The
EARLY
ACTION
COMPACT
for
The
Roanoke
Metropolitan
Statistical
Area
(
MSA)
in
the
Commonwealth
of
Virginia
(
Cities
of
Roanoke
and
Salem,
Counties
of
Roanoke
and
Botetourt,
and
Town
of
Vinton)

Submitted
by
the
Roanoke
Area
Metropolitan
Planning
Organization
and
the
Respective
Localities
Listed
Above
of
16
2
TABLE
OF
CONTENTS
1.
Background



The
National
Ozone
Standards



The
1­
Hour
Standard
in
Roanoke
MSA,
Virginia



The
8­
Hour
Standard
In
Roanoke
MSA,
Virginia
2.
Ozone
Early
Action
program
(
OEAP)




Protocol
for
OEAP



The
Program



OEAP
Versus
Traditional
Nonattainment



OEAP
Timeline



The
Area
Encompassed
By
The
OEAP



Signatories
And
Their
Responsibilities



Conditions
For
Modification
Or
Early
Termination
3.
Early
Action
Compact



General
Provisions



Local
Government
Responsibilities



Milestones
and
Reporting



Emissions
Inventories
o
Initial
modeling
emissions
inventory
o
Future
year
modeling
emissions
inventory
o
Further
episode
inventories
4.
Modeling
5.
Emission
Reduction
Strategies
6.
Maintenance
for
Growth
7.
Public
Involvement
8.
The
Virginia
Department
on
Environmental
Quality
9.
The
Environmental
Protection
Agency
of
16
3
1.
BACKGROUND
The
National
Ozone
Standards
The
Federal
Clean
Air
Act
is
the
comprehensive
law
that
regulates
airborne
emissions
from
area,
mobile,
and
stationary
sources
nationwide.
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.
The
EPA
currently
has
two
NAAQS
for
ozone,
the
1­
hour
peak
standard
and
8­
hour
standard.

Areas
formally
declared
in
violation
of
the
NAAQS
and
adjacent
contributing
areas
are
designated
"
nonattainment
areas."
Nonattainment
areas
must
meet
certain
Clean
Air
Act
requirements,
such
as:

°
Transportation
Conformity:
Requires
a
demonstration
that
regional
long
range
transportation
plans
will
not
negatively
impact
air
quality
or
federal
transportation
funds
can
be
withheld.
°
New
Source
Review:
Requires
a
review
of
new
or
expanded
industrial
operations
to
minimize
air
pollution.
°
Rate
of
Progress
Requirements:
A
certain
percentage
of
pollutants
must
be
reduced
each
year.
°
10­
year
Maintenance
Plan:
After
attainment
that
includes
additional
or
continuing
mandatory
programs.

Another
requirement
obligates
the
state
to
develop
and
implement
a
prescriptive
comprehensive
clean
air
plan
that
mandates
how
the
area
will
come
into
compliance
with
the
standard.
This
plan
and
any
revisions
to
it
are
known
as
is
incorporated
the
State
Implementation
Plan
(
SIP).

The
1­
Hour
Standard
in
the
Roanoke
Metropolitan
Statistical
Area
(
MSA)

An
area
must
have
a
monitored
hourly
peak
ozone
concentration
below
125
parts
per
billion
(
ppb)
to
meet
the
1­
hour
ozone
standard.
If
an
area
exceeds
the
standard
more
than
three
times
in
three
years,
it
is
subject
to
a
nonattainment
designation.
Since
1990
the
Roanoke
Metropolitan
Statistical
Area
(
MSA)
exceeded
the
1­
hour
standard
on
two
occasions
in
1998;
however,
the
Roanoke
MSA
remains
in
compliance
for
the
1­
Hour
Standard.
The
Roanoke
MSA
has
one
ozone
monitor
located
in
the
Town
of
Vinton.

The
8­
Hour
Standard
in
the
Roanoke
Metropolitan
Statistical
Area
(
MSA)

During
the
past
several
years
air
quality
planning
in
the
Roanoke
MSA
has
intensified
as
ozone
concentrations
in
the
Roanoke
MSA
have
exceeded
the
value
permitted
by
the
8­
hour
ozone
NAAQS.
Due
to
legal
challenges
to
the
NAAQS
and
ensuing
litigation,
EPA
has
not
formally
of
16
4
designated
areas
of
the
United
States
in
violation
of
the
8­
hour
ozone
NAAQS.
The
8­
hour
NAAQS
has
been
upheld
and
EPA
anticipates
nationwide
designation
of
nonattainment
areas
by
2004.
Based
on
recent
monitoring
data,
it
is
probable
that
the
Roanoke
MSA
will
be
designated
a
nonattainment
area
when
formal
designations
occur.

