
Date:  12/15/2010
MEMORANDUM
SUBJECT:	Reasonable Further Progress Proposal
FROM:		H. Lynn Dail, Environmental Scientist /s/
		OAQPS/AQPD/SLPG
TO:		Docket: EPA-HQ-OAR-2010-0891
EPA is expecting a strong adverse reaction from California Air Resources Board and from various California Air Quality Management Districts (AQMD).  Several of the required state implementation plans for these areas have been submitted and they rely on emissions reductions credit from an upwind nonattainment area to meet reasonable further progress and attainment requirements.  If today's proposal to not allow out of area RFP credits is finalized, California will have to submit revised RFP demonstrations for these nonattainment areas.  California expects more areas will need to rely on out of area credit for RFP obligations.
The following areas have submitted  SIPS that used credit outside nonattainment areas.
Los Angeles and San Bernadino County (W Mojave Desert)
Riverside County (Coachella Valley)
Ventura County


