shall
be
by
signature
of
each
Party's
authorized
representative.
This
agreement
remains
in
effect
until
December
31,
2007.

II.
Early
Action
Compact
Requirements
A.
Milestones
and
Reporting
DHEC
and
local
areas
will
assess
progress
towards
developing
and
implementing
the
early
action
SIP
and
make
a
report
available
to
EPA
and
the
public
every
six
months
beginning
in
June
2003.
As
per
EPA
guidance,
the
key
milestones
for
participation
in
the
EAC
are
identified
in
the
following
table.
3
Local
Plan
/
Early
Action
SIP
Milestones
DATE
MILESTONE
RESPONSIBILITY
December
31,
2002
EAC
signed
by
all
parties
and
submitted
to
EPA
Local/
State/
EPA
June
16,
2003
Discussion
of
control
measures
being
considered
to
EPA
Local/
State
March
31,
2004
Final
local
early
action
plan
submitted
to
DHEC;
copy
to
EPA
Local
December
31,
2004
Early
Action
State
Implementation
Plan
submitted
to
EPA
for
incorporation
into
SIP
State
April
1,
2005
Local/
State
control
strategies
implemented
no
later
than
this
date
Local/
State
September
30,
2005
EPA
takes
final
action
on
SIP
submitted
December
31,
2004
EPA
June
30,
2006
State
submits
progress
report
to
EPA
State
December
31,
2007
Attainment
of
the
8­
hour
ozone
standard
Local/
State
B.
Emissions
Inventories
1.
DHEC
will
be
responsible
for
developing
emissions
inventories.

2.
An
initial
modeling
emissions
inventory
will
be
completed
by
December
31,
2002.
This
inventory
includes:
a.
Emissions
modeling
data
for
a
1998
episode
that
is
representative
of
a
typical
ozone
season
exceedance
that
meets
the
EPA
episode
selection
guidance;
b.
MOBILE6
for
determining
on­
road
mobile
emissions;
c.
NONROAD
model
data;
and,
d.
Area
source
database
utilizing
population
data
allocated
statewide.

3.
A
2007
future
year
modeling
emissions
inventory
will
be
developed
by
March
31,
2004.
This
inventory
will
sufficiently
account
for
projected
future
growth
in
ozone
precursor
emissions
through
2007,
particularly
from
stationary,
non­
road
and
on­
road
mobile
sources.

4.
Additional
inventories
will
be
contingent
upon
legislative
appropriations
or
other
funding.
Selection
of
specific
episode
inventories
will
be
partially
determined
by
the
conceptual
model,
which
reflects
an
analysis
of
meteorological
conditions
typical
of
high
ozone
events.

5.
Emissions
inventories
will
be
compared
and
analyzed
for
trends
in
emission
sources
over
time.
The
emissions
inventory
comparison
and
analysis
will
be
completed
by
December
31,
2003.
4
C.
Modeling
1.
DHEC
will
be
responsible
for
conducting
the
meteorological
and
air
quality
modeling
analysis.
DHEC
will
conduct
the
modeling
analysis
based
on
the
"
Draft
Guidance
on
the
use
of
Models
and
Other
Analyses
in
Attainment
Demonstrations
for
the
8­
Hour
Ozone
NAAQS"
(
EPA­
454/
R­
99­
004,
May
1999).
The
modeling
will
follow
the
guidance
as
facilitated
by
the
EPA
Regional
Office.

2.
Base
case
modeling
will
be
completed
by
December
31,
2002.
Future
case
modeling
will
be
completed
by
October
31,
2003.
One
or
more
modeled
control
cases
will
be
completed
by
January
31,
2004,
with
final
revisions
completed
by
March
31,
2004.
All
modeling
will:
 
be
SIP
quality
and
perform
within
EPA's
accepted
margin
of
accuracy;
 
be
carefully
documented;
 
sufficiently
account
for
projected
future
growth
in
ozone
precursor
emissions;
 
be
accomplished
by
DHEC
and
reviewed
by
EPA;
and,
 
be
used
to
determine
the
effectiveness
of
NOx
and/
or
VOC
reductions.
The
control
case(
s)
will
be
used
to
determine
the
relative
effectiveness
of
different
emission
reduction
strategies
and
to
aid
in
the
selection
of
appropriate
emission
reduction
strategies.

