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Page
1
of
32
3rd
Semi­
Annual
Report:
The
Early
Action
Compact
for
the
San
Antonio
Region
June
2004
Prepared
by
the
Alamo
Area
Council
of
Governments
This
document
was
reviewed
and
approved
by
the
Air
Improvement
Resources
(
AIR)
Technical
Committee
on
June
14,
2004.
It
was
subsequently
presented
and
approved
unanimously
as
a
final
document
by
the
AIR
Executive
/
Advisory
Committees
on
June
23,
2004.

Final
Document
Due
On
or
Before
June
30,
2004
6/
23/
04
Page
2
of
32
Title:
3rd
Semi­
Annual
Report:
The
Early
Action
Compact
for
the
San
Antonio
Region
Report
Date:
June
30,
2004
Authors:
Natural
Resources
Staff
Type
of
Report:
Semi­
Annual
or
Biannual
Report
Performing
Organization
Name
and
Address:
Alamo
Area
Council
of
Governments
8700
Tesoro
Drive,
Suite
700
San
Antonio,
TX
78217
Period
Covered:
January
 
June
2004
Sponsoring
Agencies
Name
&
Address:
Texas
Commission
on
Environmental
Quality
12100
Park
35
Circle
Austin,
TX
78753
Approved
by:

Abstract:
Protocol
for
the
Early
Action
Compact
(
EAC)
stipulates
that
areas
participating
in
the
compact
will
assess
and
report
their
progress
against
milestones
every
six
months.
The
Clean
Air
Plan
for
the
San
Antonio
Metropolitan
Statistical
Area
(
MSA)
is
responsible
for
detailing
and
demonstrating
the
MSA's
commitment
to
achieving
and
maintaining
the
8­
hour
ozone
standard
through
regional
voluntary
efforts.
The
implementation
of
the
Clean
Air
Plan
occurs
through
progress
against
prescribed
milestones
stipulated
by
the
Environmental
Protection
Agency
on
a
set
timeline.
Several
milestones
were
accomplished
from
January
2004
to
June
2004,
such
as
the
submittal
of
the
Attainment
Demonstration
for
the
San
Antonio
Early
Action
Compact
Region,
updates
to
modeling
analyses,
selection
of
clean
air
strategies
as
required
by
the
control
strategy
milestone,
and
on­
going
progress
for
the
public
involvement
milestone.
The
progress
against
the
milestones
is
discussed
in
the
report.

Related
Reports:
2nd
Biannual
Report:
The
Early
Action
Compact
for
the
San
Antonio
Metropolitan
Statistical
Area
Distribution
Statement:
Permanent
File:
Alamo
Area
Council
of
Governments,
Natural
Resources
/
Transportation
Department
Number
of
Pages:
31
Cost
of
Report:
Reproduction
Cost:
6/
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Page
3
of
32
Table
of
Contents
Chapter
1
 
Introduction
1.1
Clean
Air
Plan
1.2
Planning
Process
1.3
Biannual
Report
Chapter
2
 
Stakeholders:
Roles
and
Responsibilities
2.1
Stakeholders
2.1.1
AIR
Executive
Committee
2.1.2
AIR
Advisory
Committee
2.1.3
AIR
Technical
Committee
2.1.4
AIR
Public
Education
Committee
2.1.5
Public
Meetings/
Clean
Air
Plan
Workshops
2.1.5.1
February
3rd:
Clean
Air
Plan
Workshop
2.2
Stakeholder
Roles
Chapter
3
 
Early
Action
Compact
Milestones
3.1
Control
Strategy
Development
Milestones
3.1.1
Challenges
to
Local
Clean
Air
Strategies
3.1.2
Base
Case
and
Control
Strategy:
Photochemical
Modeling
Results
3.1.3
Additional
Evidence
3.2
Pubic
Involvement
Milestones
3.2.1
Media
3.2.2
Other
Outreach
3.3
Emissions
Inventory
Milestones
3.4
Maintenance
for
Growth
Milestones
3.4.1
Methodologies:
2012
Projections
3.4.2
Comparison
of
2007­
2012
Emissions
by
Major
Category
3.4.2.1
Emissions
Trend
3.4.3
Updating
the
Planning
Process
3.4.3.1
Modeling
Updates
and
Modeling
Assumption
Verification
3.4.3.2
Transportation
Patterns
3.4.4
New
Strategy
Requirements
3.5
Modeling
Milestones
3.5.1
Conceptual
Model
Chapter
4
 
Conclusion
Appendix
A
 
Air
Quality
Outreach
Efforts
Appendix
B
 
Outreach
Process
Evaluation
Summary
6/
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4
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32
List
of
Tables
Chapter
1
 
Introduction
None
Chapter
2
 
Stakeholders:
Roles
and
Responsibilities
Table
2­
1
AIR
Executive
Member
Agencies
Table
2­
2
AIR
Advisory
Membership
Table
2­
3
AIR
Technical
Member
Agencies
Table
2­
4
Date
and
Location
of
Clean
Air
Plan
Workshop
Chapter
3
 
Early
Action
Compact
Milestones
Table
3­
1
Comparison
of
1999
and
2007
Base
Cases
and
Adopted
Control
Strategies
Table
3­
2
Anthropogenic
Emissions
within
the
San
Antonio
Early
Action
Compact
Region
Table
3­
3
2003
Ozone
Exceedance
Days
and
Possible
Modeling
Episodes
Table
3­
4
Fourth
Highest
8­
Hour
Ozone
Values
by
Year
and
Design
Values
for
the
Conceptual
Model
Table
3­
5
Episode
Comparison
Chart
1999
Base
Case
+
Potential
Candidate
Episodes
Table
3­
6
San
Antonio
Peak
Ozone
and
Meteorological
Data
(
CAMS
23):
May
23­
31,
2003
Chapter
4
 
Conclusion
None
6/
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Page
5
of
32
List
of
Figures
Chapter
1
 
Introduction
None
Chapter
2
 
Stakeholders:
Roles
and
Responsibilities
None
Chapter
3
 
Early
Action
Compact
Milestones
Figure
3­
1
Trend
of
VOC
and
NOx
Emissions
in
the
SAER,
1996,
1999,
2007,
2012
Figure
3­
2
Updated
Daily
8­
hour
Ozone
Maximum
Comparisons
for
the
Conceptual
Model
Figure
3­
3
Back
Trajectory
Percentage
by
Direction
for
All
Ozone
Exceedance
Days,
1997
 
2003
Figure
3­
4
CAMx
APCA
Analysis
July
1995
Figure
3­
5
CAMx
APCA
Analysis
September
1999
Figure
3­
6
Ozone
Exceedance
Peaks
for
the
San
Antonio
Region
from
1997
to
2003
Figure
3­
7
High
Ozone
Readings
by
Two­
week
Period
by
Metropolitan
Region
to
Demonstrate
Seasonal
Peaks
Chapter
4
 
Conclusion
None
6/
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Page
6
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32
Chapter
1
 
Introduction
During
the
ozone
seasons
of
2000
through
2002,
local
air
quality
monitors
in
the
San
Antonio
region
recorded
ozone
levels
above
the
concentrations
allowed
under
the
8­
hour
ozone
National
Ambient
Air
Quality
Standard
(
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
US
Environmental
Protection
Agency
(
EPA)
guidance
then
suggested
that
the
boundary
of
the
Metropolitan
Statistical
Area
be
considered
as
the
boundaries
for
new
8­
hour
ozone
non­
attainment
areas,
air
quality
planning
has
focused
on
Bexar,
Comal,
Guadalupe
and
Wilson
Counties.
These
four
counties
are
called
"
the
San
Antonio
EAC
region"
in
this
document
since
they
comprised
the
Metropolitan
Statistical
Area
of
San
Antonio
on
December
9,
2002,
the
signing
date
of
the
Early
Action
Compact
(
EAC)
for
the
San
Antonio
region.
The
local
signatory
governments
to
the
EAC
are
within
these
four
counties.

On
April
15,
2004,
the
counties
of
Bexar,
Comal,
and
Guadalupe
were
declared
"
nonattainment
deferred"
by
the
EPA.
The
designation
occurred
under
the
8­
hour
average
ozone
NAAQS.
The
effective
date
of
the
nonattainment
designation
was
deferred
because
the
Clean
Air
Plan
for
the
San
Antonio
region,
developed
under
the
EAC
protocol,
was
effective
and
in
force.

1.1
Clean
Air
Plan
The
Early
Action
Compact
protocol
is
designed
to
guide
development
and
implementation
of
control
strategies,
including
planning
for
near­
term
growth,
in
order
to
achieve
and
maintain
the
8­
hour
ozone
standard.
This
compact
offers
a
more
expeditious
time
line
for
achieving
emission
reductions
than
the
EPA's
draft
8­
hour
implementation
rulemaking2,
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
are
tailored
to
local
needs
and
driven
by
local
decisions.
The
EAC
agreement
signed
by
the
EPA,
the
Texas
Commission
on
Environmental
Quality
(
TCEQ)
and
local
elected
officials
is
available
online:
http://
www.
aacog.
com/
cap/.

The
Clean
Air
Plan
embodies
and
documents
the
local
planning
created
from
the
guidance
provided
by
the
EAC
protocol.
The
Plan
is
a
working
document
providing
comprehensive
planning
for
the
ozone
challenge
before
the
four­
county
San
Antonio
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.
2
"
Proposed
Rule
To
Implement
the
8­
Hour
Ozone
National
Ambient
Air
Quality
Standard,"
June
2,
2003.
Available
online
http://
www.
epa.
gov/
fedrgstr/
EPA­
AIR/
2003/
June/
Day­
02/
a13240.
pdf
6/
23/
04
Page
7
of
32
EAC
Region.
Acceptance
of
the
final
Clean
Air
Plan
requires
the
adoption
of
control
strategies
or
methodologies
for
lowering
ozone
concentrations
to
acceptable
levels.
Proposed
strategies
undergo
performance
analyses
in
the
photochemical
model
and
are
reviewed
by
staff
from
the
Alamo
Area
Council
of
Governments
(
AACOG).
Model
results
are
then
presented
to,
reviewed,
and
approved
by
the
Air
Improvement
Resources
(
AIR)
Committees
of
AACOG,
the
TCEQ,
and
the
EPA.

