The
CLEAN
AIR
PLAN
for
the
SAN
ANTONIO
METROPOLITAN
STATISTICAL
AREA
Submitted
by
the
Air
Improvement
Resources
Committee
of
the
Alamo
Area
Council
of
Governments
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
ii
CLEAN
AIR
PLAN
for
the
SAN
ANTONIO
METROPOLITAN
STATISTICAL
AREA
Table
Of
Contents
I.
Purpose
of
the
Clean
Air
Plan
II.
Background
a)
A
brief
history
of
air
quality
planning
efforts
in
the
San
Antonio
region
b)
The
Ozone
NAAQS
and
The
Clean
Air
Plan
III.
Air
Quality
In
The
San
Antonio
Metropolitan
Statistical
Area
IV.
The
Early
Action
Compact
i)
The
Area
Encompassed
by
the
Clean
Air
Plan
ii)
Participating
and
Signatory
Groups
and
Agencies
iii)
Conditions
for
Modification
or
Early
Termination
a)
Milestones
and
Reporting
b)
Emissions
Inventory
c)
Modeling
d)
Control
Strategies
e)
Maintenance
for
Growth
f)
Public
Involvement
V.
Early
Action
Compact
Memorandum
of
Agreement
(
MOA)
a)
Conditions
for
Modification
or
Early
Termination
b)
Additional
Terms
of
This
Agreement
Attachments:
Protocol
for
Early
Action
Compacts
Designed
to
Achieve
and
Maintain
the
8­
Hour
Ozone
Standard
Appendices:
A.
AIR
Committee
B.
Commitments
From
Local
Governments
And
School
Districts
C.
Commitments
From
Private
Industry
D.
Schedule
Of
Responsibilities:
State
/
Federal
/
Local
Programs
To
Be
In
Effect
By
2007
E.
Transportation
Conformity
Analysis:
1990
Less
Than
Baseline
Test
F.
Conceptual
Model
And
TCEQ
Monitoring
Data
Analysis
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
3
CLEAN
AIR
PLAN
for
the
SAN
ANTONIO
METROPOLITAN
STATISTICAL
AREA
Chapter
I.
Purpose
of
the
Clean
Air
Plan
The
Clean
Air
Act
is
the
comprehensive
Federal
law
that
regulates
airborne
emissions
from
area,
mobile,
and
stationary
sources
across
the
United
States.
This
law
authorizes
the
U.
S.
Environmental
Protection
Agency
(
EPA)
to
establish
National
Ambient
Air
Quality
Standards
(
NAAQS)
to
protect
public
health
and
the
environment.

Of
the
many
air
pollutants
commonly
found
throughout
the
country,
the
EPA
has
recognized
six
"
criteria"
pollutants
that
can
injure
health,
harm
the
environment,
and
cause
property
damage.
EPA
calls
these
pollutants
"
criteria"
air
pollutants
because
the
agency
has
regulated
them
by
first
developing
health­
based
criteria
(
science­
based
guidelines)
as
the
basis
for
setting
permissible
levels.
The
NAAQS
are
a
listing
of
the
threshold
levels,
the
concentration
values
above
which
human
health
is
put
at
risk,
for
these
criteria
pollutants.

During
the
past
several
years,
air
quality
planning
in
the
San
Antonio
region
has
intensified
since
ozone
concentrations
have
exceeded
the
values
permitted
in
the
8­
hour
ozone
NAAQS.
Due
to
legal
challenges
to
the
NAAQS
and
ensuing
litigation,
the
EPA
has
not
formally
designated
any
areas
of
the
United
States
in
violation
of
the
8­
hour
ozone
NAAQS.
However,
that
designation
process
is
expected
to
begin
as
early
as
2004.
Areas
formally
designated
in
violation
of
the
NAAQS
and
contributing
to
a
violation
are
called
"
non­
attainment
areas,"
a
term
frequently
used
in
this
and
many
other
air
quality
documents.

Local
elected
officials,
concerned
leaders
in
business
and
industry,
and
other
citizens
committed
to
air
quality
planning
have
worked
together
for
years
to
create
an
air
quality
plan
for
the
citizens
of
the
San
Antonio
region.
This
group,
meeting
as
the
Air
Improvement
Resources
(
AIR)
Committee
of
the
Alamo
Area
Council
of
Governments
(
AACOG),
has
proactively
created
an
air
quality
plan
that
is
comprehensive,
flexible,
and
relies
on
EPA­
approved
technical
analysis
for
its
control
strategy
recommendations.
They
have
created
this
document,
the
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area.
The
Clean
Air
Plan
was
designed
to
enable
a
local
approach
to
ozone
attainment
and
to
encourage
early
emission
reductions
that
will
help
keep
our
area
in
attainment
of
the
1­
hour
ozone
NAAQS
and
ensure
attainment
of
the
8­
hour
ozone
NAAQS,
and
so
protect
human
health.

This
Clean
Air
Plan
also
incorporates
the
Early
Action
Compact
for
the
San
Antonio
area.
The
Early
Action
Compact
protocol
was
endorsed
by
EPA
Region
6
on
June
19,
2002,
and
is
designed
to
develop
and
implement
control
strategies,
account
for
growth,
and
achieve
and
maintain
the
8­
hour
ozone
standard.
As
such,
it
represents
a
key
component
to
finalizing
this
area's
Clean
Air
Plan.
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
4
CLEAN
AIR
PLAN
for
the
SAN
ANTONIO
METROPOLITAN
STATISTICAL
AREA
Chapter
II.
Background
San
Antonio,
Texas
is
currently
the
largest
corporate
city
in
the
nation
that
has
not
been
designated
in
non­
attainment,
that
is,
it
has
not
officially
failed
to
meet
air
quality
standards
given
in
the
NAAQS.
However,
during
the
ozone
seasons
of
1997
through
2000,
local
air
quality
monitors
recorded
ozone
levels
above
the
concentrations
allowed
under
the
8­
hour
ozone
NAAQS.
Moreover,
in
June
of
2002,
area
monitors
recorded
some
of
the
highest
8­
hour
and
1­
hour
ozone
values
on
record
since
19981.
Since
EPA
guidance
suggests
that
Metropolitan
Statistical
Areas
be
considered
for
the
boundaries
for
new
8­
hour
ozone
non­
attainment
areas,
air
quality
planning
has
focused
on
Bexar,
Comal,
Guadalupe
and
Wilson
Counties,
which
constitute
the
San
Antonio
Metropolitan
Statistical
Area
(
SA/
MSA).

a)
A
brief
history
of
air
quality
planning
efforts
in
the
San
Antonio
region
As
early
as
1995,
the
Air
Quality
Committee
of
the
Alamo
Area
Council
of
Governments,
chaired
by
Senator
Jeff
Wentworth,
first
met
to
address
air
quality
issues.
This
committee
requested
the
first
emissions
inventory,
for
inventory
year
1994.

In
January
1996,
the
San
Antonio
Mayor's
Blue
Ribbon
Committee
on
Air
Quality
merged
with
the
Air
Quality
Committee
of
the
Alamo
Area
Council
of
Governments
(
AACOG)
to
form
the
Air
Quality
Task
Force
(
AQTF).
The
charge
of
the
AQTF
was
to
develop
public
education
and
provide
advice
to
elected
officials
on
air
quality
issues.
The
major
accomplishment
of
the
early
AQTF
was
the
establishment
of
the
Ozone
Action
Day
program.
During
FY
1996
­
1997,
the
AQTF
provided
input
on
the
first
Near
Non­
Attainment
grant,
authorized
by
the
1997
Texas
Legislature.

However,
when,
in
the
summer
of
1996,
the
EPA
proposed
the
new
eight­
hour
ozone
NAAQS,
the
focus
of
the
AQTF
began
to
shift,
first
by
providing
comments
and
guidance
on
the
impact
of
the
new
eight­
hour
ozone
NAAQS.
In
the
summer
of
1998
a
local
contingency
met
with
EPA's
Region
6
to
begin
discussion
on
the
development
of
a
Flexible
Attainment
Region
(
FAR)
agreement.

The
AACOG
developed
its
first
photochemical
model
in
1997
along
with
sponsoring
air
quality
1
On
June
24,
2002,
the
CAMS
23
monitor,
located
near
Marshall
High
School
in
San
Antonio,
recorded
a
1­
hour
average
ozone
value
of
126
parts
per
billion
(
ppb),
an
exceedance
of
the
1­
hour
ozone
NAAQS.
The
most
recent
exceedance
of
the
1­
hour
standard
prior
to
this
date
was
141
ppb
recorded
September
4,
1998
at
CAMS
58
in
Camp
Bullis.
Also
on
June
24,
2002,
the
CAMS
23
monitor
recorded
an
8­
hour
average
ozone
reading
of
110
ppb,
an
exceedance
of
the
8­
hour
average
ozone
NAAQS.
The
most
recent
8­
hour
reading
prior
to
this
date
above
100
ppb
was
a
reading
of
110
ppb
recorded
September
4,
1998
at
CAMS
58
in
Camp
Bullis.
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
5
monitoring
efforts
at
St.
Hedwig
(
southeast
Bexar
County)
during
the
1997
ozone
season.
Monitor
results
indicated
that
on
high
ozone
level
days,
background
levels
coming
into
Bexar
County
were
at
or
near
ozone
NAAQS
threshold
levels.
Later
that
year
when
EPA
finalized
the
eight­
hour
NAAQS
it
became
apparent
that,
based
on
historical
data,
the
SA/
MSA
could
well
be
designated
non­
attainment
when
the
EPA
made
the
first
eight­
hour
non­
attainment
designations
initially
scheduled
for
July
2000.

During
July
1998,
the
City
of
San
Antonio
(
COSA),
San
Antonio­
Bexar
County
Metropolitan
Planning
Organization
(
MPO),
Bexar
County,
and
AACOG
staff
recommended
to
elected
officials
that
the
AQTF
be
revised
to
fit
the
structure
advised
by
the
Texas
Commission
on
Environmental
Quality
(
TCEQ),
then
known
as
the
Texas
Natural
Resource
Conservation
Commission
(
TNRCC).
During
January
­
February
1999,
the
Boards
of
Directors
and
other
responsible
parties
representing
COSA,
Bexar
County,
MPO,
and
AACOG
approved
the
formation
of
the
Air
Improvement
Resources
(
AIR)
Committee
consortium
including
the
Executive/
Advisory,
Technical,
and
Public
Education
Committees
and
member
appointments.
The
AIR
Committee
conducted
its
first
official
meeting
during
April
1999
with
the
goal
to
establish
an
organized,
comprehensive,
and
aggressive
plan
of
action
to
keep
the
SA/
MSA
from
slipping
into
non­
attainment
of
the
ozone
standard.