D.
Control
Strategies
1.
All
adopted
Federal
and
State
control
strategies
that
have
been
or
will
be
implemented
by
the
December
31,
2007,
attainment
date
will
be
included
in
base,
future
and
control
case
modeling.

2.
Additional
local
and
state
control
strategies
under
consideration
will
be
identified
by
June
16,
2003.
The
local
and
state
control
strategies
selected
will
be
implemented
as
soon
as
practical,
but
no
later
than
April
1,
2005.

3.
Local
and
state
control
strategies
will
be
specific,
quantified,
permanent
and
enforceable.
The
strategies
will
also
include
specific
implementation
dates
and
detailed
documentation
and
reporting
processes.

4.
Voluntary
strategies
can
play
a
supporting
role
in
the
local
early
action
plan
and
the
early
action
SIP.
If
emission
reductions
from
voluntary
strategies
are
quantified
and
credit
is
taken
for
them
in
the
local
early
action
plan
or
the
early
action
SIP,
those
emission
reductions
will
be
enforceable.
Additional
strategies
must
be
implemented
to
meet
those
quantified
reduction
requirements
if
quantified
voluntary
strategies
fail.
This
is
true
for
all
quantified
emission
reductions.

5.
Local
and
state
control
strategies
will
be
designed
and
implemented
with
full
stakeholder
participation.
5
6.
Local
and
state
control
strategies
will
be
incorporated
by
DHEC
into
the
early
action
SIP.
In
the
event
that
the
local
area
desires
to
add,
delete
or
substitute
strategies
after
early
action
SIP
submittal,
the
local
area
will
request
a
modification.
Local
early
action
plan
modifications
will
be
treated
as
SIP
revisions
and
facilitated
by
DHEC.

E.
Maintenance
for
Growth
1.
The
early
action
SIP
will
include
a
component
to
address
emissions
growth
at
least
five
years
beyond
December
31,
2007,
ensuring
that
the
areas
will
remain
in
attainment
of
the
8­
hour
ozone
standard
during
that
period.
Attainment
maintenance
analysis
will
be
completed
by
January
31,
2004,
with
final
revisions
completed
by
March
31,
2004.
The
analysis
will
employ
one
or
more
of
the
following
or
any
other
appropriate
techniques
necessary
to
make
such
a
demonstration:
a.
Modeling
analysis
showing
ozone
levels
below
the
8­
hour
ozone
standard
in
2012;
b.
An
annual
review
of
growth
(
especially
mobile
and
stationary
source)
to
ensure
control
measures
and
growth
assumptions
are
adequate;
c.
Identification
and
quantification
of
federal,
state,
and/
or
local
measures
indicating
sufficient
reductions
to
offset
growth
estimates;
or,
d.
Any
other
appropriate
techniques
necessary
to
make
such
a
determination.

2.
The
early
action
SIP
must
also
detail
a
continuing
planning
process
that
includes
modeling
updates
and
modeling
assumption
verification
(
particularly
growth
assumptions).
Modeling
updates
and
planning
processes
must
consider
and
evaluate
the
following:
a.
All
relevant
actual
new
point
sources;
b.
Impacts
from
potential
new
source
growth;
and,
c.
Future
transportation
patterns
and
their
impact
on
air
quality
in
a
manner
that
is
consistent
with
the
most
current
adopted
Long
Range
Transportation
Plan
and
most
current
trend
and
projections
of
local
motor
vehicle
emissions.

3.
If
the
review
of
emissions
growth
in
conjunction
with
the
continuing
planning
process
demonstrates
that
adopted
emission
reduction
strategies
are
inadequate
to
address
growth
in
emissions,
additional
measures
will
be
added
to
the
early
action
plan.
Local
planning
processes
should
prepare
for
this
possibility.

4.
In
the
event
that
the
continuing
planning
process
identifies
the
need
to
add,
delete,
or
substitute
control
strategies
after
the
local
early
action
plan
has
been
incorporated
into
the
early
action
SIP,
the
local
area
will
initiate,
and
DHEC
will
facilitate
a
SIP
revision
to
accommodate
changes.
6
F.
Public
Involvement
1.
Public
involvement
has
been
and
will
continue
to
be
strongly
encouraged
during
the
planning
and
implementation
process.