The
8­
hour
ozone
standard
is
found
by
averaging
three
years
of
the
fourth
highest
8­
hour
ozone
levels
in
an
area.
This
number,
called
the
design
value,
must
be
lower
than
85
parts
per
billion
(
ppb)
to
meet
the
standard.
Currently,
the
Roanoke
MSA
design
value
(
averaging
2000,
2001,
and
2002)
is
87
ppb.
Each
year
this
design
value
may
vary.
Data
is
available
for
the
Roanoke
MSA
for
the
8­
hour
ozone
standard
beginning
in
1990.
Ozone
concentrations
have
exceeded
the
standard
a
total
of
29
times
during
the
period
from
1990
to
2002.
The
number
of
exceedences
recorded
in
Roanoke
from
1990
to
2002
are
shown
below.
Data
from
the
monitors
in
Wythe
and
Rockbridge
Counties
are
also
shown
for
comparison
purposes:

Roanoke,
VA
(
Vinton
Monitor)

90
91
92
93
94
95
96
97
98
99
00
01
02
0
2
0
2
2
2
0
2
13
6
2
5
5
Wythe
County,
VA
90
91
92
93
94
95
96
97
98
99
00
01
02
3
0
0
3
3
1
0
1
6
4
2
1
6
Rockbridge
County,
VA
90
91
92
93
94
95
96
97
98
99
00
01
02
2
0
1
0
8­
Hour
Ozone
Exceedences
(
1990
to
2002)

0
5
10
15
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
Year
Exceedences
Roanoke
Wythe
Rockbridge
of
16
5
In
2002,
the
Roanoke
monitor
recorded
8­
hour
exceedences
on
the
following
days:


June
11
91
ppb

July
17
94
ppb

August
10
85
ppb

August
11
92
ppb

August
13
99
ppb
OZONE
EARLY
ACTION
PROGRAM
(
OEAP)

The
region
is
volunteering
to
put
itself
into
the
OEAP
process
to
expedite
air
cleanup
for
future
public
health
and
welfare.

Protocol
for
OEAP
The
OEAP
was
developed
according
to
protocol
endorsed
by
EPA
Region
6
on
June
19,
2002.
The
Protocol
offers
a
more
expeditious
time
line
for
achieving
clean
air
than
expected
under
EPA's
8­
hour
implementation
rulemaking.

The
principles
of
the
OEAP
to
be
executed
by
Local,
State
and
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
OEAP;
°
Formal
incorporation
of
the
OEAP
into
the
SIP;
°
Deferral
of
the
effective
date
of
nonattainment
designation
and
related
requirements
so
long
as
all
OEAP
terms
and
milestones
are
met;
and
°
Safeguards
to
return
areas
to
traditional
SIP
requirements
should
OEAP
terms
and/
or
milestones
be
unfulfilled,
with
appropriate
credit
given
for
emission
reduction
measures
implemented.

The
Roanoke
MSA
OEAP
has
two
principal
components:

1.
The
Early
Action
Compact
(
EAC)
 
EAC
is
a
Memorandum
of
Agreement
to
prepare
and
implement
an
Early
Action
Plan
(
EAP).
More
specifically,
the
EAC
sets
measurable
milestones
for
developing
and
implementing
the
EAP.

2.
The
Early
Action
Plan
(
EAP)
 
EAP
serves
as
Roanoke
MSA's
official
air
quality
improvement
plan,
with
quantified
emission­
reduction
measures.
The
EAP
will
include
all
necessary
elements
of
a
comprehensive
air
quality
plan,
(
like
the
plans
in
Richmond,
VA),
but
will
be
tailored
to
local
needs
and
driven
by
local
decisions.
Moreover,
the
EAP
will
be
incorporated
into
the
formal
SIP
and
the
region
will
be
legally
required
to
carry
of
16
6
out
this
plan
just
as
in
nonattainment
areas.
For
example,
development
of
EAP
will
require
the
same
scientific
diligence
and
undergo
the
same
scrutiny
as
the
nonattainment
areas'
SIPs,
so
that
the
emission
reduction
strategies
selected
will
be
adequate
to
ensure
the
region
stays
in
attainment
of
the
8­
hour
standard.