Working
with
partners
in
the
near
non­
attainment
areas
across
Texas,
the
AACOG
has
developed
a
second
photochemical
model
for
September
1999.
This
episode
models
ozone
formation
for
four
of
the
five
near
non­
attainment
areas
of
the
state,
Corpus
Christi,
Austin,
Victoria
and
San
Antonio.
AACOG
is
now
expanding
the
network
of
ozone
and
meteorological
monitoring
stations
in
the
San
Antonio
region.
The
TCEQ
is
responsible
for
maintaining
monitors
upon
which
official
air
quality
data
depends.
Better
monitoring
allows
for
refined
technical
analysis
of
human
exposure
to
ozone,
a
greater
understanding
of
the
formation
and
movement
of
ozone
in
the
region,
and
provides
a
database
for
verification
of
the
performance
of
future
photochemical
models.

Since
its
first
meeting,
the
AIR
Committee
has
worked
to
cast
the
results
of
its
planning
effort
into
a
protocol
able
to
address
air
quality
planning
requirements
originating
with
the
Clean
Air
Act.
The
AIR
Committee
recognizes
that
the
Clean
Air
Plan
provides
the
means
to
sustain
the
healthfulness
of
the
region's
air
by
proactively
seeking
local
solutions
to
air
quality
issues
within
a
suitable
state
and
federally
approved
protocol.

For
these
reasons,
the
AIR
Committee
is
pleased
to
engage
with
local
citizens,
the
EPA
and
the
Texas
Commission
on
Environmental
Quality
in
the
planning
effort
required
to
successfully
develop
a
Clean
Air
Plan
for
the
SA/
MSA.
From
the
point
of
view
of
the
AIR
Committee,
this
Clean
Air
Plan
is
the
culmination
of
years
of
effort
and
planning,
which
has
been
made
possible
through
enabling
funding
provided
by
the
Legislature
of
the
State
of
Texas.
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
6
b)
The
Ozone
NAAQS
and
The
Clean
Air
Plan
At
this
writing,
there
are
actually
two
NAAQS
for
ozone,
given
in
the
table
below.

The
National
Ambient
Air
Quality
Standards
(
NAAQS)
for
Ozone
1­
Hour
Ozone
NAAQS
0.12
parts
per
million
8­
Hour
Ozone
NAAQS
0.08
parts
per
million
To
attain
this
standard,
the
daily
maximum
1­
hour
average
concentration
measured
by
a
continuous
ambient
air
monitor
must
not
exceed
125
parts
per
billion
(
ppb)
more
than
once
per
year,
averaged
over
3
consecutive
years.
To
attain
this
standard,
the
3­
year
average
of
the
fourth­
highest
daily
maximum
8­
hour
average
of
continuous
ambient
air
monitoring
data
over
each
year
must
not
exceed
85
ppb.

The
EPA
intends
to
phase
out
the
1­
hour
ozone
NAAQS,
leaving
the
8­
hour
ozone
NAAQS2;
the
8­
hour
standard
is
generally
considered
to
be
more
stringent
and
more
protective
of
human
health.
However,
at
this
time,
the
implementation
policy
for
the
8­
hour
ozone
NAAQS
has
not
been
completed.
Until
the
EPA
formally
revokes
the
1­
hour
standard,
both
standards
remain
active
federal
law.

The
Clean
Air
Plan
is
designed
to
be
a
working
document
providing
comprehensive
planning
for
the
ozone
challenge
faced
by
the
citizens
of
the
entire
SA/
MSA.
Adoption
of
this
draft
Clean
Air
Plan
requires
development
of
control
strategies,
or
methodologies
for
lowering
ozone
concentrations
to
acceptable
levels,
which
are
designed
to
meet
the
region's
clean
air
challenge.
The
technical
analysis
of
the
photochemical
modeling,
used
to
demonstrate
the
effectiveness
of
the
control
strategies,
is
performed
by
the
staff
of
AACOG
and
is
reviewed
and
approved
by
the
AIR
Committee,
the
staff
of
AACOG,
the
TCEQ,
and
the
EPA.

Given
the
above
program
requirements
and
those
of
the
Early
Action
Compact
discussed
in
Chapter
IV,
this
Clean
Air
Plan
may
require
amendments
as
air
quality
assurance
planning
continues.
If
required,
such
amendments
will
be
written
for
signature
by
affected
parties
that
list
in
detail
the
air
quality
planning
needs
of
the
San
Antonio
region
as
determined
by
local,
state
and
federal
air
quality
planners.
These
subsequent
agreements
will
be
incorporated
into
this
Clean
Air
Plan
for
the
SA/
MSA
as
required.
However,
once
portions
of
the
Clean
Air
Plan
are
incorporated
into
the
SIP,
then
SIP
revision
processes
must
be
followed
to
change
those
incorporated
portions.
SIP
revisions
are
binding
and
federally
enforceable.

2
"
Once
the
8­
hour
standard
has
become
fully
enforceable
and
subject
to
no
further
legal
challenge,
EPA
again
will
take
action
to
revoke
the
1­
hour
ozone
standard
in
areas
where
air
quality
meets
the
standard."
Fact
Sheet,
EPA
Reinstates
the
1­
Hour
Ground­
Level
Ozone
(
Smog)
Standard,
page
3;
published
July
7,
2000.
Available
online
June
23,
2002:
http://
www.
epa.
gov/
ttn/
oarpg/
t1/
fact_
sheets/
reinstate_
fs.
pdf
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
7
CLEAN
AIR
PLAN
for
the
SAN
ANTONIO
METROPOLITAN
STATISTICAL
AREA
Chapter
III.
Air
Quality
in
the
San
Antonio
Metropolitan
Statistical
Area
The
three­
year
average
of
the
fourth­
highest
eight­
hour
averaged
ozone
values
recorded
at
CAMS
23
for
1997,
1998
and
1999
is
88
parts
per
billion
(
ppb).
The
three­
year
average
of
the
fourthhighest
eight­
hour
averaged
ozone
values
recorded
at
CAMS
23
for
1998,
1999,
and
2000
is
85
parts
per
billion
(
ppb).
The
three­
year
average
of
the
fourth­
highest
eight­
hour
averaged
ozone
values
recorded
at
CAMS
23
for
2000,
2001,
and
2002
is
88
parts
per
billion
(
ppb).
These
threeyear
averages
are
violations
of
the
eight­
hour
ozone
NAAQS.
The
following
table
lists
the
8­
hour
ozone
exceedances
recorded
at
the
San
Antonio
monitors
from
1995
to
October
31,
2002.
The
accompanying
1­
hour
ozone
values
show
the
maximum
reading
in
the
area
for
the
same
day.
(
All
ozone
data
provided
by
TCEQ.)

8­
hour
Ozone
Exceedances
in
the
San
Antonio
Region,
1995
­
1997
1995
8­
hour
Ozone
Exceedances;
1­
hour
maximums,
same
day
1
Hour
8
Hour
Consecutive
Exceedances
/
Periods
06/
13/
1995
105
96
06/
21/
1995
100
93
06/
22/
1995
97
85
06/
23/
1995
111
89
June
21­
23
06/
27/
1995
105
89
07/
08/
1995
109
87
07/
09/
1995
99
87
07/
10/
1995
100
79
07/
11/
1995
109
86
July
8­
11
09/
03/
1995
120
104
09/
09/
1995
105
94
09/
10/
1995
108
91
September
9
­
10
09/
25/
1995
119
108
09/
26/
1995
122
101
September
25
­
26
10/
10/
1995
108
90
1996
8­
hour
Ozone
Exceedances;
1­
hour
maximums,
same
day
1
Hour
8
Hour
Consecutive
Exceedances
/
Periods
06/
03/
1996
130
97
07/
03/
1996
106
89
1997
8­
hour
Ozone
Exceedances;
1­
hour
maximums,
same
day
1
Hour
8
Hour
Consecutive
Exceedances
/
Periods
07/
16/
1997
123
95
08/
26/
1997
103
95
09/
06/
1997
100
88
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
8
8­
hour
Ozone
Exceedances
in
the
San
Antonio
Region,
1998
­
2002
1998
8­
hour
Ozone
Exceedances;
1­
hour
maximums,
same
day
1
Hour
8
Hour
Consecutive
Exceedances
/
Periods
05/
07/
1998
140
101
05/
10/
1998
107
89
Excused
1­
hour
values
 
Mexican
Fire
/
Smoke
08/
28/
1998
99
89
08/
30/
1998
99
92
09/
03/
1998
105
87
09/
04/
1998
141
110
August
28
­
September
4
09/
16/
1998
107
91
10/
09/
1998
121
95
1999
8­
hour
Ozone
Exceedances;
1­
hour
maximums,
same
day
1
Hour
8
Hour
Consecutive
Exceedances
/
Periods
08/
05/
1999
120
100
08/
16/
1999
109
87
08/
21/
1999
109
87
08/
30/
1999
101
85
08/
31/
1999
108
95
09/
01/
1999
109
91
August
30
­
September
1
09/
16/
1999
93
85
09/
18/
1999
108
96
09/
19/
1999
96
91
09/
20/
1999
107
86
September
16
 
20
10/
01/
1999
99
88
2000
8­
hour
Ozone
Exceedances;
1­
hour
maximums,
same
day
1
Hour
8
Hour
Consecutive
Exceedances
/
Periods
09/
05/
2000
92
87
09/
16/
2000
90
86
09/
18/
2000
108
93
September
16
 
18
2001
8­
hour
Ozone
Exceedances;
1­
hour
maximums,
same
day
1
Hour
8
Hour
Consecutive
Exceedances
/
Periods
06/
18/
2001
101
90
2002
8­
hour
Ozone
Exceedances;
1­
hour
maximums,
same
day
1
Hour
8
Hour
Consecutive
Exceedances
/
Periods
06/
15/
2002
103
86
06/
17/
2002
119
107
06/
18/
2002
108
104
06/
23/
2002
103
97
06/
24/
2002
126
110
06/
25/
2002
119
99
June
15
 
25
07/
08/
2002
94
85
08/
05/
2002
101
90
08/
06/
2002
117
100
August
5
 
7
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
9
08/
07/
2002
98
86
08/
30/
2002
109
98
08/
31/
2002
103
97
August
30­
31
09/
12/
2002
130
111
09/
13/
2002
104
97
09/
14/
2002
108
91
September
12­
14
09/
21/
2002
97
87
09/
28/
2002
95
85
Data
provided
by
TCEQ.

The
above
table
lists
1­
hour
ozone
exceedances
recorded
in
May
1998,
excused
due
to
the
presence
of
smoke
that
originated
with
fires
in
Mexico3.
1­
hour
ozone
exceedances
are
as
follows:

1­
hour
ozone
exceedances,
per
site,
in
the
San
Antonio
Region,
1990
­
2002
CAMS
Site
Date
of
1­
hour
Ozone
Exceedance
1­
hour
Average
Exceedance
Value
Northwest
C23
September
12,
2002
130
Northwest
C23
June
24,
2002
126
Camp
Bullis
C58
September
4,
1998
141
Northwest
C23
June
3,
1996
130
North
C07
June
3,
1996
127
North
C07
Sept.
12,
1996
126
Data
provided
by
TCEQ.

