STATE
OF
TENNESSEE
DEPARTMENT
OF
ENVIRONMENT
AND
CONSERVATION
DIVISION
OF
AIR
POLLUTION
CONTROL
9TH
FLOOR
L
&
C
ANNEX,
401
CHURCH
STREET
NASHVILLE,
TENNESSEE
37243­
1531
October
29,
2003
This
letter
is
to
provide
you
a
status
report
of
our
efforts
to
continue
meeting
the
requirements
of
the
Early
Action
Compact
that
we
have
entered
into
with
the
United
States
Environmental
Protection
Agency
(
EPA).
I
am
pleased
to
report
that
thus
far,
the
state
and
signatory
local
governments
have
met
every
deadline
established
in
the
agreement.

The
next
major
EAC
milestone
to
meet
is
the
March
31,
2004
deadline
for
local
governments
to
submit
a
copy
of
the
local
measures
they
will
take
to
achieve
compliance
with
the
new,
eighthour
ozone
standard
by
December
31,
2007.
This
is
a
particularly
critical
milestone
for
local
governments
because
those
measures
will
be
made
state
and
federally
enforceable
as
part
of
the
Tennessee
State
Implementation
Plan
(
SIP).
A
quote
of
the
milestone
requirements
from
the
November
14,
2002
EPA
Early
Action
Compact
guidance
memorandum
is
as
follows:

3.
March
31,
2004
 
The
resulting
local
plan
must
be
completed
and
submitted
to
the
State
or
Tribal
leader
by
March
31,
2004
for
inclusion
in
the
SIP
or
TIP
and
a
copy
must
be
provided
to
EPA
by
that
date.
The
local
plan
shall
include
measures
that
are
specific,
quantified,
and
permanent,
and
that
if
approved
by
EPA,
will
be
Federally
enforceable
as
part
of
the
SIP
or
TIP.
The
March
31,
2004
submission
also
must
include
specific
implementation
dates
for
the
adopted
local
controls.
In
addition,
the
local
plan
must
include
detailed
documentation
supporting
the
plan
and
reports
outlined
in
the
protocol,
as
well
as
a
modeling
analysis
based
on
local
controls
demonstrating
attainment
of
the
8­
hour
ozone
NAAQS
by
December
31,
2007.

The
Division
of
Air
Pollution
Control
will
continue
to
provide
technical
support
to
local
governments
to
assist
you
in
meeting
this
deadline.
To
that
end,
we
are
working
with
the
University
of
Tennessee
to
convert
the
list
of
likely
measures
your
area
submitted
for
the
June
16,
2003
milestone
into
quantified
emission
reductions
that
can
be
used
as
inputs
for
the
computer
modeling.
We
will
take
these
inputs
from
all
of
the
local
government
EAC
signatories
and
enter
them
into
an
atmospheric
chemistry/
dispersion
model
to
determine
whether
or
not
the
federal,
state
and
local
government
measures
to
reduce
NOx
and
VOC
are
sufficient
to
predict
attainment
of
the
new
eight­
hour
ozone
standard
by
December
31,
2007.
October
29,
2003
Page
2
The
computer
model
encompasses
most
of
the
Eastern
United
States
and
as
such,
the
sensitivity
of
the
model
will
not
likely
show
the
ozone
air
quality
improvements
of
any
one
county's
measures
in
reducing
ozone
levels.
The
model
is
not
that
sensitive
to
changes.
We
should
be
able
to
tell
you
what
sort
of
NOx
and
VOC
ozone
precursor
emission
reductions
will
be
expected
from
your
control
measures,
but
again,
we
will
not
likely
be
able
to
tell
you
what
impact
they
had
in
reducing
ozone.
As
EPA
evaluates
the
March
31,
2004
submittal,
one
aspect
of
its
review
will
be
a
satisfactory
showing
that
local
governments
are
serious
about
implementing
their
measures.
In
addition
to
ordinances
or
contracts
that
you
may
be
submitting,
any
documentation
you
can
provide
in
the
way
of
federal
or
local
funding
requests
to
implement
transportation
control
measures
that
will
improve
air
quality
would
be
beneficial
We
are
doing
our
calculations
and
will
perform
the
modeling
run
on
the
belief
that
all
of
the
June
16,
2003
likely
measures
you
reported
will
be
made
into
final
measures
that
are
permanent.
If
you
are
considering
or
want
to
make
changes
to
the
list
of
likely
control
measures
for
your
area,
submit
your
updated
list
of
likely
control
measures
by
November
15th.
A
Progress
Report
must
be
submitted
to
EPA
by
December
31,
2003.
We
are
almost
certain
to
need
all
of
the
measures
we
can
get
to
predict
attainment
of
the
new,
more
restrictive
ozone
standard
by
December
2007.
We
hope
to
issue
a
report
to
you
no
later
than
mid­
January
so
you
can
begin
the
process
of
making
your
local
measures
permanent
and
enforceable
according
the
rules
that
govern
your
rulemaking
or
ordinance
process.

If
you
should
have
any
questions,
please
feel
free
to
contact
my
deputy,
Quincy
Styke
III
at
(
615)
532­
0554
or
me
at
the
same
telephone
number.

Sincerely,

Barry
R.
Stephens,
P.
E.
Director
Division
of
Air
Pollution
Control
cc:
Local
Air
Agencies
Terry
Miller,
UT