1.2
Planning
Process
The
AIR
Executive
Committee
of
AACOG
is
the
planning
committee
for
air
quality
under
the
Early
Action
Compact
for
the
San
Antonio
region
and
is
charged
with
oversight
and
coordination
of
the
development
of
the
Clean
Air
Plan.
The
AIR
Committees
assess
and
report
the
region's
progress
at
least
every
six
months,
with
deliverables
sent
to
TCEQ
and
the
EPA.
Public
reporting
of
assessment
and
progress
against
milestone
occurs
at
least
once
every
six
months
during
the
regularly
scheduled,
meetings
(
scheduled
on
a
monthly
basis
and
open
to
the
public)
of
the
AIR
Executive
and
AIR
Advisory
Committees
of
the
AACOG.

The
AIR
Executive
Committee's
meetings
satisfy
the
requirement
in
the
EAC
that
planning
meetings
will
be
open
to
the
public,
with
posted
meeting
times
and
locations.
Every
meeting
of
the
AIR
Executive
and
Advisory
Committees
is
a
public
meeting,
with
notification
of
the
meeting
time
and
location
as
stipulated
in
the
Texas
Open
Meetings
Act.
AACOG
provides
notice
of
each
meeting
to
the
Secretary
of
State
for
posting
in
the
Texas
Register,
the
County
Clerk
of
Bexar
County,
and
posts
notice
in
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
AIR
Committee
is
pleased
to
engage
with
local
citizens,
the
EPA
and
the
TCEQ
in
the
planning
effort
required
to
maintain
the
Clean
Air
Plan
for
the
San
Antonio
EAC
region.
From
the
point
of
view
of
the
AIR
Committee,
this
Clean
Air
Plan
is
the
continuation
of
years
of
effort
and
planning,
which
has
been
made
possible
through
enabling
funding
provided
by
the
Legislature
of
the
State
of
Texas.

1.3
Semi­
Annual
Report
As
required
by
EAC
guidance,
areas
that
are
participating
in
early
voluntary
8­
hour
air
quality
plans
must
assess
and
report
their
progress
in
achieving
EAC
milestones
in
a
regular,
public
process
every
six
months.
This
document
will
fulfill
the
requirement
for
the
third
semi­
annual
progress
report
written
for
the
San
Antonio
EAC.

The
milestones
in
this
report
which
are
described
in
the
EAC
are:
 
Completion
&
updates
of
emissions
inventories
as
outlined
in
section
b),
Emissions
Inventory;
 
Completion
&
updates
of
modeling
as
outlined
in
section
c),
Modeling;
 
Post­
attainment
demonstration
and
plan
updates
as
outlined
in
section
e),
Maintenance
for
Growth;
6/
23/
04
Page
8
of
32
 
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;
 
Identification
and
description
of
local
control
strategies
under
current
consideration
for
inclusion
into
the
area's
local
clean
air
plan,
including
those
analyzed
in
modeling.

In
addition,
Lydia
Wegman,
Director
of
Air
Quality
Strategies
and
Standards
Division
of
the
US
Environmental
Protection
Agency,
signed
a
memo
providing
guidance
on
the
content
required
in
the
biannual
reports
due
in
June
and
December
of
2003.
Through
this
memo,
the
EPA
requires
certain
elements
be
incorporated
into
the
report.
3
The
reporting
requirements
given
in
both
the
EAC
protocol
and
the
Wegman
memo
have
been
organized
in
the
following
chapters
of
this
report.
These
additional
elements
include:

 
Stakeholders:
Roles
and
Responsibilities
 
Evaluation
and
Selection
of
Emission
Reduction
Measures
A
list
of
control
measures
still
under
consideration
for
adoption
by
the
local
area
as
part
of
the
March
2004
submission;
Likely
implementation
dates
for
the
local
control
measures
that
are
under
consideration;
Current
assessment
of
the
amount
of
emissions
reductions
expected
to
be
achieved
through
implementation
of
the
local
control
measures;
and
The
geographical
area
in
which
each
control
measure
is
anticipated
to
apply.

 
Public
Outreach
Activities
Continuing
public
involvement
in
the
planning
process
will
be
conducted
as
outlined
in
section
f),
Public
Involvement.

 
Update
on
Modeling
and
Technical
Planning
Activities
Post­
attainment
demonstration
and
plan
updates
as
outlined
in
section
e),
Maintenance
for
Growth
The
March
2004
submission
of
the
Attainment
Demonstration
for
the
San
Antonio
EAC
region
contained
the
finalized
list
of
emission
reduction
measures
and
implementation
dates
agreed
upon
by
the
local
EAC
signatories.
Updates
to
the
other
items
noted
above
are
contained
in
this
report.

3
"
Early
Action
Compacts
(
EACs):
The
June
16,
2003
Submission
and
Other
Clarifications,"
Lydia
N.
Wegman,
Director
Air
Quality
Strategies
and
Standards
Division,
April
4,
2003.
US
Environmental
Protection
Agency,
Research
Triangle
Park,
NC
27711.
Available
online:
http://
www.
epa.
gov/
ttn/
naaqs/
ozone/
eac/
6­
16­
2003_
eac_
milestone_
memo.
pdf
6/
23/
04
Page
9
of
32
Chapter
2
 
Stakeholders:
Roles
and
Responsibilities
2.1
Stakeholders
Stakeholders
for
the
Clean
Air
Plan
include
local
governments,
businesses,
industries,
schools
and
citizens
within
the
San
Antonio
EAC
region.
The
AIR
Committee
enables
area
governments
and
industrial
groups
to
participate
in
addressing
air
quality
concerns.
The
AIR
Committee
is
comprised
of
the
Executive/
Advisory,
Technical,
and
Public
Education
Committees.

2.1.1
AIR
Executive
Committee
The
AIR
Committee
makes
recommendations
regarding
actions
and
policy
to
the
local
governments
represented
by
the
AIR
Executive
Committee
membership.
The
AIR
Executive
Committee
is
the
planning
committee
for
air
quality
planning
under
the
Early
Action
Compact
in
the
San
Antonio
region.

The
AIR
Executive
membership
represents
the
major
government
organizations
within
the
San
Antonio
Metropolitan
Statistical
Area
(
SA/
MSA)
as
the
SA/
MSA
was
defined
at
the
time
the
EAC
was
signed,
December
9,
2002.
Membership
has
been
extended
to
similar
local
governments
brought
into
the
San
Antonio
Metropolitan
Statistical
Area
through
US
Census
redesignations
of
the
SA/
MSA
boundary
in
2003.

The
AIR
Executive
Committee
comprises
local
elected
officials
and
representatives
of
major
government
organizations
from
the
four
counties
of
Bexar,
Comal,
Guadalupe
and
Wilson.
County
governments
are
represented
by
elected
County
Judge
or
County
Commissioner
and
municipal
governments
are
represented
by
an
elected
official
serving
as
Mayor
or
City
Councilperson.
Other
entities
serving
on
the
AIR
Executive,
as
designated
by
the
bylaws,
have
one
representative
on
the
committee.
The
following
table
lists
agencies
for
AIR
Executive
memberships.
4
Table
2­
1
AIR
Executive
Member
Agencies
Air
Improvement
Resources
Executive
Member
Agencies
Bexar
County
City
of
San
Antonio
Comal
County
City
of
New
Braunfels
Guadalupe
County
City
of
Seguin
Wilson
County
City
of
Floresville
Greater
Bexar
County
Council
of
Cities
Alamo
Area
Council
Of
Governments
San
Antonio
/
Bexar
County
Metropolitan
Planning
Organization
2.1.2
AIR
Advisory
Committee
The
AIR
Advisory
Committee
acts
as
a
liaison
between
the
AIR
Executive
Committee
and
public
and
private
citizens.
Membership
of
the
AIR
Advisory
Committee
includes
the
AIR
Executive
Committee.
The
committee
is
comprised
of
representatives
from
local
governmental
entities
and
industrial
groups
within
the
San
Antonio
MSA
and
includes
representatives
listed
below.
5
 
Business
representatives
 
Environmental
Groups
 
Education
agencies
4
Bylaws,
Air
Improvement
Resources
Committee
of
the
Alamo
Area
Council
of
Governments,
available
Dec.
4,
2003
online
as:
http://
www.
aacog.
com/
air/
WhatWeDo/
AIRCO
Bylaws.
htm
5
Ibid
6/
23/
04
Page
10
of
32
 
Transportation
organizations
 
Utilities
 
Industry
representatives
 
Chambers
of
Commerce
 
Health
Organizations
 
Neighborhood
Organizations
 
Other
elected
officials
 
Minority
Organizations
The
following
table
lists
the
business,
industry,
and
other
groups
from
which
the
current
members
to
the
AIR
Advisory
Committee
are
drawn.

Table
2­
2
AIR
Advisory
Membership
Air
Improvement
Resources
Advisory
Member
Agencies
HEB
TxDOT
Kendall
County
Zachry
Construction
S.
A.
Manufacturers
Association
Word
Construction
Company
VIA
Metropolitan
Transit
Lackland
Independent
School
District
Holt
Company
City
Of
San
Antonio
Neighborhood
Associations
SAWS
Martin
Marietta
New
Braunfels
Chamber
of
Commerce
City
of
Seguin
Guadalupe
County
Valero
Texas
State
Inspection
Association
USAA
Toyota
Manufacturing
of
North
America
American
Lung
Association
Greater
San
Antonio
Chamber
of
Commerce
Northside
Independent
School
District
2.1.3
AIR
Technical
Committee
The
AIR
Technical
Committee
provides
recommendations
and
technical
assistance
on
air
quality
technical
issues
to
the
AIR
Executive
Committee.
The
members
of
the
committee
are
representatives
of
local
planning
agencies;
those
currently
providing
members
to
the
committee
are
listed
in
the
table
provided.
6
Table
2­
3
AIR
Technical
Member
Agencies
Air
Improvement
Resources
Technical
Committee
Member
Agencies
Alamo
Area
Council
of
Governments
Metropolitan
Planning
Organization
Bexar
County
City
of
New
Braunfels
City
Public
Service
City
of
San
Antonio
Comal
County
City
of
Seguin
City
of
Floresville
Texas
State
Inspection
Association
(
ex­
officio)
Guadalupe
County
TxDOT
District
Office
Metropolitan
Health
District
US
Environmental
Protection
Agency
(
ex­
officio)
VIA
Metropolitan
Transit
Wilson
County
Texas
Commission
on
Environmental
Quality
(
ex­
officio)

6
Bylaws,
Air
Improvement
Resources
Committee
of
the
Alamo
Area
Council
of
Governments,
available
Dec.
4,
2003
online
as:
http://
www.
aacog.
com/
air/
WhatWeDo/
AIRCO
Bylaws.
htm
6/
23/
04
Page
11
of
32
2.1.4
AIR
Public
Education
Committee
The
AIR
Public
Education
Committee
provides
stakeholders
with
the
opportunity
to
participate
monthly
in
the
development
of
materials,
advertisements,
activities,
and
events
aimed
at
educating
the
public
about
regional
air
quality
issues
and
Clean
Air
Plan
development.