3
According
to
voice
mail
from
Guy
Donaldson,
USEPA
Region
6,
recorded
July
21,
1999,
the
EPA
informed
the
TNRCC
that,
in
1998,
San
Antonio
had
been
impacted
by
smoke
on
April
14­
17,
26,
27,
May
4­
31,
and
June
4­
6.
S
an
A
n
ton
io
E
igh
t­
H
o
u
r
O
zo
n
e
D
esig
n
V
a
lu
e
T
ren
d
s
b
y
S
ite
7
0
7
5
8
0
8
5
9
0
9
5
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
Y
e
a
r
Design
Value
(
ppb)

N
orthwest
C
23
N
orth
C
07
C
am
p
B
u
llis
C
5
8
C
alaveras
C
59
C
P
S
/
T
rin
ity
C
6
7
8
L
e
v
e
l
to
E
xc
e
e
d
th
e
8
­
H
o
u
r
O
zo
n
e
S
tan
d
a
rd
E
a
ch
P
lo
tte
d
V
a
lu
e
C
o
vers
a
3
­
Yea
r
P
e
rio
d
E
nd
in
g
w
ith
th
e
Y
e
ar
In
dica
te
d
C
23
C
23
C
23
C
07
C
07
C
07
C
58
C
59
C
678
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
10
The
graph
above
shows
the
"
design
values"
in
the
San
Antonio
region
for
the
8­
hour
ozone
NAAQS.
The
design
value
is
the
3­
year
average
of
the
fourth­
highest
8­
hour
average
ozone
level
recorded
each
year
at
each
monitor
 
the
method
for
determining
non­
attainment
for
the
8­
hour
ozone
NAAQS.
The
graph
shows
this
3­
year
average
since
1980,
clearly
illustrating
that
San
Antonio's
ozone
levels,
as
recorded
over
the
last
twenty
or
so
years,
have
frequently
violated
the
8­
hour
standard
promulgated
in
1997.
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
11
CLEAN
AIR
PLAN
for
the
SAN
ANTONIO
METROPOLITAN
STATISTICAL
AREA
Chapter
IV.
The
Early
Action
Compact
In
response
to
a
request
by
the
TCEQ,
on
June
19th,
2002,
EPA
Region
6
Administrator
Gregg
A.
Cooke
addressed
a
letter
to
the
Chairman
of
the
TCEQ,
Robert
J.
Huston.
In
that
letter,
Regional
Administrator
Cooke
encouraged
the
TCEQ,
as
well
as
other
Region
6
State
Agencies,
to
engage
eligible
local
communities
in
the
development
of
a
local
air
quality
compact
based
on
the
Protocol
for
Early
Action
Compacts
Designed
to
Achieve
and
Maintain
the
8­
Hour
Ozone
Standard.
Regional
Administrator
Cooke
wrote
that,
in
creating
the
Early
Action
Compact
(
EAC)
protocol,
the
"
TNRCC
has
created
an
original
means
to
achieve
air
quality
benefits,
and
we
commend
your
leadership
and
support
your
efforts
as
you
move
to
improve
air
quality
in
Texas."
Regional
Administrator
Cooke
noted
that,
upon
"
the
completion
of
a
Compact
agreement
that
meets
the
requirements
of
the
Protocol,
the
EPA
will
honor
the
commitments
as
outlined
in
the
Protocol."

The
principles
of
the
tri­
party
EAC
to
be
executed
by
Local,
State
and
the
EPA
officials
are:
 
Early
planning,
implementation,
and
emission
reductions
leading
to
expeditious
attainment
and
maintenance
of
the
8­
hour
ozone
standard;
 
Local
control
of
the
measures
to
be
employed,
with
broad
based
public
input;
 
State
support
to
ensure
technical
integrity
of
the
early
action
plan;
 
Formal
incorporation
of
the
early
action
plan
into
the
SIP;
 
Deferral
of
the
effective
date
of
nonattainment
designation
and
related
requirements
so
long
as
all
Early
Action
Compact
terms
and
milestones
are
met;
and
 
Safeguards
to
return
areas
to
traditional
SIP
requirements
should
EAC
terms
and/
or
milestones
be
unfulfilled,
with
appropriate
credit
given
for
emission
reduction
measures
implemented.

The
Clean
Air
Plan
provides
for
the
adoption
of
the
EAC,
which
facilitates
early
voluntary
8­
hour
ozone
NAAQS
air
quality
plans
in
a
manner
consistent
with
applicable
local,
state,
and
federal
air
quality
policy
and
which
follows
the
guidance
provided
by
the
EAC
protocol.
The
EAC
protocol
as
endorsed
by
the
EPA
is
attached,
and
the
Clean
Air
Plan
is
designed
to
embody
and
fulfill
all
requirements
of
the
protocol.

The
local
entities
whose
representatives
support
and
sign
the
Clean
Air
Plan
are
committed
to
holding
primary
responsibility
for
the
development
and
implementation
of
the
plan,
as
well
as
for
maintaining
communication
with
all
parties.
These
commitments
by
local
agencies
are
enumerated
in
Chapter
V,
Memorandum
of
Agreement,
along
with
the
commitments
of
the
State
and
the
EPA.

According
to
the
protocol,
the
plans
can
be
developed
through
execution
of
a
Compact
between
Local,
State
and
the
EPA
officials
for
areas
that
are
in
attainment
(
including
no
monitored
violations)
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
12
of
the
1­
hour
ozone
standard.
If
a
monitor
records
a
1­
hour
average
ozone
concentration
of
125
parts
per
billion
(
ppb)
or
greater,
the
monitor
has
recorded
an
exceedance
of
the
1­
hour
ozone
NAAQS.
If
a
monitor
averages
more
than
three
exceedances
of
the
1­
hour
ozone
NAAQS
over
three
years,
then
the
area
in
which
the
monitor
resides
has
violated
the
1­
hour
ozone
NAAQS
and
the
area
may
not
petition
to
enter
into
a
Clean
Air
Plan
based
on
the
Early
Action
Compact.

In
addition,
according
to
the
protocol,
the
plans
can
be
developed
through
execution
of
a
Compact
between
Local,
State
and
the
EPA
officials
for
areas
that
approach
or
monitor
exceedances
of
the
8­
hour
standard.
If
a
monitor
records
an
8­
hour
average
ozone
concentration
of
85
ppb
or
greater,
the
monitor
has
recorded
an
exceedance
of
the
8­
hour
ozone
NAAQS.
The
Early
Action
Compact
is
available
to
areas
in
which
exceedances
of
the
8­
hour
ozone
NAAQS
have
been
recorded.

The
Early
Action
Compact
is
designed
to
develop
and
implement
control
strategies,
account
for
growth,
and
achieve
and
maintain
the
8­
hour
ozone
standard.
This
approach
will
offer
a
more
expeditious
time
line
for
achieving
emission
reductions
than
the
EPA's
expected
8­
hour
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.
In
general,
these
early
action
plans
will
include
all
necessary
elements
of
a
comprehensive
air
quality
plan,
but
will
be
tailored
to
local
needs
and
driven
by
local
decisions.

The
area
encompassed
by
the
Clean
Air
Plan:
The
SA/
MSA,
which
comprises
Bexar,
Wilson,
Comal
and
Guadalupe
Counties,
is
the
planning
area
for
which
the
Clean
Air
Plan
is
designed.
The
EPA
recommends
that
the
MSA
serve
as
the
presumptive
boundary
for
the
8­
hour
ozone
NAAQS
non­
attainment
areas.

Participating
and
signatory
groups
and
agencies:
The
individuals
representing
the
entities
which
are
expected
to
endorse
this
Clean
Air
Plan
are:
the
County
Judges
for
Bexar,
Wilson,
Comal
and
Guadalupe
Counties;
the
mayors
for
the
cities
of
San
Antonio,
Floresville,
Seguin
and
New
Braunfels;
appropriate
signatures
from
EPA
and
TCEQ;
and
the
Chairman
of
the
Alamo
Area
Council
of
Governments.

Conditions
for
Modification
or
Early
Termination
This
agreement
may
be
modified
at
any
time
or
terminated
at
any
time
by
mutual
consent
of
all
signatory
parties.
Any
signatory
party
may
withdraw
from
the
agreement
if
the
other
signatory
parties
do
not
carry
out
provisions
of
the
agreement.
However,
once
portions
of
the
Clean
Air
Plan
are
incorporated
into
the
SIP,
then
SIP
revision
processes
must
be
followed
to
change
those
incorporated
portions.
SIP
revisions
are
binding
and
federally
enforceable.
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
13
CLEAN
AIR
PLAN
for
the
SAN
ANTONIO
METROPOLITAN
STATISTICAL
AREA
Chapter
IV.
The
Early
Action
Compact
a)
Milestones
and
Reporting
The
AIR
Committee
of
the
AACOG
is
the
local
entity
charged
with
oversight
and
coordination
of
the
development
of
the
Clean
Air
Plan
for
the
SA/
MSA.
The
AIR
Committee
shall
be
responsible
for
the
assessment
and
reporting
of
the
region's
progress
against
milestones
with
deliverables
sent
to
TCEQ
and
the
EPA
and
reported
in
a
regular,
public
process,
at
least
every
six
months.
Public
reporting
of
assessment
and
progress
against
milestone
will
occur
at
least
once
every
six
months
during
the
regularly
scheduled,
public
meetings
(
scheduled
on
a
monthly
basis),
of
the
joined
AIR
Executive/
Advisory
Committees
of
the
AACOG.
Every
meeting
of
the
AIR
Executive
and
Advisory
Committees
is
a
public
meeting,
with
notification
of
the
meeting
time
and
location
published
by
AACOG
according
to
the
Texas
Open
Meetings
Act.
AACOG
shall
provide
notice
of
each
meeting
to
the
secretary
of
state,
the
county
clerk
of
Bexar
County,
and
at
AACOG's
main
administrative
offices
in
a
place
readily
accessible
to
the
general
public
at
all
times
for
at
least
72
hours
before
the
scheduled
time
of
the
meeting.
(
Although
the
AIR
Executive
and
the
AIR
Advisory
Committees
are
separate
committees,
they
typically
hold
joint
committee
meetings
at
least
once
a
month.
In
each
case,
the
notification
process
is
as
described
above.)
The
reports
made
during
these
meetings
satisfy
the
public
reporting
requirements
of
the
Early
Action
Compact
protocol.