OEAP
Versus
Traditional
Nonattainment
A
major
advantage
of
the
region's
participation
in
an
OEAP
is
the
flexibility
afforded
to
the
signatories
in
selecting
emission
reduction
measures
and
programs
that
are
best
suited
to
local
needs
and
circumstances.
Recognizing
the
varied
social
and
economic
characteristics
of
the
region,
not
all
measures
can
or
should
be
implemented
by
every
entity.

The
primary
differences
between
OEAP
and
the
traditional
nonattainment
area
process
are:
°
The
OEAP
allows
for
more
local
control
in
selecting
emission­
reduction
measures.
°
The
OEAP
provides
deferral
of
nonattainment
designation
and
related
requirements,
as
long
as
Plan
requirements
and
milestones
are
met.
This
would
prevent
any
related
stigma
associated
with
a
nonattainment
designation.
°
The
OEAP
is
designed
to
achieve
clean
air
faster
than
under
the
traditional
SIP
process.
°
Should
any
milestones
be
missed
in
designing
or
implementing
the
Plan,
the
area
would
automatically
revert
to
the
traditional
SIP
requirements,
with
appropriate
credit
given
for
emission
reduction
measures
already
implemented.

OEAP
Timeline
The
Roanoke
MSA's
OEAP
is
designed
to
enable
a
local,
proactive
approach
to
ensuring
attainment
of
the
8­
hour
ozone
NAAQS,
and
so
protect
human
health.
Using
the
OEAP
approach,
the
region
could
begin
implementing
by
2005
emission­
reduction
measures
directed
at
attaining
the
8­
hour
standard.
This
allows
for
a
significantly
earlier
start
than
waiting
for
formal
EPA
nonattainment
designation
and
it
gives
more
flexibility
in
choosing
which
emission
reduction
strategies
to
implement.

The
Area
Encompassed
By
The
OEAP
The
Roanoke
MSA,
which
is
comprised
of
the
Cities
of
Roanoke
and
Salem,
Counties
of
Roanoke
and
Botetourt
and
the
Town
of
Vinton
is
the
planning
area
for
which
the
Early
Action
Compact
is
designed.
After
signing
the
initial
compact,
additional
jurisdictions
may
be
added
upon
request
and
mutual
consent
of
all
the
signatory
parties,
due
to
expansion
of
the
nonattainment
area
or
other
reasons.
of
16
7
Signatories
And
Their
Responsibilities
The
individuals
representing
the
entities
that
will
sign
this
Early
Action
Compact
are
elected
officials
from
each
jurisdiction,
along
with
representatives
from
the
United
States
Environmental
Protection
Agency
(
EPA)
and
the
Virginia
Department
of
Environmental
Quality
(
VDEQ):

City
of
Roanoke
Council
Member,
W.
D.
"
Bill"
Bestpitch
(
Chairman
RVAMPO)
County
of
Roanoke
Board
of
Supervisors
Member,
Joe
McNamara
(
Vice
 
Chairman
RVAMPO)
City
of
Salem
Council
Member,
Howard
Packett
(
MPO
Member)
County
of
Botetourt
Board
of
Supervisors
Member,
Wendy
Wingo
(
MPO
Member)
Town
of
Vinton
Mayor,
Don
Davis
(
MPO
Member)
Virginia
DEQ
Director,
Robert
Burnley
U.
S.
EPA
Region
III
Regional
Administrator
or
Designee
The
local
entities
whose
representatives
support
and
sign
the
EAC
are
committed
to
holding
primary
responsibility
for
the
development
and
implementation
of
the
EAP,
and
for
maintaining
communication
with
all
parties.
These
commitments
by
local
agencies
are
enumerated
in
the
following
Memorandum
of
Agreement,
along
with
the
commitments
of
VDEQ
and
EPA.
After
signing
the
initial
compact,
additional
jurisdictions
may
be
added
upon
request
and
mutual
consent
of
all
the
signatory
parties.