2.1.5
Public
Meetings/
Clean
Air
Plan
Workshops
In
accordance
with
the
EAC,
the
public
will
have
opportunities
to
participate
with
the
ongoing
development
of
the
Clean
Air
plan
in
order
to
familiarize
themselves
with
the
process
and
goals
of
the
project.
Although
the
regularly
scheduled
monthly
meetings
of
the
AIR
Executive
Committee,
the
planning
committee
for
air
quality
planning
under
the
Early
Action
Compact
in
the
San
Antonio
region,
are
open
to
the
public
and
always
have
a
Citizens
to
Be
Heard
agenda
item,
additional
exposure
to
the
project
is
expressly
provided
to
the
public
through
these
meetings.
This
is
achieved
through
the
hosting
of
Clean
Air
Plan
Workshops.
Information
about
the
workshop
held
during
the
first
half
of
2004
is
given
here.

Goals:
 
Education
­
The
public
meetings
and
workshops
are
designed
to
give
the
public
background
information
and
updates
on
topics
such
as
air
quality
health
issues,
applicable
federal
and
state
law,
current/
historic
ozone
levels,
the
local
response
provided
by
the
Early
Action
Compact.
Other
background
may
include
an
explanation
of
the
EAC,
the
concept
of
control
strategies,
the
current
status
of
the
plan,
the
role
of
local
elected
officials,
of
AACOG's
committees,
of
the
public,
of
the
state
and
federal
governments,
timelines,
deliverables
under
the
EAC,
etc.
 
Communication
of
public
opinion
/
feedback
to
the
elected
officials.

Table
2­
4
Date
and
Location
of
Clean
Air
Plan
Workshop
Date
Location
February
3,
2004
AACOG
Board
Room,
8700
Tesoro,
San
Antonio,
TX
78217
2.1.5.1
February
3rd:
Clean
Air
Plan
Workshop
The
workshop
on
February
3rd
focused
on
presenting
the
selected
clean
air
strategies
that
were
to
be
incorporated
into
the
Clean
Air
Plan
to
the
public.
Elected
officials
were
present
to
provide
answers
to
citizen
questions
during
the
course
of
the
workshop.

2.2
Stakeholder
Roles
Roles
of
the
AIR
Committee
The
AIR
Committee
is
composed
of
several
committees:
AIR
Executive,
AIR
Advisory,
AIR
Technical,
and
AIR
Public
Education
Committee.
The
mission
of
the
AIR
Committee
is
to
facilitate
the
completion
of
the
air
quality
studies,
complete
necessary
planning
activities,
and
develop
a
comprehensive
emission
reduction
plan
that
will
guide
our
region's
actions
to
attain
the
8­
hour
ozone
NAAQS.

Roles
of
the
Public
Public
participation
is
an
integral
part
of
the
Clean
Air
Plan,
thus
various
avenues
must
be
provided
to
enable
citizens
to
have
access
to
the
development
process.
Every
citizen
in
the
region
has
three
avenues
they
can
partake
1)
in
AIR
Committee
public
meetings,
2)
in
public
meetings
and
upcoming
Clean
Air
Plan
Workshops,
and
3)
by
responding
through
the
AACOG
website.
6/
23/
04
Page
12
of
32
Chapter
3
 
Early
Action
Compact
Milestones
The
Attainment
Demonstration
for
the
San
Antonio
Early
Action
Compact
Region
was
submitted
to
the
Texas
Commission
on
Environmental
Quality
and
the
Environmental
Protection
Agency
on
March
31,
2004.
The
Demonstration
addressed
each
of
the
required
milestones
as
stipulated
by
the
Early
Action
Compact
and
detailed
the
efforts
and
clean
air
strategies
that
were
selected
by
EAC
signatories
as
the
strategies
that
would
help
attain
the
8­
hour
NAAQS
for
ground­
level
ozone.
The
following
sections
will
describe
the
milestones
and
progress
completed
through
the
months
of
January
to
June
2004.

3.1
Control
Strategy
Development
Milestones
The
AIR
Committee
recommended
three
Clean
Air
Strategies
for
inclusion
in
the
Clean
Air
Plan
to
local
Early
Action
Compact
signatory
governments
for
their
final
approval.
The
strategies
were:
 
Reid
Vapor
Pressure
lowered
to
7.2
pounds
per
square
inch
during
the
ozone
season
for
the
San
Antonio
region;
 
Degreasing
Equipment
Operation
Controls,
described
in
TAC,
Title
30,
Ch.
115;
and
 
Stage
I
Vapor
Recovery
required
of
service
stations
of
25,000
gallons
throughput
of
gasoline
or
more
per
month.

The
eight
local
governments
which
are
signatories
to
the
Early
Action
Compact
for
the
San
Antonio
region
deliberated
these
strategies
during
regularly
scheduled
meetings
of
their
representatives
(
i.
e.,
during
City
Council
meetings
or
during
Commissioners'
Court
sessions).
All
eight
local
governments
voted
to
endorse
the
three
Clean
Air
Strategies
above
and
to
support
this
planning
process.
The
San
Antonio
EAC
Region,
acting
through
the
AIR
Committee,
has
incorporated
these
three
strategies
into
the
Clean
Air
Plan
and
requests
that
the
Texas
Commission
on
Environmental
Quality
take
the
necessary
actions,
including
development
of
enforcement
provisions,
to
implement
these
clean
air
strategies.
The
following
list
details
the
dates
the
signatory
governments
met
and
approved
the
proposed
clean
air
strategies.

­
February
3,
2004:
City
of
Seguin
­
February
5,
2004:
Comal
County
Commissioner's
Court
­
February
9,
2004:
Wilson
County
Commissioner's
Court
­
February
10,
2004:
Bexar
County
Commissioner's
Court
­
February
12,
2004:
City
of
San
Antonio
­
February
12,
2004:
City
of
Floresville
­
February
23,
2004:
City
of
New
Braunfels
­
February
24,
2004:
Guadalupe
County
Commissioner's
Court
Copies
of
the
resolutions
signed
by
each
of
the
governments
are
available
as
Appendix
N:
Resolutions
from
Early
Action
Compact
Signatory
Local
Governments
in
Support
of
the
Proposed
Local
Revisions
to
the
State
Implementation
Plan
and
the
Local
Clean
Air
Strategies
of
the
Proposed
Local
Revisions
to
the
State
Implementation
Plan.
This
document
set
is
available
online:
http://
www.
aacog.
com/
sip.

3.1.1
Challenges
to
Local
Clean
Air
Strategies
6/
23/
04
Page
13
of
32
During
the
Clean
Air
Strategy
ratification
phase,
TCEQ
and
EPA
notified
AACOG
staff
of
possible
"
challenges"
to
several
of
the
clean
air
strategies
that
were
under
consideration
by
the
EAC
signatory
governments.
The
challenges
concerned
the
Clean
Air
Strategies
requesting
seasonal
RVP
7.2
gasoline
as
well
as
the
strategy
requiring
degreasing
equipment
controls.
The
proceeding
bulleted
list
details
the
timeline
of
which
the
notifications,
endorsements,
and
resolutions
occurred
during
the
strategy
ratification
process
for
each
locally
selected
strategy.

RVP
7.2
Gasoline
 
January
27,
2004:
AACOG
received
communication
from
EPA's
Region
6
Office
regarding
the
request
for
gasoline
with
an
RVP
of
7.2
and
Section
211
of
the
Clean
Air
Act.
EPA
expressed
concern
on
whether
Section
211
would
apply
to
a
lower
RVP
request
by
a
region
acting
under
the
Early
Action
Compact.
This
was
the
first
notification
to
AACOG
that
there
might
perhaps
be
existing
law
affecting
some
conditions
of
the
request
by
the
San
Antonio
area
for
lower
RVP.

 
January
28,
2004:
During
a
regularly
scheduled
meeting
of
the
AIR
Executive/
Advisory
Committees,
lower
RVP
received
the
formal
endorsement
by
the
committee
as
a
strategy
selected
for
ratification
by
the
local
EAC
signatory
governments.

 
Between
February
3­
February
12,
2004,
six
of
the
eight
local
Early
Action
Compact
signatory
governments
took
up
the
formal
endorsement
of
RVP
as
one
of
three
Clean
Air
Strategies
for
their
approval.

 
February
13,
2004:
TCEQ
provided
AACOG
some
clarification7
regarding
the
circumstances
allowing
such
a
measure
to
be
implemented
in
the
local
EAC
SIP.
According
to
EPA
and
TCEQ
preliminary
investigations,
Section
211(
c)(
4)(
A)
of
the
federal
CAA
prohibits
state
and
federal
governments
from
enforcing
RVP
as
it
was
being
requested.
Such
a
measure
can
only
be
implemented
in
an
EAC
SIP
if
there
are
special
circumstances.

 
February
17,
2004:
an
EPA
Working
Group
confirmed
their
earlier
interpretation
of
this
provision,
supporting
TCEQ's
opinion.

 
The
remaining
two
of
the
eight
local
Early
Action
Compact
signatory
governments
took
up
formal
endorsement
of
RVP
as
one
of
the
three
Clean
Air
Strategies
for
their
approval.
­
February
23,
2004:
City
of
New
Braunfels
approved
RVP
­
February
24,
2004:
Guadalupe
County
Commissioner's
Court
approved
RVP
Given
the
formal
approval
of
the
EAC
signatory
governments,
the
San
Antonio
EAC
Region
committed
to
request
the
state
to
implement
a
4­
county
EAC
regional
rule
requiring
gasoline
stations
to
dispense
gasoline
with
an
RVP
7.2
during
the
months
of
March
to
October.
Due
to
the
apparent
enforcement
prohibitions
described
above,
the
emissions
reduction
credits
which
would
be
expected
through
such
a
rule
are
not
7
Email
from
Candy
Garrett,
dated
February
13,
2004
to
Peter
Bella
of
AACOG.
Ms.
Garrett
is
Director,
Environmental
Planning
and
Implementation
for
TCEQ.
6/
23/
04
Page
14
of
32
considered
SIP­
creditable
and
are
not
modeled
in
the
Attainment
Demonstration
model.
If
a
resolution
is
reached
such
that
lower
RVP
is
supplied
to
the
San
Antonio
region
as
approved
by
local
governments
on
a
permanent,
enforceable
basis,
appropriate
SIP
credit
will
be
taken
for
the
measure
as
a
successful
local
Clean
Air
Strategy.