The
milestones
in
the
Early
Action
Compact
within
the
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
(
area)
are:
1.
Completion
of
emissions
inventories
as
outlined
in
section
b),
Emissions
Inventory;
2.
Completion
of
modeling
as
outlined
in
section
c),
Modeling;
3.
Adoption
of
control
strategies
that
demonstrate
attainment
as
outlined
in
section
d)
Control
Strategies;
4.
Post­
attainment
demonstration
and
plan
updates
as
outlined
in
section
e),
Maintenance
for
Growth;
5.
Continuing
public
involvement
in
the
planning
process
will
be
conducted
as
outlined
in
section
f),
Public
Involvement.
This
is
in
addition
to
the
public
reporting
conducted
at
least
once
every
six
months,
as
outlined
above;
6.
Identification
and
description,
by
no
later
than
June
16,
2003,
of
local
control
strategies
under
then­
current
consideration
for
inclusion
into
the
area's
local
clean
air
plan,
including
those
analyzed
in
modeling.
This
will
be
combined
with
the
first
biannual
report
of
assessment
and
progress
against
milestones,
as
outlined
above;
7.
Completion
and
adoption
of
the
early
action
SIP
revision
by
December
31,
2004;
and
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
14
8.
Attainment
not
later
than
December
31,
2007.

The
timelines
required
for
completion
of
the
above
tasks
are
found
within
each
corresponding
section
as
indicated
in
the
numbered
list
immediately
above.
That
is,
for
example,
the
timeline
for
the
development
of
required
emissions
inventories
is
found
in
section
b),
Emissions
Inventory.

In
the
following
sections
of
Chapter
IV,
the
Early
Action
Compact,
the
symbol

denotes
a
milestone
required
by
the
Early
Action
Compact.
The
requirement
listing
is
followed
by
the
timeline
associated
with
meeting
this
milestone.

The
deadline
for
delivery
of
the
local
early
action
plan
from
the
AIR
Committee
to
the
TCEQ
will
be
March
31,
2004.
December
31,
2004
is
the
date
by
which
the
State
must
have
completed,
adopted
and
submitted
the
SIP
revisions
to
the
EPA.

If
the
area
does
not
achieve
its
milestones,
including
attaining
the
8­
hour
ozone
standard
on
or
before
December
31,
2007,
the
area
will
be
deemed
in
violation
of
the
EAC
and
will
be
subject
to
the
full
planning
requirements
under
applicable
Clean
Air
Act
(
CAA)
standard
SIP
processes
including
requirements
defined
as
part
of
the
EPA's
8­
hour
implementation
rulemaking.
The
area
will
be
subject
to
the
same
requirements
and
deadlines
which
would
have
been
effective
under
the
CAA
and
the
EPA's
8­
hour
designation
rulemaking
had
it
not
participated
in
this
program,
with
no
preferential
delays
or
exemptions
from
the
EPA.
However,
the
area
will
receive
appropriate
credit
in
the
standard
SIP
process
for
all
emission
reductions
from
measures
implemented
in
this
program.

If
the
area
has
had
the
effective
date
of
its
nonattainment
designation
deferred
and
the
area
does
not
reach
attainment
of
the
8­
hour
ozone
standard
by
December
31,
2007,
then
the
nonattainment
designation
will
be
effective
immediately.
If
the
EPA's
implementation
schedule
also
requires
SIP's
from
areas
on
or
before
December
31,
2007,
then
a
SIP
revision
demonstrating
attainment
by
the
new
attainment
date
will
be
due
for
the
nonattainment
area
no
later
than
December
31,
2008.
The
EPA
will
offer
participating
areas
no
extensions
or
delays
of
the
applicable
attainment
date.
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
15
CLEAN
AIR
PLAN
for
the
SAN
ANTONIO
METROPOLITAN
STATISTICAL
AREA
Chapter
IV.
The
Early
Action
Compact
b)
Emissions
Inventory

The
Early
Action
Compact
requires
that
the
modeling
of
emissions
inventories
using
the
most
current
tools
available
will
be
completed
for
at
least
one
recent
episode
in
order
to
support
the
control
strategies
incorporated
into
the
early
action
plan
SIP.
Emission
inventories
will
include:
­
1999
or
later
episode
reflective
of
a
typical
ozone
season
exceedance
that
meets
the
EPA
episode
selection
guidance
to
ensure
that
representative
meteorological
regimes
are
considered;
­
MOBILE6
data
with
link
based
Travel
Demand
Model
(
TDM)
mobile
data
in
urban
areas;
­
NONROAD
model
data
adjusted
for
local
equipment
populations
and
usage
rates;
­
Area
source
data
based
when
possible
on
local
survey
data.

The
above
requirements
for
emissions
inventory
development
will
be
met
as
follows:
­
The
AACOG
is
currently
refining
a
September
1999
photochemical
modeling
emissions
inventory.
The
September
1999
episode
meets
the
EPA
episode
selection
guidance
criteria.
This
emissions
inventory
does
incorporate
NONROAD
model
data
adjusted
for
local
equipment
populations
and
usage
rates
and
area
source
data
based
on
some
local
survey
data.
­
The
AACOG
will
incorporate
MOBIILE6
data
with
link
based
TDM
mobile
data
in
urban
areas
into
the
1999
emissions
inventory
by
April
30,
2003.
­
The
AACOG
will
project
this
emissions
inventory
to
2007
by
September
30,
2003.


The
Early
Action
Compact
requires
that
further
episode
inventories
will
also
be
developed
over
time
to
fully
represent
the
variety
of
situations
that
typically
contribute
to
ozone
production
in
the
area
and
to
include
the
most
recent
developments.

The
above
requirement
for
development
of
further
episode
inventories
will
be
based
on
consecutive
updates
to
the
Conceptual
Model
performed
by
AACOG,
which
will
be
concluded
by
April
30,
2003
and
April
30,
2005.
The
decision
to
develop
other
episode
inventories
will
be
made
by
the
local
entities,
TCEQ
and
the
EPA,
within
six
months
of
completion
of
the
updates.


The
Early
Action
Compact
requires
that
emission
inventories
will
be
compared
and
analyzed
for
trends
in
emission
sources
over
time.

The
above
required
trends
analysis
will
be
concluded
by
September
30,
2003
and
September
30,
2005,
based
on
AACOG's
analysis
of
the
local
1996,
1999
and
2002
National
Emissions
Trends
Emissions
Inventories.
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
16
CLEAN
AIR
PLAN
for
the
SAN
ANTONIO
METROPOLITAN
STATISTICAL
AREA
Chapter
IV.
The
Early
Action
Compact
c)
Modeling

Emission
inventories
will
be
used
to
develop
SIP
quality
modeling
episodes
that
perform
within
the
EPA's
accepted
margin
of
accuracy,
including
a
base
case
and
future
case
on
or
before
December
31,
2007.
Inventories
must
sufficiently
account
for
projected
future
growth
in
ozone
precursor
emissions,
particularly
from
stationary,
non­
road,
and
on­
road
mobile
sources.
The
local
area
must
carefully
document
their
modeling
approach,
and
work
will
be
supported
and
reviewed
by
the
State
and
concurrently
reviewed
by
the
EPA.


Quantifiable
emission
reduction
measures
will
be
integrated
into
the
future
case
to
produce
one
or
more
control
cases.
These
control
cases
will
be
used
to
indicate
the
relative
effectiveness
of
different
measures
and
aid
in
selecting
appropriate
measures.


Prior
to
plan
implementation,
the
control
strategies
should
be
determined
based
on
model
results
from
a
control
case
episode
that
shows
achievement
of
the
8­
hour
ozone
standard
on
or
before
December
31,
2007
through
implementation
of
the
control
strategies.

The
above
required
base
case
and
future
case
on
or
before
December
31,
2007,
will
be
developed
based
on
the
September
1999
photochemical
model
currently
under
refinement
by
the
AACOG,
or
other
photochemical
model
as
agreed
upon
by
the
partners
under
this
compact
and
which
meets
the
requirements
of
this
compact.
AACOG
will
follow
the
most
recent
EPA
draft
8­
hour
ozone
modeling
guidance
for
model
and
episode
selection­
base
case
and
future
case,
input
data
preparation
and
quality
assurance,
and
the
"
modeled"
attainment
test.
This
future
base
case
will
be
available
as
a
carefully­
documented
report
by
September
2003
from
the
AACOG
for
review
by
TCEQ
and
EPA.
All
model
inputs
will
be
included
with
the
written
report.


Communities
will
continue
to
develop
other
episodes
as
necessary
to
fully
represent
the
variety
of
situations
that
typically
contribute
to
ozone
production
in
the
area
and
to
support
the
plan
with
the
most
current
information
and
tools.
Other
episodes
may
also
indicate
necessary
revisions
to
ensure
that
sufficient
emission
reduction
measures
are
selected
and
implemented
to
continue
to
achieve
target
ozone
concentration
levels.

The
above
requirement
for
development
of
further
episode
will
be
based
on
the
analysis
of
two
consecutive
updates
to
the
Conceptual
Model
performed
by
AACOG,
which
will
be
concluded
by
April
30,
2003
and
April
30,
2005.
The
decision
to
develop
other
episode
inventories
will
be
made
by
the
local
entities
in
concert
with
TCEQ
and
the
EPA.
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
17
CLEAN
AIR
PLAN
for
the
SAN
ANTONIO
METROPOLITAN
STATISTICAL
AREA
Chapter
IV.
The
Early
Action
Compact
d)
Control
Strategies

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
will
identify
additional
local
controls,
as
necessary,
to
demonstrate
attainment
of
the
8­
hour
standard
on
or
before
December
31,
2007.
These
local
controls
will
be
specific,
quantified,
permanent
and
enforceable
control
strategies.
All
controls
will
include
specific
implementation
dates,
as
well
as
detailed
documentation
and
reporting
processes.


Controls
will
be
implemented
as
soon
as
practicable,
but
not
later
than
December
31,
2005.


Controls
will
be
designed
and
implemented
by
the
community
with
full
stakeholder
participation.


All
control
measures
will
be
incorporated
by
the
state
into
the
State
Implementation
Plan,
which
will
be
submitted
to
the
EPA
for
review
and
approval.
In
the
event
that
areas
wish
to
add
or
substitute
measures
after
SIP
submittal,
plan
modifications
will
be
treated
as
SIP
revisions
and
facilitated
by
the
state.

The
above
control
strategy
development
requirements
will
be
satisfied
by
development
of
a
base
case
and
future
case
on
or
before
March
31,
2004.
This
base
and
future
case
set
will
account
for
all
Federal,
State
and
local
controls
that
have
been
or
will
be
adopted
by
2007.
The
base
and
future
case
set
will
be
developed
based
on
the
September
1999
photochemical
model
currently
under
refinement
by
the
AACOG,
or
other
photochemical
model
as
agreed
upon
by
the
partners
under
this
compact
and
which
meets
the
requirements
of
this
compact.
This
future
case
analysis,
control
cases
and
control
case
showing
achievement
of
the
8­
hour
ozone
standard
on
or
before
December
31,
2007
will
be
available
as
a
report
by
March
31,
2004
from
the
AACOG.

