M E M O R A N D U M 
To:   		Docket EPA-R09-OAR-2012-0713, Docket EPA- R09-OAR-2012-0721
From: 		Wienke Tax, EPA Region IX, Air Planning Office
Date:		September 14, 2012
Concerning:  	EPA Proposed Rules, Finding of Substantial Inadequacy of Implementation Plan; Call for California State Implementation Plan Revision; South Coast, and Disapproval of Implementation Plan Revisions; State of California; South Coast VMT Emissions Offset Demonstrations - Conference Call Notes, Conference Call, September 14, 2012.
_____________________________
On Friday, September 14, 2012, EPA Region 9 staff and managers Elizabeth Adams, Jefferson Wehling, Jeanhee Hong, Carol Bohnenkamp, Karina O'Connor, and Wienke Tax participated in a conference call with staff and managers from the South Coast Air Quality Management District (SCAQMD) Elaine Chang, Henry Hogo, Joseph Cassmassi, Philip Fine, Barbara Baird, Bill Wong, and Laki Tisopulos. The purpose of the conference call was to discuss EPA's proposals regarding the 1-hour ozone SIP call for South Coast, and the requirement for the South Coast to submit new VMT emission offset demonstrations for 1-hour and 8-hour ozone. SCAQMD staff also clarified that they will be submitting a status update on the implementation of their approved 8-hour ozone plan.

In connection with the 1-hour ozone SIP call, EPA indicated that the Agency had issued the SIP call for the attainment demonstration under 182(c)(2)(A) only. If EPA were to add any additional requirements to the SIP call, EPA indicated that the Agency would have to re-propose the action. EPA also indicated that reliance on section 182(e)(5)("New technologies") for attainment demonstration purposes could be the subject of a future challenge if EPA were to approve a plan with such reliance. SCAQMD asked whether EPA had any particular format in mind for the 1-hour ozone attainment demonstration (e.g., as a separate chapter, or separate appendix, etc.), and EPA expressed no preference in that regard other than to present 1-hour ozone material separately from 8-hour ozone and other pollutant material where possible to allow for separate evaluation and action (if needed). In connection with the VMT offset demonstration, SCAQMD indicated they will be using EMFAC2011 and EPA indicated that the Agency had no objection to its use.

The agenda associated with this conference call is attached to this memorandum. 




                          AQMD/U.S.EPA Region 9 call
                                       
                                   9/14/2012

                                    Agenda


         8-hour ozone SIP update
                 Revision, update, SIP commitments
                 Revised inventory
                 Additional requirements based on new inventory
                 Attainment demonstration
        
         1-hour ozone SIP
                 Required Elements
                 RFP: Applicability of 15% VOC reduction; milestone years
                 Contingency (182(e)(5))
                 Applicability of Section 182(g)(5) Economic Incentive Program?
                 Timing/format
            
         VMT offset demonstration
        	1-hour
        8-hour
        	2007 or 2011 EMFAC