Degreasing
Equipment
Controls
 
January
28,
2004:
During
a
regularly
scheduled
meeting
of
the
AIR
Executive/
Advisory
Committees,
degreasing
equipment
controls
received
the
formal
endorsement
by
the
committee
as
a
strategy
selected
for
ratification
by
the
local
EAC
signatory
governments.

 
Early
February
2004:
TCEQ
staff
from
the
Region
13
office
informed
AACOG
staff
that
Chapter
106
of
the
TAC
contained
a
requirement
to
implement
Chapter
115­
compliant
degreasing
controls
statewide.
Subsequent
investigations
revealed
that
subchapter
T
of
Chapter
106
requires
Permit
By
Rule
degreasing
units,
regardless
of
the
county
in
which
they
are
located,
to
meet
the
requirements
of
§
115.412
and
§
115.415.
Following
the
realization
that
much
of
the
credit
previously
calculated
for
degreasing
controls
as
a
voluntary
Clean
Air
Strategy
might
no
longer
be
available
due
to
Chapter
106,
AACOG
staff
proceeded
to
analyze
Chapter
106
and
Chapter
115
and
assess
how
emission
reductions
should
be
properly
determined
and
allocated.

 
The
eight
local
Early
Action
Compact
signatory
governments
took
up
the
formal
endorsement
of
degreasing
equipment
controls
as
one
of
three
Clean
Air
Strategies
for
their
approval
during
February
2004.

Due
to
the
effectiveness
of
Chapter
106
as
an
existing
degreasing
emission
control,
effective
through
existing
state
rule,
an
additional
5.1
tons
per
day
VOC
reduction
credit
was
taken
in
the
2007
base
case.
However,
no
credit
for
degreasing
emission
controls
was
allowed
as
additional
Clean
Air
Strategy
reduction
credits
in
the
Attainment
Demonstration.

The
sole
emission
reduction
credits
entered
into
the
Attainment
Demonstration
through
enactment
of
local
clean
air
strategies
are
those
given
by
Stage
I
Vapor
Recovery.
The
"
SIP
credited"
reduction
was
in
the
amount
of
5.81
tons
per
day
of
VOC,
which
lowered
ozone
levels
as
shown
in
the
"
Control
Strategies
Included"
row
of
Table
3­
1
below.

With
the
resulting
support
and
approval
by
the
EAC
signatory
governments
of
the
recommended
clear
air
measures,
the
Attainment
Demonstration
of
the
San
Antonio
Early
Action
Compact
Region
requested
the
implementation
of
the
three
strategies.
The
Attainment
Demonstration
was
submitted
to
the
TCEQ
and
EPA
by
the
March
31,
2004
deadline.

3.1.2
Base
Case
and
Control
Strategy:
Photochemical
Modeling
Results
According
to
the
photochemical
modeling
analysis
performed
by
staff,
the
region
will
again
achieve
attainment
by
the
year
2007.
Table
3­
1
shows
design
values
for
the
1999
base
case,
the
2007
base
case,
and
the
impacts
of
adopted
control
strategies
on
design
values
for
CAMS
23,
59,
678,
and
58
where
ozone
levels
are
being
recorded.
6/
23/
04
Page
15
of
32
Table
3­
1
Comparison
of
1999
and
2007
Base
Cases
&
Adopted
Control
Strategies
Model
Run
Design
Value
at
CAMS
23
Design
Value
at
CAMS
58
Design
Value
at
CAMS
59
Design
Value
at
CAMS
678
1999
Base
Case
89
87
79
77
2007
Base
case
84.55
82.14
74.48
74.46
Control
Strategies
Included
84.43
82.05
74.44
74.39
3.1.3
Additional
Evidence
This
section
introduces
further
local
projects
as
well
as
additional
studies
and
indicators
supporting
the
likelihood
of
the
attainment
predicted
by
the
SAER's
2007
photochemical
model.

 
Degreasing
Emissions
Degreasers
in
the
SAER
are
subject
to
adherence
of
Chapter
115
controls
through
reference
in
Chapter
106.
Information
provided
by
the
TCEQ
indicates
that
at
least
50%
of
the
San
Antonio
market
are
Chapter
106
compliant.
Hence,
the
85%
reduction
effective
through
Chapter
106/
115
should
act
as
a
first
approximation
correction
to
50%
of
the
degreasing
emissions
in
the
1999
EI.

 
Pollution
Transport
Using
the
graphic
capabilities
of
the
CAMx
model
and
applying
some
post
processing
techniques,
attempts
have
shown
the
impacts
of
removing
the
anthropogenic
emissions
on
the
design
value
of
the
modeled
episode
at
various
CAMS.
Although
emissions
in
the
San
Antonio
region
is
predicted
to
increase
in
2007,
the
region's
contribution
to
its
design
value
for
the
September
1999
episode
will
remain
as
25%
of
the
total
design
value,
or
21.86
parts
per
billion
of
ozone.
8
(
AACOG,
2003a)

 
Alternative
Fuel
Vehicles
The
results
of
an
alternative
fuel
survey
conducted
in
the
San
Antonio
region
in
2001
indicated
that
there
were
2,050
AFVs
in
the
San
Antonio
region,
and
this
number
is
expected
to
increase
to
2,442
AFVs
by
2006.
Of
the
reported
fleet,
1,755
vehicles
were
modeled
as
the
September
2001
fleet
and
2,147
vehicles
for
the
September
2007
fleet.
These
fleets
provided
emission
reductions
of
62
lbs./
day
of
VOC,
45
lbs./
day
of
CO,
and
689
lbs./
day
of
NOx
and
emissions
reductions
of
72
lbs./
day
of
VOCs,
45
lbs./
day
of
CO,
and
858
lbs./
day
of
NOx
for
the
year
2007,
respectively.

 
Energy
Efficiency
/
Renewable
Energy
Projects
The
TCEQ
provided
a
protocol
for
implementing
and
calculating
emission
reductions
from
energy
saving
resulting
from
Senate
Bill
5
(
SB5)
and
Senate
Bill
7
(
SB7)
measures.
Since
passing
the
bills,
efforts
have
been
underway
both
to
implement
the
energy
reductions
required
by
the
state
and
to
quantify
the
associated
ozone
precursor
reductions.
Air
quality
planners
in
the
San
Antonio
region
currently
benefit
from
a
partnership
created
by
the
TCEQ
between
AACOG,
the
Energy
Systems
8
Alamo
Area
Council
of
Governments
(
AACOG),
2003.
Conceptual
Model
for
Ozone
Analysis
of
the
San
Antonio
Region,
San
Antonio,
TX.
6/
23/
04
Page
16
of
32
Laboratory
(
ESL)
of
Texas
A&
M
University,
the
local
Metropolitan
Partnership
for
Energy,
and
the
Brooks
Energy
Sustainability
Laboratory
(
BESL)
of
the
Texas
Engineering
Experiment
Station.

 
Lawnmower
Recycling
Program
City
Public
Service
(
CPS)
initiated
the
"
buy
back"
lawnmower
program
in
1998.
The
City
of
San
Antonio
and
the
Alamo
Area
Council
of
Governments
later
partnered
in
promoting
CPS'
"
buy
back"
events.
Since
its
inception,
CPS's
"
Mow
Down
Smog"
lawn
mower
rebate
program
has
removed
over
3,200
pieces
of
operating
gasolinepowered
lawn
equipment
and
replaced
them
with
virtually
pollution­
free
electric
lawn
equipment.

 
Lower
Reid
Vapor
Pressure
Gasoline
with
an
RVP
of
7.2
was
proposed
for
the
San
Antonio
region
after
in
depth
modeling,
cost­
benefit
analysis,
and
consideration
of
sentiments
of
the
local
communities
and
their
elected
officials.
If
allowed,
adoption
of
this
fuel
during
the
ozone
season
is
expected
to
help
reduce
emissions
of
VOCs
and
NOx
by
2.1
and
0.05
tons/
day
respectively.
The
requirement
for
gasoline
refineries
to
provide
such
gasoline
will
only
be
during
the
months
of
March
through
October,
which
is
usually
the
time
of
the
year
ozone
levels
exceed
the
national
standard
in
San
Antonio
region.

 
Windshield
Wiper
Fluid
Prior
to
EPA's
issuance
of
a
national
rule
addressing
VOC
emission
standards
for
windshield
wiper
fluid
to
35
weight­%
VOC,
Texas
adopted
a
consumer
products
rule
that
limits
automotive
windshield
washer
fluid
to
23.5
weight­%
VOC.
Due
to
the
difference
between
EPA's
35%
requirement,
the
EPA
allows
Texas
to
take
credit
for
the
difference
 
Gas­
fired
Water
Heaters,
Small
Boilers,
and
Process
Heaters
This
statewide
rule
would
reduce
NOx
emissions
from
new
natural
gas­
fired
water
heaters,
small
boilers,
and
process
heaters
sold
and
installed
in
Texas
beginning
in
2002.
It
is
estimated
that
this
rule
would
help
reduce
area
source
NOx
emissions
by
5%
to
10%.
The
rules
would
apply
to
each
new
water
heater,
boiler,
or
process
heater
with
a
maximum
rated
capacity
of
up
to
2.0
MMBtu/
hr.
(
TCEQ,
2004)

 
Transportation
Demand
Management
Transportation
Demand
Management
(
TDM)
projects
are
transportation­
related
projects
that
attempt
to
reduce
vehicle
use,
change
traffic
flow,
or
reduce
congestion
conditions.
Transportation
Emission
Reduction
Measures
(
TERMs)
are
examples
of
TDMs.
The
following
sections
are
examples
of
TDMs
exercised
in
the
area.

Transportation
Emission
Reduction
Measures
Transportation
Emission
Reduction
Measures
(
TERMs)
are
strategies
or
actions
that
can
be
employed
to
offset
increases
in
nitrogen
oxide
(
NOx)
and
volatile
organic
compound
emissions
from
mobile
sources
by
reducing
either
the
number
of
vehicle
trips,
vehicle
miles
traveled,
or
both.
Many
of
projects
in
the
San
Antonio­
Bexar
County
Metropolitan
Planning
Organization
(
SA­
BC
MPO)
Transportation
6/
23/
04
Page
17
of
32
Improvement
Programs
(
TIP)
9
can
be
quantified
as
creditable
reductions.
Local
air
quality
planners
are
currently
researching
measures
to
make
the
appropriate
TERMS
enforceable.
The
region
is
intent
on
making
them
enforceable
and
calculating
SIP
credit
for
them
in
coordination
with
the
state
and
the
SA­
BC
MPO.
Even
if
credit
is
not
taken
here
for
the
TERMS
projects
in
the
region,
the
benefits
of
the
reductions
accrue
as
Additional
Evidence
that
the
San
Antonio
region
will
reach
attainment.