In
general,
the
Early
Action
Compact
requires
the
creation
of
a
photochemical
model
that
will
demonstrate
attainment
by
Dec.
31,
2007.
A
successful
attainment
demonstration
will
depend
upon
the
proper
analysis
of
control
strategies
as
outlined
above.
These
quantified,
mandatory,
enforceable
control
strategies
are
the
core
measures
which
will
provide
the
essential
reductions
required
to
assure
attainment
under
the
Early
Action
Compact.

The
Early
Action
Compact
also
requires
an
ongoing
review
and
update
procedure
for
the
emissions
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
18
inventories
and
photochemical
model,
including
trend
analyses
and
an
analysis
of
the
impacts
of
regional
growth
through
2012,
as
outlined
in
the
Maintenance
for
Growth
subchapter.
Such
analysis
may
reveal
the
requirement
for
additional
control
strategies
as
well.

In
addition
to
these
control
strategies
evaluated
through
modeling
and
growth
analysis,
voluntary
control
strategies
will
be
developed.
Such
voluntary
measures
support
the
enforceable
control
strategies
through
the
additional
emissions
reductions,
public
involvement
and
public
education
benefits
they
provide.
Credit
allowed
by
the
EPA
for
the
following
voluntary
measures
will
be
taken
whenever
possible.
Otherwise,
these
strategy
implementations
will
be
added
to
a
"
margin
of
safety"
argument
in
the
SIP,
whenever
applicable.

Voluntary
Air
Quality
Control
Strategies
Various
entities
have
responded
to
a
request
for
Letters
of
Commitment
for
Voluntary
Implementation
Measures
to
be
implemented
under
this
compact.
The
signatory
parties
agree
to
implement
the
following
voluntary
measures
immediately,
or
as
otherwise
specified,
and
they
fully
recognize
that
the
commitments
set
forth
below
are
strictly
voluntary.
Nothing
in
this
Agreement
authorizes
the
EPA
or
TCEQ
to
convert
the
voluntary
measures
undertaken
by
a
signatory
party
into
state
or
federally
enforceable
measures
under
either
state
or
federal
law
without
the
express
written
consent
of
the
affected
party.

A.
Continuation
of
existing
AACOG
programs
providing
notification
of
forecasted
high
ozone
levels
under
the
Air
Quality
Health
Alert
program,
media
programs
and
events,
technical
assistance
to
local
industry
and
public
education.
These
programs
are
described
in
greater
detail
in
Appendix
A.

Implementation:
AIR
Committee
and
AACOG
B.
Investigation
of
additional
measures
to
reduce
emissions
of
ozone
precursors
on
a
costeffective
basis.

Implementation:
Investigation
by
AIR
Committee
and
AACOG;
implementation
of
measures
by
local
business,
industry
and
other
appropriate
entities.

C.
Implementation
of
Air
Quality
Health
Alert
programs
by
the
local
governments
and
independent
school
districts.
Details
of
individual
programs
are
described
in
the
Summary
Report
for
Local
Governments
and
Independent
School
Districts,
attached
as
Appendix
B.

Implementation:
Local
Governments
and
Independent
School
Districts
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
19
D.
Implementation
of
Air
Quality
Health
Alert
facility
management
and
employee
awareness
programs
by
the
area
entities
to
promote
actions
and
behaviors
which
will
reduce
emissions
of
ozone
precursors
in
the
SA/
MSA
region.
These
will
produce
positive
emission
reductions,
particularly
on
Air
Quality
Health
Alert
Days.
The
list
does
not
include
the
many
entities
that
support
regional
clean
air
measures
on
an
informal
basis.
Details
of
the
specific
programs
are
set
out
in
commitment
letters
contained
in
Appendix
A,
B,
and
C.

Implementation:
Local
Employers
throughout
the
region.

E.
Implementation
of
quantifiable,
voluntary
emission
reduction
programs
that
will
be
incorporated
into
the
implementation
plan
by
industries
and
local
governments
in
the
SA/
MSA
region.
The
reductions
are
described
in
more
detail
in
the
commitment
letters
in
Appendices
B
and
C.

Implementation:
Local
entities
throughout
the
region.

In
addition
to
the
voluntary
measures
described
above,
further
voluntary
control
strategies
may
be
developed
and
adopted
in
this
Clean
Air
Plan
as
a
response
to
future
local
exceedances
or
violations
of
federal
air
quality
standards.
 
If
exceedances
of
the
1­
hour
average
ozone
NAAQS
or
exceedances
and
violations
of
the
8­
hour
ozone
NAAQS
are
recorded
on
local
air
quality
monitors,
further
voluntary
control
strategies
will
be
considered
by
the
AIR
Committee,
the
TCEQ
and
the
EPA
as
they
may
result
from
the
ongoing
public
involvement
process.
 
Before
the
finalization
of
the
local
SIP
revisions,
newly
monitored
exceedances
and
violations
will
result
in
a
public
review
of
the
control
strategies
being
planned
for
that
revision.
This
review
is
an
important
part
of
the
public
involvement
process.
If
public
awareness
of
exceedances
brings
a
further
public
willingness
to
enact
further
voluntary
or
mandatory
control
strategies
beyond
those
modeled
in
the
SIP
attainment
and
maintenance
analyses,
they
should
be
duly
considered
for
inclusion
in
the
SIP
revision
control
strategy
set.
 
After
the
date
of
finalization
of
the
local
SIP
revisions,
newly
monitored
exceedances
and
violations
will
result
in
a
public
review
of
the
control
strategies
in
the
SIP
and
a
fresh
call
for
implementation
of
further
and
more
effective
voluntary
control
strategies
from
business,
industries,
local
agencies
and
citizens.
This
review
is
an
important
part
of
the
public
involvement
process.
 
Should
the
exceedances
occur
before
the
full
impacts
of
control
strategies
within
the
locally
adopted
SIP
revisions
are
realized
(
i.
e.,
before
the
entire
vehicle
fleet
has
been
through
the
first
year
test
cycle,
should
a
state
vehicle
Inspection
and
Maintenance
emission
test
be
implemented
locally),
then
the
resulting
public
review
and
assessment
process
will
include
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
20
careful
consideration
of
that
fact.

Such
an
event­
responsive
review
process
clearly
complements
and
gives
fresh
impetus
to
the
public
involvement
goals
in
the
EAC.
Such
a
review
process
allows
local
air
quality
planners
the
opportunity
not
just
to
offer
the
public
a
strategy
review
and
progress
report,
but
to
ask
the
public
for
a
renewal
of
their
involvement
in
and
commitment
to
the
ongoing
planning
process
in
the
context
of
new
exceedances
of
the
air
quality
standards.
Such
a
review
process
allows
local
businesses,
industry
and
other
agencies
further
opportunity
to
implement
fresh
voluntary
emission
reduction
methods.
Enactment
of
control
strategies
resulting
from
the
public
involvement
process
should
not
conflict
with
the
role
of
the
SIP
planning
process
mandated
in
the
Early
Action
Compact,
but
will
be
a
harmonious
element
of
the
SIP
planning
process.

By
responding
to
future
exceedances
and
violations
with
a
public
review
of
control
strategies
and
their
purpose,
local
elected
officials,
air
quality
planners,
and
the
citizens
themselves
remain
committed
to
ongoing
local
air
quality
planning
needs.
Since
new
exceedances
and
violations
are
grounds
for
a
review
of
the
plan,
we
give
assurances
to
the
reader
of
our
common
vigilance,
in
which
public
participation
is
required.
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
21
CLEAN
AIR
PLAN
for
the
SAN
ANTONIO
METROPOLITAN
STATISTICAL
AREA
Chapter
IV.
The
Early
Action
Compact
e)
Maintenance
for
Growth

The
plan
must
include
a
component
to
address
emissions
growth
at
least
5
years
beyond
December
31,
2007,
ensuring
that
the
area
will
remain
in
attainment
of
the
8­
hour
standard
during
that
period.
This
future
attainment
maintenance
analysis
may
employ
one
or
more
of
the
following
or
any
other
appropriate
techniques
necessary
to
make
such
a
demonstration:
­
Modeling
analysis
showing
ozone
levels
below
the
8­
hour
standard
in
2012;
­
An
annual
review
of
growth
(
especially
mobile
and
stationary
source)
to
ensure
control
measures
and
growth
assumptions
are
adequate;
­
Identification
and
quantification
of
federal,
state,
and/
or
local
measures
indicating
sufficient
reductions
to
offset
growth
estimates.

The
satisfactory
choice
of
methodologies
to
demonstrate
a
maintenance
analysis
through
2012
will
be
agreed
upon
by
the
AIR
Committee,
TCEQ
and
the
EPA.
The
resultant
analysis
to
show
attainment
through
2012
will
be
agreed
upon
by
the
AIR
Committee,
TCEQ
and
the
EPA.
The
analysis
will
be
completed
by
the
AACOG
as
part
of
the
SIP
revisions
package
when
the
SIP
revisions
are
due
with
TCEQ
by
March
31,
2004.
December
31,
2004
is
the
date
by
which
the
State
must
have
completed,
adopted
and
submitted
the
SIP
revisions
to
the
EPA.
A
6
month
reporting
period
will
follow
the
past
6
months
updates;
anticipated
updates
will
be
reported
in
the
next
6
months.


The
plan
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:
­
all
relevant
actual
new
point
sources;
­
impacts
from
potential
new
source
growth;
and
­
future
transportation
patterns
and
their
impact
on
air
quality
in
a
manner
that
is
consistent
with
the
most
current
adopted
Long
Term
Transportation
Plan
and
most
current
trend
and
projections
of
local
motor
vehicle
emissions.
This
update
and
verification
will
be
an
ongoing
process
between
the
TCEQ
and
the
AACOG.


If
at
any
time
the
review
of
growth
demonstrates
that
adopted
control
measures
are
inadequate
to
address
growth
in
emissions,
additional
measures
will
be
added
to
the
plan.
Local
planning
processes
should
anticipate
this
possibility.

If
warranted,
additional
control
measures
revealed
by
analysis
for
growth
will
be
included
by
the
AACOG
as
part
of
an
additional
SIP
revision
to
be
submitted
after
December
31,
2004,
the
date
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
22
for
submitting
the
original
SIP
revision
to
the
EPA.
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
23
CLEAN
AIR
PLAN
for
the
SAN
ANTONIO
METROPOLITAN
STATISTICAL
AREA
Chapter
IV.
The
Early
Action
Compact
f)
Public
Involvement

Public
involvement
will
be
included
in
all
stages
of
the
planning
and
implementation
process.