2.
Public
awareness
programs
will
be
used
to
provide
opportunities
for
involvement
in
the
planning
process,
implementation
of
control
strategies,
and
any
other
issues
important
to
the
area.

3.
Interested
stakeholders
(
i.
e.,
local,
state,
and
federal
government,
citizens,
public
interest
groups,
and
the
business
community)
will
continue
to
be
involved
in
the
planning
process
as
early
as
possible.
Planning
meetings
will
be
open
to
the
public,
with
posted
meeting
times
and
locations.
Early
action
SIP
drafts
will
be
publicly
available,
and
the
drafting
process
will
have
sufficient
opportunities
for
comment
from
all
interested
stakeholders.

4.
Opportunities
for
public
comment
on
the
proposed
early
action
SIP
will
be
provided
and
will
follow
the
traditional
SIP
revision
process
as
implemented
by
DHEC.

5.
Semi­
annual
reports
detailing,
at
a
minimum,
progress
toward
key
milestones,
will
be
made
available
to
the
public.

6.
DHEC
has
established
and
will
maintain
a
website
for
South
Carolina's
Early
Action
Plan
for
the
8­
hour
ozone
standard,
located
at
www.
scdhec.
net/
baq/
eap.
html.

III.
Local
Government
Responsibilities
The
local
governments
agree
to
develop
and
implement
a
local
early
action
plan
that
will
promote
the
area's
attainment
by
December
31,
2007,
of
the
8­
hour
ozone
standard
and
maintenance
until
at
least
2012.
The
local
governments
will
develop
this
plan
in
coordination
with
the
DHEC,
EPA,
stakeholders
and
the
public.
The
local
early
action
plan
will
include
a
process
to
evaluate
the
effectiveness
and
maintain
long­
term
compliance
with
the
standard.

After
all
adopted
Federal
and
State
controls
that
have
been
or
will
be
implemented
by
the
attainment
date
of
December
31,
2007,
are
accounted
for
in
the
modeling,
the
local
area
must
adopt
additional
local
controls,
as
necessary
to
demonstrate
attainment
of
the
8­
hour
ozone
standard
by
December
31,
2007.
Local
controls
under
consideration
must
be
identified
and
described
by
June
16,
2003.
These
measures
must
be
included
in
the
semi­
annual
report
made
available
to
the
public.

The
draft
local
early
action
plan
will
be
submitted
to
DHEC
by
August
31,
2003.
The
final
local
early
action
plan
will
be
submitted
to
DHEC,
with
a
copy
forwarded
to
EPA,
by
March
31,
2004.
The
adopted
local
early
action
plan
will
be
included
in
the
early
action
SIP
due
December
31,
2004.
7
In
the
event
a
development
or
issue
arises
that
may
impact
performance
or
progress
toward
key
milestones
(
including
if
a
key
milestone
will
be
or
has
been
missed
and/
or
if
a
termination
or
modification
has
been
requested),
the
responsible
party
will
notify
all
other
signatories
in
writing
as
soon
as
possible.

IV.
The
South
Carolina
Department
of
Health
and
Environmental
Control
DHEC
agrees
to
develop
and
implement
a
state
early
action
SIP
that
will
demonstrate
the
participating
area's
attainment
by
December
31,
2007,
of
the
8­
hour
ozone
standard
and
maintenance
until
at
least
2012.
DHEC
will
develop
this
plan
in
coordination
with
the
local
governments,
EPA,
stakeholders
and
the
public.
The
state
early
action
SIP
will
include
a
process
to
monitor
and
maintain
long­
term
compliance
with
the
standard.

It
is
the
responsibility
of
each
state
under
the
CAA
to
ensure
attainment
with
all
National
Ambient
Air
Quality
Standards.
At
any
such
time
that
an
area
is
deemed
non­
attainment,
the
state
will
be
required
to
develop
a
plan
to
return
the
area(
s)
to
attainment
in
accordance
with
the
CAA.
If
applicable,
South
Carolina
is
committed
to
working
with
adjacent
states
to
assure
mutual
attainment
of
national
standards.