Intersection
Improvement
and
Signalization
Traffic
signalization
projects
can
reduce
carbon
monoxide
(
CO)
and
hydrocarbon
(
HC)
by
reducing
the
number
of
vehicular
stops
and
idling,
which
would
reduce
travel
times
and
traffic
delays.
Reductions
in
fuel
consumption
have
also
been
observed
through
traffic
signal
re­
timing.
Traffic
flow
at
intersections
can
be
improved
in
interconnection
and
coordination
of
signals.
 
TransGuide
ITS
have
a
significant
impact
on
reducing
the
delays
due
to
accidents
and
congestion
on
freeway
systems
in
metropolitan
areas.
(
Henk,
R.,
et.
al.,
1996),
(
Carter,
M.,
et.
al.,
2000)
For
the
particular
corridor
modeled
during
this
study,
optimum
implementation
of
the
integrated
VMS
and
incident
management
result
in
a
5.7%
decrease
in
delay,
a
2.8%
decrease
in
crashes,
and
a
1.2%
decrease
in
fuel
consumption
annually.
Integrated
use
of
incident
management,
VMS
and
arterial
traffic
control
can
achieve
an
annual
benefit
of
a
5.9%
reduction
in
delay,
a
2.0%
decrease
in
crashes,
and
a
1.4%
decrease
in
fuel
consumption
for
travelers
in
the
corridor.

 
Public
Education
The
concept
of
public
education
is
to
familiarize
the
public
with
actions
they
can
take
to
improve
the
air
quality.
There
has
been
no
attempt
to
quantify
the
air
quality
impacts
of
these
public
outreach
projects.

 
Voluntary
Measures
by
Governmental
and
Industrial
Entities
Various
measures
which
benefit
the
area's
ambient
air
quality
are
currently
implemented
by
local
municipalities
and
companies.
The
implementation
of
the
strategies
by
the
various
entities
are
voluntary
efforts
that
benefit
the
air
quality
as
well
as
the
community
they
serve.
Here
are
a
few
examples
of
the
committed
and
voluntary
strategies
that
are
currently
in
effect.
 
Bexar
County
committed
to
use
Texas
Ultra
Low
Sulfur
Diesel
Fuel
in
the
county's
diesel
fleet
vehicles
as
well
as
voluntarily
post
signs
at
facilities
promoting
ozone
reduction
measures
 
City
Public
Service
(
CPS)
is
committed
to
fulfill
their
Emission
Reduction
Program
by
including
combustion
tuning
and
installation
of
advanced
technology.
CPS
also
voluntarily
allows
flextime
or
telecommuting
for
CPS
employees
for
which
this
option
is
feasible
and
allowed
by
the
management
of
that
area.
 
Lackland
Independent
School
District
commits
to
not
use
gas
powered
lawn
equipment
when
an
Air
Quality
Health
Alert
is
issued
but
rather
assign
grounds
personnel
alternative
tasks.
The
school
district
will
also
voluntarily
research
and
consider
the
feasibility
of
alternative
fuels
for
the
district's
vehicle
fleets
9
Available
online:
http://
www.
co.
bexar.
tx.
us/
mpo/
pages/
futureprojects/
short/
main.
html
6/
23/
04
Page
18
of
32
3.2
Public
Involvement
Milestones
Educating
the
public
about
the
importance
of
the
region's
air
quality
continues
to
be
a
crucial
effort
for
this
Clean
Air
Plan.
Outreach
and
education
efforts
continue
within
the
MSA,
often
through
partnerships
with
other
governmental
entities
and
industrial
leaders
in
the
area.
As
the
Clean
Air
Plan
is
developed,
citizens
and
citizen
groups
are
given
the
opportunity
to
be
involved
in
the
Clean
Air
Plan
development
process.

3.2.1
Media
Local
media
efforts
have
played
an
important
role
in
notifying
the
public
about
the
development
of
the
Clean
Air
Plan
as
well
as
in
educating
the
public
on
the
state
of
the
region's
air
quality
and
how
air
quality
affects
respiratory
health.
Television,
radio,
newspapers,
and
websites
have
been
avenues
through
which
information
about
the
Clean
Air
Plan
and
the
four
county's
air
quality
has
been
dispersed.
Press
releases
and
public
service
announcements
have
been
and
will
continue
to
be
utilized
to
educate
the
public.
Between
January
and
May
2004,
there
were
18
television
pieces,
18
radio
pieces,
and
32
newspaper
pieces
regarding
the
Clean
Air
Plan
and
air
quality
issues.
During
this
time,
public
service
announcements
are
confirmed
to
have
aired
on
four
television
stations
(
WOAI,
KABB,
KRRT,
and
News9
San
Antonio)
and
nine
radio
stations
(
KISS,
KSMG,
KKYX/
KCYY,
WOAI,
KAJA,
KXTN,
KROM,
and
KONO)

3.2.2
Other
Outreach
Efforts
Non­
media
related
outreach
efforts
continue.
Between
January
and
May
2004,
13
governmental,
business,
and/
or
civic
group
presentations
have
been
provided.
In
the
same
time
period,
AACOG
staff
provided
presentations
to
five
area
schools,
reaching
approximately
80
students.
Whenever
possible,
AACOG
coordinates
and/
or
participates
in
public
events;
such
events
allow
AACOG
staff
to
educate
citizens
on
how
everyday
actions
contribute
to
air
pollution
and
that
alternate
methods
of
doing
the
same
tasks
can
help
reduce
emissions.
During
this
time
period,
AACOG
participated
in
17
events.
Additionally,
AACOG
maintains
an
air
quality
website,
which
is
updated
weekly
and
provides
a
wealth
of
information
on
air
quality
issues.

On
March
27,
2004,
AACOG
along
with
the
AIR
Public
Education
Committee
hosted
Ozone
Season
Kickoff
to
promote
awareness
among
the
public
about
health
concerns
caused
by
ozone
exposure
as
well
as
alternative
activities
that
can
be
done
to
reduce
ozone
pollution.
Approximately
500
people
attended
Ozone
Season
Kickoff
and
were
given
the
opportunity
to
have
emission
tests
performed
on
their
vehicle,
receive
advice
regarding
proper
car
maintenance
by
certified
mechanics,
and
examine
hybrid
vehicles
as
well
as
alternative
fuel
vehicles.
Various
city,
county,
state,
and
public
entities
participated
in
the
event
promoting
various
environmentally
friendly
actions
as
well
as
the
services
they
provide.

AACOG
is
involved
with
the
promotion
and
coordination
of
the
Adopt­
A­
Schoolbus
program,
which
is
a
cooperative
partnership
established
to
aid
non­
attainment
area
school
districts
in
replacing
their
aging
diesel
school
buses
with
new
"
clean
fuel"
buses.
This
goal
will
be
achieved
by
educating
school
districts
and
corporations
about
the
benefits
of
replacing
older
diesel
buses
with
lower
emission
"
clean
fuel"
buses.
Approximately
275
school
buses
in
the
San
Antonio
area
are
projected
to
be
converted
to
"
clean
fuel"
buses
over
the
course
of
three
school
fiscal
years,
which
could
result
in
a
reduction
of
approximately
110
tons/
year
of
NOx
and
11
tons/
year
of
PM.
Efforts
at
reducing
the
emission
capacity
of
school
buses
could
involve
the
combination
of
6/
23/
04
Page
19
of
32
replacing
and
retrofitting
buses
with
new
technology
to
achieve
NOx
and
PM
reductions
and
the
possible
use
of
low­
sulfur
fuel.

In
addition,
the
AACOG
staff
is
vigorously
promoting
the
Texas
Emissions
Reduction
Plan
(
TERP)
created
in
2001
by
Texas
Senate
Bill
5.
With
the
partnership
of
the
Texas
Commission
on
Environmental
Quality
and
a
number
of
stakeholders,
AACOG
hosted
a
TERP
workshop
on
January
21,
2004.
Attendees
received
direct,
hands­
on
guidance
in
filling
out
the
grant
application
forms
for
TERP
projects.
10
AACOG
has
also
hosted
a
series
of
workshops
for
local
governments,
citizens,
and
homebuilders
on
the
energy
efficiency
aspects
of
Senate
Bill
5
as
well.

3.3
Emissions
Inventory
Milestones
Emissions
for
the
2012
projection
were
analyzed
and
verified
for
quality
assurance.
These
efforts
were
necessary
for
incorporation
of
the
emissions
into
the
Maintenance
for
Growth
chapter
of
the
Attainment
Demonstration
as
well
as
compliance
when
analyzing
emission
trends.
Emission
trend
analysis
is
an
ongoing
effort
and
will
be
helpful
when
developing
the
Emission
Trend
Analysis
as
required
by
the
EAC
in
September
2005.

3.4
Maintenance
for
Growth
Milestones
The
maintenance
for
growth
will
demonstrate
maintenance
of
the
8­
hour
ozone
standard
through
the
year
2012
while
accounting
for
projected
population
growth.
Chapter
6
and
Appendix
L
of
the
Attainment
Demonstration
for
the
San
Antonio
Early
Action
Compact
Region
describes
in
detail
the
region's
planning
for
five
years
beyond
the
2007
attainment
date.

The
Maintenance
for
Growth
section
analyzes
the
emissions
inventories
from
1996
and
1999
and
projects
emissions
to
2007
and
2012.
These
future
year
projections
encompass
all
relevant
changes
affecting
future
emissions,
including
revised
or
new
federal,
state,
and
local
rules
and
any
new
practices
that
would
result
in
changes
to
future
year
emissions
inventories.

3.4.1
Methodologies:
2012
projections
The
2012
emission
projections
were
developed
using
the
same
methodologies
in
the
development
of
2007
emissions.
However,
there
are
some
components
in
the
methodologies,
such
as
emission
factors,
that
were
altered
to
reflect
predicted
changes
for
2012
different
from
2007.
New
emission
sources
that
came
into
existence
after
2007
but
before
2012
were
accounted
for
as
well.