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


Interested
stakeholders
will
be
involved
in
the
planning
process
as
early
as
possible.
Planning
meetings
will
be
open
to
the
public,
with
posted
meeting
times
and
locations.
Plan
drafts
will
be
publicly
available,
and
the
drafting
process
will
have
sufficient
opportunities
for
comment
from
all
interested
stakeholders.


Public
comment
on
the
proposed
final
plan
will
follow
the
normal
SIP
revision
process
as
implemented
by
the
State.


Semi­
annual
reports
detailing,
at
a
minimum,
progress
toward
milestones
will
be
publicly
presented
and
publicly
available.

Public
reporting
of
assessment
and
progress
against
milestones
will
occur
at
least
once
every
six
months
during
the
regularly
scheduled,
public
meetings
of
the
joined
AIR
Executive/
Advisory
Committees
of
the
AACOG.
In
addition,
the
AIR
Public
Education
Committee
(
see
Appendix
A)
is
charged
with
fulfilling
these
requirements.

The
development
of
a
regional
Clean
Air
Plan
requires
continuing
collaboration
with
the
EPA
and
TCEQ,
as
well
as
many
other
state
and
local
agencies.
The
local
planning
process
can
be
outlined
in
two
essential
steps.
These
measures
will
be
ongoing
through
the
term
of
this
plan,
as
follows:

Step
1
­
Secure
Stakeholder
Participation
Vital
Participation
of
Interested
and
Necessary
Stakeholders
Throughout
the
SA/
MSA
The
history
of
efforts
to
identify,
contact,
and
secure
the
participation
of
interested
and
necessary
stakeholders
has
its
origins
in
1995.
This
effort
has
led
to
the
present­
day
AIR
Committee.
The
AIR
Committee
is
a
group
of
elected
officials,
business
and
industry
leaders,
local
citizenry
and
technical
research
staff
drawn
from
the
twelve­
county
AACOG
region.
The
AIR
Committee
is
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
24
dedicated
to
public
involvement
through
their
public
monthly
meetings
held
through
the
AACOG
and
public
education
outreach
efforts
across
the
region.
The
public
education
efforts
include
television
and
radio
programs,
as
well
as
advertisement
of
ozone­
reducing
practices.

The
AIR
Committee
also
draws
support
from
and
coordinates
efforts
with
other
projects
within
the
Natural
Resources
/
Transportation
Department
of
AACOG.
These
AACOG
projects
include:
the
San
Antonio
Clean
Cities
Program,
for
the
promotion
of
cleaner
burning
fuels
and
fleets
across
the
region;
the
Commute
Solutions
program,
responsible
for
public
awareness
campaigns
including
an
ongoing
Rideshare
program;
and
the
Air
Quality
Health
Alert
campaign,
responsible
for
the
release
of
health
alerts
throughout
the
region
for
days
of
expected
high
ozone
readings.

Step
2
 
Coordinate
Plan
Development
Vital
Participation
of
the
Public,
State
and
Federal
Air
Quality
Planning
Agencies
The
AIR
Committees
have
been
meeting
publicly
at
least
once
a
month
since
the
spring
of
1999.
The
many
stakeholders
involved
in
the
plan
development
process
have
shown
differing
knowledge,
strengths
and
ability
to
volunteer
time
to
participate.
During
this
time,
the
committees
have
reviewed
many
control
strategies
and
considered
several
forms
of
what
has
become
the
Clean
Air
Plan.
Each
of
the
plans
has
been
subject
to
review
by
1)
the
public,
through
their
participation
in
the
AIR
Committee
meetings
and
public
stakeholder
meetings,
2)
business
and
industry,
through
their
participation
in
the
AIR
Advisory
Committee,
and
3)
through
technical
analysis
provided
by
the
AIR
Technical
Committee,
the
TCEQ
and
the
EPA.
During
this
entire
process,
TCEQ
and
the
EPA
have
been
working
in
close
partnership
with
the
AIR
Committee
both
to
review
and
assess
the
technical
basis
for
the
control
strategy
choices
and
to
offer
guidance
regarding
applicable
state
rules
and
procedures.
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
25
CLEAN
AIR
PLAN
for
the
SAN
ANTONIO
METROPOLITAN
STATISTICAL
AREA
Chapter
V.
Early
Action
Compact
Memorandum
of
Agreement
(
MOA)

Participating
and
signatory
groups
and
agencies
The
individuals
representing
the
entities
which
are
expected
to
endorse
this
Early
Action
Compact
are:
the
County
Judges
for
Bexar,
Wilson,
Comal
and
Guadalupe
Counties;
the
mayors
for
the
cities
of
San
Antonio,
Floresville,
Seguin
and
New
Braunfels;
the
Chairman
of
the
Texas
Commission
on
Environmental
Quality;
the
Administrator
of
EPA
Region
6;
and
the
Chairman
of
the
Alamo
Area
Council
of
Governments.

Local,
State
and
the
EPA
Commitments
The
entities
whose
representatives
support
and
sign
the
Early
Action
Compact
(
the
"
signatory
parties")
are
committed
to
specific
tasks
and
timelines.
By
affixing
their
signature
to
this
MOA,
the
representative
commits
their
signatory
party
to
the
terms
of
this
MOA
and
to
the
actions
and
milestones
outlined
therein.
The
commitments
include
the
following:

Local
Officials'
Commitments:
1.
Early
Action
Compact
Milestones
and
Timeline
Milestone
Completion
Date
Reference
in
the
Early
Action
Compact
Emissions
Inventory
Milestones
Development
of
a
1999
or
later
episode
emissions
inventory
according
to
requirements
in
Chapter
IV,
b)
Completed;
now
being
refined
by
AACOG
Chapter
IV,
b)

Incorporate
MOBILE6
data
with
Link­
Based
Travel
Demand
Model
data
in
urban
areas
April
30,
2003
by
AACOG
Chapter
IV,
b)

Further
emission
inventory
episode
development
based
on
local
Conceptual
Model
update.
Other
episode
inventories,
if
required,
made
in
concert
with
EPA,
TCEQ,
and
local
entities.
Conceptual
Model
updates
completed
by
AACOG
by
April
30,
2003
and
April
30,
2005
Chapter
IV,
b)

NONROAD
model
data
adjusted
for
local
equipment
populations
and
usage
rates;
Area
source
data
is
based
when
possible
on
local
survey
data.
Current
1999
episode
does
incorporate
these
requirements
Chapter
IV,
b),
c)

Emissions
Trend
Analysis
utilizing
National
Emissions
Trends
(
NET)
Emissions
Inventories
(
EI's)
By
September
30,
2003
and
September
30,
2005,
based
on
local
1996,
1999,
2002
NET
EI's,
conducted
by
AACOG
Chapter
IV,
b)
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
26
Milestone
Completion
Date
Reference
in
the
Early
Action
Compact
Modeling
Milestones
Develop
SIP
quality
modeling
episodes
that
perform
within
the
EPA's
accepted
margin
of
accuracy,
including
a
base
case
and
future
case
on
or
before
December
31,
2007.
Documented
&
reviewed
by
TCEQ
&
EPA.
Quantifiable
emission
reduction
measures
in
the
future
case
to
produce
one
or
more
control
cases.
Control
strategies
determined
against
control
case
model.
Deliver
future
base
case
model
by
September
30,
2003
from
AACOG,
based
on
the
Sept.
1999
photochemical
model
currently
under
refinement
by
AACOG,
or
other
photochemical
model
as
agreed
upon
by
the
partners
under
this
compact
and
which
meets
the
requirements
of
this
compact.
Chapter
IV,
c)

Develop
other
episodes
as
necessary
to
fully
represent
the
variety
of
situations
that
typically
contribute
to
local
ozone
production
Requirement
for
further
episode
development
based
on
Conceptual
Model
updates.
Updates
completed
by
AACOG
by
April
30,
2003
and
April
30,
2005.
Chapter
IV,
c)

Control
Strategy
Development
Milestones
Identify
additional
local
controls,
as
necessary,
to
demonstrate
2007
attainment
of
the
8­
hour
standard.
Controls
implemented
by
Dec.
31,
2005,
with
full
local
stakeholder
participation.
Future
case
analysis,
control
cases
and
control
case
showing
achievement
of
the
8­
hour
ozone
standard
on
or
before
Dec.
31,
2007
will
be
available
as
a
report
by
March
31,
2004
from
AACOG
Chapter
IV,
d)

All
control
measures
will
be
incorporated
by
the
state
into
the
State
Implementation
Plan.
Required
deliverables
from
AACOG
to
TCEQ
&
EPA
by
March
31,
2004
Chapter
IV,
d)

Maintenance
for
Growth
Milestones
Component
to
address
emissions
growth
at
least
5
years
beyond
December
31,
2007,
ensuring
that
the
area
will
remain
in
attainment
of
the
8­
hour
standard
during
that
period.
The
satisfactory
choice
of
methodologies
to
demonstrate
a
maintenance
analysis
through
2012
will
be
agreed
upon
by
the
AIR
Committee,
TCEQ
and
the
EPA.
In
any
case,
required
deliverables
from
AACOG
to
TCEQ,
EPA
by
March
31,
2004.
Chapter
IV,
e)

A
continuing
planning
process
will
include
modeling
updates
and
modeling
assumption
verification
(
particularly
growth
assumptions)
Ongoing
process
between
the
TCEQ,
EPA
and
AACOG
Chapter
IV,
e)

If
the
review
of
growth
demonstrates
that
adopted
control
measures
are
inadequate
to
address
growth
in
emissions,
additional
measures
will
be
added
to
the
plan
Required
deliverables
from
AACOG
to
TCEQ,
EPA
as
needed
for
additional
SIP
revision
after
December
31,
2004
Chapter
IV,
e)
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
27
Milestone
Completion
Date
Reference
in
the
Early
Action
Compact
Public
Involvement
Milestones
Conducted
in
all
stages
of
the
planning
and
implementation
process.
Public
education
programs
used
to
raise
awareness
regarding
issues,
opportunities
for
involvement
in
the
planning
process,
implementation
of
control
strategies.
Interested
stakeholders
involved
in
the
planning
process
as
early
as
possible.
Planning
meetings
open
to
the
public,
with
posted
meeting
times
and
locations.
Plan
drafts
made
publicly
available,
and
the
drafting
process
will
have
sufficient
opportunities
for
comment
from
all
interested
stakeholders.
Semi­
annual
reports
detailing,
at
a
minimum,
progress
toward
milestones,
publicly
presented
and
publicly
available.
Public
reporting
of
assessment
and
progress
against
milestone
will
occur
at
least
once
every
six
months
during
the
regularly
scheduled,
public
meetings
of
the
joined
AIR
Executive
/
Advisory
Committees
of
the
AACOG.
AIR
Public
Education
Committee
is
charged
with
fulfilling
these
requirements.
Chapter
IV,
f)

In
addition,
local
signatories
will
be
responsible
for:

2.
Notifying
parties
as
soon
as
possible
of
issues
and
developments,
which
may
impact
performance
and
progress
toward
milestones.