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
before
formal
incorporation
into
the
SIP
in
2004.
Before
2004,
any
signatory
party
may
withdraw
from
the
agreement
if
the
other
signatory
parties
do
not
carry
out
provisions
of
the
agreement.
If
a
party's
withdrawal
from
the
agreement
prevents
the
remaining
signatories
from
satisfying
any
of
the
terms
and
milestones
of
the
original
agreement,
the
agreement
will
be
void
and
the
area's
nonattainment
designation
immediately
effective.
Once
the
EAP
is
incorporated
into
the
SIP,
modification
is
considerably
more
difficult,
as
the
SIP
is
a
legally
binding
state
and
federal
agreement
to
carry
out
specific
emission­
reduction
activities.

Additional
Terms
of
This
Agreement
1.
This
agreement
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
agreement
cannot
be
used
against
one
another
or
by
a
third
party
as
an
enforceable
order
in
any
court
proceedings.
This
agreement
will
be
reviewed
and
modified
as
needed.

2.
Each
jurisdiction
is
required
to
discuss
and
formally
approve
and/
or
adopt
the
local
emission
reduction
strategies
included
in
the
Early
Action
Plan
prior
to
its
formal
submission
to
the
state
and
federal
agencies
involved.
of
16
8
ROANOKE
METROPOLITAN
STATISTICAL
AREA
EARLY
ACTION
COMPACT
This
EAC
is
between
the
local
governments
representing
Cities
of
Roanoke
and
Salem,
Counties
of
Roanoke
and
Botetourt
and
Town
of
Vinton
(
herein
after
referred
to
as
the
local
governments),
VDEQ
and
EPA.
It
is
for
the
express
purpose
of
developing
and
implementing
a
plan
that
will
reduce
ground­
level
ozone
concentrations
in
the
Roanoke
Metropolitan
Statistical
Area
(
MSA)
to
comply
with
the
8­
hour
ozone
standard
by
December
31,
2007
and
maintain
that
standard
until
at
least
2012.
Failure
to
meet
that
obligation
results
in
immediate
reversion
to
the
traditional
nonattainment
process.

General
Provisions
A.
The
signatory
parties
commit
to
develop,
implement
and
maintain
the
Early
Action
Plan
according
to
EPA
Protocol
for
Early
Action
Compacts
issued
June
19,
2002
(
supplemented
per
a
letter
dated
October
18,
2002
from
Gregg
Cooke,
Regional
Administrator,
EPA
Region
6,
to
Robert
Huston,
Texas
Commission
of
Air
Quality),
and
adhere
to
all
terms
and
conditions
stated
in
the
guidelines.

B.
If
the
region
does
not
meet
all
the
terms
of
the
EAC,
including
meeting
agreed­
upon
milestones,
then
it
will
forfeit
its
participation
and
deferred
effective
date
of
its
nonattainment
designation,
thus
having
an
effective
nonattainment
designation
and
becoming
subject
to
EPA's
8­
hour
ozone
nonattainment
implementation
rules.

C.
This
agreement
may
be
modified
or
terminated
by
mutual
consent
of
all
signatory
parties.

D.
The
signature
date
of
the
EAC
is
the
start
date
of
the
agreement's
term
and
the
agreement
remains
in
effect
until
December
31,
2007.

Local
Government
Responsibilities
The
local
governments
agree
to
enter
into
a
compact
to
develop
and
implement
an
EAP
that
will
demonstrate
attainment,
by
December
31,
2007,
of
the
8­
hour
ozone
standard
and
continued
maintenance
of
the
standard
until
at
least
2012.
The
Roanoke
Valley­
Alleghany
Regional
Commission
(
RVARC),
in
consultation
with
the
local
governments,
will
develop
this
plan
in
coordination
with
VDEQ,
EPA,
stakeholders
and
the
public.
In
this
regard,
the
local
area
holds
the
primary
responsibility
for
the
development
and
implementation
of
the
plan,
as
well
as
for
maintaining
communication
with
all
parties
involved.
Specific
local
commitments
to
the
compact
and
plan
are:

1.
Drawing
up
the
compact,
which
embodies
the
requirements
for
Early
Action
Compacts
as
outlined
is
Sections
A
to
F
of
the
protocol,
including
a
timeline
for
milestones.
2.
Completing
and
signing
by
all
parties
of
the
compact
no
later
than
December
31,
2002.
of
16
9
3.
Identifying
and
describing
local
strategies
being
considered
for
inclusion
in
the
Early
Action
Plan
no
later
than
June
16,
2003.
4.
Selecting
local
control
strategies
no
later
than
January
31,
2004.
Each
jurisdiction
must
consider
and
formally
approve
and/
or
adopt
the
controls
that
make
up
the
local
component
of
the
Early
Action
before
this
date.
5.
Submitting
the
final
Early
Action
Plan
to
state
and
federal
agencies
no
later
than
March
31,
2004.
6.
Notifying
parties
as
soon
as
possible
of
issues
and
developments,
which
may
impact
performance
and
progress
towards
milestones.
7.
Notifying
parties
as
soon
as
possible
if
Compact
milestones
will
be
missed
or
have
been
missed.
8.
Notifying
parties
as
soon
as
possible
if
Compact
modification/
termination
is
to
be
requested.

