

                       PM2.5 NAAQS ATTAINMENT DEADLINES

	The DC Circuit directed the EPA to align emissions reduction compliance dates in the rule replacing CAIR with the attainment deadlines for the relevant NAAQS, i.e., those for which the rule addresses upwind states' emissions that significantly contribute to downwind nonattainment areas' nonattainment or that interfere with their ability to maintain the standards.   Where the NAAQS compliance deadlines are prospective, the agency  -  and upwind states  -  are obligated to eliminate their significant contribution no later than the NAAQS compliance deadline.  Where the NAAQS deadline is already passed, the agency and the upwind states are obligated to eliminate significant contribution "as expeditiously as practicable."  

2006 PM2.5 NAAQS Attainment Deadlines
      
      The attainment deadlines for all areas designated nonattainment for the 2006 24-hr PM2.5 NAAQS is December 14, 2014 (5 years from the effective date of the nonattainment designations).   In general, the EPA determines whether an area has attainment air quality on the basis of the data from the last complete calendar year prior to the attainment date to determine if the area has achieved the standard.  Because the deadline for the 2006 standard, however, is so close to the end of the 2014 calendar year, we determined that it would be acceptable to base attainment determinations on data from the 2014 calendar year.  Thus, upwind areas that significantly contribute to nonattainment or interfere with maintenance in downwind states need to have controls in place to eliminate such emissions by 1/1/2014 to ensure that the needed reductions occur during the 2014 calendar year.   The following chart shows the impact of reductions in 2014 in six key areas.
      
                                     Area
       Consequences of TR Controls in 2014 for Attainment/Nonattainment 
                         of the 2006 24-Hour PM NAAQS


Liberty-Clairton, PA
- Projected to remain in nonattainment following implementation of TR 2012 requirements. 
- Upwind states significantly contribute to the area's nonattainment problem.
 -  Significant contribution to nonattainment from upwind states eliminated by 2014 TR requirements. 
- TR 2014 reductions bring the area closer, but not completely into attainment by the December 2014 attainment deadline.
- Known local problem.
-Absence of Phase 2 reductions in 2014 will mean that significant contribution will not be eliminated in NAAQS deadline-relevant year 
Pittsburgh-Beaver Valley, PA
- Projected to have a potential nonattainment problem following implementation of all TR 2012 requirements.
- Upwind states significantly contribute to the area's potential nonattainment problem.
- Significant contribution to potential nonattainment from upwind states eliminated by 2014 TR requirements.
- TR 2014 reductions will allow the area to meet the December 2014 attainment date.
-Absence of Phase 2 reduction in 2014 will mean that significant contribution to area's maintenance of NAAQS during deadline-relevant year will not be eliminated
Lancaster, PA
- Projected to have a potential nonattainment problem following implementation of all TR 2012 requirements.
- Upwind states significantly contribute to the area's potential nonattainment problem.
- TR 2014 reductions bring the area closer, but not completely into attainment by the December 2014 attainment deadline.
- Significant contribution to potential nonattainment from upwind states eliminated by 2014 TR requirements.
- Still at risk of missing attainment date without additional in-state controls, but upwind state contributions addressed by TR.
-Absence of Phase 2 reductions in 2014 will mean that significant contribution to area's nonattainment of NAAQS not eliminated in deadline-relevant year
Cleveland-Akron-Lorain, OH
- Projected to have a potential nonattainment problem following implementation of all TR 2012 requirements.
- Upwind states significantly contribute to the area's potential nonattainment problem.
- Significant contribution to potential nonattainment from upwind states eliminated by 2014 TR requirements.
- TR 2014 reductions will allow the area to meet the December 2014 
attainment date.
- Absence of Phase 2 reductions in 2014 will mean that significant contribution to area's nonattainment will not be eliminated during deadline-relevant year
Chicago-Gary-Lake, IL
- Projected to be potential nonattainment by 2014 even with implementation of all TR 2012 requirements. 
- Upwind states significantly contribute to the area's potential nonattainment problem.
- With TR 2014 reductions, area projected to be much closer to attainment.
- Significant contribution to potential nonattainment from upwind states eliminated by 2014 TR requirements.
- Still at risk of having nonattainment air quality in 2014 without additional in-state controls (beyond TR 2014 requirements) to get reductions during 2014 calendar year.
- Absence of Phase 2 reductions in 2014 will mean that significant contribution to area's nonattainment will not be eliminated during deadline-relevant year
Detroit-Ann Arbor, MI
- Projected to remain in nonattainment following implementation of TR 2012 requirements.
- TR 2014 reductions very close to resolving potential nonattainment problem (projected to be just 0.07 ug/m3 from attainment). 
 -  Significant contribution to nonattainment/potential nonattainment from upwind states eliminated by 2014 TR requirements. 
- May need additional in-state controls that get reductions during 2014 to meet December 2014 attainment deadline.
= Absence of Phase 2 reductions in 2014 will mean that significant contribution to area's nonattainment will not be eliminated during deadline-relevant year



1997 PM2.5 NAAQS Attainment Deadlines
      
      The original attainment deadline for all areas designated nonattainment for the 1997 annual PM2.5 NAAQS was expeditiously as practicable, but no later than April 5, 2010 (5 years from the effective date of the nonattainment designations).  In general, we look at data from the last complete calendar year prior to the attainment date to determine if the area has achieved the standard.  The last complete calendar year prior to the attainment deadline was 2009.  Areas with clean data in 2009 generally were given two one year extensions to an April 5, 2011 deadline.  Other areas, those with nonattainment air quality, were given the maximum 5 year extension to April 5, 2015.  The last complete calendar year prior to the attainment deadline is 2014; air quality improvements after 12/31/2014 thus would not help states demonstrate attainment by the deadline.  Thus, upwind areas that significantly contribute to nonattainment or interfere with maintenance in downwind states need to have controls in place to eliminate such emissions by 1/1/2014 to ensure that the needed reductions occur during the 2014 calendar year.   The following chart shows the impact of reductions in 2014 in Liberty-Clairton, PA. 
                                     Area
       Consequences of TR Controls in 2014 for Attainment/Nonattainment 
                         of the 2006 24-Hour PM NAAQS


Liberty-Clairton, PA
- Projected to remain in nonattainment following implementation of TR 2012 requirements. 
- Upwind states significantly contribute to the area's nonattainment problem.
- Significant contribution to nonattainment/potential nonattainment from upwind states eliminated by 2014 TR requirements. - TR 2014 reductions bring the area into attainment in 2014, allowing the area to meet its April 5, 2015 attainment deadline.
- Absence of Phase 2 reductions in 2014 will mean that significant contribution to area's nonattainment will not be eliminated during deadline-relevant year.
      