3.
Notifying
parties
as
soon
as
possible
if
Early
Action
Compact
milestones
will
be
missed
or
have
been
missed.

4.
Notifying
parties
as
soon
as
possible
if
Early
Action
Compact
modification/
termination
is
to
be
requested.

The
State's
Commitments
The
State
will
provide
support
to
areas
throughout
the
planning
and
implementation
process,
including:

5.
Technical
assistance
in
the
development
of
emission
inventories,
modeling
process,
trend
analysis
and
quantification
and
comparison
of
control
measures;

6.
Necessary
information
on
all
Federal
and
State
adopted
emission
reduction
measures
which
affect
the
area;

7.
Critical
third
party
review
of
emissions
inventory,
modeling,
and
self­
evaluation
work;

8.
Technical
and
strategic
assistance,
as
appropriate,
in
the
selection
and
implementation
of
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
28
control
strategies;

9.
Technical
and
planning
assistance
in
developing
and
implementing
processes
to
address
the
impact
of
emissions
growth
beyond
the
attainment
date;

10.
Maintenance
of
monitors
and
reporting
and
analysis
of
monitoring
data;

11.
Support
for
public
education
efforts;

12.
Coordinate
communication
between
local
areas
and
the
EPA
to
facilitate
continuing
the
EPA
review
of
local
work;

13.
Expeditious
review
of
the
locally
developed
plan,
and
if
deemed
adequate,
propose
modification
of
the
SIP
to
adopt
the
early
action
plan;

14.
Adoption
of
control
measures
into
the
SIP
as
expeditiously
as
possible.
The
final
complete
SIP
revision
must
be
completed,
adopted,
and
submitted
by
the
state
to
the
EPA
by
December
31,
2004.

15.
The
EPA
will
provide
technical
assistance
to
the
state
and
local
area
in
the
development
of
the
early
action
plan.

16.
The
EPA
will
move
quickly
to
review
and
approve
completed
plans
by
no
later
than
nine
months
after
submission
of
the
SIP
revision
by
the
state.

17.
When
the
EPA's
8­
hour
implementation
guidelines
call
for
designations,
the
EPA
will
defer
the
effective
date
of
nonattainment
designation
and
related
requirements
for
participating
areas
that
fail
to
meet
the
8­
hour
ozone
standard
as
long
as
all
terms
and
milestones
of
the
Early
Action
Compact,
included
in
the
Clean
Air
Plan,
are
being
met,
including
submission
of
the
early
action
SIP
revision
by
December
31,
2004.

18.
Provided
that
the
monitors
in
the
area
reflect
attainment
by
December
31,
2007,
the
EPA
will
move
expeditiously
to
designate
the
area
as
attainment
and
impose
no
additional
requirements.

19.
If
at
any
time
the
area
does
not
meet
all
the
terms
of
this
Compact,
including
meeting
agreed­
upon
milestones,
then
it
will
forfeit
its
participation
and
its
designation
(
or
redesignation
if
necessary)
will
become
effective
according
to
the
EPA's
8­
hour
ozone
implementation
guidelines.
The
EPA
will
offer
the
area
no
delays,
exemptions
or
other
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
29
favorable
treatment
because
of
its
previous
participation
in
this
program.

20.
If
the
area
violates
the
standard
as
of
December
31,
2007,
and
the
area
has
had
the
effective
date
of
its
nonattainment
designation
deferred,
the
area's
nonattainment
designation
will
become
effective.
The
state
will
then
submit
a
revised
attainment
demonstration
SIP
revision
according
to
the
CAA
and
the
EPA's
8­
hour
implementation
rule,
unless
the
8­
hour
implementation
schedule
requires
SIP's
from
8­
hour
nonattainment
areas
before
December
31,
2008.
In
that
event,
a
revised
attainment
demonstration
SIP
revision
for
the
participating
area
will
be
due
as
soon
as
possible
but
no
later
than
December
31,
2008.
In
no
event
will
the
EPA
extend
the
attainment
date
for
the
area
beyond
that
required
by
the
CAA
and/
or
the
EPA's
8­
hour
implementation
rule.

21.
No
area
will
be
allowed
to
renew
its
Early
Action
Compact
after
December
31,
2007,
or
initiate
a
new
compact
if
it
has
previously
forfeited
its
participation.

Conditions
for
Modification
or
Early
Termination
This
agreement
may
be
modified
at
any
time
or
terminated
at
any
time
by
mutual
consent
of
all
signatory
parties.
Any
signatory
party
may
withdraw
from
the
agreement
if
the
other
signatory
parties
do
not
carry
out
provisions
of
the
agreement.
However,
once
portions
of
the
Clean
Air
Plan
are
incorporated
into
the
SIP,
then
SIP
revision
processes
must
be
followed
to
change
those
incorporated
portions.
SIP
revisions
are
binding
and
federally
enforceable.

Additional
Terms
of
This
Agreement
1.
This
MOA
creates
no
cause
of
action
against
any
party
beyond
those,
if
any,
that
may
already
exist
under
state
or
federal
law.
In
addition,
all
parties
agree
that
this
MOA
cannot
be
used
against
one
another
or
by
a
third
party
as
an
enforceable
order
in
any
court
proceedings.
This
MOA
will
be
reviewed
and
modified
as
needed.
2.
It
is
understood
that
emission
reductions
achieved
through
the
measures
described
in
this
document
will
be
donated
to
the
regional
Clean
Air
Plan
effort
and
will
not
be
available
for
use
in
an
emissions
banking/
trading
program,
unless
agreed
upon
by
the
signatory
parties.
3.
Additional
signatories
can
be
added
at
any
time.

Executed
in
multiple
copies
by
the
signatory
parties
to
this
Memorandum
of
Agreement.
The
representatives
of
the
signatory
parties
executing
this
MOA
represent
that
they
have
the
authority
to
sign
the
MOA
and
to
bind
the
signatory
party
that
they
represent
to
the
terms
of
the
MOA.
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
30
The
Honorable
Nelson
Wolff
Bexar
County
Judge
Bonnie
Conner
on
behalf
of
The
Honorable
Ed
Garza
Mayor,
City
of
San
Antonio
Date:
Date:

Jay
Millikin
on
behalf
of
The
Honorable
Danny
Scheel
Comal
County
Judge
The
Honorable
Adam
Cork
Mayor,
City
of
New
Braunfels
Date:
Date:

The
Honorable
James
E.
Sagebiel
Guadalupe
County
Judge
The
Honorable
Mark
Stautzenberger
Mayor,
City
of
Seguin
Date:
Date:

The
Honorable
Marvin
Quinney
Wilson
County
Judge
The
Honorable
Raymond
Ramirez
Mayor,
City
of
Floresville
Date:
Date:

The
Honorable
Gregg
Cooke,
Administrator,
Region
6,
US
Environmental
Protection
Agency
The
Honorable
Robert
J.
Huston,
Chairman,
Texas
Commission
on
Environmental
Quality
Date:
Date:
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
Page
31
The
Honorable
Marcy
Meffert,
Chair,
Alamo
Area
Council
of
Governments
Date:

OFFICERS
OF
THE
AIR
IMPROVEMENT
RESOURCES
COMMITTEE
(
Alamo
Area
Council
of
Governments)

The
Honorable
Patrick
Heath,
Chairman,
Air
Improvement
Resources
Committee
The
Honorable
Jay
Millikin,
Vice
Chairman,
Air
Improvement
Resources
Committee
Date:
Date:
Page
32
Protocol
for
Early
Action
Compacts
Designed
to
Achieve
and
Maintain
the
8­
Hour
Ozone
Standard
Purpose
of
the
Compact
Early
voluntary
8­
hour
air
quality
plans
can
be
developed
through
a
Compact
between
Local,
State
and
the
Environmental
Protection
Agency
(
EPA)
officials
for
areas
that
are
in
attainment
(
including
no
monitored
violations)
of
the
1­
hour
ozone
standard
but
approach
or
monitor
exceedances
of
the
8­
hour
standard.
These
early
action
plans
will
include
all
necessary
elements
of
a
comprehensive
air
quality
plan,
but
will
be
tailored
to
local
needs
and
driven
by
local
decisions.
The
Early
Action
Compact
is
designed
to
develop
and
implement
control
strategies,
account
for
growth,
and
achieve
and
maintain
the
8­
hour
ozone
standard.
This
approach
will
offer
a
more
expeditious
time
line
for
achieving
emission
reductions
than
the
EPA's
expected
8­
hour
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.
Early
Action
Compacts
should
complement
any
existing
Ozone
Flex
Agreements.

The
principles
of
the
tri­
party
Early
Action
Compact
to
be
executed
by
Local,
State
and
the
EPA
officials
are:
 
Early
planning,
implementation,
and
emission
reductions
leading
to
expeditious
attainment
and
maintenance
of
the
8­
hour
ozone
standard;
 
Local
control
of
the
measures
to
be
employed,
with
broad
based
public
input;
 
State
support
to
ensure
technical
integrity
of
the
early
action
plan;
 
Formal
incorporation
of
the
early
action
plan
into
the
SIP;
 
Deferral
of
the
effective
date
of
nonattainment
designation
and
related
requirements
so
long
as
all
Compact
terms
and
milestones
are
met;
and
 
Safeguards
to
return
areas
to
traditional
SIP
requirements
should
Compact
terms
and/
or
milestones
be
unfulfilled,
with
appropriate
credit
given
for
emission
reduction
measures
implemented.

Compact
Requirements
The
Compact
will
address
the
following
components:

A.
Milestones
and
Reporting

In
order
to
facilitate
self­
evaluation
and
communication
with
the
EPA,
TNRCC
and
stakeholders,
the
Early
Action
Compact
must
include
clearly
measurable
milestones
for
the
development
and
implementation
of
the
plan.
Local
areas
will
assess
and
report
their
progress
against
milestones
in
a
regular,
public
process,
at
least
every
six
months.
Milestones
will
include,
at
a
minimum:
­
Completion
of
emissions
inventories
and
modeling;
­
Adoption
of
control
strategies
that
demonstrate
attainment;
­
Completion
and
adoption
of
the
early
action
SIP
revision;
­
Attainment
not
later
than
December
31,
2007;
­
Post­
attainment
demonstration
and
plan
updates
as
outlined
in
Section
E;
Page
33

In
the
absence
of
achieving
milestones,
including
attaining
the
8­
hour
ozone
standard
on
or
before
December
31,
2007,
the
area
will
be
deemed
in
violation
of
the
Compact
and
will
be
subject
to
the
full
planning
requirements
under
applicable
Clean
Air
Act
(
CAA)
standard
SIP
processes
including
requirements
defined
as
part
of
the
EPA's
8­
hour
implementation
rulemaking.
Such
an
area
will
be
subject
to
the
same
requirements
and
deadlines
which
would
have
been
effective
under
the
CAA
and
the
EPA's
8­
hour
designation
rulemaking
had
it
not
participated
in
this
program,
with
no
preferential
delays
or
exemptions
from
the
EPA.
However,
the
area
will
receive
appropriate
credit
in
the
standard
SIP
process
for
all
emission
reductions
from
measures
implemented
in
this
program.