Milestones
and
Reporting
1.
Milestones
Table
1:
Early
Action
Compact
Milestones
December
31,
2002
Signed
EAC
(
All
parties)
Initial
Modeling
Emissions
Inventory
Completed
(
VDEQ)
Conceptual
Model
Completed
(
VDEQ)
May
31,
2003
Base
Case
Modeling
Completed
(
VDEQ)
June
16,
2003
Identify
and
describe
local
strategies
being
considered
for
inclusion
in
the
local
clean
air
plan
(
Local
Governments)
June
30,
2003
Semi­
annual
status
reports
to
begin
(
RVARC,
VDEQ)
Future
Year
Emissions
Inventory
Modeling
Completed
(
VDEQ)
Emissions
trend
comparison
and
analysis
completed
(
VDEQ)
October
31,
2003
Future
Case
Modeling
Completed
(
VDEQ)
Attainment
Maintenance
Analysis
Completed
(
VDEQ)
One
or
more
modeled
control
cases
completed
(
VDEQ)
Local
emission
reduction
strategies
selected
(
Local
Governments)
January
31,
2004
Submission
of
preliminary
EAP
to
VDEQ
and
EPA
(
Local
Governments)
Final
Revisions
to
Modeled
Control
Cases
Completed
(
VDEQ)
Final
Revisions
to
Local
Control
Strategies
Completed
(
VDEQ)
Final
Revisions
to
Attainment
Maintenance
Analysis
Completed
(
VDEQ)
March
31,
2004
Submission
of
final
EAP
to
VDEQ
and
EPA
(
Local
Governments)
December
31,
2004
Early
Action
Clean
Air
Plan
Adopted
and
Incorporated
into
the
SIP
and
submitted
to
EPA
(
VDEQ)
December
31,
2005
Local
Control
Strategies
Implemented
No
Later
Than
This
Date
(
Implementing
Agency)
June
30,
2006
Semi­
annual
status
reports
on
implementation
of
measures
and
assessment
of
air
quality
improvement
begin
on
this
date
(
RVARC,
VDEQ)
of
16
10
December
31,
2007
Attainment
of
the
8­
Hour
Standard
no
later
than
this
date
2.
Reporting
In
order
to
facilitate
self­
evaluation
and
communication
with
EPA,
VDEQ,
stakeholders,
and
the
public,
the
region
will
assess
and
report
progress
towards
milestones
in
a
regular,
public
process,
at
least
every
six
months,
beginning
with
a
biannual
in
June
2003.

Emissions
Inventories
1.
An
initial
modeling
emissions
inventory
will
be
developed
by
May
31,
2003.
This
inventory
will
include:
a.
Emissions
modeling
data
for
a
1996,
1997,
or
1999
(
or
later)
episode,
which
will
be
representative
of
a
typical
ozone
season
event
and
meets
EPA
episode
selection
guidance;
b.
MOBILE6
data
with
link
based
Travel
Demand
Model
(
TDM)
mobile
data
where
available;
c.
NONROAD
model
data
adjusted
for
local
equipment
populations
and
usage
rates
(
if
available);
d.
Area
source
data
using
best
activity
data
available.

2.
A
2007
future
year
modeling
emissions
inventory
will
be
developed
by
October
31,
2003.
This
inventory
will
include
projected
future
growth
in
ozone
precursor
emissions
through
2007,
particularly
from
stationary,
non­
road
and
onroad
mobile
sources.

3.
Selection
of
specific
episode
inventories
was
partially
determined
by
the
conceptual
model,
which
reflects
an
analysis
of
meteorological
conditions
typical
of
high
ozone
events.
The
conceptual
model
will
be
updated
by
May
31,
2003.

4.
Emissions
inventories
will
be
compared
and
analyzed
for
trends
in
emission
sources
over
time.
The
emissions
inventory
comparison
and
analysis
will
be
completed
by
May
31,
2003.