When
projecting
2012
point
source
emissions,
point
sources
that
are
expected
to
come
into
existence
between
2007
to
2012
were
accounted
for.
These
new
point
sources
include
the
Guadalupe
County
Power
Plants,
the
Tessman
Road
Landfill
Gas
Power
Station,
the
new
City
Public
Service
Power
Plant,
and
the
Toyota
Manufacturing
Plant.
VOC
emissions
are
projected
to
increase
due
to
the
contribution
of
the
Toyota
Manufacturing
Plant.
The
remaining
new
point
source
projects
such
as
the
CPS
power
plant,
the
Tessman
LFG
Power
Station,
and
the
Guadalupe
Power
Plant
are
not
10
Visit
http://
www.
tnrcc.
state.
tx.
us/
oprd/
sips/
terp.
html
for
more
information
on
the
TCEQ's
TERP
program.
For
more
information
on
AACOG's
TERP
workshops,
please
visit
http://
www.
aacog.
com/
terp/.
6/
23/
04
Page
20
of
32
expected
to
contribute
as
significant
amount
of
VOC
emissions
as
the
Toyota
Manufacturing
Plant.
NOx
emissions
are
projected
to
decrease
in
the
2007
and
2012
projections.

3.4.2
Comparison
of
2007­
2012
Emissions
by
Major
Category
Emissions
in
each
category
for
2007
and
2012
were
compared
and
analyzed
in
order
to
ensure
attainment.
VOC
emissions
from
point
source
are
estimated
to
increase
approximately
38.5%
from
2007
to
2012.
The
rise
is
attributed
to
the
emergence
of
new
point
sources
within
the
region,
such
as
the
Toyota
Manufacturing
Plant.
Point
source
NOx
emissions
are
expected
to
decrease
by
13.6%.
The
drop
in
NOx
is
anticipated
due
to
use
of
improved
emission
reducing
technologies
employed
at
the
City
Public
Service
power
production
facilities.
In
non­
road
sources,
a
17.6%
drop
in
VOC
and
a
8.2%
drop
in
NOx
emissions
is
anticipated
across
the
four
counties
between
2007
and
2012.
The
emission
reductions
are
due
to
various
state
and
federal
control
strategies.
Area
source
VOC
emissions
are
projected
to
increase
3.2%
and
NOx
emissions
by
5.6%.
This
can
be
attributed
to
various
growth
assumptions,
such
as
population
growth.
On­
road
VOCs
decreased
by
25.5%
and
NOx
emissions
dropped
by
40%
from
2007
to
2012.
State
and
federal
on­
road
control
strategies
that
will
be
implemented
by
2007
are
reasons
for
the
decrease
in
both
ozone
precursors.
Airport/
Military
emissions
were
not
projected
due
to
the
uncertainty
of
future
of
airport
and
military
base
activities
in
the
region.
Biogenic
emissions
emissions
were
unchanged
from
1999
for
2012.
Table
3­
2
details
the
emissions
from
1996,
1999,
2007,
and
2012.
6/
23/
04
Page
21
of
32
Tons
per
Day
Emission
1996*
1999
2007
2012
San
Antonio
Early
Action
Compact
Region
VOC
NOx
VOC
NOx
VOC
NOx
VOC
NOx
Bexar
78.3
2.4
73.4
4.7
69.2
5.0
71.4
5.2
Comal
4.4
0.1
3.7
0.3
3.4
0.5
3.6
0.5
Guadalupe
6.1
0.3
5.4
0.9
5.2
1.7
5.4
1.8
Wilson
2.6
0.4
2.7
0.9
2.7
1.8
2.7
2.0
Area
Sources
Total
91.4
3.3
85.2
6.8
80.5
9.0
83.1
9.5
Bexar
7.0
64.3
6.3
83.9
11.8
53.2
17.0
43.0
Comal
0.4
8.2
0.5
12.2
0.5
13.8
0.5
13.8
Guadalupe
0.4
0.3
0.5
0.5
1.1
8.1
1.1
8.1
Wilson
0.0
0.0
0.01
0.004
0.1
0.004
0.1
0.004
Point
Sources
Total
7.8
72.8
7.3
96.6
13.5
75.1
18.7
64.9
Bexar
106.6
122.39
82.1
121.87
45.5
69.1
33.7
41.4
Comal
6.8
10.4
6.2
11.7
3.9
7.1
3
4.3
Guadalupe
6.6
10
5.6
10.5
3.4
6.5
2.6
3.9
Wilson
1.9
1.9
1.6
1.9
1
1.3
0.8
0.8
On
Road
Sources
Total
121.9
144.69
95.5
145.97
53.8
84
40.1
50.4
Bexar
54.3
55.2
36.3
36.4
25.6
36.3
21.0
32.9
Comal
9.8
3.5
3.4
2.6
2.1
3.4
1.8
3.3
Guadalupe
4.3
4.4
4.1
2.3
1.7
3.3
1.4
3.3
Wilson
1.4
4.1
1.0
0.7
0.6
1.0
0.5
0.9
Non
Road
Sources
Total
69.9
67.2
45.7
42.0
30.0
44.0
24.7
40.4
*
note
1996
estimates
includes
version
two
of
the
1995
Mobile6
inventory
Table
3­
2
Anthropogenic
Emissions
within
the
San
Antonio
Early
Action
Compact
Region
6/
23/
04
Page
22
of
32
3.4.2.1
Emissions
Trend
Figure
3­
1
illustrates
the
predicted
emission
trend
from
1996
to
2012.
This
illustration
further
supports
the
SAER's
projected
maintenance
of
attainment
of
the
NAAQS
8­
hour
ozone
standard.
Between
1999
and
2007,
an
overall
reduction
of
28%
of
NOx
emissions
and
a
23%
reduction
in
VOC
emissions
are
predicted.
Between
2007
and
2012,
an
additional
22%
reduction
in
NOx
emissions
and
7%
reduction
in
VOC
emissions
can
be
expected.
These
reductions
are
a
result
of
the
positive
actions
enforced
by
the
USEPA
and
TCEQ
and
indicate
improved
air
quality
is
in
the
future
of
the
San
Antonio
EAC
region.

Figure
3­
1
Trend
of
VOC
and
NOx
Emissions
in
the
SAER,
1996,
1999,
2007,
2012
3.4.3
Updating
the
Planning
Process
Various
stages
of
planning
and
verification
must
be
performed
on
a
continual
basis
to
ensure
timely
emission
reductions
for
the
region
to
maintain
air
quality
standards.
The
impacts
of
new
point
source
related
emissions,
economic
and
population
growth,
and
the
implementation
of
new
control
strategies
are
evaluated
during
the
air
quality
modeling
process.
In
the
development
of
the
State
Implementation
Plan
for
the
San
Antonio
Early
Action
Compact
Region,
projected
growth
of
emission
sources
in
the
area
was
integral
in
the
air
quality
planning
process.
This
preliminary
trend
analysis
indicated
that
emissions
for
some
sources
were
projected
to
increase
while
other
sources
would
have
a
decrease
in
emissions.
Model
analysis
of
their
effect
on
ambient
ozone
levels
will
be
essential
in
ensuring
the
maintenance
of
attainment.

3.4.3.1
Modeling
Updates
and
Modeling
Assumption
Verification
AACOG
staff
will
analyze
air
quality
and
related
data
and
perform
necessary
modeling
updates
and
modeling
assumption
verification
annually.
In
the
event
that
updated
0
50
100
150
200
250
300
350
1996*
1999
2007
2012
Emission
Inventory
Years
Tons/
Day
Anthropgenic
NOx
Anthropgenic
VOC
6/
23/
04
Page
23
of
32
emission
inventories,
updates
in
any
photochemical
model
inputs,
or
corrections
to
earlier
modeling
assumptions
are
created
and
available,
the
modeling
scenarios
used
to
demonstrate
attainment
for
the
SAER
will
be
brought
up
to
date.
Modeling
updates
will
be
performed
in
accordance
with
state
and
federal
guidelines.

Ongoing
Updates
Gathering,
updating,
and
verifying
data
is
part
of
an
ongoing
process
between
the
Texas
Commission
on
Environmental
Quality,
the
US
Environmental
Protection
Agency,
and
the
Alamo
Area
Council
of
Governments.
The
updating
and
verification
process
will
continue
to
occur
in
the
context
of
the
Joint
Near
Nonattainment
Area
meetings
held
by
air
quality
planning
technical
staff
representing
TCEQ,
and
the
San
Antonio,
Victoria,
Corpus
Christi,
Austin
and
the
Tyler­
Longview
areas,
or
other
appropriate
venue
(
technical
meetings
with
TCEQ
and
/
or
EPA,
etc.).
AACOG
frequently
attends
other
technical
modeling
meetings
hosted
by
the
TCEQ,
EPA
as
well
as
regularly
scheduled
monthly
technical
meetings
of
the
local
San
Antonio
/
Bexar
County
Metropolitan
Planning
Organization
(
MPO).
All
local
transportation
planning
updates
to
the
modeling
inputs
will
be
incorporated
as
they
occur,
and
their
impacts
analyzed.

Reporting
of
modeling
updates
and
modeling
assumption
verification
will
be
reported
in
the
Semi­
Annual
Reports
written
by
the
AACOG.
These
reports
are
due
on
an
ongoing
six­
month
cycle
ending
December
31
and
June
30
of
each
year
of
the
Early
Action
Compact,
ending
December
31,
2007.

3.4.3.2
Transportation
Patterns
The
development
of
transportation
patterns
is
influenced
by
many
factors
such
as
land
use
and
urban
planning.
Transportation
patterns
directly
effect
emissions
originating
from
on­
road
sources,
therefore
they
must
be
evaluated
for
their
impact
on
ozone
levels.
Throughout
the
continuing
planning
process,
the
air
quality
impact
on
the
region's
ozone
levels
imposed
by
transportation
patterns
will
be
evaluated
and
assessed
by
technical
staff
of
various
local,
regional,
state,
and
federal
offices.
As
specified
in
3.4.3.1,
the
ongoing
technical
collaboration
between
AACOG
and
the
local
MPO
is
the
central
conduit
such
that
updated
transportation
planning
becomes
integrated
in
air
quality
planning.
These
cooperative
relations
will
assist
in
maintaining
the
8­
hour
ozone
standard
by
the
technical
assistance
provided
by
each
agency
and
in
the
event
additional
planning
is
necessary.

3.4.4
New
Strategy
Requirements
The
annual
reviews
of
growth,
including
the
updates
and
the
continuing
planning
processes
reported
in
the
Semi­
Annual
Updates
will
provide
air
quality
planners
the
insight
necessary
to
ensure
attainment
of
the
8­
hour
standard
up
to
2012.
The
extensive
clean
air
strategy
modeling
performed
by
AACOG
staff
will
facilitate
the
planning
if
the
continuous
review
process
indicates
additional
measures
should
be
considered.