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

B.
Emissions
Inventory

Modeling
emissions
inventories
using
the
most
current
tools
available
will
be
completed
for
at
least
one
recent
episode
in
order
to
support
the
early
action
plan.
Emission
inventories
must
include:
­
1999
or
later
episode
reflective
of
a
typical
ozone
season
exceedance
that
meets
the
EPA
episode
selection
guidance
to
ensure
that
representative
meteorological
regimes
are
considered;
­
MOBIILE6
data
with
link
based
Travel
Demand
Model
(
TDM)
mobile
data
in
urban
areas;
­
NONROAD
model
data
adjusted
for
local
equipment
populations
and
usage
rates;
­
Area
source
databased
when
possible
on
local
survey
data.

Further
episode
inventories
will
also
be
developed
over
time
to
fully
represent
the
variety
of
situations
that
typically
contribute
to
ozone
production
in
the
area
and
to
include
the
most
recent
developments.

Emission
inventories
will
be
compared
and
analyzed
for
trends
in
emission
sources
over
time.
This
will
improve
an
area's
understanding
of
the
trends
in
emissions
in
their
community
and
will
aid
in
verification
of
the
accuracy
of
the
inventories.

C.
Modeling

Emission
inventories
will
be
used
to
develop
SIP
quality
modeling
episodes
that
perform
within
the
EPA's
accepted
margin
of
accuracy,
including
a
base
case
and
future
case
on
or
before
December
31,
2007.
Therefore,
inventories
must
sufficiently
account
for
projected
future
growth
in
ozone
precursor
emissions,
particularly
from
stationary,
non­
road,
and
onroad
mobile
sources.

Local
area
must
carefully
document
modeling
approach,
and
work
will
be
supported
and
reviewed
by
the
State
and
concurrently
reviewed
by
the
EPA.

Quantifiable
emission
reduction
measures
will
be
integrated
into
the
future
case
to
produce
one
or
more
control
cases.
These
control
cases
will
be
used
to
indicate
the
relative
effectiveness
of
different
measures
and
aid
in
selecting
appropriate
measures.

Prior
to
plan
implementation
the
control
strategies
should
be
determined
based
on
model
results
from
a
control
case
episode
that
shows
achievement
of
the
8­
hour
ozone
standard
on
or
before
December
31,
2007
through
implementation
of
the
control
strategies.
Page
34

Communities
will
continue
to
develop
other
episodes
as
necessary
to
fully
represent
the
variety
of
situations
that
typically
contribute
to
ozone
production
in
the
area
and
to
support
the
plan
with
the
most
current
information
and
tools.
Other
episodes
may
also
indicate
necessary
revisions
to
ensure
that
sufficient
emission
reduction
measures
are
selected
and
implemented
to
continue
to
achieve
target
ozone
concentration
levels.

D.
Control
Strategies

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
will
identify
additional
local
controls,
as
necessary,
to
demonstrate
attainment
of
the
8­
hour
standard
on
or
before
December
31,
2007.
These
local
controls
will
be
specific,
quantified,
permanent
and
enforceable
control
strategies.
All
controls
will
include
specific
implementation
dates,
as
well
as
detailed
documentation
and
reporting
processes.

Controls
will
be
implemented
as
soon
as
practicable,
but
not
later
than
December
31,
2005.

Controls
will
be
designed
and
implemented
by
the
community
with
full
stakeholder
participation.

All
control
measures
will
be
incorporated
by
the
state
into
the
State
Implementation
Plan
and
submitted
to
the
EPA
for
review
and
approval.
In
the
event
that
areas
wish
to
add
or
substitute
measures
after
SIP
submittal,
plan
modifications
will
be
treated
as
SIP
revisions
and
facilitated
by
the
state.

E.
Maintenance
for
Growth

The
plan
must
include
a
component
to
address
emissions
growth
at
least
5
years
beyond
December
31,
2007,
ensuring
that
the
area
will
remain
in
attainment
of
the
8­
hour
standard
during
that
period.
This
future
attainment
maintenance
analysis
may
employ
one
or
more
of
the
following
or
any
other
appropriate
techniques
necessary
to
make
such
a
demonstration:
­
Modeling
analysis
showing
ozone
levels
below
the
8­
hour
standard
in
2012;
­
An
annual
review
of
growth
(
especially
mobile
and
stationary
source)
to
ensure
control
measures
and
growth
assumptions
are
adequate;
­
Identification
and
quantification
of
federal,
state,
and/
or
local
measures
indicating
sufficient
reductions
to
offset
growth
estimates.

The
plan
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:
­
all
relevant
actual
new
point
sources;
­
impacts
from
potential
new
source
growth;
and
­
future
transportation
patterns
and
their
impact
on
air
quality
in
a
manner
that
is
consistent
with
the
most
current
adopted
Long
Term
Transportation
Plan
and
most
current
trend
and
projections
of
local
motor
vehicle
emissions.

If
the
review
of
growth
demonstrates
that
adopted
control
measures
are
inadequate
to
address
growth
in
emissions,
additional
measures
will
be
added
to
the
plan.
Local
planning
processes
should
prepare
for
this
possibility.

F.
Public
Involvement

Public
involvement
will
be
conducted
in
all
stages
of
the
planning
and
implementation
process.
Page
35

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

Interested
stakeholders
will
be
involved
in
the
planning
process
as
early
as
possible.
Planning
meetings
will
be
open
to
the
public,
with
posted
meeting
times
and
locations.
Plan
drafts
will
be
publicly
available,
and
the
drafting
process
will
have
sufficient
opportunities
for
comment
from
all
interested
stakeholders.

Public
comment
on
the
proposed
final
plan
will
follow
the
normal
SIP
revision
process
as
implemented
by
the
State.

Semi­
annual
reports
detailing,
at
a
minimum,
progress
toward
milestones,
will
be
publicly
presented
and
publicly
available.

Local,
State
and
the
EPA
Commitments
Local
Areas
Local
areas
hold
primary
responsibility
for
the
development
and
implementation
of
the
plan,
as
well
as
for
maintaining
communication
with
all
parties,
including:
 
Drawing
up
the
Compact,
which
embodies
the
requirements
described
in
Sections
A­
F,
including
a
time
line
for
milestones.
 
Completing
and
signing
by
all
parties
of
the
Early
Action
Compact
no
later
than
December
31,
2002.
 
Completing
and
adopting
the
early
action
plan
as
part
of
the
SIP
no
later
than
December
31,
2004.
 
Notifying
parties
as
soon
as
possible
of
issues
and
developments,
which
may
impact
performance
and
progress
toward
milestones.
 
Notifying
parties
as
soon
as
possible
if
Compact
milestones
will
be
missed
or
have
been
missed.
 
Notifying
parties
as
soon
as
possible
if
Compact
modification/
termination
is
to
be
requested.

State
The
state
will
assist
in
the
drafting
of
the
Early
Action
Compact
and
will
provide
support
to
areas
throughout
the
planning
and
implementation
process,
including:
 
Technical
assistance
in
the
development
of
emission
inventories,
modeling
process,
trend
analysis
and
quantification
and
comparison
of
control
measures;
 
Necessary
information
on
all
Federal
and
State
adopted
emission
reduction
measures
which
affect
the
area;
 
Critical
third
party
review
of
emissions
inventory,
modeling,
and
self­
evaluation
work;
 
Technical
and
strategic
assistance,
as
appropriate,
in
the
selection
and
implementation
of
control
strategies;
 
Technical
and
planning
assistance
in
developing
and
implementing
processes
to
address
the
impact
of
emissions
growth
beyond
the
attainment
date;
 
Maintenance
of
monitors
and
reporting
and
analysis
of
monitoring
data;
 
Support
for
public
education
efforts;
 
Coordinate
communication
between
local
areas
and
the
EPA
to
facilitate
continuing
the
EPA
review
of
local
work;
 
Expeditious
review
of
the
locally
developed
plan,
and
if
deemed
adequate,
propose
modification
of
the
SIP
to
adopt
the
early
action
plan;
Page
36
 
Adoption
of
control
measures
into
the
SIP
as
expeditiously
as
possible.
The
final
complete
SIP
revision
must
be
completed,
adopted,
and
submitted
by
the
state
to
the
EPA
by
2004.

EPA
The
EPA
will
recognize
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
Early
Action
Compact
developed
in
conformance
with
this
protocol.
 
The
EPA
will
provide
technical
assistance
to
the
state
and
local
area
in
the
development
of
the
early
action
plan.
 
The
EPA
will
move
quickly
to
review
and
approve
completed
plans
by
no
later
than
nine
months
after
submission
of
the
SIP
revision
by
the
state.
 
When
the
EPA's
8­
hour
implementation
guidelines
call
for
designations,
the
EPA
will
defer
the
effective
date
of
nonattainment
designation
and
related
requirements
for
participating
areas
that
fail
to
meet
the
8­
hour
ozone
standard
as
long
as
all
terms
and
milestones
of
the
compact
are
being
met,
including
submission
of
the
early
action
SIP
revision
by
2004.
 
Provided
that
the
monitors
in
the
area
reflect
attainment
by
December
31,
2007,
the
EPA
will
move
expeditiously
to
designate
the
area
as
attainment
and
impose
no
additional
requirements.
 
If
at
any
time
the
area
does
not
meet
all
the
terms
of
this
Compact,
including
meeting
agreed­
upon
milestones,
then
it
will
forfeit
its
participation
and
be
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
previous
participation
in
this
program.
 
If
the
area
violates
the
standard
as
of
December
31,
2007,
and
the
area
has
had
a
nonattainment
designation
deferred,
the
area
will
be
designated
nonattainment.
The
state
will
then
submit
a
revised
attainment
demonstration
SIP
revision
according
to
the
CAA
and
the
EPA's
8­
hour
implementation
rule,
unless
the
8­
hour
implementation
schedule
requires
SIP's
from
8­
hour
nonattainment
areas
before
December
31,
2008.
In
that
event,
a
revised
attainment
demonstration
SIP
revision
for
the
participating
area
will
be
due
as
soon
as
possible
but
no
later
than
December
31,
2008.
In
no
event
will
the
EPA
extend
the
attainment
date
for
the
area
beyond
that
required
by
the
CAA
and/
or
the
EPA's
8­
hour
implementation
rule.
 
No
area
will
be
allowed
to
renew
their
Early
Action
Compact
after
December
31,
2007,
or
initiate
a
new
compact
if
it
has
previously
forfeited
its
participation.