Modeling
1.
Regional
photochemical
modeling
will
be
performed
to
provide
a
demonstration
of
attainment
of
the
ozone
standard
through
the
local,
state,
and
regional
control
strategies
included
in
the
EAP.
Base
case
modeling
will
be
completed
by
May
31,
2003
and
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:
of
16
11
a.
Will
be
SIP
quality
and
perform
within
EPA's
accepted
margin
of
accuracy;
b.
Will
be
carefully
documented;
c.
Will
sufficiently
account
for
projected
future
growth
in
ozone
precursor
emissions;
d.
Will
be
accomplished
by
VDEQ
and
reviewed
by
EPA;
d.
Will
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.

In
addition,
all
modeling
will
be
based
on,
to
the
extent
possible,
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).
This
modeling
will
follow
this
guidance
as
negotiated
and
agreed
to
with
the
EPA
Regional
Office.
Any
deviations
from
this
guidance
and
the
resulting
modeling
with
be
identified
and
reconciled
with
the
draft
guidance.
Data
availability
issues
may
limit
this
reconciliation.

Emission
Reduction
Strategies
1.
All
adopted
Federal
and
State
controls
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
emission
reduction
strategies
that
are
under
consideration
will
be
identified
and
described
by
June
16,
2003.
Any
additional
strategies
needed
to
demonstrate
attainment
for
the
Roanoke
MSA
will
then
be
selected
by
January
31,
2004,
with
final
revisions
completed
by
March
31,
2004.
The
selected
strategies
will
be
implemented
as
soon
as
practical,
but
no
later
than
December
31,
2005.

3.
Local
emission
reduction
strategies
will
be
specific,
quantified,
permanent
and
enforceable.
Local
controls
will
also
include
specific
implementation
dates
and
detailed
documentation
and
reporting
processes.

4.
Voluntary
measures
can
play
a
supporting
role
in
the
EAP.
If
emission
reductions
from
voluntary
emission
reductions
are
quantified
and
credit
is
taken
for
them
in
the
EAP,
those
emission
reductions
will
be
enforceable.
Additional
strategies
must
be
implemented
to
meet
those
quantified
reduction
requirements
if
quantified
voluntary
measures
fail.
This
is
true
for
all
quantified
emission
reductions.
of
16
12
5.
Local
emission
reduction
strategies
will
be
designed
and
implemented
by
the
community
with
stakeholder
participation.

6.
Local
emission
reduction
strategies
will
be
incorporated
by
the
state
into
the
SIP.
In
the
event
that
the
region
desires
to
add,
delete
or
substitute
strategies
after
SIP
submittal,
EAP
modifications
will
be
treated
as
SIP
revisions
and
facilitated
by
the
state.

Maintenance
for
Growth
1.
The
EAP
will
include
a
component
to
address
emissions
growth
at
least
five
years
beyond
December
31,
2007,
ensuring
that
the
area
will
remain
in
attainment
of
the
8­
hour
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:

o
Attainment
emissions
budget
evaluation
for
maintenance
demonstration
year
showing
that
future
emissions
remain
below
the
attainment
budget
for
the
area;
o
Modeling
analysis
showing
ozone
levels
below
the
8­
hour
standard
in
2012;
o
An
annual
review
of
growth
(
especially
mobile
and
stationary
source)
to
ensure
emission
reduction
strategies
and
growth
assumptions
are
adequate;
o
Identification
and
quantification
of
federal,
state,
and/
or
local
measures
indicating
sufficient
reductions
to
offset
growth
estimates.

2.
A
continuing
planning
process
that
includes
modeling
updates
and
modeling
assumption
verification
(
particularly
growth
assumptions)
will
be
conducted
concurrent
with
the
tracking
and
reporting
process
for
the
EAP.
This
update
and
verification
will
be
an
ongoing
process
between
the
signatories,
stakeholders
and
the
public.
Modeling
updates
and
planning
processes
must
consider
and
evaluate:

o
All
relevant
actual
new
point
sources;
o
Impacts
from
potential
new
source
growth;
and
o
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
demonstrates
that
adopted
emission
reduction
strategies
are
inadequate
to
address
growth
in
emissions,
additional
of
16
13
measures
will
be
added
to
the
EAP.