In
the
event
a
development
or
issue
arises
that
may
impact
performance
or
progress
toward
key
milestones
(
including
if
a
key
milestone
will
be
or
has
been
missed
and/
or
if
a
termination
or
modification
has
been
requested),
DHEC
will
notify
all
other
signatories
in
writing
as
soon
as
possible.

DHEC
will
provide
support
to
areas
throughout
the
planning
and
implementation
process
by:

1
Developing
emission
inventories,
modeling,
trend
analysis,
and
quantification
and
comparison
of
control
measures.

2.
Providing
necessary
information
on
all
federal
and
state
adopted
emission
reduction
measures,
which
affect
the
area.

3.
Providing
technical
and
strategic
assistance,
as
appropriate,
in
the
selection
and
implementation
of
control
strategies.

4.
Providing
technical
and
planning
assistance
in
developing
and
implementing
processes
to
address
the
impact
of
emissions
growth
beyond
the
attainment
date.

5.
Maintaining
monitors
and
reporting
and
analysis
of
monitoring
data.

6.
Promoting
public
awareness
efforts.

7.
Coordinating
communication
between
local
areas
and
the
EPA
to
facilitate
continuing
the
EPA
review
of
local
work.

8.
Ensuring
expeditious
review
of
local
early
action
plan(
s),
and
if
deemed
adequate,
proposing
modification
of
the
early
action
SIP
to
adopt
the
early
action
plan.
8
9.
Adopting
control
measures
into
the
early
action
SIP
as
expeditiously
as
possible.
The
final
complete
early
action
SIP
revision
must
be
completed,
adopted,
and
submitted
by
the
state
to
the
EPA
by
December
31,
2004.

10.
Tracking
progress.
If
any
milestone
is
missed
and
EPA
withdraws
the
deferred
effective
date,
thereby
triggering
a
non­
attainment
designation
and
applicable
statutory
requirements,
the
state
will
strive
to
submit
a
traditional
non­
attainment
SIP
within
one
year.
However,
due
to
the
South
Carolina
legislative
review
process,
it
may
take
at
least
eighteen
months.

11.
Working
concurrently
with
areas
not
electing
to
participate
in
the
early
action
SIP
process
in
preparing
the
traditional
SIP
submittal
as
required
by
the
CAA.

V.
The
Environmental
Protection
Agency
The
EPA
will
participate
by:

1.
Recognizing
the
local
area's
and
state's
commitment
to
voluntarily
adopt
an
early,
substantive,
enforceable,
and
scientifically­
based
attainment
plan
with
early
implementation
of
control
measures
by
becoming
a
party
to
the
EAC
developed
in
conformance
with
South
Carolina's
Protocol
for
Early
Action
Compacts.

2.
Providing
technical
assistance
to
the
state(
s)
and
local
area(
s)
in
the
development
of
the
early
action
plan.

3.
Reviewing
and
approving
the
completed
early
action
SIP
by
no
later
than
September
30,
2005.

4.
Deferring
the
effective
date
of
non­
attainment
designation
and
related
requirements
for
participating
areas
that
fail
to
meet
the
8­
hour
ozone
standard
as
long
as
all
terms
and
key
milestones
of
the
EAC
are
being
met,
including
submission
of
the
early
action
SIP
revision
by
December
31,
2004.

5.
Designating
the
area
expeditiously
as
attainment
and
imposing
no
additional
requirements,
provided
that
the
monitors
in
the
area
reflect
attainment
by
December
31,
2007.

6.
Taking
action
to
withdraw
the
deferred
effective
date
if
the
area
violates
the
standard
as
of
December
31,
2007,
and
the
area
has
had
the
effective
date
of
its
non­
attainment
designation
deferred.
The
area's
non­
attainment
designation
will
become
effective
soon
after.

7.
Ensuring
appropriate
credit
in
the
traditional
SIP
process
for
all
emissions
reductions
from
measures
implemented
in
the
early
action
SIP
if
the
area
does
not
meet
all
the
terms
of
the
EAC;
including
meeting
agreed­
upon
key
milestones
and
is
designated
(
or
redesignated
if
necessary)
according
to
the
EPA's
8­
hour
ozone
implementation
guidelines.
The
EPA
will
offer
such
an
area
no
delays,
exemptions,
or
other
favorable
treatment
because
of
its
participation
in
the
EAC.