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.
If
additional
control
measures
for
2007
attainment
are
suggested
as
being
necessary
through
a
review
of
growth,
they
will
be
verified
using
the
current
attainment
demonstration
photochemical
model
and
adopted
according
to
the
public
review
process
overseen
by
the
Air
Improvement
Resources
Committee.
If
additional
control
measures
for
2012
attainment
are
suggested
as
being
necessary
through
a
review
of
growth,
6/
23/
04
Page
24
of
32
AACOG
staff
will
work
with
the
TCEQ
and
EPA
to
analyze
control
strategies
based
on
then­
currently
available
photochemical
models.
Appropriate
control
strategies
will
be
adopted
according
to
the
public
review
process
overseen
by
the
Air
Improvement
Resources
Committee.

3.5
Modeling
Milestones
Performing
on­
going
modeling
activities
ensures
the
quality
of
modeling
products
required
for
air
quality
planning
activities.
The
ongoing
analysis
of
the
ambient
air
situation
in
the
San
Antonio
Early
Action
Compact
Region
requires
continuous
updates
to
provide
air
quality
planners
the
comprehension
of
the
air
quality
situation
in
the
region.

3.5.1
Conceptual
Model
A
conceptual
model
profiles
or
typifies
the
conditions
in
which
high
ozone
levels
occur
for
a
region
through
the
study
of
the
meteorology,
seasonal
variables,
and
regional
influences,
accompanying
high
levels
of
ozone.
From
this
data,
episodes
are
designated
as
possible
modeling
candidates.
Thus,
a
conceptual
model
is
a
tool
a
tool
to
compare
possible
episodes
that
could
be
incorporated
into
a
photochemical
model
for
control
strategy
evaluation.

The
conceptual
model
developed
and
referenced
in
the
1st
Biannual
Report
submitted
in
June
of
2003
analyzed
various
data
up
to
2002.
Updates
were
recently
performed
on
the
conceptual
model
and
included
obtaining
ozone
data,
meteorological
data
sets,
information
on
transport,
wind
direction,
and
back
trajectories
from
2003.
Ozone
levels
were
recorded
for
the
nonattainment
and
near
nonattainment
areas
in
Texas.
Selection
of
a
possible
"
episode"
occurs
when
the
comparison
of
ozone
levels
from
each
area
allows
the
identification
of
a
timeframe
in
which
all
the
areas
experienced
high
ozone
levels
at
the
same
time.
The
following
table
lists
all
eight­
hour
ozone
exceedance
days
recorded
in
San
Antonio
for
the
2003
ozone
season.
This
list
was
added
to
a
list
of
candidate
episode
dates
from
1995­
2002
that
was
originally
included
in
the
Conceptual
Model
report.
After
compiling
a
list
of
ozone
exceedance
days
 
using
eight­
hour
definitions
for
exceedance
­­
from
TCEQ
archives,
the
task
of
identifying
patterns
in
the
data
begins.

Table
3­
3
2003
Ozone
Exceedance
Days
and
Possible
Modeling
Episodes
Date
8
Hour
Multiple
Exceedance
Days
Notes
Additional
Notes
5/
23/
03
88
5/
24/
03
85
May
23­
24
Weak
candidate:
fewer
than
3
exceedance
days
5/
28/
03
96
5/
29/
03
87
May
28­
29
Weak
candidate:
fewer
than
3
exceedance
days
Could
be
modeled
together
as
one
episode
with
4
exceedance
days.

6/
7/
03
86
6/
20/
03
87
9/
6/
03
91
9/
7/
03
87
September
6­
7
Weak
candidate:
fewer
than
3
exceedance
days
6/
23/
04
Page
25
of
32
Of
the
ozone
data
gathered
during
the
update
process,
a
design
value
for
2001­
2003
was
recalculated
for
an
average
of
89.3.
This
average
is
still
in
violation
of
the
8­
hour
ozone
NAAQS.
Table
3­
4
lists
the
fourth
highest
ozone
values
for
2001­
2003
and
the
design
value
for
CAMS
23.

Table
3­
4
Fourth
Highest
8­
Hour
Ozone
Values
by
Year
and
Design
Values
for
the
Conceptual
Model
(
ppb)

Site
2001
2002
2003
Design
Value
CAMS
23
78
104
86
89.3
CAMS
58
81
95
85
87.0
In
addition
to
the
design
value
at
CAMS
23,
the
design
value
at
CAMS
58
was
87.0,
which
is
also
in
violation
of
the
8­
hour
ozone
standard.
The
San
Antonio
EAC
Region
has
two
monitors
in
violation
of
the
NAAQS.

Analyses
were
performed
with
these
new
data
sets
and
involved
observing
the
effect
of
some
meteorological
variables
(
temperature,
precipitation,
wind
speed
and
direction),
particulate
matter
(
PM
2.5),
solar
radiation,
and
atmospheric
stability.
Figure
3­
2
details
the
new
analyses
that
were
performed
incorporating
the
2003
data.

Figure
3­
2
Updated
Daily
8­
hour
Ozone
Maximum
Comparisons
for
the
Conceptual
Model
0
20
40
60
80
100
120
40
60
80
100
Daily
Peak
Temperatures
in
Degrees
F
Daily
Ozone
8
­
Hour
Maximums
96%
of
exceedance
days
had
temps
>
84
F
8­
hr
Ozone
Standard
Daily
8­
hour
Ozone
Maximums
v.
Peak
Temperature,
1998­
2003
Ozone
Season
Days
Daily
8­
hour
Ozone
Maximums
v.
Average
Wind
Speeds,
1997­
2003
Ozone
Season
Days
0
20
40
60
80
100
120
2
4
6
8
10
12
14
Average
Daily
Wind
Speed
(
mph)
Daily
Ozone
8­
Hour
Maximum
(
ppb)

8­
hr
Ozone
Standard
21%
of
exceedance
days
had
average
wind
speeds
>
5mph
&
5%
>
6mph
6/
23/
04
Page
26
of
32
Air
Parcel
Paths
Studying
air
parcel
paths
can
assist
in
the
comprehension
of
"
air
pollution
behavior."
Back
trajectories
allow
the
movement
of
air
parcels
to
be
analyzed
and
recognize
the
path
followed
by
the
parcel
before
reaching
its
destination.
The
HYSPLIT
model
is
used
to
develop
back
trajectories,
as
recommended
by
TCEQ.
11
By
utilizing
the
HYSPLIT
model
for
the
forty­
two
exceedance
days
in
the
San
Antonio
area,
spatial
patterns
were
observed
for
the
exceedance
days.
Figure
3­
3
illustrates
air
parcel
paths.

Figure
3­
3
Back
Trajectory
Percentage
by
Direction
for
All
Ozone
Exceedance
Days,
1997
 
2003
Analysis
of
wind
directions
is
another
component
of
the
episode
selection
process.
Table
3­
5
the
base
case
and
composite
(
base
case
and
candidate
episode)
percentages
of
air
parcels
by
directional
octant.
Following
table
3­
5
is
table
3­
6,
which
provides
an
overall
comparison
of
ozone
and
meteorological
conditions
for
the
extended
May
2003
candidate
episode.
The
table
compares
some
of
the
meteorological
characteristics
analyzed
when
identifying
a
potential
episode.

11
TCEQ,
Air
Monitoring,
"
Where
did
the
Air
Come
from
and
Where
is
It
Going?"
Available
on­
line:
http://
www.
tnrcc.
state.
tx.
us/
updated/
air/
monops/
data/
trajectories/
maintraj.
html
6/
23/
04
Page
27
of
32
Table
3­
5
Episode
Comparison
Chart
1999
Base
Case
+
Potential
Candidate
Episodes
Octant
All
Exceedances
1997­
2003
San
Antonio
Base
Case:
Sept.
16
&
18­
20,
1999
Base
Case
+
May
28­
29,
2003
Base
Case
+
May
28­
29,
2003
Base
Case
+
May
23­
24
&
28­
29,
2003
Base
Case
+
Sept.
6­
7,
2003
N
3%
0%
0%
5%
4%
0%
NE
23%
18%
12%
27%
20%
13%
E
27%
16%
12%
12%
10%
37%
SE
34%
47%
54%
33%
42%
37%
S
7%
14%
18%
9%
14%
9%
SW
3%
3%
2%
2%
2%
2%
W
3%
3%
2%
10%
7%
2%
NW
1%
0%
0%
2%
1%
0%

Table
3­
6
San
Antonio
Peak
Ozone
and
Meteorological
Data
(
CAMS
23):
May
23­
31,
2003
Date
Max
8­
hr.
Ozone
(
ppb)
Peak
Temperature
(
F)
Windspeed
6
a.
m.­
2
p.
m.
Average
(
mph)
Morning/
Afternoon
Wind
Direction
5/
23/
2003
88
88
4.5
NE
/
SE
5/
24/
2003
85
91
6.0
SE
/
SE
5/
25/
2003
57
89
6.1
SE/
SE
5/
26/
2003
55
83
4.0
SE
to
NW
/
NE
5/
27/
2003
61
81
8.2
NE
/
NE
5/
28/
2003
87
89
5.2
NE
/
NW
to
SE
5/
29/
2003
95
93
4.3
W
to
N
/
SE
to
S
5/
30/
2003
78
96
5.7
SW
/
S
5/
31/
2003
81
94
4.9
S
/
SE
Stagnant
vs.
Transport
The
Anthropogenic
Precursor
Culpability
Assessment
(
APCA)
was
used
to
analyze
the
concentration
of
ozone
in
the
San
Antonio
area
and
quantify
the
ozone
contribution
due
to
transport
from
neighboring
areas
and
to
source
type.
Figures
3­
4
and
3­
5
graphically
depict
the
apportionment
of
ozone
to
its
contributing
sources
and
provide
insight
to
the
behavior
and
contributing
trends
of
meteorological
patterns
to
cause
the
high
ozone
levels
in
the
San
Antonio
area.