4.
In
the
event
that
the
continuing
planning
process
identifies
the
need
to
add,
delete,
or
substitute
emission
reduction
strategies
after
the
Plan
has
been
incorporated
into
the
SIP,
the
local
area
will
initiate,
and
VDEQ
will
facilitate
a
SIP
revision
to
accommodate
changes.

Public
Involvement
1.
Public
involvement
will
be
conducted
in
all
stages
of
planning
by
one
or
more
of
the
following,
or
other
appropriate
party:
Roanoke
Valley­
Alleghany
Regional
Commission
(
RVARC),
the
Roanoke
Area
Metropolitan
Planning
Organization
(
RVAMPO)
and
the
Virginia
Department
of
Environmental
Quality
(
VDEQ).
Outreach
may
include
one
more
of
the
following
techniques:
public
meetings
and
presentations,
stakeholder
meetings,
websites,
print
advertising
and
radio.

2.
Public
education
programs
will
be
used
to
raise
awareness
regarding
issues,
opportunities
for
involvement
in
the
planning
process,
implementation
of
emission
reduction
strategies,
and
any
other
issues
important
to
the
area.

3.
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.

4.
Public
comment
on
the
proposed
final
plan
will
follow
the
normal
SIP
revision
process
as
implemented
by
the
State.

5.
Semi­
annual
reports
detailing,
at
a
minimum,
progress
toward
milestones,
will
be
publicly
presented
and
publicly
available.

The
Virginia
Department
of
Environmental
Quality
The
state,
represented
by
VDEQ,
will
provide
support
to
areas
throughout
the
planning
and
implementation
process,
including:

1.
Development
of
emission
inventories,
modeling
process,
trend
analysis
and
quantification
and
comparison
of
emission
reduction
strategies;

2.
Necessary
information
on
all
Federal
and
State
adopted
emission
reduction
measures,
which
affect
the
area;

3.
Critical
third
party
review
of
emissions
inventory,
modeling,
and
self­
evaluation
work;
of
16
14
4.
Technical
and
strategic
assistance,
as
appropriate,
in
the
selection
and
implementation
of
emission
reduction
strategies;

5.
Technical
and
planning
assistance
in
developing
and
implementing
processes
to
address
the
impact
of
emissions
growth
beyond
the
attainment
date;

6.
Maintenance
of
monitors
and
reporting
and
analysis
of
monitoring
data;

7.
Support
for
public
education
efforts;

8.
Coordinate
communication
between
local
areas
and
EPA
to
facilitate
continuing
EPA
review
of
local
work;

9.
Expeditious
review
of
the
locally
developed
plan,
and
if
deemed
adequate,
propose
modification
of
the
SIP
to
adopt
the
early
action
plan;

10.
Adoption
of
emission
reduction
strategies
into
the
SIP
as
expeditiously
as
possible.
The
final
complete
SIP
revision
must
be
completed,
adopted,
and
submitted
by
the
state
to
EPA
by
2004.
The
SIP
revision
will
include
a
demonstration
that
the
area
will
attain
the
8­
hour
standard
by
December
31,
2007.

11.
If
EPA
withdraws
the
deferred
effective
date,
thereby
triggering
a
nonattainment
designation
and
applicable
statutory
requirements,
the
State
will
submit
a
nonattainment
SIP
to
EPA
within
1
year
of
the
new
effective
date
of
the
nonattainment
designation.

The
Environmental
Protection
Agency
1.
The
EPA
will
provide
technical
assistance
to
the
state
and
local
area
in
the
development
of
the
early
action
plan.

2.
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.

3.
At
the
time
of
designations,
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
EAC
are
being
met,
including
submission
of
the
early
action
SIP
revision
by
2004.

4.
Provided
that
the
monitor(
s)
in
the
area
reflect
attainment
by
December
31,
2007,
EPA
will
move
expeditiously
to
designate
the
area
as
attainment
and
impose
no
additional
of
16
15
requirements.

5.
If
at
any
time
the
area
does
not
meet
all
the
terms
of
this
EAC,
including
meeting
agreed­
upon
milestones,
then
it
will
forfeit
its
participation
and
its
nonattainment
designation
(
or
redesignation
if
necessary)
will
become
effective
after
EPA
withdraws
the
deferred
date.

6.
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.
EPA
will
take
action
to
withdraw
the
deferred
effective
date,
and
the
area's
nonattainment
designation
will
become
effective.

7.
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.