Figure
3­
4
presents
a
high
ozone
episode
for
the
San
Antonio
region
in
July
of
1995
and
analysis
of
the
episode
indicates
a
stagnant
air
situation.
As
time
elapsed,
ozone
levels
from
the
initial
conditions,
boundary
conditions,
and
San
Antonio
sources
remained
at
significant
levels.
Initial
condition
ozone
decreased
at
a
slow
rate,
while
boundary
condition
ozone
slowly
increased
and
San
Antonio
source
levels
remained
constant.
Ozone
contributed
from
neighboring
areas
were
not
significant
therefore
not
indicative
of
a
transport
issue.
6/
23/
04
Page
28
of
32
Figure
3­
4
CAMx
APCA
Analysis
July
1995
Figure
3­
5
depicts
a
high
ozone
episode
in
September
1999.
This
episode
differs
from
the
July
1995
episode
in
the
fact
that
ozone
from
boundary
sources
and
other
sources
were
significant
to
the
measured
ozone
levels.
Initial
condition
ozone
decreased
significantly
while
ozone
from
the
other
source
categories
increased
and
remained
at
constant
high
levels.
A
fairly
constant
contribution
of
ozone
levels
from
Houston/
BPA
and
Victoria/
Corpus
Sources
can
be
observed
as
well.
With
this
contributing
factors,
this
episode
is
indicative
of
a
transport
episode.
Significant
transport
of
ozone
from
sources
other
than
San
Antonio
resulted
in
high
ozone
readings
in
the
San
Antonio
area.

Figure
3­
5
CAMx
APCA
Analysis
September
1999
0
10
2
0
3
0
4
0
5
0
6
0
7
0
8
0
9
0
0
:
00
8
:
00
16
:
00
0
:
00
8
:
00
16
:
00
0
:
00
8
:
00
16
:
00
0
:
00
8
:
00
16
:
00
0
:
00
8
:
00
16
:
00
0
:
00
8
:
00
16
:
00
0
:
00
8
:
00
16
:
00
0
:
00
8
:
00
16
:
00
S
ept.
7
­
2
0
,
19
9
9
,
H
o
ur
O
z
o
n
e
C
o
n
c
e
n
t
r
a
t
i
o
n
(
p
p
b
)

I
n
it
ia
l
C
o
n
d
itio
n
s
B
o
u
n
d
ary
C
o
n
d
it
io
n
s
B
io
g
e
n
ic
s
S
o
u
rce
s
H
o
us
to
n
/
B
PA
S
o
u
rc
e
s
V
ic
to
ria
/
Co
r
pu
s
S
o
u
rc
e
s
O
the
r
S
o
u
rc
e
s
S
a
n
A
n
to
n
io
S
o
u
rce
s
0
10
20
30
40
50
60
70
80
90
0
:
0
0
8
:
0
0
16
:
0
0
0
:
0
0
8
:
0
0
16
:
0
0
0
:
0
0
8
:
0
0
16
:
0
0
0
:
0
0
8
:
0
0
16
:
0
0
0
:
0
0
8
:
0
0
16
:
0
0
0
:
0
0
8
:
0
0
16
:
0
0
July
7
­
12,
1995,
H
our
O
z
o
n
e
C
o
n
c
e
n
t
r
a
t
i
o
n
(
p
p
b
)

Initial
Conditions
Boundary
Conditions
Biogenics
Sources
Houston/
BPA
Sources
Victoria/
Corpus
Sources
Other
Sources
San
A
ntonio
Sources
6/
23/
04
Page
29
of
32
Ozone
Seasonal
Peaks
in
the
Region
San
Antonio's
ozone
season,
April­
October,
was
analyzed
by
two­
week
periods
for
the
years
of
1997
through
2003
to
determine
if
and
when
seasonal
peaks
occur.
Figure
3­
6
illustrates
the
number
of
days
the
ozone
levels
exceeded
the
85
parts
per
billion
standard
during
the
indicated
2­
week
period.

Figure
3­
6
Ozone
Exceedance
Peaks
for
the
San
Antonio
Region
from
1997
to
2003
The
identified
peaks
are
periods
of
time
where
ozone
exceedances
commonly
occur.
The
higher
the
bar
on
the
bar
graph,
the
greater
the
peak
thus
the
more
days
the
ozone
level
was
over
the
85
ppb
threshold
for
the
8­
hour
average,
during
that
2­
week
period.
Figure
3­
7
shows
the
total
number
of
exceedance
days
by
two
week
periods
from
2000­
2003
for
the
near
nonattainment
and
nonattainment
regions
of
Texas.
Comparing
the
peak
trends
of
the
various
areas
helps
identify
any
local
or
regional
events.
The
figure
shows
the
first
seasonal
peak
occurring
in
May,
with
all
four
exceedance
days
occurring
in
2003.
The
next
peak
occurs
in
late
June.
The
largest
peak
occurs
from
August
to
late
September,
represented
by
a
hump.
It
should
be
noted
that
the
"
peaking"
bars
of
Figure
3­
6
coincide
with
the
"
peaking"
curves
of
Figure
3­
7
for
the
San
Antonio
area.
Two­
Week
Periods
for
San
Antonio,
1997­
2003
0
2
4
2
7
1
1
4
8
10
8
2
0
0
4
8
12
16
Late
Apr.

Early
May
Late
May
Early
Jun.

Late
Jun.

Early
Jul.

Late
Jul.

Early
Aug.

Late
Aug.

Early
Sep.

Late
Sep.

Early
Oct.

Late
Oct.
Total
#
of
Days
over
0.08/
8
Hr.
Small
Peak
Peak
Extended
Peak
6/
23/
04
Page
30
of
32
Figure
3­
7
High
Ozone
Readings
by
Two­
week
Period
by
Metropolitan
Region
to
Demonstrate
Seasonal
Peaks
Once
these
various
analyses
are
completed,
the
modeling
scenarios
can
be
compared
to
the
air
quality
scenarios
from
other
near
nonattainment
areas.
This
will
provide
air
quality
planners
with
the
best
candidate
episodes
for
selection
to
develop
a
new
photochemical
model.
The
following
episodes
from
2003
are
deemed
as
possible
candidate
additions
for
the
San
Antonio
region:

May
23­
29,
2003
 
4
exceedance
days
in
episode
 
Back
trajectory
on
the
29th
is
from
the
W,
NW,
&
N,
which
is
not
typical
of
a
high
ozone
day
in
the
San
Antonio
region
 
Could
be
modeled
with
other
regions
to
reduce
costs
 
Maybe
suitable
to
represent
a
stagnate
air
situation:
max
hourly
average
wind
speeds
were
of
4.5,
6.0,
5.2,
&
4.3
mph
(
1999
episode
had
speeds
of
8.1,
6.0,
5.0
&
5.6
mph)

September
6­
7,
2003
 
Has
only
2
exceedance
days
in
the
episode
 
Could
be
modeled
with
other
regions
to
reduce
costs
(
although
Austin
had
only
one
exceedance
that
coincides)
 
PM
2.5
had
an
unusually
high
reading
(
for
San
Antonio)
on
the
7th­
30.82
 
Max
hourly
average
wind
speeds
were
4.9
mph
&
5.9
mph
respectively
3.5.2
Future
Photochemical
Modeling
Episodes
The
eventual
selection
of
a
candidate
episode
ultimately
leads
to
the
development
of
a
photochemical
model
which
allows
air
quality
planners
to
further
understand
the
mechanics
of
ozone
exceedance
days
and
the
conditions
that
typify
the
occurrence.
0
5
10
15
20
25
30
Early
Jan.

Late
Jan.

Early
Feb.

Late
Feb.

Early
Mar.

Late
Mar,

Early
Apr.

Late
Apr.

Early
May
Late
May
Early
Jun.

Late
Jun.

Early
Jul.

Late
Jul.

Early
Aug.

Late
Aug.

Early
Sep.

Late
Sep
.

Early
Oct.

Late
Oct.

Early
Nov.

Late
Nov.

Early
Dec.

Late
Dec.

Coverage
Years:
2000­
2003
Total
#
of
Days
over
0.08/
8
Hr.
Dallas/
Fort
Worth
Tyler/
Longview
El
Paso
Beaumont/
Port
Arthur
Austin
Houston/
Galveston
San
Antonio
Corpus
Christi/
Victoria
McAllen/
Rio
Grande
Valley
6/
23/
04
Page
31
of
32
The
update
of
the
conceptual
model
with
data
from
2003
offers
two
potential
episodes
in
2003,
May
2003
and
September
2003.
Aside
from
analysis
and
comparison
of
meteorological
conditions,
air
quality
planning
tools
such
as
the
APCA
enable
a
better
comprehension
of
air
quality
scenarios
thus
allowing
the
selection
of
a
transport
or
a
local
condition
episode.

A
comprehensive
TexAQS
study
is
going
to
be
conducted
in
2004
and
2005
which
would
provide
additional
information
but
also
possible
new
insights
of
various
influences
on
air
quality
situations.
In
the
event
the
San
Antonio
EAC
fails
or
San
Antonio
is
declared
effective
nonattainment
in
2008,
the
development
of
a
new
photochemical
modeling
episode
would
be
essential
in
additional
air
quality
analyses.
The
September
1999
episode,
which
was
used
in
the
development
of
the
Clean
Air
Plan,
will
be
out
of
date
in
2008.
The
episode
also
only
provides
control
strategy
analysis
for
one
type
of
high
ozone
event,
that
event
being
one
of
transport.
6/
23/
04
Page
32
of
32
Chapter
4
 
Conclusion
The
San
Antonio
EAC
region
has
successfully
maintained
steady
progress
in
accomplishing
EAC
milestones
and
ensuring
proper
development
of
the
Clean
Air
Plan.
The
Attainment
Demonstration
for
the
San
Antonio
Early
Action
Compact
Regions
was
successfully
developed
and
submitted
to
the
TCEQ
and
EPA
on
March
31,
2004.
Successful
completion
of
the
milestones
included
appropriate
participation
of
stakeholders
in
the
air
quality
planning
process,
ongoing
development
and
research
of
potential
control
strategies,
provide
for
public
participation
in
the
development
of
the
Clean
Air
Plan,
and
continue
technical
activities
in
developing
and
testing
model
performance.
Accomplishing
these
milestones
allowed
efficient
development
of
the
Attainment
Demonstration
with
assurances
in
the
validity
of
its
technical
data.

The
San
Antonio
EAC
region
remains
compliant
with
the
prescribed
milestones
as
given
by
the
Protocol
for
Early
Action
Compacts
Designed
to
Achieve
and
Maintain
the
8­
Hour
Ozone
Standard.
12
The
region
will
continue
to
comply
to
the
milestones
as
required.

12
The
"
Protocol
for
Early
Action
Compacts
Designed
to
Achieve
and
Maintain
the
8­
Hour
Ozone
Standard"
is
available
online
as
http://
www.
epa.
gov/
ttn/
naaqs/
ozone/
eac/
20020619_
eac_
protocol.
pdf
